Agenda packet — San Carlos City Council, May 27, 2025 (part 5 of 9)

CITY OF SAN CARLOS
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PLACEWORKS 4.11-5
Hearing Loss
While physical damage to the ear from an intense noise impulse is rare, a degradation of auditory acuity can occur even within a community noise environment. Hearing loss occurs mainly due to chronic exposure to excessive noise but may be due to a single event such as an explosion. Natural hearing loss associated with aging may also be accelerated from chronic exposure to loud noise.

The Occupational Safety and Health Administration has a noise exposure standard that is set at the noise threshold where hearing loss may occur from long-term exposures. The maximum allowable level is 90 dBA, averaged over eight hours. If the noise is above 90 dBA, the allowable exposure time is correspondingly shorter.

Annoyance
Attitude surveys are used for measuring the annoyance felt in a community for noises intruding into homes or affecting outdoor activity areas. In these surveys, it was determined that causes for annoyance include interference with speech, radio and television, house vibrations, and interference with sleep and rest. Both the Ldn and CNEL as measures of noise have been found to provide a valid correlation of noise level and the percentage of people annoyed. People have been asked to judge the annoyance caused by aircraft noise and ground transportation noise. There continues to be disagreement about the relative annoyance of these different sources.

Psychological and Physiological Effects of Noise
Physical damage to human hearing begins at prolonged exposure to noise levels higher than 85 dBA.

Exposure to high noise levels affects our entire system, with prolonged noise exposure in excess of 75 dBA increasing body tensions, and thereby affecting blood pressure, functions of the heart and the nervous system. In comparison, extended periods of noise exposure above 90 dBA could result in permanent hearing damage. When the noise level reaches 120 dBA, a tickling sensation occurs in the human ear even with short-term exposure. This level of noise is called the threshold of feeling. As the sound reaches 140 dBA, the tickling sensation is replaced by the feeling of pain in the ear. This is called the threshold of pain. Table 4.11-1, Typical Noise Levels, shows typical noise levels from familiar noise sources.

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TABLE 4.11-1 TYPICAL NOISE LEVELS
Common Outdoor Activities Noise Level (dBA) Common Indoor Activities Onset of Physical Discomfort 120+ Onset of physical discomfort 110 Rock Band (near amplification system)
Jet Flyover at 1,000 Feet
100
Gas Lawn Mower at 3 feet
90 Diesel Truck at 50 feet, at 50 mph Food Blender at 3 feet 80 Garbage Disposal at 3 feet
Noisy Urban Area, Daytime
70 Vacuum Cleaner at 10 feet
Commercial Area Normal Speech at 3 feet
Heavy Traffic at 300 feet 60
Large Business Office
Quiet Urban Daytime 50 Dishwasher Next Room
Quiet Urban Nighttime 40 Theater, Large Conference Room (Background)
Quiet Suburban Nighttime
30 Library
Quiet Rural Nighttime Bedroom at Night, Concert Hall
(Background)
20 Broadcast/Recording Studio
10 Lowest Threshold of Human Hearing 0 Lowest Threshold of Human Hearing Source: California Department of Transportation, May 13, 2011, I-80 Davis OGAC Pavement Noise Study, https://dot.ca.gov/-/media/dotmedia/programs/environmental-analysis/documents/env/davis-noise-study-12yr-report-may2011-a11y.pdf, accessed October 4, 2022.

Vibration Fundamentals
Vibration is a trembling, quivering, or oscillating motion of the earth. Like noise, vibration is transmitted in waves, but in this case through the earth or solid objects. Unlike noise, vibration is typically of a frequency that is felt rather than heard. Vibration can be either natural as in the form of earthquakes, volcanic eruptions, sea waves, landslides, or man-made as from explosions, the action of heavy machinery or heavy vehicles such as trains. Both natural and man-made vibration may be continuous such as from operating machinery, or transient as from an explosion.

Low-level vibrations frequently cause irritating secondary vibration, such as a slight rattling of windows, doors or stacked dishes. The rattling sound can give rise to ex-aggerated vibration complaints, even though there is very little risk of actual structural damage. In high noise environments, which are more prevalent where ground-borne vibration approaches perceptible levels, this rattling phenomenon may 2045 GENERAL PLAN RESET DRAFT EIR

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also be produced by loud airborne environmental noise causing induced vibration in exterior doors and windows.

Construction activities can cause vibration that varies in intensity depending on several factors. The use of pile-driving and vibratory compaction equipment typically generates the highest construction related ground-borne vibration levels. Because of the impulsive nature of such activities, the use of the PPV descriptor has been routinely used to measure and assess ground-borne vibration and almost exclusively to assess the potential of vibration to induce structural damage and the degree of annoyance for humans.

Structural damage can be classified as cosmetic only, such as minor cracking of building elements, or may threaten the integrity of the building. Safe vibration limits that can be applied to assess the potential for damaging a structure vary by researcher and there is no general consensus as to what amount of vibration may pose a threat for structural damage to the building. Construction-induced vibration that can be detrimental to the building is very rare and has only been observed in instances where the structure is at a high state of disrepair and the construction activity occurs immediately adjacent to the structure.

Psychological and Physiological Effects of Vibration
As with noise, vibration can be described by both its amplitude and frequency. Amplitude may be characterized in three ways including displacement, velocity, and acceleration. Particle displacement is a measure of the distance that a vibrated particle travels from its original position and for the purposes of soil displacement is typically measured in inches or millimeters. Particle velocity is the rate of speed at which soil particles move in inches per second or millimeters per second. Particle acceleration is the rate of change in velocity with respect to time and is measured in inches per second or millimeters per second. Typically, particle velocity (measured in inches or millimeters per second) and/or acceleration (measured in gravities) are used to describe vibration. Table 4.11-2, Human Reaction to Typical Vibration Levels, presents the human reaction to various levels of peak particle velocity.

TABLE 4.11-2 HUMAN REACTION TO TYPICAL VIBRATION LEVELS Vibration Level
PPV (in/sec) Human Reaction Effect on Buildings

0.01 Barely perceptible No effect

0.04 Distinctly perceptible Vibration unlikely to cause damage of any type to any structure

0.08 Distinctly perceptible to
strongly perceptible
Recommended upper level of the vibration to which ruins and ancient monuments should be subjected

0.1 Strongly perceptible Threshold at which there is a risk of damage to fragile buildings with no risk of damage to most buildings

0.25 Strongly perceptible to
severe
Threshold at which there is a risk of damage to historic and some old buildings

0.3 Strongly perceptible to
severe
Threshold at which there is a risk of damage to older residential structures

0.5 Severe – vibrations
considered unpleasant
Threshold at which there is a risk of damage to new residential and modern commercial/industrial structures
Note: in/sec = inches per second
Source: California Department of Transportation, 2020, Transportation and Construction Vibration Guidance Manual. 2045 GENERAL PLAN RESET DRAFT EIR

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REGULATORY FRAMEWORK
Federal Regulations
Federal Highway Administration
Proposed federal or federal-aided highway construction projects at a new location, or the physical alteration of an existing highway that significantly changes the horizontal or vertical alignment or increases the number of through-traffic lanes, require an assessment of noise and consideration of noise abatement per 23 Code of Federal Regulations Part 772, “Procedures for Abatement of Highway Traffic Noise and Construction Noise.” The Federal Highway Administration (FHWA) has adopted noise abatement criteria for sensitive receivers—such as picnic areas, recreation areas, playgrounds, active sport areas, parks, residences, motels, hotels, schools, churches, libraries, and hospitals—when “worsthour” noise levels approach or exceed 67 dBA Leq. 1 Federal Transit Administration
The Federal Transit Administration (FTA) has identified construction noise thresholds in the Transit Noise and Vibration Impact Assessment Manual2 that limit daytime construction noise to 80 dBA Leq at residential land uses and to 90 dBA Leq at commercial and industrial land uses. The FTA also provides damage criteria during construction vibration exposure. The criteria is summarized in Table 4.11-3, Construction Vibration Damage Criteria.

TABLE 4.11-3 CONSTRUCTION VIBRATION DAMAGE CRITERIA
Building/Structural Category PPV (in/sec) Approximate LV a Reinforced-concrete, steel or timber (no plaster) 0.5 102 Engineered concrete and masonry (no plaster) 0.3 98
Non-engineered timber and masonry buildings 0.2 94
Buildings extremely susceptible to vibration damage 0.12 90 Note:
a. Root-mean square velocity in decibels, VdB re 1 micro-in/sec. Vibration Decibel (VdB) = A unitless measure of vibration, expressed on a logarithmic scale and with respect to a defined reference vibration velocity. In the U.S., the standard reference velocity is one microinch per second (1x10-6 in/sec).

Source: United States Department of Transportation Federal Transit Administration, 2018, Transit Noise and Vibration Impact Assessment Manual.

The FTA has identified vibration impact criteria for sensitive buildings, residences, and institutional land uses near rail transit and railroads (Table 4.11-4, FTA Groundborne Vibration Impact Criteria). The thresholds for residences and buildings where people normally sleep (e.g., nearby residences) are 72 VdB for frequent events (more than 70 events of the same source per day), 75 VdB for occasional events 1 California Department of Transportation, April 2020, Traffic Noise Analysis Protocol for New Highway Construction, Reconstruction, and Retrofit Barrier Projects, https://dot.ca.gov/-/media/dot-media/programs/environmentalanalysis/documents/env/traffic-noise-protocol-april-2020-a11y.pdf, accessed October 4, 2022. 2 Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, FTA Report No. 0123, September 2018.
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(30 to 70 vibration events of the same source per day), and 80 VdB for infrequent events (less than 30 vibration events of the same source per day).

TABLE 4.11-4 FTA GROUNDBORNE VIBRATION IMPACT CRITERIA
Land Use Category
Impact Levels (VdB re 1 micro-in/sec)
Frequent Events a Occasional Events b Infrequent Events c Category 1: Buildings where vibration
would interfere with interior operations 65 VdB d 65 VdB d 65 VdB d Category 2: Residences and buildings
where people normally sleep 72 VdB 75 VdB 80 VdB
Category 3: Institutional land uses with
primarily daytime use 75 VdB 78 VdB 83 VdB
Notes: Vibration Decibel (VdB) = A unitless measure of vibration, expressed on a logarithmic scale and with respect to a defined reference vibration velocity. In the U.S., the standard reference velocity is one microinch per second (1x10-6 in/sec). a. “Frequent Events” is defined as more than 70 vibration events per day. Most rapid transit projects fall into this category. b. “Occasional Events” is defined as between 30 and 70 vibration events of the same source per day. Most commuter trunk lines have this many operations.
c. “Infrequent Events” is defined as fewer than 30 vibration events per day. This category includes most commuter rail systems. d. This limit is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes.

Source: US Department of Transportation Federal Transit Administration, 2018, Transit Noise and Vibration Impact Assessment Manual.

United States Environmental Protection Agency
In addition to FHWA standards, the United States Environmental Protection Agency (USEPA) has identified the relationship between noise levels and human response. The USEPA has determined that over a 24-hour period, a Leq of 70 dBA will result in some hearing loss. Interference with activity and annoyance will not occur if exterior levels are maintained at a Leq of 55 dBA and interior levels at or below 45 dBA. These levels are relevant to planning and design and useful for informational purposes, but they are not land use planning criteria because they do not consider economic cost, technical feasibility, or the needs of the community; therefore, they are not mandated.

The USEPA also has set 55 dBA Ldn as the basic goal for exterior residential noise intrusion. However, other federal agencies, in consideration of their own program requirements and goals, as well as difficulty of actually achieving a goal of 55 dBA Ldn, have settled on the 65 dBA Ldn level as their standard.

At 65 dBA Ldn, activity interference is kept to a minimum, and annoyance levels are still low. It is also a level that can realistically be achieved.3
United States Department of Housing and Urban Development The United States Department of Housing and Urban Development (HUD) has set the goal of 65 dBA Ldn as a desirable maximum exterior standard for residential units developed under HUD funding. (This level is also generally accepted within the State of California.) Although HUD does not specify acceptable 3 United States Environmental Protection Agency. 1978, November. Protective Noise Levels. EPA 550/9-79-100. (Condensed version of 1971 and 1974 documents.)
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interior noise levels, standard construction of residential dwellings typically provides 20 dBA or more of attenuation with the windows closed. Based on this premise, the interior Ldn should not exceed 45 dBA.4 State Regulations
General Plan Guidelines
The State of California, through its General Plan Guidelines, discusses how ambient noise should influence land use and development decisions and includes a table of normally acceptable, conditionally acceptable, normally unacceptable, and clearly unacceptable uses at different noise levels. These suggested noise and land use compatibility standards provide local governments with a basis for setting limits appropriate to their jurisdiction.5
California Building Code
The State of California provides a minimum standard for building design through Title 24, Part 2, of the California Code of Regulations (CCR), commonly referred to as the “California Building Code” (CBC). The CBC is updated every three years. The noise limit is a maximum interior noise level of 45 dBA Ldn/CNEL.

Where exterior noise levels exceed 60 dBA Ldn/CNEL, a report must be submitted with the building plans describing the noise control measures that have been incorporated into the design of the project to meet the noise limit. The California Governor’s Office of Land Use and Climate Innovation (formerly the Office of Planning and Research) guidelines require the General Plan to facilitate the implementation of the CBC noise insulation standards. The noise metric is evaluated as either the day-night average sound level (Ldn) or the community noise equivalent level (CNEL), whichever is consistent with the noise element of the local general plan.

The State of California’s noise insulation standards for non-residential uses are codified in CCR, Title 24, Part 11, California Green Building Standards Code (CALGreen). CALGreen noise standards are applied to new or renovation construction projects in California to control interior noise levels resulting from exterior noise sources. Proposed projects may use either the prescriptive method (Section 5.507.4.1) or the performance method (Section 5.507.4.2) to show compliance. Under the prescriptive method, a project must demonstrate transmission loss ratings for the wall and roof-ceiling assemblies and exterior windows when located within a noise environment of 65 dBA CNEL or higher. Under the performance method, a project must demonstrate that interior noise levels do not exceed 50 dBA Leq(1hr).

California Department of Transportation
The California Department of Transportation (Caltrans) recommends a vibration limit of 0.5 in/sec PPV for buildings structurally sound and designed to modern engineering standards. A conservative vibration limit of 0.25 to 0.30 in/sec PPV has been used for older buildings that are found to be structurally sound but cosmetic damage to plaster ceilings or walls is a major concern. For historic buildings or buildings 4 United States Department of Housing and Urban Development. 1985, March. Noise Guidebook: A Reference Document for Implementing the Department of Housing and Urban Development's Noise Policy. 5 Governor’s Office of Planning and Research. 2020. State of California General Plan 2020 Guidelines. 2045 GENERAL PLAN RESET DRAFT EIR

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that are documented to be structurally weakened, a conservative limit of 0.08 in/sec PPV is often used to provide the highest level of protection. All of these limits have been used successfully and compliance with these limits has not been known to result in appreciable structural damage. All vibration limits referred to herein apply on the ground level and take into account the response of structural elements (i.e., walls and floors) to groundborne excitation. These thresholds are summarized in Table 4.11-5, Caltrans' Vibration Threshold Criteria for Building Damage, and Table 4.11-6, Caltrans' Vibration Threshold Criteria for Human Response.

TABLE 4.11-5 CALTRANS' VIBRATION THRESHOLD CRITERIA FOR BUILDING DAMAGE Structural Integrity
Maximum PPV (in/sec)
Transient Sources
Continuous/Frequent
Intermittent Sources
Extremely fragile historic buildings, ruins, ancient monuments 0.12 0.08 Fragile Buildings 0.2 0.1
Historic and some older buildings 0.50 0.25
Older residential structures 0.50 0.3
New residential structures 1.00 0.5
Modern industrial and commercial structures 2.00 0.5
Notes: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent sources include impact pile drivers, pogo-stick compactors, crack-and-seat equipment, vibratory pile drivers, and vibratory compaction equipment.

PPV (in/sec) = peak particle velocity (inches per second).

Source: California Department of Transportation, 2020, Transportation and Construction Vibration Guidance Manual.

TABLE 4.11-6 CALTRANS' VIBRATION THRESHOLD CRITERIA FOR HUMAN RESPONSE Human Response
Maximum PPV (in/sec)
Transient Sources
Continuous/Frequent
Intermittent Sources
Barely perceptible 0.04 0.01
Distinctly perceptible 0.25 0.04
Strongly perceptible 0.9 0.10
Severe 2.00 0.4
Notes: Transient sources create a single isolated vibration event, such as blasting or drop balls. Continuous/frequent intermittent sources include impact pile drivers, pogo-stick compactors, crack-and-seat equipment, vibratory pile drivers, and vibratory compaction equipment.

PP V(in/sec) = peak particle velocity (inches per second).

Source: California Department of Transportation, 2020, Transportation and Construction Vibration Guidance Manual.

Division of Aeronautic Noise Standards
CCR Title 21 sets forth the State’s airport noise standards.6 In the findings described in Section 5006, the standard states the following: “A level of noise acceptable to a reasonable person residing in the vicinity of an airport is established as a CNEL value of 65 dB for purposes of these regulations. This criterion level 6 California Code of Regulations Airport Noise Standards, Title 21, Public Works Division 2.5, Division of Aeronautics (Department of Transportation), Chapter 6 Noise Standards, Article 1. General. 2045 GENERAL PLAN RESET DRAFT EIR

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has been chosen for reasonable persons residing in urban residential areas where houses are of typical California construction and may have windows partially open. It has been selected with reference to speech, sleep, and community reaction.” Based on this finding, the airport noise standard as defined in Section 5012 is set at a CNEL of 65 dBA.

Assembly Bill 1307
Signed into law on September 7, 2023, Assembly Bill (AB) 1307 amends California Environmental Quality Act (CEQA) and adds Public Resources Code (PRC) Section 21085. Pursuant to PRC Section 20185 for residential projects, the effects of noise generated by project occupants and their guests on human beings is not a significant effect on the environment. Accordingly, the noise from residential development projects is limited to construction noise, noise from the operation of the house (e.g., heating, ventilation, and air conditioning equipment), and increases in transportation noise from vehicle trips generated from the residential project.

City of San Carlos Municipal Code
The San Carlos Municipal Code (SCMC) is the primary document that regulates the policies and practices of the City. The SCMC contains the Zoning Code, the Subdivision Ordinance, the Building and Construction Code, and other titles that are important in implementing the goals, policies, and actions of the General Plan. The SCMC includes various directives pertaining to noise as follows:
 Chapter 9.30, Noise Control, declares that the policy of the City is to protect the peace, health and safety of its citizens from unnecessary and unreasonable noises produced by any machine, person or device. It shall also be the City’s policy to continuously evaluate the noise levels specified in the body of this chapter and adjust them as quieter equipment becomes available or as demanded by State and Federal requirements.
 Section 9.30.030, Basic Noise Regulation, states that, except as otherwise permitted under this chapter, no person shall cause and no property owner shall permit, as to property owned by him, a noise produced by any person, amplified sound or device, or any combination thereof in excess of ten dBA above the local ambient to emanate from any property, public or private, as measured at a distance of forty-nine feet beyond the property line.  Section 9.30.070, Exempt Activities, lists the following noise-generating activities that exempt from the provisions of SCMC Chapter 9.30:
 Transportation facilities, such as freeways, airports, buses and railroads; 2045 GENERAL PLAN RESET DRAFT EIR

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 Construction Activities; such activities, however, shall be limited to the hours of eight a.m. to five p.m., Monday through Friday and nine a.m. to five p.m. on Saturday, Sunday and holidays;
 Home Workshop and Gardening Equipment; such activities, however, shall be limited to the hours of eight a.m. to sunset, Monday through Friday and ten a.m. to sunset on Saturday.

No construction noise-related activities can occur on Sundays and certain holidays.  Public works and public utilities activities, which shall be limited to the hours set forth under Subsection B above, except for emergency situations;
 Emergency vehicles;
 Solid waste pickup.
 Section 18.21.050-A, Noise Limits, prohibits use or activity that create noise levels that exceed the established standards. The maximum allowable noise levels specified in SCMC Table 18.21.050-A, Noise Limits, (see Table 4.11-10, Non-Transportation Noise Standards) do not apply to noise generated by automobile traffic or other mobile noise sources in the public right-of-way. The maximum allowable noise levels in Table 4.11-10 (SCMC Table 18.21.050-A, Noise Limits) shall be adjusted according to the following provisions, with no more than one increase in the maximum permissible noise level applied to the noise generated on each property:
 Ambient Noise. If the ambient noise level at a noise-sensitive use is 10 dBA or more below the standard, the allowable noise standard shall be decreased by 5 dBA.  Duration. The maximum allowable noise level (L50) shall be increased as follows to account for the effects of duration:
 Noise that is produced for no more than a cumulative period of fifteen minutes in any hour (L25) may exceed the noise limit by 5 dBA; and
 Noise that is produced for no more than a cumulative period of five minutes in any hour (L8) may exceed the noise limits by 10 dBA;
 Noise that is produced for no more than a cumulative period of one minute in any hour (L2) may exceed the noise limits by 15 dBA.
 Character of Sound. If a noise contains a steady audible tone or is a repetitive noise (such as hammering or riveting) or contains music or speech conveying informational content, the maximum allowable noise levels shall be reduced by 5 dBA.  Prohibited Noise. Noise for a cumulative period of thirty minutes or more in any hour which exceeds the noise standard for the receiving land use is prohibited.  Section 18.21.050-B, Noise Exposure, includes SCMC Table 18.21.050-B (see Table 4.11-7, Noise Exposure—Land Requirements and Limitations) which describes the requirements and limitations of various land uses within the listed day/night average sound level (Ldn) ranges. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.11-7 NOISE EXPOSURE—LAND REQUIREMENTS AND LIMITATIONS Land Use
Day/Night Average
Sound Level (Ldn) Requirements and Limitations
Residentiala and Other Noise-Sensitive
Uses (e.g., Schools, Hospitals, and
Churches)
Less than 60 Satisfactory
60 to 75 Acoustic study and noise attenuation measures required Over 75 Acoustic study and noise attenuation measures required Auditoriums, Concert Halls,
Amphitheaters
Less than 70 Acoustic study and noise attenuation measures required Over 70 Not Allowed
Commercial and Industrial
Less than 70 Satisfactory
70 to 80 Acoustic study and noise attenuation measures required Over 80 Acoustic study and noise attenuation measures required Outdoor Sports and Recreation, Parks
Less than 65 Satisfactory
65 to 80 Acoustic study and noise attenuation measures required; avoid uses involving concentrations of people or animals Over 80 Limited to open space; avoid uses involving
concentrations of people or animals
Note:
a. New residential development in noise impacted areas are subject to the following noise levels:
 For new single-unit residential development, maintain a standard of 60 Ldn for exterior noise in private use areas.  For new multi-unit residential development, maintain a standard of 65 Ldn in community outdoor recreation areas. Noise standards are not applied to private decks and balconies and shall be considered on a case-by-case basis in the MU-DC District.  Where new residential units (single and multifamily) would be exposed to intermittent noise levels generated during train operations, maximum railroad noise levels inside homes shall not exceed forty-five dBA in bedrooms or fifty-five dBA in other occupied spaces. These single-event limits are only applicable where there are normally four or more train operations per day.

Source: City of San Carlos Municipal Code, Chapter 18.21 Performance Standards, revised 1/24.  Section 18.21.050-C, Acoustic Study, permits the Director to require an acoustic study for any proposed project that could cause any of the following:
 Create an inconsistency with the noise requirements of the San Carlos Airport as defined in Section 18.21.150, San Carlos Airport land use compatibility plan consistency;  Where applicable, noise attenuation measures may be required;  Cause noise levels to exceed the limits in Table 18.21.050-A (Table 4.11-10, Non-Transportation Noise Standards);
 Create a noise exposure that would require an acoustic study and noise attenuation measures listed in Table 18.21.050-B (Table 4.11-7), Noise Exposure-Land Use Requirements and Limitations;
 Cause the Ldn at noise-sensitive uses to increase three dBA or more.  Section 18.21.050-D, Establishing Ambient Noise, states that when the Director has determined that there could be cause to make adjustments to the standards, an acoustical study shall be performed to establish ambient noise levels. In order to determine if adjustments to the standards should be made either upwards or downwards, a minimum twenty-four-hour-duration noise measurement shall be conducted. The noise measurements shall collect data utilizing noise metrics that are consistent with the noise limits presented in SCMC Table 18.21.050-A, e.g., L max (zero minutes), L 02 (one minute), L 08 (five minutes), L 25 (fifteen minutes) and L 50 (thirty minutes). An arithmetic average of these ambient noise levels during the three quietest hours shall be made to demonstrate that the ambient noise levels are regularly ten or more decibels below the respective noise 2045 GENERAL PLAN RESET DRAFT EIR

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standards. Similarly, an arithmetic average of ambient noise levels during the three loudest hours should be made to demonstrate that ambient noise levels regularly exceed the noise standards.  Section 18.21.050-E, Noise Attenuation Measures, states that any project subject to the acoustic study requirements of subsection C of this section may be required as a condition of approval to incorporate noise attenuation measures deemed necessary to ensure that noise standards are not exceeded.
 New noise-sensitive uses (e.g., schools, hospitals, churches, and residences) shall incorporate noise attenuation measures to achieve and maintain an interior noise level of forty-five dBA.  Noise attenuation measures identified in an acoustic study shall be incorporated into the project to reduce noise impacts to satisfactory levels.
 Emphasis shall be placed upon site planning and project design measures. The use of noise barriers shall be considered and may be required only after all feasible design-related noise measures have been incorporated into the project.
 Section 18.21.050-F, Airport Land Use Compatibility Plan Consistency, states that where required, conformance with applicable airport land use compatibility plan standards, as described in Section

18.21.150, San Carlos Airport land use compatibility plan consistency, is required.  Section 18.21.060, Vibration, prohibits the production of vibration that is transmitted through the ground and is discernible without the aid of instruments by a reasonable person at the lot lines of the site. Vibrations from temporary construction, demolition, and vehicles that enter and leave the subject parcel (e.g., construction equipment, trains, trucks, etc.) are exempt from this standard.  Section 18.21.150-C, Airport Noise Evaluation and Mitigation, requires all proposed development projects, alterations, or changes of use subject to the ALUCP to be reviewed for consistency with the noise policies of the ALUCP, including the avigation easement requirements of San Carlos ALUCP Noise Policy 7. Uses listed as “conditionally compatible” in the ALUCP will be required to mitigate impacts to comply with the interior noise standards established in the ALUCP or General Plan, whichever is more restrictive.

EXISTING CONDITIONS
The City's existing General Plan Noise Element identifies the primary contributors to the city's noise environment as coming from motor vehicles and aircraft overflights. The San Carlos Airport is located in the eastern area of the city, east of Hwy 10, near Holly Avenue interchange. Other sources of community noise include rail activities and commercial and industrial land uses. One rail line operated by Caltrain runs parallel to El Camino Real and Old County Road through the city. The majority of commercial and industrial land uses within San Carlos are located east-northeast of El Camino Real.

Sensitive Receptors
Certain land uses, such as residences, schools, and hospitals, are particularly sensitive to noise and vibration. Sensitive receptors include residential uses, retirement homes, hotel/motels, schools, libraries, community centers, places of public assembly, daycare facilities, churches and hospitals in the City of San Carlos. These uses are regarded as sensitive because they are where citizens most frequently engage in activities which are likely to be disturbed by noise, such as reading, studying, sleeping, resting, working 2045 GENERAL PLAN RESET DRAFT EIR

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from home, or otherwise engaging in quiet or passive recreation. Commercial and industrial uses are not particularly sensitive to noise or vibration.

Traffic Noise
On-road vehicles represent the most prominent source of noise in the city. Traffic noise levels depend primarily on the speed of the traffic and the volume of trucks. The primary source of noise from automobiles is high-frequency tire noise, which increases with speed. Highways and arterials that traverse San Carlos include HWY 101 along the eastern portion of the City and El Camino Real (SR-82) through the central portion of the City. In addition to these highways, major roadways in San Carlos include Holly Street, San Carlos Avenue, Alameda de Las Pulgas, Brittan Avenue, Crestview Drive, and Edgewood Road. Existing traffic noise conditions were modeled using the FHWA’s traffic noise prediction model (FHWA RD-77-108). Average daily traffic (ADT) volumes, vehicle mix (auto, medium-duty truck, heavy-duty truck), speeds, time of day split (day, evening, night), speeds, and number of lanes data were provided by Kittelson and Associates for roadway segments throughout the city. Table 4.11-8, Existing Traffic Noise Conditions, dBA CNEL, lists the calculated existing noise levels on roadways at a distance of 50 feet from the nearest travel lane centerline and the distances to the 70 dBA, 65 dBA, and 60 dBA CNEL noise contours.

TABLE 4.11-8 EXISTING TRAFFIC NOISE, DBA CNEL
Roadway
Segment
Daily Traffic
Volumes
Noise Level
at 50 feet
(dBA CNEL)
Distance to Noise Contour (feet)
From To
70 dBA
CNEL
65 dBA
CNEL
60 dBA
CNEL
El Camino Real the North Holly St 18,510 69 44 140 442
El Camino Real Holly St San Carlos Ave 19,025 70 45 144 454 El Camino Real San Carlos Ave Brittan Ave 19,815 70 48 152 480 El Camino Real Brittan Ave Howard Ave 18,170 69 44 139 440 El Camino Real Howard Ave the South 18,465 70 45 142 448 Old Country Road the North Holly St 11,095 66 19 59 188 Old Country Road Holly St Brittan Ave 6,045 63 10 32 102 Old Country Road Brittan Ave Howard Ave 10,480 67 25 78 245 Old Country Road Howard Ave the South 6,745 65 16 50 158 Industrial Road the North Holly St 10,500 67 25 79 251
Industrial Road Holly St Brittan Ave 9,615 67 23 73 229 Industrial Road Brittan Ave the South 10,855 67 26 82 259 Club Drive San Carlos Ave the South 10,530 62 8 26 83
Alameda de Las
Pulgas San Carlos Ave Brittan Ave 9,465 64 11 36 115
Alameda de Las
Pulgas Brittan Ave the South 9,980 64 12 38 121
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TABLE 4.11-8 EXISTING TRAFFIC NOISE, DBA CNEL
Roadway
Segment
Daily Traffic
Volumes
Noise Level
at 50 feet
(dBA CNEL)
Distance to Noise Contour (feet)
From To
70 dBA
CNEL
65 dBA
CNEL
60 dBA
CNEL
Holly Street the West El Camino Real 17,705 64 14 44 139 Holly Street El Camino Real Old Country Rd 7,170 61 6 18 57 Holly Street Old Country Rd Industrial Rd 17,310 66 21 66 209 San Carlos Avenue Club Dr Alameda de Las
Pulgas 3,535 59 4 14 43
San Carlos Avenue Alameda de Las
Pulgas El Camino Real 14,130 64 11 36 113
Brittan Avenue the West Alameda de Las
Pulgas 8,310 63 10 32 101
Brittan Avenue Alameda de Las
Pulgas El Camino Real 7,165 62 9 28 87
Brittan Avenue Old Country Rd Industrial Rd 6,205 63 11 34 107 Howard Avenue the West El Camino Real 9,350 63 9 29 92
Howard Avenue Old Country Rd the East 4,870 62 8 27 84
Source: Federal Highway Administration Highway Traffic Noise Prediction Model based on traffic volumes provided by Kittelson and Associates in 2024.

Calculations included in Appendix C, Noise Data, of this Draft EIR.

Rail Noise and Vibration
There are 35 weekday northbound stops a day scheduled and 35 weekday southbound stops a day scheduled at the San Carlos Caltrain Station. In addition to the scheduled stops, Caltrain makes a number of passbys through the city throughout the day. Day-night average noise levels are estimated to range from 67 to 69 dBA Ldn at a distance of 100 feet from the tracks. Due to the grade-separated line, train warning whistles are not sounded frequently in San Carlos but can generate maximum noise levels of approximately 105 dBA at 100 feet.

Trains are considered to be a source of perceptible ground-borne vibration within approximately 50 to 100 feet of the tracks. Ground-borne vibration occurs in areas adjacent to fixed rail lines when railroad trains pass through San Carlos. Ground vibration levels along the railroad corridors are proportional to the speed and weight of the trains as well as the condition of the tracks and train engine and car wheels.

Vibration measurements conducted in San Carlos indicate that the acceptable levels occur about 65 feet from the center of the near railroad track for the maximum measured train vibration level and about 55 feet from the center of the near railroad track for typical train passbys.

San Carlos Airport Noise
Aircraft using San Carlos Airport intermittently contribute to ambient noise levels in the city. This general aviation airport is located east of Highway 101 near the Holly Avenue interchange within the San Carlos city limit. The airport is owned and operated by the County of San Mateo and accommodates almost 400 2045 GENERAL PLAN RESET DRAFT EIR

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based aircraft and a variety of aviation-related businesses, including flight schools. San Carlos Airport is designated as a reliever airport in the National Plan of Integrated Airport Systems (NPIAS). Reliever airports are located in major metropolitan areas and provide general aviation pilots and users with an alternative to congested commercial service airports like San Francisco International Airport. San Mateo County and the San Carlos Pilot’s Association promote noise reduction practices by airport users, including avoiding flying over sensitive areas.

Land uses near San Carlos Airport are predominantly industrial and commercial uses compatible with the aircraft noise. Noise from aircraft is audible, but not in excess of 65 dB CNEL. Individual event passes over San Carlos do not produce any additional amount of noise that would cause the existing noise contour configuration to be altered. Jet aircraft to and from the San Jose and San Francisco International Airports generate intermittent noise when passing over the City of San Carlos. Noise generated by these over-flights, although audible and noticeable in quiet areas above other ambient noise sources, do not contribute to daily average noise levels in the city.7
Non-Transportation Noise
Non-transportation sources also contribute to the project area's existing noise environment. Commercial and industrial land uses are located throughout the project area, primarily along key roadways like US 101, El Camino Real, Industrial Road, and San Carlos Avenue. Schools and outdoor park and recreation facilities, and residential land uses generate noise from daily operations of landscaping equipment, stationary sources such as heating, ventilation, and air conditioning (HVAC) equipment, business deliveries, solid waste pickup services, etc. Such sources of noise are considered local sources that only influence the immediate surroundings.

4.11.2 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant noise impact if it would:

NOISE-1 Generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

NOISE-2 Generate excessive groundborne vibration or groundborne noise levels.

NOISE-3 For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, expose people residing or working in the project area to excessive noise levels.

NOISE-4 In combination with past, present, and reasonably foreseeable projects, result in cumulative noise impacts in the area.
7 City/County Association of Governments of San Mateo County. 2015, October. Comprehensive Land Use Compatibility Plan for the Environs of San Carlos Airport. https://ccag.ca.gov/wp-content/uploads/2015/11/SQL_FinalALUCP_Oct15_read.pdf 2045 GENERAL PLAN RESET DRAFT EIR

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Construction Noise
SCMC Section 9.30.070 exempts construction noise during the hours of eight a.m. to five p.m., Monday through Friday, and nine a.m. to five p.m. on Saturday. However, the City does not have established noise thresholds for construction noise impact analysis. Therefore, the FTA construction noise criterion of 80 dB(A) Leq(8hr) is used in this analysis to assess construction noise impacts at sensitive receptors. Because this is a programmatic EIR, project-level analysis of construction noise would be speculative and is therefore not presented. Potential future impacts from construction noise are addressed qualitatively and include program-level mitigation measures.

Stationary Noise
SCMC provides noise standards for non-transportation noise sources in Section 18.21.050, Noise Limits.

For non-transportation noise sources that would be analyzed at the project level, pursuant to Section

18.21.050, the exterior noise level limit in residential districts is 55 dB(A) L50 and 70 dBA Lmax during daylight hours and 45 dB(A) L50 and 60 dBA Lmax during nighttime hours. The interior noise level limit in residential districts is 40 dB(A) L50 and 55 dBA Lmax during daylight hours and 30 dB(A) L50 and 45 dBA Lmax during nighttime hours.

Vibration
SCMC Section 18.21.060 considers vibrations from temporary construction, demolition, and vehicles that enter and leave the subject parcel (e.g., construction equipment, trains, trucks, etc.) exempt from the City’s standard. However, the City does not have established vibration thresholds for construction noise impact analysis. Therefore, Caltrans’ vibration thresholds shown in Table 4.11-3, Construction Vibration Damage Criteria, would apply to assess building damage and FTA thresholds shown in Table 4.11-4, FTA Groundborne Vibration Impact Criteria, would apply to assess human annoyance. Because this is a programmatic EIR, project-level analysis of construction noise would be speculative and is therefore not presented. Potential future impacts from construction noise are addressed qualitatively and include program-level mitigation measures.

Portions of the project are within the “Conditionally Acceptable” range for residential land uses, according to the San Carlos noise and land use compatibility standards (see Table 4.11-9, San Carlos Land Use Compatibility for Community Noise Environments). However, as a result of the Supreme Court decision regarding the assessment of the environment’s impacts on projects (California Building Industry Association (CBIA) v. Bay Area Air Quality Management District (BAAQMD), 62 Cal. 4th 369 (No. S 213478) issued December 17, 2015), it is generally no longer the purview of the CEQA process to evaluate the impact of existing environmental conditions on any given project. As a result, while the noise from existing sources is taken into account as part of the baseline condition, the direct effects of exterior noise from nearby noise sources relative to land use compatibility of a proposed project is typically no longer a required topic for impact evaluation under CEQA. Generally, no determination of significance is required except for certain school projects, projects affected by airport noise, and projects that would exacerbate existing conditions (i.e., projects that would have a significant operational impact).
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4.11.3 IMPACT DISCUSSION
NOISE-1 The proposed project would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

The City of San Carlos General Plan provides objectives, policies, and implementing actions in Chapter 9, Noise Element, that address land use compatibility with environmental noise levels and to ensure that city residents will be protected from excessive noise intrusion, both now and in the future. The noise standards specified in the Noise Element are a guideline to evaluate the acceptability of the noise levels generated by vehicular traffic and the San Carlos Airport. These standards are used for assessment of long-term traffic- and aircraft-related noise impacts on land uses. The Noise Element also establishes the noise/land use compatibility criteria to be used in determining whether a new use is appropriate within a given noise environment, the criteria is presented in Table 4.11-9, San Carlos Land Use Compatibility for Community Noise Environments.

TABLE 4.11-9 SAN CARLOS LAND USE COMPATIBILITY FOR COMMUNITY NOISE ENVIRONMENTS Land Uses
Ldn (dBA)
55 60 65 70 75 80 85
Single-Family Residential
Multi-Family Residential, Hotels, and Motelsa
Schools, Libraries, Museums, Hospital, Personal Care, Meeting Halls, Churches
Auditoriums, Concert Halls, Amphitheaters
Outdoor Sports and Recreation, Neighborhood Parks, and Playgrounds Office Buildings, Business, Commercial and Professional Normally Acceptable:

Specified land use is satisfactory based upon the assumption that any buildings involved are of normal conventional
construction, without any special noise insulation
requirements.

Conditionally Acceptable:

Specified land use may be permitted only after detailed analysis of the noise reduction requirements and needed noise
insulation features included in the design.

Unacceptable:

New construction or development generally should not
be undertaken because mitigation is usually not feasible to comply with noise element policies.

Source: City of San Carlos, 2030 General Plan.
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Table 4.11-10, Non-Transportation Noise Standards, lists exterior and interior daytime and nighttime noise standards for various land uses, as presented in the Noise Element.

TABLE 4.11-10 NON-TRANSPORTATION NOISE STANDARDS
Land Use Receiving the
Noise
Hourly
Noise-Level
Descriptor
Exterior Noise-Level
Standard in Any Hour (dBA)
Interior Noise-Level
Standard In Any Hour (dBA)
Daytime
(7 a.m. to 10 p.m.)
Nighttime
(10 p.m. to 7 a.m.)
Daytime
(7 a.m. to 10 p.m.)
Nighttime
(10 p.m. to 7 a.m.)
Residential L50
Lmax
55 70
45 60
40 55
30 45
Medical, convalescent L50
Lmax
55 70
45 60
45 55
35 45
Theater, auditorium L50
Lmax
--
--
--
--
35 50
35 50
Church, meeting hall L50
Lmax
55 --
--
--
40 55
40 55
School, library, museum L50
Lmax
55 --
--
--
40 55
--
--
Notes:

1. The Residential standards apply to all residentially zoned properties.

2. Each of the noise levels specified above shall be lowered by 5 dBA for tonal noises characterized by a whine, screech, or hum, noises consisting primarily of speech or music, or recurring impulsive noises.

3. In situations where the existing noise level exceeds the noise levels indicated in the above table, any new noise source must include mitigation that reduces the noise level of the noise source to the existing level.

4. The exterior noise standards are measured at any point on the receiving property where there is, or could be in the future, frequent human use and quiet would be beneficial.

5. These standards do not apply to temporary sources such as construction activities.

Source: City of San Carlos, 2009, San Carlos 2030 General Plan. Revised January 2023.

Construction Noise
Because this is a programmatic EIR, project-level conclusions of construction noise would be speculative and are therefore not presented in this analysis. Potential future impacts from construction noise are addressed qualitatively and include program-level mitigating policies.

Future development in the project area could result in two types of temporary noise impacts during construction. First, the transport of workers and movement of materials to and from the site could incrementally increase noise levels along local access roads. Second, noise would be generated from activities related to demolition, site preparation, grading, and/or physical construction. Construction is performed in distinct steps, each of which has its own mix of equipment and, consequently, its own noise characteristics. Table 4.11-11, Typical Construction Equipment Noise Emission Levels, lists typical construction equipment noise levels recommended for noise-impact assessments, based on a distance of 50 feet between the equipment and noise receptor.
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TABLE 4.11-11 TYPICAL CONSTRUCTION EQUIPMENT NOISE EMISSION LEVELS Construction
Equipment
Typical Max Noise Level
(dB(A) Lmax) a
Construction
Equipment
Typical Max Noise Level
(dB(A) Lmax) a
Air Compressor 81 Pile-Driver (Impact) 101
Backhoe 80 Pile-Driver (Sonic) 96
Ballast Equalizer 82 Pneumatic Tool 85
Ballast Tamper 83 Pump 76
Compactor 82 Rail Saw 90
Concrete Mixer 85 Rock Drill 98
Concrete Pump 71 Roller 74
Concrete Vibrator 76 Saw 76
Crane, Derrick 88 Scarifier 83
Crane, Mobile 83 Scraper 89
Dozer 85 Shovel 82
Generator 81 Spike Driver 77
Grader 85 Tie Cutter 84
Impact Wrench 85 Tie Handler 80
Jack Hammer 88 Tie Inserter 85
Loader 85 Truck 88
Paver 89
Note:
a. Measured 50 feet from the source.

Source: Federal Transit Administration, 2018, Transit Noise and Vibration Impact Assessment Manual.

As described in Section 4.11.2.1, Construction Noise, the City does not have established noise thresholds for construction noise, and the FTA construction noise criterion of 80 dB(A) Leq(8hr) is applied in this analysis to assess construction noise impacts at sensitive receptors. As shown in Table 4.11-11, construction equipment generating high levels of noise from 81 dB(A) to 101 dB(A) exceed the applied standard. Construction of future development projects within the buildout horizon of the proposed project would most likely have multiple pieces of construction equipment operating at once, which would temporarily increase the ambient noise environment and would have the potential to affect noise-sensitive land uses in the vicinity of development sites.

Construction noise levels are highly variable and dependent upon the specific locations, site plans, and construction details of individual projects. Construction would be localized and would occur intermittently for varying periods of time. Significant noise impacts may occur from operation of heavy earth-moving equipment and truck haul operations associated with construction of individual development projects, particularly if construction techniques such as impact or vibratory pile driving are used. The time of day that construction activity is conducted would also determine the significance of such potential impacts, particularly during the more sensitive nighttime hours.

As described in Section 4.11.1.2, Regulatory Framework, under the subheading “San Carlos Municipal Code,” the City requires an acoustic study for any projects that may create noise levels in excess of City standards or otherwise expose noise-sensitive uses to increases of 3 dBA or more. 2045 GENERAL PLAN RESET DRAFT EIR

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In addition, the Noise (NOI) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to noise, including construction noise. The following General Plan goal and policy would serve to minimize construction noise effects:
 Goal NOI-1: Encourage compatible noise environments for new development and control sources of excessive noise citywide.
 Policy NOI-1.8: All construction activities shall comply with the City’s noise ordinance.

Development projects that require an acoustical study shall incorporate reasonable noise and vibration reduction measures and best management practices to minimize excessive noise levels during all phases of construction activity. Reduction measures and best management practices may include, but are not limited to, noise control techniques for construction tools and equipment, construction site management techniques, temporary noise barriers, noise monitoring and reporting, and/or construction traffic management.

General Plan Policy NOI-1.8 requires the implementation of construction best management practices to minimize noise to the extent feasible. Some common construction best management practices include requiring projects to:
 Use the best-available noise control techniques (e.g., improved mufflers, use of intake silencers, ducts, engine enclosures, and acoustically attenuating shields or shrouds) wherever feasible on equipment and trucks used for project construction.
 Require the contractor to use impact tools (e.g., jack hammers and hoe rams) that are hydraulically or electrically powered wherever possible. Where the use of pneumatic tools is unavoidable, an exhaust muffler on the compressed air exhaust shall be used along with external noise jackets on the tools.
 Locate stationary equipment such as generators and air compressors as far as feasible from nearby noise-sensitive uses.
 Locate stockpiling as far as feasible from nearby noise-sensitive receptors.  Limit construction traffic—to the extent feasible—to haul routes approved in advance of issuing building permits by the City.
 Require the telephone numbers of the authorized representatives for the City and the contractor that are assigned to respond in the event of a noise or vibration complaint to be displayed on construction signs posted at the construction site. If the authorized contractor’s representative receives a complaint, he/she shall investigate, take appropriate corrective action, and report the action to the City.
 Post signs at the job site entrance(s), within the on-site construction zones, and along queueing lanes (if any) to reinforce the prohibition of unnecessary engine idling. All other equipment shall be turned off if not in use for more than 5 minutes.
 Require that noise-producing signals, including horns, whistles, alarms, and bells, be used for safety warning purposes only, to the extent feasible. The construction manager shall use smart back-up alarms, which automatically adjust the alarm level based on the background noise level, 2045 GENERAL PLAN RESET DRAFT EIR

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or switch off back-up alarms and replace with human spotters in compliance with all safety requirements and laws.
 Erect temporary noise barriers (at least as high as the exhaust of equipment and breaking line-ofsight between noise sources and sensitive receptors), as necessary and feasible, to maintain construction noise levels at or below the performance standard of 80 dB(A) Leq(8hr) and/or when the anticipated construction duration is greater than typical (two years or greater). Barriers shall be constructed with a solid material that has a density of at least 4 pounds per square foot with no gaps from the ground to the top of the barrier.

In most cases, construction of individual development projects would temporarily increase the ambient noise environment in the vicinity of each individual project, potentially affecting existing and future nearby sensitive uses. General Plan Policy NOI-1.8 and SCMC requirements would ensure construction activities do not occur during the most sensitive time periods (e.g., evening and nighttime periods) and require future discretionary projects to assess and minimize construction noise levels consistent with City goals, policies, and code standards as applicable. With compliance with SCMC requirements and General Plan Policy NOI-1.8, in addition to best management practices, temporary program-level construction noise impacts associated with implementation of the proposed 2045 General Plan Reset are considered less than significant.

Significance without Mitigation: Less than significant.

Traffic Noise
Future development within the buildout horizon of the proposed project would cause increases in vehicle traffic along local roadways. Vehicle traffic noise levels were estimated using the FHWA Highway Traffic Noise Prediction Model. Vehicle traffic volumes for existing and 2045 conditions were obtained from Kittelson and Associates (see Appendix C, Noise Data). Vehicle trips for the proposed project include all trip purposes, such as home-based trips, work commute trips, recreational trips, and schoolrelated trips. The FHWA model predicts noise levels through a series of adjustments to a reference sound level. These adjustments account for distances from the roadway, vehicle traffic volumes, vehicle speeds, car/truck mix, number of lanes, and road width.

Table 4.11-12, Project-Related Increase in Cumulative Traffic Noise, dBA CNEL, shows the existing and future predicted noise levels at 50 feet from the nearest travel centerline, as well as the predicted traffic noise increases with implementation of the project. Appendix C, Noise Data, of this Draft EIR contains the traffic noise modeling inputs and outputs.

As shown in Table 4.11-12, there are no roadway segments that would experience a traffic noise increase of 1.5 dBA CNEL or greater with buildout of the proposed project. The highest traffic noise increase is predicted to be 1 dBA CNEL along El Camino Real. Therefore, traffic noise impacts due to implementation of the proposed project would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.11-12 PROJECT-RELATED INCREASE IN CUMULATIVE TRAFFIC NOISE, DBA CNEL Roadway
Segment dBA CNEL at 50 Feet
2045 Noise
Increase,
CNEL
Significant
From To Existing Increase
2045 No
Project
2045 Plus
Project
El Camino Real the North Holly St 69 69 70 1 No
El Camino Real Holly St San Carlos Ave 70 69 70 1 No
El Camino Real San Carlos Ave Brittan Ave 70 70 71 1 No El Camino Real Brittan Ave Howard Ave 69 69 70 1 No
El Camino Real Howard Ave the South 70 69 70 1 No
Old Country Road the North Holly St 66 68 68 <1 No
Old Country Road Holly St Brittan Ave 63 65 65 <1 No
Old Country Road Brittan Ave Howard Ave 67 69 69 <1 No
Old Country Road Howard Ave the South 65 67 67 <1 No
Industrial Road the North Holly St 67 69 70 <1 No
Industrial Road Holly St Brittan Ave 67 70 70 <1 No
Industrial Road Brittan Ave the South 67 69 69 <1 No
Club Drive San Carlos Ave the South 62 63 64 <1 No
Alameda de Las
Pulgas San Carlos Ave Brittan Ave 64 65 65 <1 No
Alameda de Las
Pulgas Brittan Ave the South 64 65 65 <1 No
Holly Street the West El Camino Real 64 65 66 <1 No
Holly Street El Camino Real Old Country Rd 61 62 62 <1 No Holly Street Old Country Rd Industrial Rd 66 67 67 <1 No San Carlos Avenue Club Dr Alameda de Las
Pulgas 59 61 61 <1 No
San Carlos Avenue Alameda de Las
Pulgas El Camino Real 64 64 64 <1 No
Brittan Avenue the West Alameda de Las
Pulgas 63 64 64 <1 No
Brittan Avenue Alameda de Las
Pulgas El Camino Real 62 64 64 <1 No
Brittan Avenue Old Country Rd Industrial Rd 63 64 65 <1 No Howard Avenue the West El Camino Real 63 63 63 <1 No
Howard Avenue Old Country Rd the East 62 63 63 <1 No
Source: Federal Highway Administration Highway Traffic Noise Prediction Model based on traffic volumes provided by Kittelson and Associates in 2024.

Calculations included in Appendix C, Noise Data, of this Draft EIR.

Rail Noise
As discussed in Section 4.11.1.3, Existing Conditions, the City of San Carlos has one rail line that runs north-south through the eastern half of the city along El Camino Real. In addition to the scheduled stops, Caltrain makes a number of passbys through the city throughout the day. Day-night average noise levels are estimated to range from 67 to 69 dBA Ldn at a distance of 100 feet from the tracks. Due to the grade 2045 GENERAL PLAN RESET DRAFT EIR

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separation of the line, train warning whistles are not sounded frequently in San Carlos but can generate maximum noise levels of approximately 105 dBA at 100 feet.

The Noise (NOI) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to noise, including rail noise.

The following General Plan goal and policies would integrate noise considerations into land use planning decisions and require design strategies for minimize noise effects:
 Goal NOI-1: Encourage compatible noise environments for new development and control sources of excessive noise citywide.
 Policy NOI-1.1 Use the Noise and Land Compatibility Standards shown in Figure 9-1, the noise level performance standards in Table 9-1 and the projected future noise contours for the General Plan shown in Figure 9-3 and detailed in Table 9-2, as a guide for future planning and development decisions.
 Policy NOI-1.2 Minimize noise impacts on noise sensitive land uses. Noise-sensitive land uses include residential uses, retirement homes, hotel/motels, schools, libraries, community centers, places of public assembly, daycare facilities, churches and hospitals.  Policy NOI-1.3 Limit noise impacts on noise-sensitive uses to noise level standards as indicated in Table 9-1.
 Policy NOI-1.4 Require a detailed acoustic report in all cases where noise-sensitive land uses are proposed in areas exposed to exterior noise levels of 60 CNEL Ldn or greater. If recommended in the report, mitigation measures shall be required as conditions of project approval.  Policy NOI-1.5 New development of noise-sensitive land uses proposed in noise-impacted areas shall incorporate effective mitigation measures into the project design to reduce exterior and interior noise levels to the following acceptable levels:
a. For new single-family residential development, maintain a standard of 60 Ldn (day/night average noise level) for exterior noise in private use areas. b. For new multi-family residential development maintain a standard of 65 Ldn in community outdoor recreation areas. Noise standards are not applied to private decks and balconies and shall be considered on a case-by-case basis.
c. Interior noise levels shall not exceed 45 Ldn in all new residential units (single- and multifamily). Development sites exposed to noise levels exceeding 60 Ldn shall be analyzed following protocols in Appendix Chapter 12, Section 1208, A, Sound Transmission Control, 2001 Building Code Chapter 12, Appendix Section 1207.11.2 of the 2007 California Building Code (or the latest revision).
d. Where new residential units (single and multi-family) would be exposed to intermittent noise levels generated during train operations, maximum railroad noise levels in side homes shall not exceed 50 dBA in bedrooms or 55 dBA in other occupied spaces. These single event limits are only applicable where there are normally four or more train operations per day. 2045 GENERAL PLAN RESET DRAFT EIR

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 Policy NOI-1.6 Where noise mitigation measures are required to achieve the noise level standards, the emphasis of such measures shall be placed upon site planning and project design.

The use of noise barriers shall be considered after practical design-related noise mitigation measures have been integrated into the project.
 Policy NOI-1.9 Minimize potential transportation related noise through the use of setbacks, street circulation design, coordination of routing and other traffic control measures and the construction of noise barriers and consider use of “quiet” pavement surfaces when resurfacing roadways.

Noise levels along the railroad under the proposed project would remain the same as existing conditions; any changes to the frequency of trains or to train equipment would be initiated and implemented by the respective rail authority, rather than the City of San Carlos, and are not part of the proposed project. However, implementation of the proposed project could locate sensitive receptors and future structures near the existing rail line with development intensity to accommodate new population and employment growth. All future development projects subject to discretionary review under the proposed project would be evaluated for noise/land use compatibility, including railway noise/land use compatibility. Caltrain noise sources are addressed with General Plan Policies NOI-1.1 through NOI-1.6, and NOI-1.9, land use compatibility standards, shown in Table 4.11-10, Non-Transportation Noise Standards. and requirements and limitations of SCMC 18.21.050-B, shown in Table 4.11-7, Noise Exposure—Land Requirements and Limitations.

No aspect of the proposed project would increase railway noise levels along the existing railroad.

Compliance with SCMC requirements and General Plan goals and policies would ensure rail noise impacts associated with implementation of the proposed 2045 General Plan Reset are considered less than significant.

Significance without Mitigation: Less than significant.

Stationary Source Noise
Stationary sources of noises may occur on all types of land uses. Residential uses generate noise from landscaping, maintenance activities, and air conditioning systems. Commercial uses generate noise from HVAC systems, loading docks, and other sources. Industrial uses may generate noise from HVAC systems, loading docks, and possibly machinery. Noise generated by residential or commercial uses is generally short and intermittent. Industrial uses may generate noise on a more continual basis. Nightclubs, outdoor dining areas, gas stations, car washes, fire stations, drive-throughs, swimming pool pumps, school playgrounds, and public parks are other common noise sources. Stationary noise sources are controlled by General Plan non-transportation noise standards, shown in Table 4.11-10, NonTransportation Noise Standards, and SCMC Section 9.30 and Section 18.21.050.

With adherence to SCMC requirements and General Plan goals, policies, and actions, stationary noise impacts associated with future development and activities under the proposed project are considered less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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NOISE-2 The proposed project would not generate excessive groundborne vibration or groundborne noise levels.

Construction Vibration
Construction of future projects in the project area would generate varying degrees of ground vibration that may cause human reactions (annoyance) and effects on buildings (damage), depending on the construction procedures and equipment. The use of construction equipment generates vibration that spreads through the ground and diminishes with distance from the source. The effect on sensitive buildings in the vicinity of a construction site varies depending on soil type, ground strata, and the type of construction equipment used. The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibrations at moderate levels, to slight structural damage at the highest levels. Vibration from construction activities rarely reaches the levels that can damage structures, but can achieve the audible and perceptible ranges in buildings close to a construction site. However, vibration is almost never annoying to people who are outdoors, so it is usually evaluated in terms of indoor receivers. Table 4.11-14, Reference Vibration Levels for Construction Equipment, lists typical vibration levels for construction equipment in PPV and VdB.

TABLE 4.11-14 REFERENCE VIBRATION LEVELS FOR CONSTRUCTION EQUIPMENT Equipment
Approximate Vibration Level at 25
feet, PPV in/sec a
Approximate Vibration Level at 25
feet, VdB re 1 micro-in/sec b
Pile Driver, Impact (Upper Range) 1.518 112
Pile Driver, Impact (Typical) 0.644 104
Pile Driver, Sonic (Upper Range) 0.734 105
Pile Driver, Sonic (Typical) 0.170 93
Vibratory Roller 0.210 94
Large Bulldozer 0.089 87
Caisson Drilling 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
Note:
a. Peak Particle Velocity (PPV) = The peak rate of speed at which soil particles move (e.g., inches per second) due to ground vibration. b. Vibration Decibel (VdB) = A unitless measure of vibration, expressed on a logarithmic scale and with respect to a defined reference vibration velocity. In the U.S., the standard reference velocity is one microinch per second (1x10-6 in/sec).

Source: Federal Transit Administration, 2018, Transit Noise and Vibration Impact Assessment.

As described in Section 4.11.2.3, Vibration, because the City does not have established thresholds for vibration, Caltrans’ vibration thresholds shown in Table 4.11-3, Construction Vibration Damage Criteria, are applied to the assessment building damage and FTA thresholds shown in Table 4.11-4, FTA Groundborne Vibration Impact Criteria, are applied to the assessment of human annoyance. As shown in Table 4.13-14, vibration generated by construction equipment has the potential to be substantial, since it has the potential to exceed the Caltrans criteria for architectural damage (i.e., 0.12 in/sec PPV for buildings extremely susceptible to vibration damage, 0.2 in/sec PPV for nonengineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). Typical construction 2045 GENERAL PLAN RESET DRAFT EIR

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activities may be barely to distinctly perceptible when occurring within approximately 150 feet of sensitive land uses with regards to annoyance. Most construction equipment does not operate in the same location for prolonged periods of time. Therefore, even if construction equipment were to operate near a building where receptors may feel vibration, it would only be for a temporary amount of time and would be limited to daytime hours.

Vibration sources are controlled by SCMC Section 9.30.070, limiting construction to daytime hours, and Section 18.21.060, temporary construction vibration exemption. In most cases of individual developments associated with implementation of the proposed project, construction that requires the use of vibration-causing construction equipment, such as pile driving, caisson drilling, vibratory roller, or a large bulldozer, would temporarily increase the ambient vibration environment in the vicinity of the individual project, potentially affecting existing and future nearby sensitive receptors. The use of alternate methods/equipment for construction throughout the entire active construction period would help to ensure that construction vibration is minimized to the extent feasible. Some common alternate methods/equipment used for construction include, but are not limited to:
 For pile driving, the use of caisson drilling (drill piles), vibratory pile drivers, oscillating or rotating pile installation methods, pile pressing, “silent” piling, and jetting or partial jetting of piles into place using a water injection at the tip of the pile.
 For paving, use of a static roller in lieu of a vibratory roller.  For grading and earthwork activities, off-road equipment limited to 100 horsepower or less.

Compliance with SCMC requirements construction in addition to best management practices, temporary program-level construction vibration impacts associated with implementation of the proposed project are considered less than significant.

Significance without Mitigation: Less than significant.

Caltrain Vibration
The proposed project could facilitate the construction of new buildings adjacent to the existing Caltrain railroad tracks. With regards to vibration impacts on new development near railroads, human disturbance is the primary concern. Trains are considered to be a source of perceptible ground-borne vibration within approximately 50 to 100 feet of the tracks. It is extremely rare for vibration levels from trains passing to result in structural damage to buildings. Ground vibration levels along the railroad corridors are proportional to the speed and weight of the trains as well as the condition of the tracks and train engine and car wheels.

The following General Plan goal and policies would integrate noise considerations into land use planning decisions and require design strategies to minimize noise effects associated with trains:
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 Goal NOI-1: Encourage compatible noise environments for new development and control sources of excessive noise citywide.
 Policy NOI-1.7 The City shall seek to reduce impacts from ground-borne vibration associated with rail operations by requiring that vibration-sensitive buildings (e.g. residences) are sited at least 100 feet from the centerline of the railroad tracks whenever feasible. The development of vibration-sensitive buildings within 100 feet from the centerline of the rail-road tracks would require a study demonstrating that ground borne vibration issues associated with rail operations have been adequately addressed (i.e. through building siting, foundation design and construction techniques).
 Policy NOI-1.14 The Federal Transit Administration vibration impact criteria and assessment methods shall be used to evaluate the compatibility of train vibration with proposed land uses adjoining the UPRR (Caltrain) corridor. Site specific vibration studies shall be completed for vibration- sensitive uses proposed within 100 feet of active railroad tracks.

Ground vibration from trains passing through San Carlos could exceed the annoyance guidelines set forth by the FTA, shown in Table 4.11-4, if new buildings are constructed within 100 feet of the railroad tracks.

Policies NOI-1.7 and NOI-1.14 of the Noise Element calls for a study applying FTA vibration criteria to ensure that ground borne vibration issues associated with rail operations are adequately addressed for new development within 100 feet from the centerline of the railroad tracks.

Compliance with General Plan Policies NOI-1.7 and NOI-1.14 would ensure that Caltrain vibration impacts associated with implementation of the proposed 2045 General Plan Reset are considered less than significant.

Significance without Mitigation: Less than significant.

NOISE-3 The proposed project would not expose people residing or working in the project area to excessive noise levels for a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport.

As discussed in Section 4.11.1.3, Existing Conditions, the San Carlos Airport is a reliever airport that accommodates almost 400 based aircraft and a variety of aviation related businesses including flight.

The flight pattern is generally north and east of US Highway 101. Noise from aircraft is audible, but not in excess of 65 dBA CNEL, General Plan San Carlos Airport Noise Contour Map Figure 9-2, the 55 dBA CNEL/Ldn noise contour does not extend west of Industrial Road. Land uses near the San Carlos Airport are predominantly commercial and industrial uses that are compatible with the aircraft noise of up to 65 dBA CNEL/Ldn and 70 dBA CNEL/Ldn, respectively.

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The following General Plan goal and policies would integrate noise considerations into land use planning decisions and require design strategies to minimize noise effects associated with the San Carlos Airport:
 Goal NOI-1: Encourage compatible noise environments for new development and control sources of excessive noise citywide.
 Policy NOI-1.11 Ensure that proposed noise sensitive land uses include appropriate mitigation to reduce noise impacts from aircraft operations at San Carlos Airport. Work with the San Carlos Airport Pilots Association and San Mateo County to continue to refine and implement the Airport’s noise abatement procedures.
 Policy NOI-1.12 Ensure consistency with the noise compatibility policies and criteria contained in the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Carlos Airport.  Policy NOI-1.13 Require a noise analysis for new residential uses located within the 55 CNEL impact area of the San Carlos Airport. If recommended in the report, mitigation measures shall be required as conditions of project approval.

Aircraft noise sources are controlled by General Plan Policies NOI-1.11 through NOI-1.13, SCMC Sections

18.21.050-F and 18.21.150-C, and compliance with land use compatibility standards of the San Carlos Airport Land Use Plan would require a noise analysis if residential uses located within 55 dBA CNEL/Ldn airport noise contour and ensure appropriate mitigation measures are included at proposed noise sensitive uses.

Compliance with General Plan Policies NOI-1.11 and NOI-1.13, SCMC Sections 18.21.050-F and

18.21.150-C, and compliance with land use compatibility standards of the San Carlos Airport Land Use Plan, would ensure aircraft noise impacts associated with implementation of the proposed 2045 General Plan Reset are considered less than significant.

Significance without Mitigation: Less than significant.

NOISE-4 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative noise impacts in the area.

Implementation of the proposed 2045 General Plan Reset would result in construction noise and vibration with development of individual projects to be constructed over time. Typically, if there are no planned or approved projects within 500 feet of a proposed project, there would be no cumulative construction noise impact. Construction noise is greatly reduced at distance 500 feet or further in an urban and buildout out environment. If construction of individual projects were to overlap with cumulative projects in the vicinity, construction noise could result in a significant cumulative construction noise impact. Each individual project would be subject to City regulations and policies regarding construction noise and vibration, as discussed under impact discussions NOISE-1 and NOISE-2.

These policies, measures, and best management practices require the appropriate evaluation of construction noise and vibration impacts at sensitive receptor locations and to implement feasible construction noise and vibration control measures when development occurs near noise-sensitive 2045 GENERAL PLAN RESET DRAFT EIR

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receptors to ensure residents would not be exposed to excessive construction noise and vibration levels.

Therefore, cumulative construction noise and vibration impacts would be less than significant.

While traffic volumes would likely increase regardless of the implementation of the proposed project, the proposed project would introduce new development that would contribute to cumulative traffic volumes. A significant cumulative traffic noise increase would be identified if project traffic were calculated to contribute an increase of greater than the significance thresholds (1.5 dBA for ambient noise environments of 65 dBA CNEL and higher; 3 dBA for ambient noise environments of 60 to less than 65 CNEL; and 5 dBA for ambient noise environments of less than 60 dBA CNEL). As shown in Table 4.11- 12, Project-Related Increase in Cumulative Traffic Noise, dBA CNEL, project contribution to the cumulative increase of traffic noise would not exceed 1 dBA CNEL. Future cumulative transportation noise levels would not exceed the established noise standards, resulting in a significant cumulative impact. Therefore, cumulative traffic noise impacts would be less than significant.

Individual development projects would contribute to potential permanent increases in stationary noise levels evaluated under Impact NOISE-1. Individual development projects would be required to show compliance with City’s noise standards and General Plan noise policies for potential operational noise impacts during the development review process through evaluation and design considerations. New noise sensitive development would be limited in noise-impacted areas unless the development includes measures to reduce noise and vibration levels to acceptable levels. New noise producing developments would be required to show compliance with the SCMC noise standards to protect residents from excessive stationary noise sources. Therefore, cumulative operational noise impacts would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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4.12 PARKS AND RECREATION
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to parks and recreation, and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

4.12.1 ENVIRONMENTAL SETTING

REGULATORY FRAMEWORK
State Regulations
The 1975 Quimby Act (California Government Code Section 66477) authorizes cities and counties to adopt ordinances requiring that developers set aside land, donate conservation easements, or pay fees for park improvements. Revenues generated through the Quimby Act cannot be used for operation and maintenance of park facilities. A 1982 amendment (Assembly Bill [AB] 1600) requires agencies to clearly show a reasonable relationship between the public need for the recreation facility or parkland and the type of development project upon which the fee is imposed. Cities with a high ratio of park space to inhabitants can set a standard of up to 5 acres per 1,000 persons for new development. Cities with a lower ratio can only require the provision of up to 3 acres of park space per 1,000 persons.1 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.

Regional Regulations
In 1969, the McAteer-Petris Act designated the Bay Conservation and Development Commission (BCDC) as the agency responsible for the protection of the San Francisco Bay and its natural resources. BCDC fulfills this mission through the implementation of the San Francisco Bay Plan (Bay Plan), an enforceable plan that guides the future protection and use of San Francisco Bay and its shoreline.2 The Bay Plan includes a range of policies on public access, water quality, project design, and dredging and fill. The Bay Plan also designates shoreline areas that should be reserved for water-related sports, industry, and public recreation; airports; and wildlife areas. Note that the City of San Carlos is within BCDC’s jurisdiction. Impacts related to aesthetics, biological resources, and water quality, are discussed in Chapter 4.1, Aesthetics, Chapter 4.3, Biological Resources, and Chapter 4.9, Hydrology and Water Quality, of this Draft EIR.
1 California Legislative Information, 2015, Assembly Bill No. 1191, Chapter 276, https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201520160AB1191, accessed July 29, 2022. 2 San Francisco Bay Conservation and Development Commission, May 5, 2020, San Francisco Bay Plan, https://bcdc.ca.gov/pdf/bayplan/bayplan.pdf, accessed August 9, 2022. 2045 GENERAL PLAN RESET DRAFT EIR

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Local Regulations
San Carlos General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.12.3, Impact Discussion.

San Carlos Municipal Code
The San Carlos Municipal Code (SCMC) includes various directives pertaining to parks and recreation.

The SCMC is organized by title, chapter, and section, and in some cases, articles. Most provisions related to parks and recreation impacts are included in Title 3, Revenue and Finance and Title 17, Subdivisions.  Chapter 3.34, Park Facility Development Fee, as known as the Park Facility Development Fee Law of the City of San Carlos, applies to new residential development buildings in San Carlos. The Park Facility Development fee for Fiscal Year 2024-25 is $2,709 per bedroom.  Section 17.32.030, Park and recreation land dedications or in-lieu fees, states that where a park or recreational facility has been designated in the General Plan, and the park or facility is to be located in whole or in part within a proposed subdivision to serve the immediate and future needs of the residents of the subdivision, the subdivider shall be required to dedicate land for park and recreational facilities sufficient in size to serve the residents of the subdivision area. Additionally, if there are no park or recreation facilities designation but the subdivision is within a one-half- mile radius of a neighborhood park or recreational facility the subdivider shall be required to pay a cash payment in lieu of the land equal to the value of the land.

Parks, Open Space, Buildings and other Recreational Facilities Master Plan 2009-2029 Local regulations for parks and recreational facilities are contained within the Master Plan for Parks, Open Space, Buildings and other Recreational Facilities (Parks Master Plan), which was adopted in August 2008. The purpose of the Parks Master Plan is to provide the City with a long-term vision for its park system. The Parks Master 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 Parks Master Plan assumes a population of 34,264 in 2030, which is approximately 3,435 more people than the existing conditions of San Carlos in 2024. Using this rate of population growth, in addition to other factors, the Parks Master Plan identifies the following needs within the next 10 to 15 years:
 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
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 Playground upgrades
 Improvements and upgrades to existing 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 Parks Master Plan:
 Parks Provision Standard: Provide 2.5 acres of developed/active parks for every 1,000 residents in San Carlos.
 Trails Provision Standard: Provide 1-mile of hiking trail per 1,000 residents.  Walkability Policy: Locate a park or recreational facility within ¼- to ½-mile of every resident.

In 2024, the City of San Carlos began the process to update the Parks Master Plan.

Trails Connections Plan
The San Carlos Trails Committee completed a Trails Connections Plan that was adopted by City Council in February 2007. The Trail Connections Plan identified and prioritized 14 possible connections to our local trail system as well as neighboring regional open space parks and trails, including Pulgas Ridge, and trails within the City of Belmont and the County of San Mateo.

San Carlos Hillside Trails Plan
Adopted in 2012, the San Carlos Hillside Trails Plan identifies 1.62 miles of new trails within Big Canyon Park, Eaton Park, and Devonshire Canyon. The Hillside Trails Plan also provides design guidelines and construction protocols, in addition to a parking program for the identified trails.

EXISTING CONDITIONS
A variety of different park lands and facilities are needed to serve the diverse needs of the community.

The City’s parks include mostly developed, or active, parkland and some undeveloped sites.

Parks and Open Space
San Carlos residents have access to a variety of open space and park areas in and around the city.

According to the Parks Master Plan, San Carlos contains 62.5 acres of traditional developed parkland.3 These parks and open space areas provide passive recreation facilities, including trails, views, natural vegetation and wildlife and environmental education facilities. The City’s Parks and Recreation Department manages 16 parks, including 3 community parks, 4 neighborhood parks, 5 mini parks, 2 open space parks, and 2 dog parks. Additionally, Eaton Park and Big Canyon Park offer 73 acres of natural open space in the City of San Carlos.
3 City of San Carlos, Parks, Open Space, Buildings, and other Recreational Facilities Master Plan 2009 – 2029, https://cms3.revize.com/revize/sancarlos/Departments/Parks%20and%20Recreation/CIP/San%20Carlos%20Park%20Master%2 0Plan%20Final%209-08[1].pdf, accessed on October 16, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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Other open space areas around the city are owned and operated by the Midpeninsula Regional Open Space District (MROSD), San Mateo County, and the State Department of Fish and Game. MROSD manages 26 open space preserves totaling over 57,000 acres. The three closest MROSD preserves are Pulgas Ridge, Purisima Creek Redwoods, and Teague Hill, with Pulgas Ridge Open Space Preserve located within San Carlos’ sphere of influence. San Mateo County manages five regional parks. The largest is the 467-acre Edgewood Preserve, located approximately 3 miles south of San Carlos. The State Department of Fish and Wildlife runs Bair Island, a 1,985-acre Ecological Preserve within the Don Edwards National Wildlife Refuge. The Don Edwards National Wildfire Refuge is provided by the United States Fish and Wildlife Service and is located adjacent to San Carlos in the wetlands of San Francisco Bay.

Recent park improvement projects include pickleball courts at Crestview Park, installation of new sports field lighting at Flanagan Field & Stadium Field, Chilton Park improvements, and an LED sports field lighting design at Burton & Highlands Parks.4 Design for new improvements are underway as part of the North Crestview Park Master Plan Project.5
As described in Chapter 3, Project Description, of this Draft EIR, the existing population of San Carlos is 28,890 people. San Carlos contains 62.5 acres of traditional developed parkland, which equates to 2.2 acres of parks per 1,000 residents.6 This is below the standard established in the City’s Parks Master Plan of 2.5 acres of traditional parkland for every 1,000 residents. Taking into account the city’s existing open space, San Carlos contains 135 acres of both traditional developed parkland and open space which equates to 4.7 acres per 1,000 residents.7
The City of San Calros is currently undergoing an update to the Parks Master Plan, which was last developed in 2009. This project also includes an update to the Parks and Recreation Element of the General Plan. The San Carlos Parks Master Plan will guide the City in enhancing the current park system to accommodate the needs of the existing and growing community and visitors for the next 20 years.8 Recreational Programs
A variety of programs for youth and adults are organized through the Parks and Recreation Department.

The Department also runs the San Carlos Youth Center at 1001 Chestnut Street, at the edge of Burton Park, which is open to pre-teens and young teens on weekdays from 9:00 a.m. to 7:00 p.m. and on Saturdays from noon to 5:00 p.m. and the Adult Community Center at 601 Chestnut Street.

4.12.2 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant parks and recreation impact if it would:
4 City of San Carlos Parks and Recreation, communication with PlaceWorks in October 2024. 5 City of San Carlos Parks and Recreation, communication with PlaceWorks in October 2024. 6 28,890 people/1,000 = 28.89; 62.5 acres/28.89 = 2.2 acres per 1,000 people 7 28,890 people/1,000 = 28.89; 135 acres/28.89 = 4.7 acres per 1,000 people 8 City of San Carlos, Parks and Recreation Capital Improvement Projects, https://www.cityofsancarlos.org/city_hall/departments_and_divisions/parks_and_recreation/parks_and_facilities/parks_and_r ecreation_capital_improvement_projects.php, accessed on December 4, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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REC-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered parks or recreation facilities, need for new or physically altered parks or recreation facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for parks or recreation facilities.

REC-2 Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

REC-3 Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

REC-4 In combination with past, present, and reasonably foreseeable projects, result in cumulative recreation impacts in the area.

4.12.3 IMPACT DISCUSSION
REC-1 The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered parks or recreation facilities, need for new or physically altered parks or recreation facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios or other performance objectives for parks or recreation facilities.

As discussed in Section 4.12.1.2, Existing Conditions, the EIR Study Area currently provides 2.2 acres of parks per 1,000 residents. Buildout projections for the proposed project include an increase in residential development, which would increase the demand for parks and recreational facilities. If no further parkland is added by 2045, and the existing 62.5 acres of parkland serve the projected total 2045 population of 46,450 people, then the ratio of parkland per 1,000 population would decrease to 1.34 acres of parks per 1,000 residents. However, this is a very conservative assumption (i.e., it represents a “worst case” scenario), as it is expected that parks will be acquired, expanded, and/or made publicly accessible as part of private development over the horizon of the proposed project.

SCMC Section 17.32.030 would continue to require residential subdivisions to either provide parkland or pay in-lieu fees to the City to dedicate parkland elsewhere. Additionally, SCMC Chapter 3.34 requires new residential projects to pay park facility development fees. This would result in an incremental addition of parkland if a residential subdivision or residential development is proposed in the city.

Additionally, the Land Use (LU) Element and Parks and Recreation (PR) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to parks and recreation, including available parkland and the quality of facilities. The following General Plan goals, policies, and actions would serve to reduce impacts to performance objectives for parks and recreation facilities:
 Goal LU-2: Preserve and strengthen Downtown as the civic, cultural and social heart of the city. 2045 GENERAL PLAN RESET DRAFT EIR

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 Policy LU-2.15: Provide for and encourage the development of parks and public gathering places in and near Downtown.
 Goal LU-7: Promote the community character of San Carlos, including the unique village character of Downtown.
 Action LU-7.3: Revise the Zoning Ordinance to establish a zoning district for existing parks and open space lands and amend the zoning map accordingly.
 Goal LU-9: Protect and enhance all residential neighborhoods.  Policy LU-9.6: Encourage the location of support facilities such as schools, parks and churches within or near residential neighborhoods.
 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.  Goal PR-1: Increase the amount of City-owned park and open space land.  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.
 Action PR-1.1: Explore opportunity sites for the development of new parks facilities, focusing on providing recreation opportunities to underserved areas based on the City‘s Master Plan for Parks, Open Space, Buildings and other Recreational Facilities.  Action PR-1.2: Work to fund land acquisition for parks and open space including all available mechanisms both public and private.
 Action PR-1.3: Continue to monitor possibilities for acquisition of land to expand the Adult Community Center and/or City Hall Park.
 Action PR-1.4: Strive to provide a minimum of 2.5 acres of traditional parkland for every 1,000 residents.
 Action PR-1.5: Strive to provide a park facility within ½-mile of every resident.  Action PR-1.6: Provide the opportunity for the Parks and Recreation Department during the development review process to assess on-site open space and recreational amenities.  Action PR-1.7: Investigate acquisition of open space lands or easements to expand trail network, especially in areas adjacent to existing open space.
 Action PR-1.9: Update the City’s park development impact fee to address residential renovations, remodels and additions that potentially increase the number of residents living in a dwelling unit.
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 Action PR-1.10: Identify parcels that may be suitable for acquisition; for example, parcels in underserved areas of the city and parcels adjacent to parks and public facilities.  Action PR-1.11: Consider adoption of an ordinance requiring the maximum allowable park land dedication fee.
 Action PR-1.12: All City-owned Park Facilities and Open Space Park Facilities, as defined by the Municipal Code, should be rezoned to allow such uses. The City Council may change the zoning to allow other uses if it finds that it is a change in use that will meet the goals of the Parks and Recreation Element of the General Plan.
 Goal PR-2: Provide cultural, historical, environmental education and recreational facilities that support a diversity of needs and interests.
 Policy PR-2.1: Consider the recreational needs and interests of all segments of the San Carlos community when evaluating decisions relating to parks facilities.  Policy PR-2.2: Consider establishing a new facility for the visual and performing arts.  Policy PR-2.3: Continue to support implementation of trail connections as identified in the City’s Potential Trail Connections Plan.
 Policy PR-2.4: Continue to maintain City-owned open space trails and connections to regional trails.
 Policy PR-2.6: Complete the Bay Trail alignment in San Carlos.  Policy PR-2.10: Improve the availability and quality of athletic fields in San Carlos  Action PR-2.1: Study the feasibility of acquiring additional parkland to construct a new community center and outdoor aquatics facility.
 Action PR-2.4: Continue and enhance alternative funding strategies for providing additional facilities, including naming rights and sponsorships, grants and endowments.  Action PR-2.6: Prepare an Open Space Management and Trails Master Plan to further identify trail connectivity and future trail development for public benefit.  Action PR-2.7: Maintain a current map of trails that is available to the public and update as necessary to define trails as multi-use or single-use.
 Action PR-2.8: Extend and improve trails in Big Canyon, Eaton Park and Arguello Park.  Action PR-2.9: Consider providing space, whether in new or existing parks, for off-leash dog areas, a skate park, bocce courts, Frisbee golf, BMX bicycling and other alternative sports.  Goal PR-3: Provide recreational programs to meet the needs of all residents.  Policy PR-3.1: Ensure that recreational programs are available for all ages and abilities.  Policy PR-3.2: Support recreational programs that encourage the interaction of different segments of the San Carlos population.
 Policy PR-3.3: Expand the availability of aquatics facilities and programming. 2045 GENERAL PLAN RESET DRAFT EIR

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 Policy PR-3.4: Promote visual and performing arts programs.  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.  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.  Policy PR-3.7: Protect the Youth Center as a valuable venue giving priority to youth activities and programs as subject to the terms in the Youth Center Use Policy adopted by City Council.  Action PR-3.1: Seek to establish a joint use agreement with the Sequoia Union High School District to increase access to pools, gymnasiums, theaters, athletic fields and other facilities.  Action PR-3.2: Seek to improve existing fields through the City/San Carlos Elementary School District joint use agreement.

As indicated above, new residents from future development within the buildout horizon of the proposed project would increase the demand for park facilities, and park standards could require the construction of new or expanded neighborhood or community parks in order to meet the City’s parkland standard of

2.5 acres per 1,000 residents. As required by the SCMC, new residential development would be required to pay park impact fees at the time of future project approval to generate revenue to fund the park facilities needed to serve new development. Furthermore, as shown in the General Plan goals, policies, and actions listed above, the City would update existing parks and acquire new parks in San Carlos over the 2045 horizon of the proposed project. Implementation of and adherence to the General Plan goals, policies, and actions listed above, and ongoing collection of impact fees, would help to meet acceptable service levels.

As described above, the city is currently not meeting its established service level standard of 2.5 acres of parkland per 1,000 residents, and with the projected population increase the City of San Carlos would need to continue to expand neighborhood or community parks. Potential impacts would occur if the physical expansion or construction of a park would cause significant environmental impacts. The proposed project is a policy-level document and does not propose specific development projects. The estimated timing or location of such facilities or the exact nature of these facilities are not known at this time, so project-specific environmental impacts that could occur from their construction and operation cannot be determined at this time. Depending on the type, size, and location of new parks, the construction of new parks would be subject to environmental review and the mitigating polices and mitigation measures described in this EIR to ensure the impacts from the construction would be less than significant. The construction of project-specific parks would require permitting and review in accordance with City standards, which would ensure that any environmental impacts are disclosed and mitigated to the extent possible. Therefore, the impact is considered less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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REC-2 The proposed project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

Future development in San Carlos would result in increased population, which would increase demands for parks and recreational facilities in the EIR Study Area and regional parks in the larger San Mateo County area. The increased number of residents and workers anticipated by 2045 could increase park use and cause physical deterioration of park facilities.

Population increases in San Carlos would occur incrementally over time. As described in Section 4.12.1.1, Regulatory Framework, the SCMC establishes parkland dedication and/or fee requirements for new residential development, helping to ensure that new park and recreation facilities are provided as growth occurs and that individual park and recreation facilities are not overburdened by use.

As described in impact discussion REC-1, the Land Use (LU) Element and Parks and Recreation (PR) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to parks and recreation, including the quality of existing parks and facilities. The General Plan goals, policies, and actions listed in impact discussion REC1 would serve to minimize potential adverse impacts related to increased park use and deterioration of park facilities.

While future development within the buildout horizon of the proposed project would result in an increased population with an increased demand for parks and recreational facilities, buildout would occur incrementally throughout the 20-year horizon, and future development would be subject to the SCMC regulations and the General Plan goals, policies, and actions listed in impact discussion REC-1.

Therefore, impacts would be less than significant.

Significance without Mitigation: Less than significant.

REC-3 The proposed project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

A significant impact would result if the proposed project would cause the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

As described in impact discussion REC-1, the Land Use (LU) Element and Parks and Recreation (PR) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to parks and recreation, including the need for expanded or new recreational facilities. The General Plan goals, policies, and actions listed in impact discussion REC-1 would serve to minimize potential adverse impacts related to the need for expanded or new recreational facilities.
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Future development within the buildout horizon of the proposed project would result in an increased population with an increased demand for parks and recreational facilities, buildout would occur incrementally throughout the 20-year horizon. Furthermore, future residential development would be subject to SCMC Chapter 3.34 requiring new residential projects to pay park facility development fees and the General Plan goals, policies, and actions to plan for and provide recreational facilities for existing and future users.

The proposed 2045 General Plan Reset is a policy-level document and does not propose specific development projects. The estimated timing or location of such facilities or the exact nature of these facilities are not known, so project-specific environmental impacts that would occur from their construction and operation cannot be determined at this time. The construction of project-specific recreational facilities would require permitting and review in accordance with City standards, which would ensure that any environmental impacts are disclosed and mitigated to the extent possible.

Therefore, the impact is considered less than significant.

Significance without Mitigation: Less than significant.

REC-4 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative parks and recreation impacts in the area.

As discussed in Chapter 4, Environmental Analysis, of this Draft EIR, the cumulative analysis takes into account growth from development under the proposed project within the City combined with the estimated growth in the service areas of each service provider in the region. Parks and recreation services in the EIR Study Area are provided by the City, and regional parks are provided by the County of San Mateo’s Parks and Recreation, California Department of Parks and Recreation, California Department of Fish and Wildlife, and the United States Fish and Wildlife Service.

Future growth in the region would result in increased demand for parks and recreational facilities throughout the EIR Study Area and region. As a result, the local service providers would need to expand and construct additional parks and other recreational facilities to meet the increased demand and maintain existing service levels. State law allows jurisdictions to require additional development to fund park improvements, and the SCMC requires new residential development to pay development impact fees to help fund parks and recreation. Implementation of the General Plan goals, policies, and actions listed under impact discussion REC-1 would also help provide new parklands along with new development. The final location and size of additional facilities would be determined as part of future development activity, and as specific parkland expansion or improvement projects are identified.

Additional project-specific environmental analysis would be completed at that future time. As a result, the proposed project would not result in a cumulatively considerable impact to parks and recreational facilities and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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4.13 POPULATION AND HOUSING
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to population and housing, and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

4.13.1 ENVIRONMENTAL SETTING

REGULATORY FRAMEWORK
State Regulations
California Housing Element Law
California Housing Element Law1 includes provisions related to the requirements for housing elements of local government General Plans. Among these requirements, some of the necessary parts include an assessment of housing needs and an inventory of resources and constraints relevant to the meeting of these needs. Additionally, in order to assure that counties and cities recognize their responsibilities in contributing to the attainment of the State housing goals, this section of the Government Code calls for local jurisdictions to plan for and allow the construction of a share of the region’s projected housing needs, known as the Regional Housing Needs Allocation (RHNA). The City of San Carlos needs to accommodate 2,735 residences in total. The City’s 2023-2031 Housing Element was adopted on January 22, 2023.

Housing Opportunity and More Efficiency Act
The Housing Opportunity and More Efficiency (HOME) Act (Senate Bill [SB] 9) was signed in September 2021 and went into effect in January 2022. The HOME Act streamlines the process for a homeowner to create a duplex or subdivide an existing lot, with the effect of legalizing fourplexes in areas that previously only allowed one home.2 To be eligible for the streamlining process under the HOME Act, a parcel must meet a specific list of qualifications that protects historic districts, preserves the environmental quality and visual characteristics of communities, and prevents tenants from being displaced. Homeowners would still be required to comply with local zoning requirements, such as, but not limited to, height, floor area ratios, and lot coverage, when developing a duplex as long as they do not physically preclude a duplex.
1 Government Code Section 65580 through 65589.8.
2 California Senate, SB 9 (Atkins): The California H.O.M.E. Act, https://focus.senate.ca.gov/sb9, accessed May 25, 2023. 2045 GENERAL PLAN RESET DRAFT EIR

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The Housing Crisis Act
SB 330, or the Housing Crisis Act of 2019, aims to address California’s housing shortage by expediting the approval process for housing development of all types, particularly in regions suffering the worst housing shortages and highest rates of displacements. To address the crisis, this bill prohibits some local discretionary land use controls currently in place and generally requires cities to approve all housing developments that comply with current zoning codes and general plans. SB 330 requires that a housing development project only be subject to the ordinances, policies, and standards adopted and in effect when a preliminary application is submitted, notwithstanding the provisions of the HAA or any other law, subject to certain exceptions.

State Density Bonus Law
The State Density Bonus Law (California Government Code Sections 65915-65918) encourages the development of affordable and senior housing, including up to a 50-percent increase in project densities for most projects, depending on the amount of affordable housing provided. Cities and counties are required to grant a density bonus and other incentives or concessions to housing projects which contain one of the following:
 At least 5 percent of the housing units are restricted to very low income residents.  At least 10 percent of the housing units are restricted to lower income residents.  At least 10 percent of the housing units in a for-sale common interest development are restricted to moderate income residents.
 100 percent of the housing units (other than manager’s units) are restricted to very low, lower and moderate income residents (with a maximum of 20 percent moderate).  At least 10 percent of the housing units are for transitional foster youth, disabled veterans or homeless persons, with rents restricted at the very low income level.  At least 20 percent of the housing units are for low income college students in housing dedicated for full-time students at accredited colleges.
 The project donates at least one acre of land to the city or county for very low income units, and the land has the appropriate general plan designation, zoning, permits and approvals, and access to public facilities needed for such housing.
 The project is a senior citizen housing development (no affordable units required).  The project is a mobile home park age-restricted to senior citizens (no affordable units required).

Assembly Bill 1397
California’s AB 1397 amended Sections 65580, 65583, and 65583.2 of the Government Code, relating to housing by revising what could be included in a local government’s inventory of land suitable for residential development. AB 1397 changed the definition of land suitable for residential development to increase the number of multifamily sites. Identified sites must be “available” and “suitable” for residential development and have a “realistic and demonstrated potential” for redevelopment during the planning period. In addition, AB 1397 requires housing element inventory sites to be 0.5 acre to 10 acres, have sufficient infrastructure, or be included in a program to provide such infrastructure, to support and be accessible for housing development. The local government must specify the realistic unit count for each site and whether it can accommodate housing at various income levels. 2045 GENERAL PLAN RESET DRAFT EIR

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Senate Bill 166
SB 166 (2017) requires a local government to ensure that its housing element inventory can accommodate its share of the regional housing need throughout the planning period. It prohibits them from reducing, requiring, or permitting the reduction of the residential density to a lower residential density than what was used by the California Department of Housing and Community Development for certification of the housing element, unless the city or county makes written findings supported by substantial evidence that the reduction is consistent with the adopted general plan, including the housing element. In such cases, any remaining sites identified in the housing element update must be adequate to accommodate the jurisdiction’s share of the regional housing need. A local government may reduce the residential density for a parcel only if it identifies sufficient sites remaining within the housing element as replacement sites, so that there is no net loss of residential unit capacity.

Regional Regulations
Plan Bay Area is the regional transportation plan/sustainable community strategy, as mandated by the Sustainable Communities and Climate Protection Act (SB 375). Plan Bay Area lays out a development scenario for the nine-county Bay Area region that works to align transportation and land use planning in order to reduce vehicle miles traveled through modified land use patterns. The current Plan Bay Area projects growth and development patterns through 2050 and was adopted in October 2021.3 Plan Bay Area is prepared and regularly updated by the Metropolitan Transportation Commission (MTC) in partnership with the Association of Bay Area Governments (ABAG), Bay Area Air Quality District (BAAQMD), and the Bay Conservation and Development Commission (BCDC). Each of the agencies has a different role in regional governance. ABAG primarily does regional land use planning, housing, environmental quality, and economic development; MTC is tasked with regional transportation planning, coordinating, and financing; BAAQMD is responsible for regional air pollution regulation; and BCDC’s focus is to preserve, enhance, and ensure responsible use of the San Francisco Bay.

As described in Chapter 4, Environmental Analysis, of this Draft EIR, Plan Bay Area designates Priority Development Areas (PDAs) and Transit Priority Areas (TPAs) throughout the region. PDAs are areas along transportation corridors which are served by public transit that allow opportunities for development of transit-oriented, infill development within existing communities that are expected to host the majority of future development. TPAs are similar in that they are formed within one-half mile around a major transit stop such as a transit center or rail line. As shown on Figure 4-1, Priority Development Areas and Transit Priority Areas, in Chapter 4, the EIR Study Area has one PDA and one TPA. The PDA is called Railroad Corridor and includes El Camino Real and the downtown area. The TPA surrounds El Camino Real and the Caltrain station in San Carlos.

Plan Bay Area 2050 distributes future growth across the San Francisco Bay Area region in order to meet its GHG emissions reduction, housing, and other performance targets, but it is not intended to override 3 Metropolitan Transportation Commission and Association of Bay Area Governments, October 2021, Plan Bay Area 2050, https://www.planbayarea.org/sites/default/files/documents/Plan_Bay_Area_2050_October_2021.pdf, accessed August 9, 2022.
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local land use control. Cities and counties, not MTC/ABAG, are ultimately responsible for the manner in which their local communities continue to be built out in the future. For this reason, cities and counties are not required to revise their land use policies and regulations, including general plans, to be consistent with the regional transportation plan or an alternative planning strategy. Rather than increase regional land use control, Plan Bay Area 2050 facilitates implementation by expanding incentives and opportunities available to local jurisdictions to support growth in PDAs. In addition to funding transportation and planning projects in PDAs, Plan Bay Area 2050 sets the stage for cities and counties to increase the efficiency of the development process, if they choose, for projects consistent with Plan Bay Area and other state legislation.4
Local Regulations
San Carlos General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.13.3, Impact Discussion.

San Carlos Municipal Code
The San Carlos Municipal Code (SCMC) is the primary document that regulates the policies and practices of the City. The SCMC contains the Zoning Code, the Subdivision Ordinance, the Building and Construction Code, and other titles that are important in implementing the goals, policies, and actions of the General Plan. The SCMC includes various directives pertaining to population and housing as follows:
 Title 18, Zoning Code, divides the city into distinct zones in order to implement the land use and development policies in the General Plan. Among the primary objectives of the Zoning Code are the regulation of building form, placement, density, and the provision of sufficient parking and open spaces in conjunction with development.
 Chapter 18.04, Residential Districts, serves to preserve, protect, and enhance the character of the City’s different residential neighborhoods. It also promotes residential development that is compatible with environmental constraints and neighborhood characteristics.  Chapter 18.05, Mixed-Use Districts, serves to provide for the orderly, well planned, and balanced development of mixed-use districts.
 Chapter 18.17, Affordable Housing programs, the purpose of this chapter is to Encourage the development and availability of housing affordable to a broad range of households with varying income levels within the City as mandated by State law, California Government Code Section 65580 et seq. This chapter establishes below market rate housing requirements and provides exemptions.
4Association of Bay Area Governments and Metropolitan Transportation Commission, 2022, Frequently Asked Questions:

Does Plan Bay Area override local land use control?, https://www.planbayarea.org/2040-plan/quick-facts/faq-page#n4851, accessed August 31, 2022.
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EXISTING CONDITIONS
This section describes the existing population and housing conditions in the City of San Carlos, as well as San Mateo County as a whole, to provide context for the analysis of the proposed project in this EIR. This section uses 2024 data because 2024 is the baseline year for purposes of most analyses in this EIR, as explained in Chapter 4.0, Environmental Analysis, of this Draft EIR.

Population
The EIR Study Area’s population grew from 29,648 in 2014 to 30,830 in 2024. As shown in Table 4.13-1, Total Population, 2014 to 2024, the population growth in San Carlos is greater than the population growth of San Mateo County during the 10-year period, during which the population of the county decreased.

TABLE 4.13-1 TOTAL POPULATION, 2014 TO 2024
2014 2020 2024
2014-2024
Change
2014-2024
Percent Change
San Carlos EIR Study Area 29,648 a 30,738 a 30,830 1,182 4% San Mateo County 751,906 764,442 741,565 (10,341) (1%)
Note:
a. 2014 and 2020 numbers do not include San Carlos’s sphere of influence population.

Source: State of California, Department of Finance, 2024 (accessed), E-5 Population and Housing Estimates for Cities, Counties and the State, 2020- 2024, https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-counties-and-the-state-2020-2024/, accessed September 26, 2024; State of California, Department of Finance, November 2023, E-8 Population and Housing Estimates for Cities, Counties, and the State, April 1, 2010-April 1, 2020, with January Estimates, https://dof.ca.gov/forecasting/demographics/estimates/estimates-e8-2010-2020/, accessed September 26, 2024.

Housing
Between 2014 and 2024, San Carlos experienced steady housing growth. As shown in Table 4.13-2, Housing Units, 2014 to 2024, the city’s number of housing units grew by approximately 10 percent; this growth was higher than the level of housing growth in San Mateo County as a whole, which was 6 percent during the same period. As of 2024, the average household size in the City of San Carlos is 2.47 persons per household while San Mateo County’s average person per household is 2.66 persons per household.5
5 State of California, Department of Finance, 2024 (accessed), E-5 Population and Housing Estimates for Cities, Counties and the State, 2020-2024, https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-forcities-counties-and-the-state-2020-2024/, accessed September 26, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.13-2 HOUSING UNITS, 2014 TO 2024
2014 2020 2024
2014-2024
Change
2014-2024
Percent Change
San Carlos EIR Study Area 11,980 a 12,244 a 13,250 1,270 10% San Mateo County 273,287 283,693 289,782 16,495 6%
Note:
a. 2014 and 2020 numbers do not include San Carlos’s sphere of influence housing unit count.

Regional Growth Projections
Plan Bay Area 2050 includes growth projections to 2050 for counties within the region. As shown in Table 4.13-3, San Mateo County Regional Growth Projections, 2015 to 2050, projections anticipate the number of households in San Mateo County to increase by 48 percent, with jobs projected to increase by 29 percent.

TABLE 4.13-3 SAN MATEO COUNTY REGIONAL GROWTH PROJECTIONS, 2015 TO 2050 2015 2050 Change Percent Change
Households 265,000 394,000 129,000 48%
Jobs 393,000 507,000 114,000 29%
Source: Plan Bay Area 2050, 2021 January, Projected Household and job Growth, by County, https://planbayarea.org/sites/default/files/FinalBlueprintRelease_December2020_GrowthPattern_Jan2021Update.pdf, accessed on October 17, 2024.

Regional Housing Needs Allocation
As the San Francisco Bay Area’s regional agency, MTC/ABAG calculates the RHNA for jurisdictions in San Mateo County, including San Carlos. Table 4.13-4, San Carlos Regional Housing Needs Allocation, shows the RHNA for the current planning period, which is the number of housing units the City of San Carlos would need to accommodate by 2031.

As shown in Table 4.13-4, the housing unit allocations are categorized by household size and income. The household income categories are as follows:
 Very Low Income: Households making less than 50 percent of the area median income.  Low Income: Households making between 50 and 80 percent of the area median income.  Moderate Income: Households making between 80 and 120 percent of the area median income.  Above Moderate Income: Households making more than 120 percent the area median income.

Household median income is calculated based on household size. The median household income for San Carlos for a family of four is $186,600, based on federal income limits for San Mateo County. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.13-4 SAN CARLOS REGIONAL HOUSING NEEDS ALLOCATION Dwelling Units by Income Category
RHNA Planning
Period Very Low Income Low Income
Moderate
Income
Above Moderate
Income Total
2023 to 2031 739 425 438 1,133 2,735
Source: City of San Carlos, January 2023, San Carlos 2023-2031 Housing Element, https://cms3.revize.com/revize/sancarlos/Document%20Center/Housing%20Element/03-Needs%20Assessment_Final.pdf, accessed September 26, 2024.

4.13.2 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant population and housing impact if it would:

POP-1 Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).

POP-2 Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

POP-3 In combination with past, present, and reasonably foreseeable projects, result in cumulative population and housing impacts in the area.

4.13.3 IMPACT DISCUSSION
POP-1 The proposed project would not induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).

As described in Chapter 3, Project Description, of this Draft EIR, the proposed 2045 General Plan Reset is a high-level policy document that will replace the existing General Plan 2030 as the City’s overarching policy document that defines a vision for future change and sets the “ground rules” for planned growth.

The proposed project considers growth over an approximately 20-year period but does not include specific development proposals. The proposed 2045 General Plan Reset is the policy document that projects the amount of reasonably foreseeable growth given past growth trends and the ability of existing services and infrastructure to support future growth.

The buildout projections evaluated in this EIR include housing development associated with current development projects, development of the sites in the City’s 2023-2031 Housing Element Sites Inventory, development of accessory dwelling units and units under SB 9 as allowed under State housing law, and estimated future housing development under future RHNA cycles. Future housing development in the 2045 GENERAL PLAN RESET DRAFT EIR

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EIR Study Area is projected to occur primarily on infill parcels near Downtown, along the El Camino Real corridor, along Old County Road between Holly Street and Terminal Avenue, and along East San Carlos Avenue. Most of the commercial growth is expected to occur in the Downtown area. Most of the office growth is expected in the Downtown and Northeast areas. Research and development and industrial growth would be limited to the east side area of San Carlos. In addition, these areas contain one PDA, which is expected by ABAG to be where future growth will be concentrated. Given that future development would be concentrated in areas currently served by public services and infrastructure, implementation of the proposed project would require less extension and improvement of infrastructure than if development were to occur on “greenfield” sites. Therefore, the proposed project would not induce substantial, unplanned population growth directly or indirectly in any particular location but instead includes policy guidance for expected incremental planned growth through 2045.

The EIR Study Area has a population of approximately 30,830, with 13,250 housing units as of 2024. As shown in Table 3-1, Proposed 2045 General Plan Reset Buildout Projections In The EIR Study Area, in Chapter 3, Project Description, of this Draft EIR, the proposed 2045 General Plan Reset plans for an overall increase of 8,300 housing units and 15,620 residents in the EIR Study Area by 2045. This equates to a 63-percent increase in housing units and a 50-percent increase in total population over the 20-year horizon of the proposed 2045 General Plan Reset. However, approximately 32 percent of this residential development projection is from the City’s current 2023-2031 RHNA allocation of 2,735 units, which is housing capacity required by the California Housing Law and not by the City. Over the buildout horizon of the proposed project, it is assumed that the City’s RHNA during future RHNA cycles would be similar to recent RHNA amounts, and this is accounted for in the 2045 General Plan Reset buildout projections.

As shown in Table 4.13-3, Plan Bay Area 2050 anticipates a 48-percent increase in households and a 29- percent increase in jobs in San Mateo County in 2050. As described in Chapter 3, Project Description, of this Draft EIR, development potential under the proposed 2045 General Plan would result in a 50- percent increase in total population, 63-percent increase in housing units, and 128-percent increase in jobs. As described in Section 4.13.1.2, Existing Conditions, recent development trends have shown that development in San Carlos has outpaced that of San Mateo County as a whole. Additionally, the net increase in households for San Carlos is only 6 percent of the regional household growth accounted for in San Mateo County6 and the net increase in jobs in San Carlos is 23 percent of the job growth accounted for the county.7 Therefore, projected housing and job development would not exceed the projections of Plan Bay Area 2050 and the proposed project would not be expected to induce unplanned population growth as a result of housing or job growth.

The Land Use (LU) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to population and housing, including population growth. In addition to the goals, policies, and actions of the adopted 2023-2031 Housing Element, the following General Plan goals, policies, and actions would serve to support population growth:
 Goal LU-1: Ensure a sustainable land use pattern.
6 8,300 net new housing units in San Carlos/129,000 net new households in San Mateo County = 6 percent. 7 26,530 net new jobs in San Carlos/114,000 net new jobs in San Mateo County = 23 percent. 2045 GENERAL PLAN RESET DRAFT EIR

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 Policy LU-1.2: Encourage development of higher density housing and support additional job growth within the TOD corridor while being sensitive to surrounding uses.  Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well being of the City.
 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.  Action LU-5.3: Review impact fees for new development to ensure that fees are appropriate to contribute to the cost of providing public facilities and services.  Action LU-5.4: Ensure that new development is not a financial burden on municipal service levels by evaluating the fiscal impact of all new projects and establishing preferences for projects that generate sufficient revenue to offset increased operation and maintenance costs, consistent with other local, state and federal regulations.

Implementation of the proposed 2045 General Plan Reset itself would not introduce a substantial amount of unplanned population in the EIR Study Area and is instead the overriding policy document that plans for such growth. As determined in Chapter 4.17, Utilities and Service Systems, of this Draft EIR, there are no existing infrastructure deficiencies identified in the EIR Study Area, and no future deficiencies are likely to occur as a result of the proposed project. Further, Chapter 4.12, Parks and Recreation, and Chapter 4.14, Public Services, of this Draft EIR determine that population growth under the proposed project would not result in a parks, recreation, or public service deficiency. Therefore, implementation of the proposed project would not induce substantial unplanned population growth and would not necessitate the construction of additional infrastructure, and the impact is less than significant.

Significance without Mitigation: Less than significant.

POP-2 The proposed project would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

Displacement is typically considered substantial in cases where major development such as a freeway or a large-scale redevelopment would result in the displacement of large amounts of existing housing, such that the construction of replacement housing is necessary.

Future development within the buildout horizon of the proposed project is expected to result in an increase of approximately 8,300 housing units in the EIR Study Area over an approximately 20-year horizon. As identified under impact discussion POP-1, approximately 32 percent of the projected 8,300 housing units anticipated by 2045 are from the City’s current 2023-2031 RHNA allocation of 2,735 units, which is housing capacity required by the California Housing Law and not by the City. Future housing development in the EIR Study Area is projected to occur primarily on infill parcels near Downtown, along the El Camino Real corridor, along Old County Road between Holly Street and Terminal Avenue, and along East San Carlos Avenue. Most of the commercial growth is expected to occur in the Downtown 2045 GENERAL PLAN RESET DRAFT EIR

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area. Most of the office growth is expected in the Downtown and Northeast areas. Research and development and industrial growth would be limited to the east side area of San Carlos. Due to the builtout nature of the EIR Study Area, future development would occur largely through redevelopment activities; therefore, it is possible that future development could displace an unknown number of existing residents or housing.

The Land Use (LU) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to population and housing, including displacement. In addition to the goals, policies, and actions of the adopted 2023-2031 Housing Element, the following General Plan goal, policy, and action would serve to minimize impacts related to population and housing displacement:
 Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well being of the City.
 Policy LU-5.6: Strive for a balanced ratio of jobs and housing units.  Action LU-5.5: Routinely review the jobs to housing balance and make recommendations to correct imbalances.

Future development is anticipated to result in a net increase in density and utilization of infill or underutilized sites in existing urban areas. Therefore, displacement of people or housing would be temporary as redevelopment occurs. While the proposed 2045 General Plan Reset does focus on infill development which may occur as redevelopment, the proposed 2045 General Plan Reset does not call for any large-scale development that would be considered to result in substantial displacement of existing housing. The scale of temporary removal of housing would be typical for urban development projects. Further, redevelopment in the EIR Study Area would occur largely on sites that are underutilized and/or with older structures that are past their past their useful life, and small levels of displacement that may occur would be addressed through compliance with the General Plan goal, policy, and action listed above. Therefore, any potential displacement of persons in the EIR Study Area would not be substantial, and the impact would be less than significant.

Significance without Mitigation: Less than significant.

POP-3 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative population and housing impacts in the area.

The context for the cumulative population and housing impacts would be future development under the proposed project combined with development on lands adjacent to the EIR Study Area. As described in impact discussions POP-1 and POP-2, implementation of the proposed project would not induce a substantial amount of unplanned population growth or growth for which inadequate planning has occurred, or displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. The proposed 2045 General Plan Reset would provide adequate planning to accommodate the proposed new increase in growth in the EIR Study Area. Therefore, the 2045 GENERAL PLAN RESET DRAFT EIR

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proposed project would not result in a cumulatively considerable impact to population and housing, and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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4.14 PUBLIC SERVICES
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to public services, and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

This chapter covers the following public services:
 Fire protection
 Police
 Schools
 Libraries

4.14.1 FIRE PROTECTION SERVICES

ENVIRONMENTAL SETTING
Regulatory Framework
State Regulations
California Government Code
Section 65302 of the California Government Code requires General Plans to include a Safety Element, which must include an assessment of wildland and urban fire hazards. The Environmental Safety and Public Services (ESPS) Element of the existing General Plan 2030 satisfies this requirement.

California Department of Forestry and Fire Protection
The California Department of Forestry and Fire Protection (CAL FIRE) is dedicated to the fire protection and stewardship of over 31 million acres of California’s wildlands. The Office of the State Fire Marshal supports CAL FIRE’s mission to protect life and property through fire prevention engineering programs, law and code enforcement, and education.

California Building Code
The State of California provides a minimum standard for all building design except detached one- and two-family residential dwellings and townhouses not more than three stories above grade plane, through Title 24, Part 2, of the California Code of Regulations (CCR), commonly referred to as the “California Building Code” (CBC). The CBC incorporates, by adoption, the International Building Code of the International Code Council, with California amendments, and is updated every three years, with supplements published in intervening years. It is adopted by the State, and can be modified on a jurisdiction-by-jurisdiction basis, based on local geologic, climatic, and topographic conditions. Typical 2045 GENERAL PLAN RESET DRAFT EIR

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fire safety requirements of the CBC include the installation of sprinklers in most new buildings, including all high-rise buildings, all residential buildings and other facilities; fire resistant rated construction and construction in designated wildland fire hazard severity zones; fire alarm systems and exiting requirements; and fire safety requirements during construction. The CBC also establishes structural stability, and seismic safety for buildings and structures.

California Residential Code
The State of California provides a minimum standard for all building design of detached one- and twofamily residential dwellings and townhouses not more than three stories above grade plane, through Title 24, Part 2.5, of the CCR, commonly referred to as the “California Residential Code.” The California Residential Code incorporates, by adoption, the International Residential Code of the International Code Council, with California amendments, and is updated every three years. Like the CBC, it is modified by the City, as needed, to address local conditions.

California Fire Code
The California Fire Code (CFC) incorporates, by adoption, the International Fire Code of the International Code Council, with California amendments. The CFC is the official fire code for the State of California (State) and all political subdivisions. It is found in CCR Title 24, Part 9, and, like the CBC, it is revised and published every three years by the California Building Standards Commission. Also like the CBC, the CFC is effective statewide, but a local jurisdiction may adopt more restrictive standards based on local conditions.

The CFC is a model code that regulates minimum fire safety regulations for new and existing buildings, facilities, storage, and processes, including emergency planning and preparedness, fire service features, fire protection systems, hazardous materials, fire flow requirements, and fire hydrant locations and distribution. Typical fire safety requirements include the installation of sprinklers in most new buildings, including all high-rise buildings, all residential buildings, and other facilities; fire resistant rated construction; construction in designated wildland fire hazard severity zones; fire alarm systems and exiting requirements; fire safety requirements during construction; the regulation of hazardous materials not covered by the unified program (described below); and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas.

Mitigation Fee Act (California Government Code 66000-66008) Assembly Bill (AB) 1600, the Mitigation Fee Act, requires a local agency establishing, increasing, or imposing an impact fee as a condition of development to identify the purpose of the fee and the use to which the fee is to be put. The agency must also demonstrate a reasonable relationship between the fee and the purpose for which it is charged, and between the fee and the type of development project on which it is to be levied. This act became enforceable on January 1, 1989. 2045 GENERAL PLAN RESET DRAFT EIR

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Local Regulations
San Carlos General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.14.1.3, Impact Discussion.

Fire Inspection Fees
Fire Inspection Fees are generated by the Redwood City/San Carlos Fire Department on an annual basis and are $292 for Fiscal Year 2024-25.1 The primary goal for the Annual Fire and Life Safety Inspection Program is to reduce the number of deaths, injuries and property losses from fire.

Existing Conditions
The City of San Carlos is served by the Redwood City-San Carlos Fire Department (RC-SCFD). The RCSCFD, a joint powers and governmental agency, provides fire and emergency response services to the cities of Redwood City and San Carlos. The RC-SCFD is responsible for fire response, vehicle accidents, public assistance, medical emergencies, water rescue, and hazardous material response. In addition, the RC-SCFD is also responsible for disaster preparedness and other services, such as building plan review, fire prevention, and fire hydrant testing.

Out of the seven stations with the RC-SCFD, two are with San Carlos: Station 13 and Station 16. Station 13 is staffed with a captain, a firefighter, and a firefighter/paramedic and houses Engine 13, Reserve Engine 113, and Reserve Battalion 103. Station 16 was recently replaced with a new station.2

1 City of San Carlos, 2024 (accessed), Fire Fees,
https://cms3.revize.com/revize/sancarlos/city_hall/departments_and_divisions/administrative_services/finance/city_fees_and _cost_of_services/fire_fees.php, accessed on October 16, 2024. 2 Redwood City, Fire Stations, 2024 (accessed), https://www.redwoodcity.org/departments/fire-department/about-thedepartment/fire-stations, accessed on October 16, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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According to the Standards of Cover Study and Community Risk Assessment for the Redwood City Fire Department, the RC-SCFD is currently challenged in three ways: response times, rising rate of medical incidents, and limitations associated with having a single ladder truck and Battalion Chief. Out of five response components, which include call processing/dispatch, crew turnout, first-unit travel, first unit call to arrive, and Effective Response Force (ERF) call to arrive, the RC-SCFD exceeds the response time best practice in all but one area—call processing/dispatch. Additionally, the RC-SCFD is challenged by the rising demand for low-acuity EMS responses for patients that seldom need immediate emergency room care and reduce the available capacity for serious, life threatening fires and EMS events. Lastly, due to the RC-SCFD only having one ladder truck and Battalion Chief / Incident Commander, response times are affected. To improve this, the Standards of Cover Study and Community Risk Assessment for the Redwood City Fire Department recommends that a second ladder truck and Battalion Chief / Incident Commander be added at Station 13 in San Carlos.3

STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant fire protection services impact if it would:

PS-1 Result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services.

PS-2 In combination with past, present, and reasonably foreseeable projects, result in cumulative fire protection service impacts in the area.

IMPACT DISCUSSION
PS-1 The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities, need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for fire protection services.

New development in the EIR Study Area would be served by the RC-SCFD. A significant impact to the RCSCFD would result if, in order for RC-SCFD to adequately serve the area, increased demand in the EIR Study Area would require the construction of new facilities or the expansion of existing facilities, the construction or operation of which would cause significant environmental impacts. 3 Citygate Associates LLC, May 2023, Standards of Cover Study and Community Risk Assessment for the Redwood City Fire Department.
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The proposed project plans for an approximately 20-year buildout horizon. While an increase in demand for fire protection services would be gradual and in line with incremental population growth, which would occur with or without adoption of the proposed project, the RC-SCFD has identified that additional staff should be considered with the increase in population.4 As previously described, the RCSCFD response times exceed the best practice benchmarks, especially for travel time and multi-unit responses.5 Additionally, RC-SCFD has been recommended to add a ladder truck and Battalion Chief at Station 13 in San Carlos to improve coverage.6
Future development would include new housing and non-residential development, with associated increases to resident and employee population served by the RC-SCFD. Future development under the proposed project would be required to comply with CFC which regulates, among other topics, hazardous material handling, emergency access, and fire protection systems, including automatic sprinkler system, fire extinguishers, and fire alarms. The City would review plans and conduct construction inspections to ensure that new development complies with existing building and fire code requirements. Compliance with the CFC would ensure any new development proposed in the EIR Study Area meets the most current building and fire codes, thereby increasing safety of the buildings, and reducing the likelihood of a fire emergency, subsequently reducing demand on RC-SCFD services.

The Land Use (LU) and Environmental Safety and Public Services (ESPS) Elements of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to public services, including fire protection services. The following General Plan goals, policies, and actions would serve to minimize potential adverse impacts related to performance objectives for fire protection services:
 Goal LU-4: Ensure that any annexation of lands occurs in an orderly and systematic manner and adheres to all City goals, policies, and standards.
 Policy LU-4.2: Annexation of all or portions of unincorporated residential areas shall only be permitted when public services and facilities meeting City standards are available to the lands proposed for inclusion in the city. All streets, sewage and drainage systems and police and fire protection must meet City standards. In no case shall the city taxpayer be burdened with paying for additional services for newly annexed lands. Funds for these services shall be generated through property tax revenue, the establishment of special assessment districts or they shall be paid for by the developer/property owner.
 Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well being of the City.
 Action LU-5.3: Review impact fees for new development to ensure that fees are appropriate to contribute to the cost of providing public facilities and services. 4 Redwood City and San Carlos Fire Departments, correspondence with PlaceWorks, November 2024. 5 Redwood City and San Carlos Fire Departments, correspondence with PlaceWorks, November 2024. 6 Redwood City and San Carlos Fire Departments, correspondence with PlaceWorks, November 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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 Action LU-5.4: Ensure that new development is not a financial burden on municipal service levels by evaluating the fiscal impact of all new projects and establishing preferences for projects that generate sufficient revenue to offset increased operation and maintenance costs, consistent with other local, state and federal regulations.
 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 fire prevention assessment, planning, and projection; and consultation and communication regarding disaster or emergency plans of San Carlos and Mutual Aid with adjacent agencies including but not limited to San Mateo County, Redwood City, Belmont, and CAL FIRE.  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.
 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-3.14: Provide adequate evacuation routes and access for fire and emergency service vehicles to all San Carlos areas.
 Goal ESPS-7: Continue effective emergency response procedures to ensure public safety in the event of natural or man-made disasters.
 Policy ESPS-7.9: Evaluate safety service limitations on an annual basis to provide for adequate levels of service.
 Goal ESPS-13: Ensure adequate public services and high quality design of public facilities to make San Carlos a 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-13.8: 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.
 Action ESPS-13.1: Define acceptable service levels for San Carlos’ public facilities and services.

In addition to the General Plan goals and policies listed above, see Chapter 4.18, Wildfire, of this Draft EIR, for a complete list of goals, policies, and actions that would minimize risk of wildfire, thereby reducing demand on RC-SCFD services.
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While future development under the proposed project would increase demand on fire protection services, growth would occur incrementally. Individual project plan review by the RC-SCFD, compliance with the regulations described under Section 4.14.1.1, Environmental Setting, and consistency with the General Plan goals, policies, and actions listed above would ensure that the RC-SCFD is involved as future development is allowed under the proposed project. RC-SCFD has indicated that adding a second ladder truck and Battalion Chief / Incident Commander at Station 13 in San Carlos would be necessary to accommodate future needs. Future construction of new fire facilities, or renovation or expansion of existing facilities, would be subject to separate project-level environmental review pursuant to the California Environmental Quality Act (CEQA), as required, to identify potential environmental impacts and mitigation measures as needed. The estimated timing or location of these future fire facility improvements are not known at this time, so project-specific environmental impacts that could occur from their construction and operation cannot be determined at this time. It would be speculative to assess the physical effects of those future construction projects and the project’s potential contribution to those effects. Pursuant to Section 15145 of the State CEQA Guidelines, if a particular impact is too speculative for evaluation, no further evaluation is required. Compliance with existing regulations, General Plan goals, policies, and actions, and future project-level environmental review would ensure that impacts on fire protection facilities would be less than significant.

Significance without Mitigation: Less than significant.

PS-2 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative fire protection service impacts.

As discussed in Chapter 4, Environmental Analysis, of this Draft EIR, this cumulative analysis takes into account growth from development under the proposed project within the EIR Study Area combined with the estimated growth in the service area of each service provider. In the case of fire protection, this would be the service area of the RC-SCFD.

Compliance with State and local regulations described under Section 4.14.1.1, Environmental Setting, and the General Plan goals, policies, and actions listed in impact discussion PS-1, would ensure that fire protection services continue to adequately serve the EIR Study Area. Likewise, the Redwood City General Plan has policies and programs that encourage coordination between the county and fire protection agencies in order to identify the most efficient delivery of fire protection services, reduce response times, and have a uniform database and communication system. This is exemplified in the Public Safety Element (PS) of the Redwood City General Plan, Program PS-60, Inter-Agency Emergency Preparedness/Mutual Aid. This program would ensure that Redwood City works with other local cities, San Mateo County, regional organizations, and State agencies to ensure emergency preparedness and fire suppression services are provided in an efficient and coordinated manner. Additionally, this program would continue to participate in mutual aid multi-agency agreements. This type of coordination will provide a coordinated approach to fire protection services and ensure that there is adequate coverage in the RC-SCFD service area.
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Further, because the proposed project is program level, and because future development would be required to undergo project review at the time of project application, to the extent applicable, future development would be assessed for impacts to fire protection services. With adequate planning in place in both the city limit and the RC-SCFD service area, the proposed project would not result in a cumulatively considerable impact to fire protection services and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant.

4.14.2 POLICE SERVICES

ENVIRONMENTAL SETTING
Regulatory Framework
State Regulations
AB 1600, the Mitigation Fee Act, requires a local agency establishing, increasing, or imposing an impact fee as a condition of development to identify the purpose of the fee and the use to which the fee is to be put. The agency must also demonstrate a reasonable relationship between the fee and the purpose for which it is charged, and between the fee and the type of development project on which it is to be levied.

This act became enforceable on January 1, 1989.

Local Regulations
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.14.2.3, Impact Discussion.

Existing Conditions
The San Mateo County Sheriff’s Office (SMCSO) has been contracted to provide law enforcement services to the City of San Carlos since October 2010. Within the San Mateo County Sheriff’s Office, the San Carlos Police Bureau assists with activities in San Carlos and is located at 600 Elm Street. Services that the San Carlos Police Bureau provides include patrol services, Report Releases & Requirements, Vehicle Releases & Requirements, Visa/Clearance Letters & Booking Chronology Requirements. Within the San Mateo County Sheriff’s Office there are 800 employees and 98,778 calls for service in 2023.

The national average for the standard ratio of officers per 1,000 residents is 2.4 sworn police officers per 1,000 residents. The department is currently falling short of meeting this national standard.7

7 Communication with Evanka Swampillai-Coss, Management Analyst of the San Mateo County Sheriff’s Office on 9/30/24. 2045 GENERAL PLAN RESET DRAFT EIR

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The national standard for meeting priority 1 calls is 5 minutes or less. The police department is currently meeting this response time standard; the average response time in 2023 was 4 minutes 23 seconds. 8 The SMCSO has indicated that existing stations are adequate and there are no existing plans for expansion or relocation.9

STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant police services impact if it would:

PS-3 Result in substantial adverse physical impacts associated with the provision of new or physically altered police facilities, need for new or physically altered police facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police services.

PS-4 In combination with past, present, and reasonably foreseeable projects, result in cumulative police service impacts in the area.

IMPACT DISCUSSION
PS-3 The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police facilities, need for new or physically altered police facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for police services.

Due to the built-out nature of San Carlos, future development would occur in previously developed areas. These locations are currently served by the SMCSO and future development or redevelopment in the EIR Study Area is not anticipated to expand SMCSO’s service area, which could increase response times or disrupt other performance objectives.

The proposed project plans for an approximately 20-year buildout horizon. While an increase in demand for police protection services would be gradual and in line with incremental population growth, which would occur with or without adoption of the proposed project, the SMCSO has identified that additional deputies would be necessary with the increase in population.10 As previously described, the SMCSO staffing ratios are below the national staffing average of 2.4 sworn personnel per 1,000 residents.11 The SMCSO has indicated that, while existing stations are adequate and there are no existing plans for expansion or relocation, with the projected increase in population the station will not be sufficient to 8 Communication with Evanka Swampillai-Coss, Management Analyst of the San Mateo County Sheriff’s Office on 9/30/24. 9 San Mateo County Sheriff's Office, correspondence with PlaceWorks, October 2024. 10 San Mateo County Sheriff's Office, correspondence with PlaceWorks, October 2024. 11 San Mateo County Sheriff's Office, correspondence with PlaceWorks, October 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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meet the needs of an increased number of personnel. 12 Therefore, SMCSO has identified that the establishment of a substation on the East Side of San Carlos sometime in the future would improve response times and accommodate staff increases.
13 The SMCSO is funded by the City’s General Fund, which future development would support through the payment of taxes and development fees, among other fees. Future development in San Carlos would be required to pay taxes and development fees, amongst other fees, that would contribute to the General Fund to support the SMCSO. Procurement of additional police equipment would occur as needed through the City’s annual budgeting process, which financially supports the procurement of needed equipment.

As discussed in impact discussion PS-1, the Land Use (LU) and Environmental Safety and Public Services (ESPS) Elements of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to public services, including police services. The General Plan goals, policies, and actions listed in impact discussion PS-1 would serve to minimize potential adverse impacts related to police services.

While the proposed project would increase demand on police protection services, growth would occur incrementally. SMCSO has indicated that existing stations would be adequate to accommodate future needs and no specific plans to construct new facilities have been developed. However, SMCSO has identified that the proposed project would increase demand which could lead to the construction of a new facility or the expansion of the current one. The estimated timing or location of future facility improvements are not known at this time, so project-specific environmental impacts that could occur from their construction and operation cannot be determined at this time. Therefore, it would be speculative to assess the physical effects of those future construction projects and the project’s potential contribution to those effects. Pursuant to Section 15145 of the State CEQA Guidelines, if a particular impact is too speculative for evaluation, no further evaluation is required. If needed, future construction of new or renovated police stations would be subject to separate project-level environmental review pursuant to CEQA, as required, to identify potential environmental impacts and mitigation measures as needed to reduce potential environmental impacts. Therefore, impacts on police service facilities would be less than significant.

Significance without Mitigation: Less than significant.

PS-4 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative police protection service impacts.

Cumulative police service impacts would occur from future development within the buildout horizon of the proposed project in the service area of SMCSO. The proposed project does not include specific 12 San Mateo County Sheriff's Office, correspondence with PlaceWorks, October 2024. 13 San Mateo County Sheriff's Office, correspondence with PlaceWorks, November 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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development projects, as it serves as a guide for future development in the city. Future development projects are currently and will continue to be assessed for impacts to police protection services.

It is unlikely that approval of the General Plan and certification of the EIR would immediately increase the degree or incidence of need for police protection services because future development would occur incrementally throughout the approximately 20-year buildout horizon. Additionally, compliance with the General Plan goals, policies, and actions discussed in impact discussion PS-3 would reduce the impact that future development could have on the SMCSO. Additionally, development would occur in the form of infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing residential and residential-serving development and which are covered by existing police services. Therefore, the proposed project would not result in a cumulatively considerable impact to police protection services and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant.

4.14.3 SCHOOLS

ENVIRONMENTAL SETTING
Regulatory Framework
State Regulations
Senate Bill 50
SB 50 (funded by Proposition 1A, approved in 1998) limits the power of cities and counties to require mitigation of school facilities impacts as a condition of approving new development and provides instead for a standardized developer fee. SB 50 generally provides for a 50/50 State and local school facilities funding match. SB 50 also provides for three levels of statutory impact fees. In setting the fees, school districts must prepare nexus studies to demonstrate a reasonable connection between new development and the need for school improvements. The fees may only be used to finance the construction or modernization of school facilities. The fee application level depends on whether State funding is available, whether the school district is eligible for State funding, and whether the school district meets certain additional criteria involving bonding capacity, year-round school, and the percentage of moveable classrooms in use.

California Government Code Section 65995
SB 50 amended California Government Code Section 65995, which contains limitations on Education Code Section 17620, the statute that authorizes school districts to assess development fees within school district boundaries. Government Code Section 65995(b)(3) requires the maximum square footage assessment for development to be increased every two years, according to inflation adjustments.

According to California Government Code Section 65995(3)(h), the payment of statutory fees is “deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental 2045 GENERAL PLAN RESET DRAFT EIR

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organization or reorganization...on the provision of adequate school facilities.” The school district is responsible for implementing the specific methods for mitigating school impacts under the Government Code.

Mitigation Fee Act
AB 1600, the Mitigation Fee Act, requires a local agency establishing, increasing, or imposing an impact fee as a condition of development to identify the purpose of the fee and the use to which the fee is to be put. The agency must also demonstrate a reasonable relationship between the fee and the purpose for which it is charged, and between the fee and the type of development project on which it is to be levied.

This act became enforceable on January 1, 1989.

San Carlos School District Long Range Facilities Master Plan Approved in 2023, the San Carlos School District (SCSD) Long Range Facilities Master Plan provides a continuous basis for planning educational facilities that will meet the changing needs of a community.

Within the SCSD Facilities Master Plan is a snapshot of needs, vision, and a plan for implementation. 14 This includes enrollment, capacity and utilization analysis, a facility conditions assessment, and site master plans for all the schools in the district.

Sequoia Union High School District Facilities Master Plan The Sequoia Union High School District (SUHSD) Facilities Master Plan establishes a clear road map for using, improving, and creating new campus facilities that best fit the needs of each school. SUHSD Facilities Master Plan contains information about the how each facility was assessed, as well as the master plans for each school within the district.
14 San Carlos School District, 2023, Long Range Facility Master Plan, https://4.files.edl.io/62c2/09/21/23/233526- 0bd38e0d-9d1a-4560-995e-c73e552a05fa.pdf, accessed on September 30, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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Measure W
On the ballot in 2022, Measure W supported authorizing SUHSD to issue $591 million in bonds to repair and upgrade the infrastructure and classrooms of local high schools, levying $14 per $100,000 in assessed value.15 This measure was passed.

Development Impact Fees
The school districts within San Carlos collect development impact fees and they are calculated on new or added square footage from the outside wall dimensions of assessable space. Once the impact fees are collected, 60 percent goes to the feeder elementary school district, and 40 percent goes to SUHSD. 16 The current fees are as follows:17
 Level 1 – Commercial/Industrial: $0.84 / sq. ft.
 Level 2 – Residential: $5.17 / sq. ft.

Existing Conditions
The following describes current conditions and potential impacts of the project with regard to schools in San Carlos. The City of San Carlos is served by two different school districts: SCSD and SUHSD.

San Carlos School District
There are eight schools within SCSD and 12 preschool classes in the Early Learning Center/Preschool. The nine sites and their associated grade levels are listed below:
 San Carlos Early Learning Center/Preschool – 2 to 4 year olds, in 12 classes across 4 elementary sites  Arundel Elementary – Transitional Kindergarten (TK) to 3rd grade  Brittan Acres Elementary – TK to 3rd grade
 Heather Elementary – TK to 3rd grade
 White Oaks Elementary – TK to 3rd grade
 Arroyo Upper Elementary – 4th to 5th grade
 Mariposa Upper Elementary – 4th to 5th grade
 Central Middle School – 6th to 8th grade
 Tierra Linda Middle School – 6th to 8th grade
15 Ballotpedia, 2024 (accessed), Sequoia Union High School District, California, Measure W, Bond Measure, https://ballotpedia.org/Sequoia_Union_High_School_District,_California,_Measure_W,_Bond_Measure_(November_2022), accessed on September 30, 2024.
16 Governing Board of the Sequioa Union High School District, 2024, Resolution No. 011, https://www.seq.org/documents/Departments/Admin%20Services/Maintenance%20and%20Operations/Resolutions%20and% 20Justification%20Reports/RESOLUTION-No.-011-INCREASE-IN-SCHOOL-FACILITIES-FEES-AND-ADOPTION-OF-CEQA-NOTICE-OFEXEMPTION-3-6-24.pdf, accessed on October 16, 2024. 17 Sequioa Union High School District, 2024, Level 1 Developer Fee Study for Sequioa Union High School District, https://www.seq.org/documents/Departments/Admin%20Services/Maintenance%20and%20Operations/Resolutions%20and% 20Justification%20Reports/Developer-Fee-Justification-Study-March-2024.pdf, accessed October 21, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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The San Carlos Education Foundation helps fund programs local public schools can offer students. The 2023-2024 funding goal was $3.7 million. Programs that are funded through the foundation include:
school PTA, technology staff and equipment, library and literacy, music programs, emotional health and wellness, physical education, innovation, principal flex funds.

In 2023, a Long-Range Facilities Master Plan was completed for the school district but, in correspondence with SCSD, certain inconsistencies were noted. Within the SCSD Facilities Master Plan a surplus of 66 classrooms across SCSD sites were noted. According to the SCSD, this analysis is based on the State Funding Program's loading standards, which calculate maximum capacity without factoring in actual space utilization or local educational programming.18 The SCSD Facilities Master Plan also does not include TK classroom usage.19 With the statewide mandate of full implementation of TK beginning in the 2025-26 school year, SCSD is projecting to need a total of 13 to 14 TK classrooms.20 The current enrollment of SCSD is 2,875 students, which is 177 more students than the 2,698 projected in the most recent Enrollment Projection Consultants Demographic Report from February 2023.21 SCSD is at capacity for grade-levels TK through 5.22 In fall of 2025, TK will be planned to move to a 10:1 ratio which is anticipated to bring in an additional 50 to 100 students in the grade level, exceeding capacity.23 In preparation for this, the TK classroom space has expanded by installing three modular classrooms in Arundel, Brittan Acres, and Heather Elementary Schools during the summer of 2024.24 Sequoia Union High School District
SUHSD serves San Carlos, Belmont, and Redwood City high school students. Overall, SUHSD serves approximately 9,741 students on the Midpeninsula with seven schools.25 Most of the students within San Carlos attend Carlmont High, with some of the students attending Sequoia High.26 The capacity for Carlmont High School is 2,343 students. Its current enrollment is 2,360 students, exceeding its capacity by 17 students.27 The capacity for Sequoia High School is 2,515 students. Its current enrollment is 1,903 students, so it is not exceeding its capacity. 28 For the purposes of district planning, SUHSD utilizes student generation rates of 0.14 for single-family detached units, 0.09 for single-family attached units, and 0.10 for multi-family units. 18 San Carlos School District, correspondence with PlaceWorks, October 2024. 19 San Carlos School District, correspondence with PlaceWorks, October 2024. 20 San Carlos School District, correspondence with PlaceWorks, October 2024. 21 San Carlos School District, correspondence with PlaceWorks, October 2024. 22 San Carlos School District, correspondence with PlaceWorks, October 2024. 23 San Carlos School District, correspondence with PlaceWorks, October 2024. 24 San Carlos School District, correspondence with PlaceWorks, October 2024. 25 California Department of Education, 2020-21 Enrollment By Ethnicity: Sequoia Union High Report (41-69062), https://dq.cde.ca.gov/dataquest/dqcensus/EnrEthGrd.aspx?cds=4169062&agglevel=District&year=2023-24, accessed October 16, 2024.
26 Sequioa Union High School District, correspondence with PlaceWorks, October 2024. 27 Sequioa Union High School District, correspondence with PlaceWorks, October 2024. 28 Sequioa Union High School District, correspondence with PlaceWorks, October 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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Funding for SUHSD comes from Local Control Funding Formula Sources and federal, State, and local sources.29 SUHSD also collects development impact fees, which fund improvements and new facilities to mitigate impacts from new development.

SUHSD has a Facilities Master plan that was completed in 2023 and sets a vision for the next ten years of future facility improvements.30 Among the various school improvements that are outlined in the plan, Carlmont High School was identified in five areas for improvement, including new construction, renovation, site/sports projects, and infrastructure.31 For Sequoia High School, the Master Plan anticipates a new classroom building and modernization of existing buildings.32

STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant schools impact if it would:

PS-5 Result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools.

PS-6 In combination with past, present, and reasonably foreseeable projects, result in cumulative schools impacts in the area.

IMPACT DISCUSSION
PS-5 The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities, need for new or physically altered school facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for schools.

A significant impact would result if, in order for the school districts to adequately serve the EIR Study Area, increased school enrollment would require the construction of new facilities or the expansion of existing schools, the construction or operation of which would cause significant environmental impacts.

Future development within the buildout horizon of the proposed project would cause an increase in student population over the next 20 years. The projected increase in students across the EIR Study Area 29 Sequioa Union High School District, Approval and Certification of 2022-23 Second Interim Fiscal Report, https://www.seq.org/documents/Accounting/22-23-Second-interim-narrative-22-23.pdf, accessed on October 16, 2024. 30 Sequoia Union High School District, September 2023, Facilities Master Plan, https://drive.google.com/file/d/14TDfrmql5JL_hyY5rvijXM0bR7_9yC6A/view, accessed on October 16, 2024.. 31 Sequoia Union High School District, September 2023, Facilities Master Plan, https://drive.google.com/file/d/14TDfrmql5JL_hyY5rvijXM0bR7_9yC6A/view, accessed on October 16, 2024.. 32 Sequioa Union High School District, correspondence with PlaceWorks, October 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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would likely be gradual for the duration of the proposed project as more housing units are incrementally added to the EIR Study Area. The public school districts that serve the EIR Study Area would continue to collect the development impact fees, which each district has adopted, throughout the horizon of the proposed project. Therefore, future development would incrementally contribute toward facility upgrades and expansions, which, pursuant to California Government Code Section 65995, has been deemed sufficient to provide full and complete school facilities mitigation for the impacts from the proposed project, regardless of whether the fees are adequate to fully fund the expansion or construction of needed facilities. While SUHSD does have capital improvements projects outlined and underway, these projects were already identified prior to the proposed project. However, increased student enrollment associated with the buildout projections for the proposed project could exacerbate and increase the need for facility expansions.

The Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to public services, including school services. In addition to the General Plan goals, policies, and actions identified in impact discussion PS-1 related to the provision of public facilities and services, the following General Plan goals, policies, and actions would serve to minimize potential adverse impacts related to performance objectives for school services:
 Goal ESPS-13: Ensure adequate public services and high quality design of public facilities to make San Carlos a safe, enjoyable and quality community in which to live, work and shop.  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-13.5: 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.  Goal ESPS-14: Provide educational opportunities for all ages.  Policy ESPS-14.1: Support schools and educational institutions as a key component of San Carlos’ identity.
 Policy ESPS-14.4: 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 ESPS-14.5: Participate in the long-range planning activities with San Carlos Unified School District and Sequoia Union High School District.
 Action ESPS-14.2: Advocate for reestablishing a high school within San Carlos for San Carlos residents.
 Action ESPS-14.3: Maintain and enhance City Council collaboration with the San Carlos School District and other appropriate educational entities.
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While future development would increase demand on school services, the increased demand would occur incrementally. Future construction of new or renovated school facilities to accommodate growth under the proposed project would be subject to separate project-level environmental review pursuant to CEQA, as required, to identify potential environmental impacts and mitigation measures as needed to reduce potential environmental impacts. The estimated timing or location of future additional facility improvements are not known at this time, so project-specific environmental impacts that could occur from their construction and operation cannot be determined at this time. It would be speculative to assess the physical effects of those future construction projects and the project’s potential contribution to those effects. Pursuant to Section 15145 of the State CEQA Guidelines, if a particular impact is too speculative for evaluation, no further evaluation is required.

Potential secondary effects associated with increased school enrollment, such as vehicle traffic and associated air quality and noise concerns, are addressed in Chapter 4.2, Air Quality; Chapter 4.11, Noise; and Chapter 4.15, Transportation, of this Draft EIR.

With the required payment of development impact fees for new development pursuant to California Government Code Section 65995, General Plan goals, policies, and actions, and future environmental review at the project level for any school facility improvements, impacts to the public-school districts that serve the EIR Study Area would be less than significant.

Significance with Mitigation: Less than significant.

PS-6 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative school impacts in the area.

This cumulative analysis takes into account growth from development within the service area of the school districts within the EIR Study Area. As described under impact discussion PS-5, the proposed project would contribute to increased population that is served by local school districts.

As described in impact discussion PS-5, through the payment of school impact fees, General Plan goal, policies, and action, and standard environmental review procedures for future school improvement projects, the proposed project would not result in significant impact to schools. Payment of school fees and project-level review of school projects to identify potential environmental impacts and mitigation measures as needed would similarly reduce potential impacts from cumulative development. Therefore, cumulative impacts related to school facilities would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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4.14.4 LIBRARIES

This act became enforceable on January 1, 1989.

Strategic Plan 2018-2023
The Strategic Plan 2018-2023 for San Mateo Public Libraries will serve as a communication tool and provide guidance on operational decisions.33 The plan allows public libraries in San Carlos to anticipate and respond to changes while keeping their core values intact. Key topics in this plan include lifelong learning, technology, outreach and marketing, user experience, and supporting and developing staff.

Existing Conditions
San Mateo County Libraries is a Joint Powers Authority (JPA), an independent entity with its own Governing Board, consisting of elected officials from each member. An Operations Committee composed of city and county leaders from each member also provides guidance. The service area is comprised of the cities of Atherton, Belmont, Brisbane, East Palo Alto, Foster City, Half Moon Bay, Millbrae, Pacifica, Portola Valley, San Carlos, Woodside, and the unincorporated areas of the county.

Library services are primarily funded by County property taxes, including Measure K, passed in 2016, which supports essential County services and critical facilities. The Governing Board approves an annual budget and service plan for the library system that includes operations, projects, and initiatives. San 33 San Mateo Public Library, 2018, Strategic Plan 2018-2023, https://www.cityofsanmateo.org/DocumentCenter/View/65607/San-Mateo-Public-Library-Strategic-Plan-2018-2023, accessed August 16, 2022.
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Mateo County Libraries distributes resources designed to meet performance and service objectives.

Input is sought from stakeholders to respond to community needs and optimize resources. Per the Library JPA, the minimum service levels are calculated for libraries based on population—the base library service shall be 60 hours per week for members with over 6,500 in population.

The San Carlos branch of the San Mateo County library system is located at 610 Elm Street, adjacent to City Hall. This library offers a large collection of books and other materials for all ages, computers and Internet access, services such as storytimes, making, afterschool programs, language conversation clubs, and technology classes. The San Carlos Library currently operates with 11 permanent positions and 9.75 full-time equivalent positions. The San Carlos Library is open 61 hours, 7 days per week. Across San Mateo County Libraries in 2023-24, 1.7 million visitors visited, 2.4 million items were circulated, and 7,500 programs and events were hosted.
34 The San Carlos Library is 25 years old and in need of several significant improvements. 35 Currently, the
San Carlos Library is expanding onto the second floor of the current facility, adding 1,000 square feet for a makerspace that is estimated to be completed in 2025.36

STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant library services impact if it would:

PS-7 Result in substantial adverse physical impacts associated with the provision of new or physically altered libraries facilities, need for new or physically altered libraries facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for libraries.

PS-8 In combination with past, present, and reasonably foreseeable projects, result in cumulative libraries impacts in the area.

IMPACT DISCUSSION
PS-7 The proposed project would not result in substantial adverse physical impacts associated with the provision of new or physically altered libraries facilities, need for new or physically altered libraries facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for libraries.

A significant impact would result if, in order for the library system to adequately serve the city, increased demand in the EIR Study Area would require the construction of new facilities or the expansion of 34 San Mateo County Libraries, correspondence with PlaceWorks October 2024. 35 San Mateo County Libraries, correspondence with PlaceWorks October 2024. 36 San Mateo County Libraries, correspondence with PlaceWorks October 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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existing library facilities, the construction or operation of which would cause significant environmental impacts. New residential and non-residential development would increase the resident and daytime population of San Carlos, increasing utilization of library services. This increased demand for library services could impact library facilities if construction activities for new and expanded facilities would result in adverse environmental impacts.

As discussed in Section 4.14.4.1, Environmental Setting, the San Carlos Library is in need of several significant improvements, which inhibits the library’s ability to meet the community’s library needs.

Currently the San Carlos Library is expanding onto the second floor of the current facility. Based on the projected population increase in San Carlos by 2045, the San Carlos Library could need to expand to accommodate potential new users.

The Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contains goals and policies that require local planning and development decisions to consider impacts to public services, including library services. In addition to the General Plan goals, policies, and actions identified in impact discussion PS-1 related to the provision of public facilities and services, the following General Plan goals and policies would serve to minimize potential adverse impacts related to performance objectives for library services:
 Goal ESPS-13: Ensure adequate public services and high quality design of public facilities to make San Carlos a safe, enjoyable and quality community in which to live, work and shop.  Policy ESPS-13.6: Maintain existing library facilities as an important activity center within the community.
 Goal ESPS-14: Provide educational opportunities for all ages.  Policy ESPS-14.3: Ensure that all residents have access to library services including access to computers and other technology.

It is expected that new growth under the proposed project would most likely occur incrementally over the next 20 years. The potential need for future library facility expansions would be assessed as development occurs. Future construction of new or renovated library facilities to accommodate growth under the proposed project would be subject to separate project-level environmental review pursuant to CEQA, as required, to identify potential environmental impacts and mitigation measures as needed to reduce potential environmental impacts. The estimated timing or location of future facility improvements are not known at this time, so project-specific environmental impacts that could occur from their construction and operation cannot be determined at this time. It would be speculative to assess the physical effects of those future construction projects and the project’s potential contribution to those effects. Pursuant to Section 15145 of the State CEQA Guidelines, if a particular impact is too speculative for evaluation, no further evaluation is required. Additionally, adherence to the General Plan goals, policies, and actions would ensure that there is a less-than-significant impact relating to the provision of new or physically altered library facilities.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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PS-8 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative libraries impacts in the area.

The geographic context for the cumulative library impacts would occur from future development within the buildout horizon of the proposed project, combined with impacts of development on lands adjacent to the city. A significant cumulative environmental impact would result if this cumulative growth would exceed the ability of San Mateo County libraries to adequately serve the EIR Study Area, thereby requiring construction of new facilities or modification of existing facilities. As described in impact discussion PS-7, existing facilities are in need of several significant improvements. The San Carlos Library is currently expanding onto the second floor, and the City plans to address other improvements at the library in the coming years.
37 The payment of County property taxes would ensure adequate library services over the course of the General Plan buildout. Additionally, future construction of new or renovated library facilities would be subject to separate project-level environmental review pursuant to CEQA to identified potential environmental impacts and mitigation measures as needed. Therefore, the proposed project would not result in a cumulatively considerable impact to library services and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant. 37 San Mateo County Libraries, correspondence with PlaceWorks October 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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4.15 TRANSPORTATION
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to transportation, and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

4.15.1 ENVIRONMENTAL SETTING

REGULATORY FRAMEWORK
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 (FHWA).

Federal Regulations
Federal Highway Administration
The FHWA is the agency of the United States Department of Transportation responsible for the federally funded roadway system, including the interstate highway network and portions of the primary State highway network, such as US Highway 101.

Americans with Disabilities Act
The Americans with Disabilities Act (ADA) of 1990 provides comprehensive rights and protections to individuals with disabilities. The goal of the ADA is to assure equality of opportunity, full participation, independent living, and economic self-sufficiency for people with disabilities. To implement this goal, the US Access Board, an independent federal agency created in 1973 to ensure accessibility for people with disabilities, has created accessibility guidelines for public rights-of-way. While these guidelines have not been formally adopted, they are widely followed by jurisdictions and agencies nationwide. These guidelines address various issues, including roadway design practices, slope and terrain issues, and pedestrian access to streets, sidewalks, curb ramps, street furnishings, pedestrian signals, parking, public transit, and other components of public rights-of-way.
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State Regulations
California Department of Transportation
Caltrans is the owner and operator of the state highway system, which includes US Highway 101 and El Camino Real within San Carlos. In its 2020 Vehicle Miles Traveled-Focused Transportation Impact Study Guide (TISG), 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 the California Environmental Quality Act (CEQA) requirements, the TISG does not consider vehicle delay in its evaluation of transportation impacts, instead focusing on vehicle miles traveled (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
On September 27, 2013, Senate Bill (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 (Assembly Bill [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 Land Use and Climate Innovation (LCI, formerly the Governor’s Office of Planning and Research) 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 LCI-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 greenhouse gas 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 level of service (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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California Complete Streets Act of 2008
Originally passed in 2008, California’s Complete Streets Act (AB 1358) came into force in 2011 and requires local jurisdictions to plan for land use transportation policies that reflect a “complete streets” approach to mobility. “Complete streets” comprises a suite of policies and street design guidelines which provide for the needs of all road users, including pedestrians, bicyclists, transit operators and riders, children, the elderly, and the disabled. From 2011 onward, any local jurisdiction, county or city, that undertakes a substantive update of the circulation element of its general plan must consider “complete streets” and incorporate corresponding policies and programs.

Regional Regulations
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 (MTC) and Association of Bay Area Governments (ABAG) 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 operatorspecific 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 micromobility through sidewalk improvements, car-free slow streets, and 10,000 miles of bike lanes or multi-use paths.
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 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 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.

Metropolitan Transportation Commission
MTC is the transportation planning, coordinating, and financing agency for the nine-county Bay Area, including San Mateo County. It also functions jointly as the federally mandated metropolitan planning organization (MPO) for the region along with ABAG. It is responsible for regularly updating the Regional Transportation Plan (RTP), a comprehensive blueprint for the development of mass transit, highway, airport, seaport, railroad, bicycle, and pedestrian facilities.

Bay Area Air Quality Management District
The Bay Area Air Quality Management District (BAAQMD) is the public agency tasked with regulating air pollution in the nine-county Bay Area, including San Mateo County. As a primary source of air pollution in the Bay Area region is from motor vehicles, air district regulations affect transportation planning. The BAAQMD’s goals include reducing health disparities due to air pollution, achieving, and maintaining air quality standards, and implementing exemplary regulatory programs and compliance with federal, State, and regional regulations.

C/CAG Congestion Management Program
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 LOS along the designated CMP network, which includes US Highway 101 and the El Camino Real (State Route 82)/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.

According to the state legislation, the purpose of CMPs is to develop a procedure to alleviate or control anticipated increases in roadway congestion and to ensure that “federal, state, and local agencies join with transit districts, business, private and environmental interests to develop and implement 2045 GENERAL PLAN RESET DRAFT EIR

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comprehensive strategies needed to develop appropriate responses to transportation needs.” The first CMP for San Mateo County was adopted by C/CAG in 1991. It has been updated and amended on a biennial basis. The last CMP update was in 2023.

C/CAG Transportation Demand Management Policy
The C/CAG Transportation Demand Management (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 Regulations
San Carlos 2030 General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.15.3, Impact Discussion.

City of San Carlos Municipal Code
The San Carlos Municipal Code (SCMC) is the primary document that regulates the policies and practices of the City. The SCMC contains the Zoning Code, the Subdivision Ordinance, the Building and Construction Code, and other titles that are important in implementing the goals, policies, and actions of the General Plan. The SCMC includes various directives pertaining to transportation as follows:
 Chapter 8.50, Traffic Impact Fee, 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.  Chapter 10.48, Load Limits, designates truck routes for vehicles exceeding a maximum gross weight, including load, of three tons. Segments of Howard Avenue and Brittan Avenue between El Camino Real and Industrial Road are designated as truck routes, along with US Highway 101, El Camino Real, and Industrial Road.
 Chapter 18.25, Transportation Demand Management, adopts a 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. Each qualifying project is required 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 2045 GENERAL PLAN RESET DRAFT EIR

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project owners/operators to modify their previously approved TDM measures. The City is currently updating its TDM requirements as part of the Citywide Transportation Demand Management and Parking Reform Project.

San Carlos Complete Streets Policy
The City adopted a Complete Streets Policy in 2012 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.

San Carlos Vehicle Miles Traveled Policy
In accordance with SB 743, the City adopted VMT thresholds on Nov 12, 2024 (Resolution No. 2024-118) that were based on assessment of local needs and development characteristics, to be used in evaluating the potential VMT impacts of land development and transportation projects. Within the VMT policy certain projects are considered to have less-than-significant transportation impacts and no further transportation analysis is required. These projects include nonresidential projects under 10,000 square feet, residential projects with 10 or fewer single-family units or 15 or fewer multi-family units; projects located within Low VMT Areas or within Transit Priority Areas (TPA); 100-percent-restricted affordable residential projects in infill locations; neighborhood-serving retail or public facility projects that are less than 30,000 square feet; and transportation projects that do not add vehicle capacity. Projects not screened out through the criteria above are required to complete a VMT analysis to determine if there would be a significant VMT impact. An impact would be considered significant if the following thresholds are exceeded:
 Total project-generated VMT per service population exceeds a level of 15 percent below the regionwide baseline VMT rate.
 Project-generated VMT per resident exceeds a level of 15 percent below the regionwide baseline VMT rate.
 Project-generated VMT per employee exceeds a level of 15 percent below the regionwide baseline VMT rate.
 The project increases total (boundary) countywide VMT compared to cumulative “no project” conditions.
 The project is inconsistent with the Regional Transportation Plan/Sustainable Community Strategy Plan (Plan Bay Area).

San Carlos Bicycle and Pedestrian Master Plan
The Bicycle and Pedestrian Master Plan (BPMP) was adopted in June 2020. The BPMP establishes a longterm 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.

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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.

East Side Innovation District Vision Plan
Approved in 2021, the East Side Innovation District Vision Plan sets forth clear goals and principles written to achieve the desired character for the East Side Innovation District. The East Side Innovation District is the area east of El Camino Real and west of US Highway 101 and is bounded by Brittan Avenue to the south and Holly Street to the north. Principles of the Vision Plan related to transportation include principles to adopt street hierarchy guidelines for all public rights of way and new nonvehicular connections within the district, undertake a citywide traffic impacts study, and develop and define districtwide TDM requirements.

EXISTING CONDITIONS
Existing Circulation Network
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:
 Freeways and State Highways: largely serve through traffic and link the City to the regional transportation network.
 Arterial Streets: the primary streets within the City, connecting major destinations to one another.  Collector Streets: provide connectivity between arterial streets and act as feeders for traffic from less densely developed areas.
 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 Highway 101
US Highway 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 Highway 101 exists at Holly Street, and a partial interchange with southbound US Highway 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 Highway 101 in Belmont and Redwood City, respectively.
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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 EIR 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 0.5 miles 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 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. Additionally, as part of the Downtown Specific Plan, El Camino Real would be redesigned based on community feedback and guiding principles for the Downtown Specific Plan.

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. Additionally, as part of the Downtown Specific Plan, a portion of Brittan Avenue could be redesigned based on community feedback and guiding principles for the Downtown Specific Plan.

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 2045 GENERAL PLAN RESET DRAFT EIR

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mix of commercial and residential along this roadway. Additionally, as part of the Downtown Specific Plan, a portion of Holly Street could be redesigned based on community feedback and guiding principles for the Downtown Specific Plan.

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.

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. The 700 block of Laurel Street was permanently closed in 2023 to be converted into a public plaza. Additionally, as part of the Downtown Specific Plan, portions of Laurel Street would be redesigned based on community feedback and guiding principles of the Downtown Specific Plan.

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. Additionally, as part of the Downtown Specific Plan, a portion of San Carlos Avenue would be redesigned based on community feedback and guiding principles for the Downtown Specific Plan.

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. 2045 GENERAL PLAN RESET DRAFT EIR

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Existing Pedestrian and Bicycle Facilities
Pedestrian Facilities
The EIR Study Area 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 EIR Study Area, in the hilly residential areas there are numerous locations where sidewalks are substandard, not present, or have gaps.

Bicycle Facilities
Bicycle facilities in the EIR Study Area 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.

Existing Transit Service
This section provides an overview of existing transit services in the EIR Study Area. The primary public transit providers in the EIR Study Area are the San Mateo County Transit District (SamTrans) and Caltrain.

In addition to the services they directly provide, they offer connections to regional transit services and local services in other nearby jurisdictions, described below.

San Mateo County Transit District
SamTrans provides fixed route bus service in San Carlos and throughout San Mateo County. SamTrans buses are equipped with bike racks that can carry two bicycles. Bike rack space is on a first come, first served basis and riders must be able to load and unload their bicycles without any help from the operator. Two additional bicycles are allowed on SamTrans buses at the discretion of the driver and depending on passenger loads. The following routes serve the City of San Carlos:
 Route ECR provides service along El Camino Real from the Palo Alto Transit Center to the Daly City Bay Area Rapid Transport (BART) Station. On weekdays, the bus runs every 15 minutes from approximately 4:00 a.m. until 2:00 a.m. On weekends, it runs every 20 minutes from 4:45 a.m. until 2:00 a.m.
 Route 61 is a school-oriented route that operates a single bus between the Cities of Belmont and San Carlos with key stops at Carlmont High School, Arundel Elementary School, Heather Elementary School, Arroyo School, various parks, Downtown San Carlos and the San Carlos Caltrain Station. This route begins operation from the San Carlos Caltrain Station at 7:24 a.m. and follows a counterclockwise route around San Carlos and ending at Ralston Avenue in Belmont. In the afternoon, this round begins at the Belmont Library at 4:00 p.m. and ends at the San Carlos Caltrain Station serving multiple schools in San Carlos. On Wednesdays, the route starts at 9:00 a.m. and 1:00 p.m., respectively to support minimum day school schedules. 2045 GENERAL PLAN RESET DRAFT EIR

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 Route 260 is a weekday route that connects the San Carlos Caltrain Station, Redwood Shores, and Carlton Village. It operates daily with a bus every 60 minutes from 8:00 a.m. until 9:00 p.m.  Route 295 is a weekday route that runs between the the Redwood City Transit Center and the Hillsdale Mall, also serving the Caltrain station in San Carlos. On weekdays, service is provided with a bus every 60 minutes from 6:30 a.m. until 8:00 p.m. and on weekend days from 7:00 a.m. to 8:00 p.m. with 60-minute headways.
 Route 397 runs between Downtown San Francisco and the Palo Alto Transit Center. It operates daily from approximately 1:00 a.m. until 6:45 a.m. with 45-minute headways, with no mid-day or evening service. This route has stops at the San Francisco International Airport, the Millbrae Transit Center, the San Carlos Caltrain station and the Redwood City Transit Center.

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.

Bay Area Rapid Transit
BART provides regional heavy-rail rapid transit service, with stations in Alameda, Contra Costa, San Francisco, San Mateo, and Santa Clara Counties. Typical hours of operation for BART are between the hours of 5:00 a.m. and midnight weekdays, 6:00 a.m. to midnight on Saturdays and 8:00 a.m. to midnight on Sundays. 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 Area Water Emergency Transportation Authority The San Francisco Bay Area Water Emergency Transportation Authority operates the regional ferry service in San Francisco Bay. 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 and 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 SamTrans’ Redi-Wheels service provides paratransit in San Carlos and other San Mateo County communities. Redi-Wheels 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.
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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.

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 online-enabled application or platform (such as smart phone apps) to connect drivers using their personal vehicles with passengers.

Travel Characteristics
Residents of San Carlos rely primarily on personal motor vehicles for commuting. As reported in the 2022 American Community Survey (which reflects commuting in the wake of the onset of the COVID-19 pandemic), approximately 62 percent of working San Carlos residents commuted by car, truck, or van, with 59 percent driving alone. Public transportation was used as the primary commute mode by approximately 4 percent of workers living in San Carlos, including 2 percent traveling by commuter rail.

Approximately 3 percent of workers reported walking or biking to work, while 29 percent worked from home.

This commute pattern is similar to San Mateo County as a whole, although a higher percentage of San Carlos residents report as working from home. Countywide, 68 percent of County residents commute by car, truck, or van; 7 percent by public transportation; 4 percent by walking and biking; and 20 percent work from home.

In terms of commute distance, 69 percent of employed San Carlos residents travel less than 25 miles to work, with 31 percent having commutes of less than 10 miles and 38 percent traveling 10 to 24 miles.

4.15.2 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant transportation impact if it would:

TRAN-1 Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

TRAN-2 Conflict or be inconsistent with CEQA Guidelines Section 15064.3(b).

TRAN-3 Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

TRAN-4 Result in inadequate emergency access.
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TRAN-5 In combination with past, present, and reasonably foreseeable projects, result in cumulative transportation impacts in the area.

4.15.3 IMPACT DISCUSSION
TRAN-1 The proposed project would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities.

The proposed project would result in increased development of residential, retail, and commercial land uses and therefore increased use of the transportation system. Based on the proximity of the project sites to mixed-use areas and high-quality transit, the proposed project would support the development of land development patterns that would allow for shorter trips and non-vehicle modes of transportation, so it is expected that the project would generate additional walking, bicycling, and transit trips.

While magnitude of projected development is known, information is not available regarding the precise location of future development projects, the design of project access points, and the adequacy of on-site pedestrian circulation; therefore, the site-specific impacts of future development projects on pedestrian, bicycle, and transit facilities cannot be evaluated as part of this program-level analysis. To ensure that future development projects do not conflict with existing or planned facilities supporting those travel modes, the adequacy of existing facilities would be assessed as part of the development review process, and future pedestrian, bicycle, and transit facilities would be designed using the appropriate design standards and guidelines.

The Land Use (LU) Element and Circulation and Scenic Highways (CSH) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to transportation, including the circulation system. The following General Plan goals, policies, and actions emphasize coordination between land use and transportation and encourage the development of complete streets and multimodal infrastructure:
 Goal LU-1: Ensure a sustainable land use pattern.
 Policy LU-1.3: Ensure that development within the TOD corridor maintains and improves the mobility of people and vehicles along and across the corridor.  Policy LU-1.4: Establish and support the El Camino Real/Caltrain multimodal TOD corridor for the purpose of the mobility of people and vehicles along and across the corridor.  Policy LU-1.5: Support land use patterns in the TOD corridor that will attract and serve riders of public transit.
 Action LU-1.1: Continue to evaluate the Transportation Demand Management Ordinance to encourage mode shift to reduce vehicular trip generation from new development. 2045 GENERAL PLAN RESET DRAFT EIR

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 Action LU-1.2: Include in the Transportation Demand Management Ordinance a requirement that new office development over a certain size include showers and safe and secure bike racks to encourage employees to bicycle to work.
 Goal LU-3: Promote connectivity and provide retail and services within walking distance of homes and employment areas.
 Policy LU-3.10: Encourage the creation of safe, walkable environments that include elements such as wide, smooth sidewalks, good lighting, safe crosswalks, clear signage, curb bulbouts, curb cuts, street furniture and trees and traffic-calming measures which allow people of all ages and abilities to exercise and safely access public transportation, community centers and schools and goods and services.
 Policy LU-3.13: Provide for safe and convenient pedestrian and bicycle connections between residential and commercial areas throughout San Carlos.  Action LU-3.2: Consider development of a Complete Streets policy, setting performance standards and prioritizing implementation steps.
 Action LU-3.3: Work with SamTrans and other public agencies to provide a public mass transit stop accessible to every home and business in San Carlos.  Goal CSH-1: To develop a circulation system that is safe, environmentally-friendly and responsive to the needs of various land uses planned within the City of San Carlos.  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.
 Goal CSH-2: To provide a safe, efficient and aesthetically pleasing circulation network for various transportation modes in addition to the automobile.
 Policy CSH-2.2: Provide for adequate pedestrian and bicycle facilities as viable transportation modes in San Carlos, as recommended in the San Carlos Bicycle and Pedestrian Master Plan.  Policy CSH-2.3: Access to public transportation facilities should be convenient and designed to encourage use of public transit.
 Action CSH-2.2: Continue to support operation of adequate public bus service throughout San Carlos.
 Action CSH-2.3: Support the Peninsula Corridor Joint Powers Board efforts to upgrade and expand the Peninsula rail service. Work with that agency in implementing its plans for local facility improvements.
 Goal CSH-3: Maintain a street and highway system which accommodates future growth while maintaining acceptable levels of service.
 Policy CSH-3.1: Strive to reduce baseline and development-related traffic by implementing and enforcing the Transportation Demand Management Ordinance. 2045 GENERAL PLAN RESET DRAFT EIR

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 Policy CSH-3.2: Support city-wide efforts to reduce vehicular trips within and through the community.
 Policy CSH-3.3: Support the incorporation of Transportation Demand Management measures in new development to reduce traffic impacts.
 Policy CSH-3.4: Support Smart Growth and Sustainability principles to reduce travel time from house to jobs, provide affordable transportation to all members of the community, allow compact mixed-use development and decrease dependency on automobiles.  Policy CSH-3.7: Public sidewalks and walkways shall be designed to accommodate access in accordance with the Americans with Disabilities Act, and including any other applicable State and federal laws, regulations and guidelines, and shall be kept clear of obstruction.  Policy CSH-3.10: The City shall support efforts for a coordinated transportation system and maintaining acceptable levels of traffic with local, regional and Caltrans agencies.  Policy CSH-3.12: The City should preserve its existing alley and pedestrian path systems to the maximum extent feasible.
 Policy CSH-3.14: The City shall support the continued operation and upgrading of the railroad commuter service between Gilroy and San Francisco.
 Policy CSH-3.15: The City supports dedication and preservation of rights-of-way for future transit service along the rail corridor.
 Policy CSH-3.16: The City shall support adequate access to affordable transportation alternatives for people with impaired mobility.
 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.  Action CSH-3.2: The City shall consider adoption of a Transportation Impact Fee for new development to support city-wide Transportation Demand Management measures.  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-3.5: The City shall coordinate with adjacent communities and responsible agencies to provide an interconnected system of pedestrian ways, trails, bikeways and transit routes.  Action CSH-3.8: The City shall support San Mateo City/County Association of Governments (C/CAG) policies on Congestion Management.
 Action CSH-3.9: The City shall support an intra-city (east/west) local shuttle to feed into other forms of local and regional transportation.
 Goal CSH-4: Provide for safe walking and bicycle riding for transportation and recreation.  Action CSH-4.1: Provisions shall be made for bicycle transportation within the city as designated on the San Carlos plan for bicycle routes.
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 Goal CSH-5: Ensure all modes of transportation connect safely and efficiently both within San Carlos and with neighboring jurisdictions.
 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.  Goal CSH-6: Integrate transportation and land use.
 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.
 Action CSH-6.1: Support improved east-west connectivity by providing pedestrian/bicycle under crossings of the Caltrain tracks at intervals, during future track reconstruction, or as developer mitigation.

These goals, policies, and actions provide for the construction of sidewalks and bicycle facilities to improve access of pedestrians and bicyclists to transit services, commercial areas, and other destinations. Due to the built-out nature of the EIR Study Area and recent development trends, it is anticipated that much of projected development would be concentrated within 0.5 miles of the Caltrain Station and/or 0.25 miles of El Camino Real; based on the proximity of future development projects to transit and mixed-use areas, they would be expected to generate transit, pedestrian, and bicycle trips. As a result, the land use pattern associated with the proposed project would be expected to further encourage the use of transit and active transportation modes. Therefore, with respect to conflicts with circulation system policies, the impact of the proposed project would be less than significant.

Significance without Mitigation: Less than significant.

TRAN-2 The proposed project would conflict or be inconsistent with CEQA Guidelines Section 15064.3 (b).

SB 743 established the potential increase in VMT associated with a project as the basis for determining transportation impacts of development projects. Guidance on VMT assessment has been provided by both LCI in the 2018 publication Transportation Impacts (SB 743) CEQA Guidelines Update and Technical Advisory and the City of San Carlos Transportation Significance Criteria adopted by Resolution No. 2024- 118 on November 12, 2024 that establish VMT thresholds.

The analysis of the proposed project’s potential transportation impacts was based on an assessment of applicable policies and a quantitative evaluation of VMT. Project VMT was assessed using the San Carlos 2045 GENERAL PLAN RESET DRAFT EIR

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version of the City/County Association of Governments of San Mateo County-Santa Clara County Valley Transportation Authority Countywide Model. This version includes updates to a 2024 existing year and other planned projects within San Carlos. VMT for the proposed project includes all trip purposes, such as home-based trips, work commute trips, recreational trips, and school-related trips.

Model inputs include households, population, and employment for six different categories. The project’s land use characteristics were entered into the model in the appropriate location at the TAZ level, model runs were completed and relevant VMT results were extracted. VMT metrics were assessed for the proposed project compared to the baseline regional average.

VMT thresholds are defined using the most recent SB 743 VMT Guidelines and thresholds identified in City of San Carlos Transportation Significance Criteria (adopted by Resolution No. 2024-118 on November 12, 2024). These were developed based on recommendations from LCI, dated December 2018. While cities and counties are allowed to develop their own methods, the City of San Carlos has developed an impact criterion that is mostly consistent with LCI recommendations.

Guidance provided by LCI recommends the use of screening thresholds to quickly identify when a project can be expected to result in a less-than-significant impact without conducting a detailed study. The CEQA screening criteria proposed for land use projects in San Carlos are listed below:
 Small Projects
 Low VMT Areas (per City and VMT maps)
 Transit Priority Areas (TPA) – usually within 0.5 mile around an existing major transit corridor with frequencies of 15 minutes or less.
 Affordable Housing – 100 percent restricted affordable residential project in an infill location  Neighborhood-serving retail or public facilities.

While some development projects may screen out based on proximity to transit or other criteria, the proposed project is assessed at a programmatic level and includes all projected development. For future development projects, a more detailed project level VMT analysis may be required to screen out or evaluate VMT based on individual project attributes such as land use, size, or proximity to transit.

The City of San Carlos has opted to compare VMT results to a regional baseline average threshold. Based on these guidelines, any development that does not screen out for a VMT assessment should generate a VMT per service, per capita, and per employee VMT of 15 percent less than the regional average in order to not incur impacts under CEQA and SB 743.

VMT per Service Population
At the aggregate level, Table 4.15-1, VMT Per Service Population, indicates that the proposed project’s overall VMT results generate higher total VMT with the project compared to the 2024 existing baseline.

This is to be expected considering the buildout projections by 2045. Table 4.15-1 also indicates that the proposed project would result in a VMT/service population of 26.51, which exceeds the significance threshold of 23.20 (15 percent below the existing baseline regionwide average) and represents a decrease of approximately 3 percent below the existing regional baseline. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.15-1 VMT PER SERVICE POPULATION
Scenario Households Population Employee Service VMT VMT/Service 15% Below 2024 Existing Conditions
EIR Study Area 13,253 43,164 20,787 1,714,960 26.82
County 272,149 792,983 385,023 34,364,121 29.17
Region 2,767,453 7,750,809 3,850,038 316,943,24 27.32 23.20 2045 Cumulative plus Project
EIR Study Area 21,554 64,781 47,326 2,972,085 26.51
County 332,206 963,942 514,487 43,445,984 29.39
Region 3,432,942 9,697,103 4,753,639 393,579,002 27.24
Note: 15 percent below San Mateo County average VMT = 23.20 per Service Population. Household and employee data do not exactly match Table 3-1, Proposed 2045 General Plan Reset Buildout Projections in the EIR Study Area, due to rounding. Population numbers do not match Table 3-1 due to differences in population assumptions by traffic analysis zone in the C/CAG traffic model.

Source: City/County Association of Governments of San Mateo County Model, Kittelson and Associates, Inc., 2024.

VMT Per Capita
Table 4.15-2, VMT per Capita, indicates that the 2045 General Plan Reset would result in a home-based work VMT per capita of 15.84, which exceeds the significance threshold of 13.71 (15 percent below existing regional baseline) and represents a decrease of approximately 2 percent below the existing regional baseline.

TABLE 4.15-2 VMT PER CAPITA
Scenario Households Population Residential VMT VMT/capita 15% Below 2024 Existing Conditions
EIR Study Area 13,253 43,164 735,863 17.05
County 272,149 792,983 12,743,901 16.07
Region 2,767,453 7,750,809 124,999,697 16.13 13.71
2045 Cumulative plus Project
EIR Study Area 21,554 64,781 1,026,010 15.84
County 332,206 963,942 14,492,305 15.03
Region 3,432,942 9,697,103 156,876,303 16.18
Note: 15 percent below San Mateo County average VMT: 13.71 per capita. Household data do not exactly match Table 3-1, Proposed 2045 General Plan Reset Buildout Projections in the EIR Study Area, due to rounding. Population numbers do not match Table 3-1 due to differences in population assumptions by traffic analysis zone in the C/CAG traffic model.

Source: City/County Association of Governments of San Mateo County Model, Kittelson and Associates, Inc., 2024.

VMT Per Employee
Table 4.15-3, VMT Per Employee, indicates that the proposed 2045 General Plan Reset would result in a home-based work VMT per employee of 18.55, which exceeds the significance threshold of 14.80 (15 percent below the existing regional baseline), and represents an increase of approximately 7 percent above the existing regional baseline.
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TABLE 4.15-3 VMT PER EMPLOYEE
Scenario Households Employees Employee VMT VMT/Employee 15% Below 2024 Existing Conditions
City 13,253 20,787 387,047 18.62
County 272,149 385,023 7,376,675 19.16
Region 2,767,453 3,850,038 66,840,112 17.36 14.80
2045 Cumulative plus Project
City 21,554 47,326 877,892 18.55
County 332,206 514,487 10,356,566 20.13
Region 3,432,942 4,753,639 84,048,418 17.68
Notes: 15 percent below San Mateo County average VMT: 14.8 per employee. Household and employee data do not exactly match Table 3-1, Proposed 2045 General Plan Reset Buildout Projections in the EIR Study Area, due to rounding.

Source: City/County Association of Governments of San Mateo County Model, Kittelson and Associates, Inc., 2024.

Cumulative Conditions
The City’s VMT Guidelines also recommend computing VMT using the “boundary method” for cumulative conditions. The boundary method estimates the sum of all VMT within a specific geographic area. As stated in the City’s VMT Guidelines, Cumulative Conditions provide a long-range view of future travel patterns based on the region’s land use and transportation system projections. Because VMT may fluctuate with population and employment growth, or changes in travel modes, the City Guidelines recommend that any impact analysis should consider the cumulative effects of the proposed project, including other changes, and all other projects. An evaluation of the project’s effect on VMT is a comparison of the total boundary VMT within San Mateo County between Cumulative without Project Conditions and Cumulative plus Project Conditions. Table 4.15-4, County VMT per Employee, indicates that the proposed project increases countywide boundary VMT by 159,008, or 0.7 percent, compared to 2045 conditions without the proposed project.

TABLE 4.15-4 COUNTY VMT PER EMPLOYEE
Scenario Boundary VMT Net Change
2024 Existing Conditions 17,852,477
2045 without Project (General Plan) 22,070,724
2045 plus Project (General Plan Reset) 22,229,732 159,008 (0.7%) Source: City/County Association of Governments of San Mateo County Model, Kittelson and Associates, Inc., 2024.

Findings
As described above, the proposed project would exceed the following thresholds per the City of San Carlos SB 743 VMT Guidelines:
 Total project-generated VMT per service population would exceed a level of 15 percent below the regionwide baseline VMT rate.
 Home-based, project-generated VMT per resident would exceed a level of 15 percent below the regionwide baseline VMT rate.
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 Home-based work, project-generated VMT per employee would exceed a level of 15 percent below the regionwide baseline VMT rate.
 Total (boundary) countywide VMT would exceed Cumulative without Project conditions.

This VMT analysis may be considered conservative at the programmatic level, as the VMT modeling analysis also includes VMT associated with existing land uses, which are not easily separated in the modeling from future land use VMT. Invariably, areawide plans may not be able to achieve baseline targets because of the existing land use VMT. As shown in Tables 4.15-1, 4.15-2, and 4.15-3, for all metrics, the 2045 project VMT would decrease VMT when compared to the 2024 existing VMT per service population, capita, and employee, respectively, in the city. This suggests the projected land uses would perform better than existing land uses by shortening average trip lengths and generally reducing overall VMT per service population, resident, and employee. Also note, while the projected land uses are modeled citywide, many future development sites would be strategically concentrated in key development areas within 0.5 miles of high-quality transit and, therefore, per City VMT guidelines, they could potentially screen out for VMT when assessed at the project level.

As discussed in impact discussion TRAN-1, the Circulation and Scenic Highways (CSH) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to transportation, including TDM. The General Plan goals, policies, and actions listed in impact discussion TRAN-1 related to TDM would serve to minimize potential adverse impacts related to VMT.

Nevertheless, the proposed 2045 General Plan Reset, when assessed at the aggregate programmatic level, could incur VMT impacts under CEQA and result in significant impacts.

Impact TRAN-2: The proposed project could exceed the City’s VMT significance criteria by generating VMT per service population, per capita, and per employee that exceeds a threshold of 15 percent less than the regional average and by increasing total countywide VMT.

Mitigation Measure TRAN-2: The City of San Carlos shall amend its Transportation Demand Management program (San Carlos Municipal Code Chapter 18.25, Transportation Demand Management) to increase the required trip reduction to the extent feasible.

Significance with Mitigation: Significant and unavoidable. With the amendment of the City’s TDM program to include a more stringent trip reduction requirement, the City would reduce vehicle miles traveled from future development projects to the extent deemed feasible by the City. The City has already begun the process of updating its TDM program, as part of the Citywide Transportation Demand Management and Parking Reform Project. However, the City has not yet determined the precise amount by which the trip reduction requirement will be amended. Until such time that the TDM program is amended, this impact remains significant and unavoidable at the programmatic level, and it is unknown if the amended program would be able to achieve a VMT reduction sufficient to reduce this impact to a less-than-significant level. This finding does not preclude future projects from identifying less-than-significant VMT impacts, or from screening out of the City’s detailed VMT analysis requirements.
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TRAN-3 The proposed 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).

Improvements to the transportation and circulation system in the vicinity of future development sites and the EIR Study Area more broadly would be implemented over time. Any such improvements would be designed and constructed to local, regional, and federal standards, and as such, would not be expected to introduce any hazardous design features. Projects that would include the development of new streets, circulation improvements and access points would be reviewed for compliance with safety guidelines and standards as part of the development review process. Safety considerations include maintenance of a substantially clear line of sight at driveways between the driver of a vehicle waiting to enter the through street and the driver of an approaching vehicle.

The Circulation and Scenic Highways (CSH) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to transportation, including design features. The following General Plan goals and policies would also serve to minimize impacts related to design hazards:
 Goal CSH-3: Maintain a street and highway system which accommodates future growth while maintaining acceptable levels of service.
 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.
 Goal CSH-4: Provide for safe walking and bicycle riding for transportation and recreation.  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, and including any other applicable State and federal laws, regulations and guidelines.
 Policy CSH-4.3: The safety of bicyclists, pedestrians, as well as motorists shall be considered in street design wherever possible.

Through compliance with safety guidelines and standards and adherence to the General Plan goals and policies, impacts would be less than significant.

Significance without Mitigation: Less than significant.

TRAN-4 The proposed project would not result in inadequate emergency access.

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required to comply with City and County standards and requirements and would undergo review by public safety officials as part of the approval process. Safety, Fire, and Building Codes would also be required to be adhered to.

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. Additionally, all roadway users must yield the right-ofway to emergency vehicles when using their sirens and lights, the added project-generated traffic would not decrease access for emergency vehicles. Roadway segments that would experience a reduction in vehicular roadway capacity, if any, would undergo individual operations analyses to assess the potential impacts to emergency vehicle access, and mitigation measures would be developed as needed to reduce potentially significant impacts to less than significant levels.

Furthermore, the Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to transportation, including emergency access. The following General Plan goal, policies, and actions would serve to minimize impacts related to emergency access:
 Goal ESPS-3: A resilient San Carlos is well prepared to minimize risks associated with wildfire.  Action ESPS-3.8: When a fire has occurred in the VHFHSZ [Very High Fire Hazard Severity Zone], evaluate if street design and size can be reconfigured to improve emergency access and evacuation efficiency.
 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-3.23: 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 nonconforming roadways, as feasible.
 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.

Compliance with City and County standards and Safety, Fire, and Building Codes, and adherence to the General Plan goal, policies, and actions, emergency access impacts of the proposed project would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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TRAN-5 The proposed project would, in combination with past, present, and reasonably foreseeable projects, result in cumulative transportation impacts in the area.

The impact evaluation described in impact discussions TRANS-1 through TRANS-4 includes discussion on cumulative transportation impacts in the City of San Carlos due to the proposed 2045 General Plan Reset. In addition to the proposed General Plan goals, actions, and policies previously listed, the following General Plan goal and policy would help mitigate cumulative transportation impacts:
 Goal CSH-3: Maintain a street and highway system which accommodates future growth while maintaining acceptable levels of service.
 Policy CSH-3.9: Where appropriate and relevant, based on the location and scope of a development project under consideration, the City shall consider regional, as well as local traffic impacts when assessing new development projects.

Implementation of the proposed 2045 General Plan Reset would not conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. The proposed project would not substantially increase hazards due to a geometric design feature or incompatible uses, nor would it result in inadequate emergency access.

However, implementation of the proposed project would generate VMT per service, per capita, and per employee that exceeds a threshold of 15 percent less than the regional average, as well as increase total countywide VMT. Therefore, the cumulative contribution to regional VMT resulting from implementation of the proposed project is significant and unavoidable. The impact is significant and unavoidable and is identified and discussed in impact discussion TRAN-2.
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4.16 TRIBAL CULTURAL RESOURCES
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to tribal cultural resources (TCR) and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

4.16.1 ENVIRONMENTAL SETTING

REGULATORY FRAMEWORK
Federal Regulations
Archaeological Resources Protection Act
The Archaeological Resources Protection Act (United States Code, Title 16, Sections 470aa–mm) became law on October 31, 1979, and has been amended four times. It regulates the protection of archaeological resources and sites that are on federal and Indian lands.

Native American Graves Protection and Repatriation Act
Native American Graves Protection and Repatriation Act, Title 25, United States Code (1990), defines “cultural items,” “sacred objects,” and “objects of cultural patrimony;” establishes an ownership hierarchy; provides for review; allows excavation of human remains, stipulates return of the remains according to ownership; sets penalties for violations; calls for inventories; and provides for return of specified cultural items.

State Regulations
California Public Resources Code
Archaeological resources are protected pursuant to a wide variety of state policies and regulations enumerated under the California Public Resources Code. Cultural resources are recognized as a nonrenewable resource and therefore receive protection under the California Public Resources Code (PRC) and the California Environmental Quality Act (CEQA).

PRC Sections 5097.9 to 5097.991 provide protection to Native American historical and cultural resources and sacred sites; identify the powers and duties of the Native American Heritage Commission (NAHC); require that descendants be notified when Native American human remains are discovered; and provide for treatment and disposition of human remains and associated grave goods. 2045 GENERAL PLAN RESET DRAFT EIR

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California Health and Safety Code
The discovery of human remains is regulated by California Health and Safety Code Section 7050.5, which states that:

In the event of discovery or recognition of any human remains in any location other than a dedicated cemetery, there shall be no further excavation…until the coroner…has determined…that the remains are not subject to…provisions of law concerning investigation of the circumstances, manner and cause of any death, and the recommendations concerning the treatment and disposition of the human remains have been made to the person responsible…. The coroner shall make his or her determination within two working days from the time the person responsible for the excavation, or his or her authorized representative, notifies the coroner of the discovery or recognition of the human remains. If the coroner determines that the remains are not subject to his or her authority and…has reason to believe that they are those of a Native American, he or she shall contact, by telephone within 24 hours, the Native American Heritage Commission.1 California Senate Bill 18
California Government Code Section 65352.3-5, formerly known as Senate Bill (SB) 18, states that prior to the adoption or amendment of a city or county’s general plan, or specific plans, the city or county shall consult with California Native American tribes that are on the contact list maintained by the NAHC.

The intent of this legislation is to preserve or mitigate impacts on places, features, and objects, as defined in PRC 5097.9 and PRC 5097.993, that are within the city or county’s jurisdiction. The bill also states that the city or county shall protect the confidentiality of information concerning the specific identity, location, character, and use of those places, features, and objects identified by Native American consultation. Government Code 65362.3-5 applies to all general and specific plans and amendments proposed after March 1, 2005.

Assembly Bill 52
Assembly Bill (AB) 52, the Native American Historic Resource Protection Act, sets forth a proactive approach intended to reduce the potential for delay and conflicts between Native American and development interests. Projects subject to AB 52 are those that file a notice of preparation for an EIR or notice of intent to adopt a negative or mitigated negative declaration on or after July 1, 2016. AB 52 adds TCRs to the specific cultural resources protected under CEQA. Under AB 52, a TCR is defined as a site, feature, place, cultural landscape (must be geographically defined in terms of size and scope), sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register or included in a local register of historical resources. A Native American Tribe or the lead agency, supported by substantial evidence, may choose at its discretion to 1 California Health and Safety Code, Division 7, Dead Bodies, Part 1, General Provisions, Chapter 2, General Provisions, Section 7050.5(b),
https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=7.&title=&part=1.&chapter=2.&articl e=. accessed August 18, 2022.
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treat a resource as a TCR. AB 52 also mandates lead agencies to consult with tribes, if requested by the tribe, and sets the principles for conducting and concluding consultation.

Government Code Section 65092
When there is a public hearing, a notice will be sent 10 days in advance to any Native American tribes who are on the contact list and filed a written request for notice. The contact list is maintained by the Native American Heritage Commission.

EXISTING CONDITIONS
The first known inhabitants of San Carlos were the Ohlone Indians.2 Ohlone is the name that has been given to the many related groups of Native Americans living along the coast between Monterey and San Francisco.

A sacred lands file search conducted by the NAHC for the project area identified sacred lands in the EIR Study Area. The NAHC identified thirteen local Native American representatives from the following seven tribes as potentially having local knowledge:
 Amah Mutsun Tribal Band
 Amah Mutsun Tribal Band of Mission San Juan Bautista
 Costanoan Rumsen Carmel Tribe
 Indian Canyon Mutsun Band of Costanoan
 Muwekma Ohlone Indian Tribe of the SF Bay Area
 The Ohlone Indian Tribe
 Wuksache Indian Tribe/Eshom Valley Band
The City notified all thirteen tribal representatives about the proposed project on July 3, 2024, and asked for information about potential resources at or near the EIR Study Area.

The Costanoan Rumsen Carmel Tribe responded requesting consultation and had a meeting on September 25th, 2024 with the City of San Carlos. During the consultation, the Costanoan Rumsen Carmel Tribe recommended that indigenous people be on-site during development processes, that cultural sensitivity trainings be conducted, and that a discovery clause be added when remains are discovered.
2 City of San Carlos, 2024 (accessed), About San Carlos, https://www.cityofsancarlos.org/community/about_san_carlos.php#collapse630b1, accessed on September 30, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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The Ohlone Indian Tribe was notified of the project and the City invited the tribe to participate in consultation, but no consultation occurred. However, the Ohlone Indian Tribe requested that a tribal member be on the project from beginning to end.

On behalf of the Indian Canyon Band of Costanoan Ohlone People, Kanyon Konsulting responded and the City invited the tribe to participate in consultation but no consultation occurred. However, Kanyon Konsulting requested that a Native American Monitor and an Archaeologist be present on-site at all times during any/all ground disturbing activities.

4.16.2 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant TCR impact if it would:

TCR-1 Would the project cause a substantial adverse change in the significance of a TCR, defined in Public Resources Code Section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is: i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k), or ii) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

TCR-2 In combination with past, present, and reasonably foreseeable projects, result in cumulative TCR impacts in the area.

4.16.3 IMPACT DISCUSSION
TCR-1 The proposed project would not cause a substantial adverse change in the significance of a TCR.

As previously described in Section 4.16.1.1, Regulatory Framework, a TCR is defined under AB 52 as a site, feature, place, cultural landscape that is geographically defined in terms of size and scope, sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register or included in a local register of historical resources, or if the City of San Carlos, acting as the lead agency, supported by substantial evidence, chooses at its discretion to treat the resource as a TCR.

In response to the Notice of Preparation for this Draft EIR, the NAHC recommended that an archeological records search be conducted for the EIR Study Area. Because the estimated timing and location of future development is not known at this time, it is unknown if archeological resources would be affected.

Impacts from future development in the EIR Study Area could impact unknown archaeological resources, including Native American artifacts and human remains. As discussed above under Section 4.16.1.2, 2045 GENERAL PLAN RESET DRAFT EIR

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Existing Conditions, the sacred lands file search conducted by the NAHC for the project area did identify sacred lands within the EIR Area. The Costanoan Rumsen Carmel Tribe was the only tribe to participate in consultation with the City. The tribe recommended that indigenous people be on-site during the development processes, cultural sensitivity trainings be conducted, and that a discovery clause be added when remains are discovered.

The Land Use (LU) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to TCRs. The following General Plan goal, policies, and actions would serve to minimize potential adverse impacts on TCRs:
 Goal LU-12: Protect San Carlos’ historic and cultural resources to maintain and enhance a unique sense of place.
 Policy LU-12.1: Evaluate historical, cultural, and tribal cultural resources early in the development review process through consultation with interested parties.  Policy LU-12.2: Foster the preservation, restoration and compatible reuse of architecturally and/or historically significant structures and sites.
 Policy LU-12.5: Treat with respect and dignity any human remains discovered during implementation of public and private projects within the city and fully comply with the California Native American Graves Protection and Repatriation Act and other appropriate laws.  Action LU-12.1: Ensure thorough compliance with the provisions of the California Environmental Quality Act (CEQA) relating to potential impacts to cultural, historical, and tribal cultural resources.
 Action LU-12.6: The City of San Carlos shall develop mapping to indicate areas in the City with archaeological sensitivity and guidance documentation for public and private construction projects that involve ground disturbance activities in areas with archaeological sensitivity. The requirements may include 1) an archeological records search, 2) construction training for cultural sensitivity, and 3) procedures if archaeologic resources are discovered.

Compliance with existing federal, State, and local regulations and the General Plan goal, policies, and actions listed above would protect unrecorded TCRs in the EIR Study Area by providing for the early detection of potential conflicts between development and resource protection, and by preventing or minimizing the material impairment of the ability of archaeological deposits to convey their significance through excavation or preservation. Impacts would therefore be less than significant.

Significance without Mitigation: Less than significant.

TCR-2 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in cumulative TCR impacts in the area.

Cumulative impacts to TCRs occur when a series of actions leads to adverse effects on local Native American tribes or tribal lands. While TCRs have been identified in the EIR Study Area, future AB 52 2045 GENERAL PLAN RESET DRAFT EIR

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consultations with Native American tribes to identify TCRs would be required for projects that have the potential to cause significant impacts to TCRs.

As discussed in Chapter 4.4, Cultural Resources, of this Draft EIR, the proposed project would comply with federal and State laws protecting cultural resources. Compliance with existing federal, State, and local regulations and the General Plan goals, policies, and actions would ensure that TCRs, if discovered on future development project sites, are protected and handled appropriately. Therefore, cumulative impacts to TCRs would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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4.17 UTILITIES AND SERVICE SYSTEMS
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to aesthetics, and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

Stormwater, as it relates to both water quality and watersheds, is addressed in Chapter 4.9, Hydrology and Water Quality, of this Draft EIR.

4.17.1 WATER
The EIR Study Area is served by three water providers: California Water Service Mid-Peninsula District (Cal Water-MPS), Mid-Peninsula Water District (MPWD), and the City of Redwood City. Cal Water-MPS provides water service for most of the EIR Study Area, while MPWD provides water to a small northern portion of the City between El Camino Real and Highway 101. There is another small southern portion within the EIR Study Area northwest of the intersection of Edgewood Road and Alameda de las Pulgas that is provided with potable water by the City of Redwood City. However, this small area is developed with residential properties and there is no anticipated future growth in this area within the buildout of the proposed project. Therefore, the analysis provided below focuses on Cal Water-MPS and MPWD.

ENVIRONMENTAL SETTING
Regulatory Framework
Federal Regulations
Federal Safe Drinking Water Act
The Safe Drinking Water Act, the principal federal law intended to ensure safe drinking water to the public, was enacted in 1974 and has been amended several times since it came into law. The Act authorizes the United States Environmental Protection Agency (USEPA) to set national standards for drinking water, called the National Primary Drinking Water Regulations, to protect against both naturally occurring and human-made contaminants. These standards set enforceable maximum contaminant levels in drinking water and require all water providers in the United States to treat water to remove contaminants, except for private wells serving fewer than 25 people. In California, the State Water Resources Control Board (SWRCB) Division of Drinking Water regulates public drinking water systems. If a water system does not meet standards, it is the water supplier’s responsibility to notify its customers.

America’s Water Infrastructure Act of 2018
America's Water Infrastructure Act was signed into law on October 23, 2018, and authorizes federal funding for water infrastructure projects; expands water storage capabilities; assists local communities in complying with the Safe Drinking Water Act and Clean Water Act (CWA); reduces flooding risks for rural, 2045 GENERAL PLAN RESET DRAFT EIR

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western, and coastal communities; and addresses significant water infrastructure needs in tribal communities.
1 Additionally, the act requires that drinking water systems that serve more than 3,300 people develop or update risk assessments and emergency response plans. Risk assessments and emergency response plans must be certified by the USEPA within the deadline specified by the act.

State Regulations
Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Act (Water Code Sections 13000 et seq.) was passed in 1969 and amended in 2013. It is the basic water quality control law for California. Under this act, the SWRCB has authority over State water rights and water quality policy. The act divided the state into nine regional basins, each under the jurisdiction of a Regional Water Quality Control Board (RWQCB), to oversee water quality on a day-to-day basis at the local and regional levels. RWQCBs engage in various water quality functions in their respective regions and regulate all pollutant or nuisance discharges that may affect either surface water or groundwater.

Urban Water Management Planning Act (Senate Bills 610 and 221) The California Urban Water Management Planning Act and Section 10620 of the Water Code require that all urban water suppliers in California that provide water to more than 3,000 customers or supply more than 3,000 acre-feet per year (AFY)2 to prepare and adopt an Urban Water Management Plan (UWMP) and update it every five years. The act is intended to support efficient use of urban water supplies. It requires the UWMP to compare water supply and demand over the next 20 years for normal years, single dry years, and multiple dry years and to determine current and potential recycled water uses.

Senate Bill (SB) 610 and SB 221 were enacted to 1) ensure better coordination between local water supply and land use decisions and 2) confirm that there is an adequate water supply for new development. The following projects that are subject to the California Environmental Quality Act (CEQA) are required at a minimum to prepare a Water Supply Assessment (WSA):
 Residential developments consisting of more than 500 dwelling units.  Shopping centers or business establishments employing more than 1,000 persons or having more than 500,000 square feet of floor space.
 Commercial office building employing more than 1,000 persons or having more than 250,000 square feet of floor space.
 Hotel or motel, or both, having more than 500 rooms.
 Industrial, manufacturing, or processing plant or industrial park planned to employ more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area.
1 John Barasso, 2018, Congress Passes America’s Water Infrastructure Act, https://www.barrasso.senate.gov/public/ index.cfm/2018/10/congress-passes-america-s-water-infrastructure-act, accessed October 25, 2024. 2 One acre-foot is the amount of water required to cover one acre of ground (43,560 square feet) to a depth of one foot. 2045 GENERAL PLAN RESET DRAFT EIR

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 Mixed-use project that includes one or more of the projects specified above.  Project that would demand an amount of water equivalent to, or greater than, the amount of water required for 500 dwelling units.

SB 221 requires written verification that there is sufficient water supply available for new residential subdivisions that include over 500 dwelling units. The verification must be provided before commencement of construction for the project.

Sustainable Groundwater Management Act of 2014
On September 16, 2014, a three-bill legislative package was signed into law collectively known as the Sustainable Groundwater Management Act (SGMA). The Governor’s signing message states “a central feature of these bills is the recognition that groundwater management in California is best accomplished locally.” Under the roadmap laid out by the legislation, local and regional authorities in medium and high priority groundwater basins must form groundwater sustainability agencies (GSAs) that oversee the preparation and implementation of groundwater sustainability plans (GSPs).

Water Conservation Act of 2009 (Senate Bill X7 7)
New mandatory requirements for increasing water use efficiency, per State law (SB-X7 7), mandate the reduction of per capita water use and agricultural water use throughout the State by 20 percent by 2020.

Effective in 2016, urban retail water suppliers who do not meet the water conservation requirements established by this bill are not eligible for State water grants or loans. SB X7-7 requires that urban water retail suppliers determine baseline water use and set reduction targets according to specified standards.

Demonstration of compliance with this regulation is a required component of each water provider’s 2020 UWMP. Both Cal Water-MPS and MPWD are in compliance with their target reductions. 2018 Water Conservation Legislation
In 2018, the California Legislature enacted two policy bills (SB 606 and Assembly Bill [AB] 1668) to establish long-term improvements in water conservation and drought planning to adapt to climate change and longer and more intense droughts in California.3 The framework applies to both urban and agricultural water use. The Department of Water Resources and the SWRCB were tasked with establishing new water use efficiency standards for:
 Indoor residential water use
 Outdoor residential water use
 Commercial, industrial, and institutional water use for landscape irrigation with dedicated meters  Water loss
Urban water suppliers are required to stay within annual water budgets based on their standards for their service areas, and to calculate and report their urban water use objectives in an annual water use 3 California Department of Water Resources, 2024, 2018 Water Conservation Legislation, https://water.ca.gov/Programs/ Water-Use-And-Efficiency/2018-Water-Conservation-Legislation, accessed October 25, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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report. The indoor residential water use standard was established with the passage of SB 1157 in 2022.

As a result, the California Water Code defines a 55-gallon-per-person daily standard for indoor residential use until 2025, at which time it decreases to 47 gallons, and further decreases to 42 gallons by 2030.

The outdoor residential and commercial water use standards are established as landscape efficiency factors (LEFs) and become progressively more efficient over time, with an LEF for residential and commercial account of 0.80 until 2035, at which time it decreases to 0.63 until 2040, and then establishes a LEF for residential outdoor accounts of 0.55 and a LEF for commercial outdoor accounts of

0.45 after 2040. The water loss standard is the maximum allowable “real” water loss measured in gallons per connection per day for each water purveyor’s service area. Real losses are defined as the volume of annual leakage from the water purveyor’s distribution system.

Collectively the water use efficiency standards and local service area characteristics (such as population and landscape area) establish the Urban Water Use Objectives (UWUOs) per urban retail water supplier that cannot be exceeded on an annual basis. Urban retail water suppliers are required to calculate and report their UWUOs alongside their actual usage in an annual report. The first reports were due to the SWRCB on January 1, 2024 and are required to be submitted every January 1 thereafter. The final proposed “Making Conservation a California Way of Life” regulation was published by the SWRCB on July 26, 2024 and is expected to become effective in April 2025.

The legislation also includes changes to UWMP preparation requirements. These changes include additional requirements for Water Shortage Contingency Plans (WSCPs), expansion of dry year supply reliability assessments to a five-year drought period, and establishment of annual drought risk assessment procedures and reporting.

Water Conservation in Landscaping Act of 2006
The Water Conservation in Landscaping Act (AB 1881) requires cities and counties to adopt the State of California’s Model Water Efficient Landscape Ordinance (MWELO) or a comparable landscape water conservation ordinance that is at least as effective as the State’s MWELO in conserving water. 4 The MWELO was revised in July 2015 via Executive Order B-29-15 to address the ongoing drought and to build resiliency for future droughts. The 2015 revisions to the MWELO increased water efficiency standards for new and retrofitted landscapes through more efficient irrigation systems, greywater usage, and on-site stormwater capture and by limiting the portion of landscapes that can be covered in turf.

Each city and county is required to submit annual reports to DWR that document how the agency is achieving compliance with the State MWELO and how many projects were subject to the ordinance during the annual reporting period. Recently, MWELO went through a round of revisions in 2024 to reduce ambiguity and improve clarity of the requirements as well as reorganize the content to better adhere to the landscape design process. The 2024 revisions did not modify or add new requirements to MWELO.
4 California Legislative Information, 2006, Assembly Bill No. 1881, https://leginfo.legislature.ca.gov/faces/ billTextClient.xhtml?bill_id=200520060AB1881, accessed October 25, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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California Building Code: CALGreen
The California Building Standards Commission adopted the nation’s first green building standards in July 2008, the California Green Building Standards Code, also known as CALGreen. CALGreen applies to the planning, design, operation, construction, use, and occupancy of every newly constructed building or structure in California. The code establishes planning and design standards for sustainable site development, including water efficiency and water conservation measures that typically reduce water consumption by 20 percent. CALGreen is updated every three years to allow for consideration and possible incorporation of new low flow plumbing fixtures and water efficient appliances. The mandatory provisions of CALGreen became effective January 1, 2011, and the latest version, the 2022 California Green Building Standards Code, became effective on January 1, 2023.5 The building efficiency standards are enforced through the local building permit process.

California Plumbing Code
The latest version of the California Plumbing Code was issued in 2022 and became effective as of January 1, 2023. is updated on a three-year cycle. It specifies technical standards for the design, materials, workmanship, and maintenance of plumbing systems. One of the purposes of the plumbing code is to prevent conflicting plumbing codes within local jurisdictions. Among many topics covered in the code are water fixtures, potable and non-potable water systems, and recycled water systems.

California Water Code
The California Water Code states that the water resources of the State must be put to beneficial use and that waste or unreasonable use of water should be prevented. The code is divided into several sections that include provisions regarding water quality, formation of irrigation districts and water districts, safe drinking water, and water supply and infrastructure improvements.

Mandatory Water Conservation
Following the declaration of a state of emergency on July 15, 2014, due to drought conditions, the SWRCB adopted Resolution No. 2014-0038 for emergency regulation of Statewide water conservation efforts.
6 These regulations, which went into effect on August 1, 2014, were intended to reduce outdoor urban water use and persuade all California households to voluntarily reduce their water consumption by 20 percent. Urban water suppliers with 3,000 or more service connections were required to report monthly water consumption to the SWRCB.

In January of 2022, following the Governor’s proclamation of a drought state of emergency for all counties, the SWRCB adopted the prohibited wasteful water uses emergency regulations. These include 5 Department of General Services, 2024, CALGreen, https://www.dgs.ca.gov/BSC/CALGreen#codes, accessed October 25, 2024.
6 Water Resources Control Board, 2014, Resolution No. 2014-0038, https://www.waterboards.ca.gov/board_decisions/adopted_orders/resolutions/2014/rs2014_0038_regs.pdf, accessed October 25, 2024.
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the prohibition of the following wasteful water use practices: 1) the application of potable water to outdoor landscapes in a manner that causes excess runoff; 2) the washing of vehicles without an automatic shut-off nozzle; 3) the application of potable water to driveways and sidewalks; 4) the use of potable water in nonrecirculating ornamental fountains; and 5) the application of potable water to outdoor landscapes during and within 48 hours after at least 0.25 inch of rainfall. In June of 2022 additional emergency water conservation regulations were enacted prohibiting the irrigation of nonfunctional turf at commercial, industrial, and institutional accounts, and the implementation of conservation actions under Level 2 of urban water suppliers’ WSCPs. As of June 5, 2024, the emergency regulations expired.

In October of 2023, AB 1572 was signed into law by the Governor, prohibiting the irrigation of nonfunctional turf at commercial, industrial, and institutional sites (with exceptions for areas irrigated with recycled water or harvested rainwater). The irrigation prohibitions become effective in stages between 2027 and 2031, beginning with state and local government facilities. Under the law, urban water suppliers must adopt the same irrigation prohibitions into their local regulations.

Regional Regulations
Cal Water-Mid-Peninsula District: Urban Water Management Plan Cal Water-MPS serves the Cities of San Carlos and San Mateo and adjacent unincorporated areas of San Mateo County, including the Highlands and Palomar Park. Cal Water-MPS adopted its current 2020 UWMP in June 2021 in compliance with the Urban Water Management Planning Act, the Water Conservation Act of 2009, and Sections 10610 to 10656 of the California Water Code. 7 All urban water
suppliers are required to prepare, adopt, and file a UWMP with DWR every five years.

The Water Conservation Act of 2009, also known as SBX7-7, requires that urban water suppliers reduce per capita water use by 20 percent by 2020. As reported in the UWMP, Cal Water-MPS met this goal in 2020 with a per capita water demand of 95 gallons per capita per day (gpcd) as compared to the target goal of 124 gpcd.8
The 2020 UWMP describes water demands, water supply sources, and supply reliability for its service area in five-year increments for normal years, single dry years, and multiple dry years. The UWMP also provides water supply contingency planning in case of shortage emergencies, demand management measures to increase water use efficiency, and current and planned water conservation efforts. The UWMP states that there will be sufficient supplies to meet existing and future demands through 2045 for normal years, but that there could be a shortage of water supplies in single-dry years and multiple-dry years with implementation of the Bay-Delta Plan.
7 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District. 8 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District. 2045 GENERAL PLAN RESET DRAFT EIR

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Cal Water-Mid-Peninsula District: Water Supply Planning Documents Cal Water-MPS uses a series of integrated planning processes and reports to support water resource and environmental sustainability efforts and updates them on a recurring basis to adjust to changing conditions and risks and ensure that there are sufficient water supplies for their customers. Pertinent plans and studies developed by Cal Water-MPS are summarized below:
 Climate Change Study. This study consists of two parts: Phase 1, Water Resources Monitoring and Adaptation Plan, and Phase 2, Climate Change Risk Assessment and Adaptation Framework. These studies analyze climate-related vulnerabilities in Cal Water-MPS service areas, facilities, operations, and water supply portfolios. The results indicate how risks may change over time based on vulnerabilities, such as sea level rise and wildfires, and provide a framework for future mitigation and adaptation planning.
 Water Supply and Demand Assessment. This document is an annual report submitted to DWR that requires each urban water supplier to prepare an annual assessment and an annual shortage report that evaluates the near-term water supply reliability and describes actions that are taken to address potential shortages, including implementation of the WSCP.  Urban Water Management Plans. UWMPs are completed every five years and provide critical information for the Cal Water-MPS service area, including historical and projected water demands, water supplies, supply reliability, potential vulnerabilities, water shortage contingency planning, and demand management programs.
 Water Shortage Contingency Plans. The WSCP is included as an appendix to the UWMP and is updated every five years. The plan outlines appropriate responses during water supply shortages and interruptions to protect health and safety, minimize economic disruption, and present environmental and community assets.
 Conservation Master Plans. These plans are also included as an appendix to the UWMP and updated on a five-year cycle. The plans summarize the mix of conservation measures that Cal WaterMPS plans to implement, including the estimated water savings, costs, and effects on water demand, as well as progress toward reaching its conservation goals.  Water Supply Reliability Plans/Studies. These plans and studies evaluate the reliability of existing regional water supplies and assess supply and demand options to enhance future reliability. The reports also contain water supply project recommendations for facilities planning processes.  Water Supply and Facilities Master Plans. Based on the water supply strategies, these plans forecast potential infrastructure needs and support long-term operational reliability.

Cal Water -Mid-Peninsula District: Water Shortage Contingency Plan The Cal Water-MPS 2020 UWMP includes the WSCP which outlines stages of response to water shortages caused by drought or supply interruptions.9 The primary objective of the WSCP is to ensure 9 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District, Appendix L: Water Shortage Contingency Plan.
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that the District has in place the necessary resources and management responses to protect health, minimize economic disruption, and preserve environmental and community assets during water supply shortages and interruptions.

Water shortage levels range from 1 to 6, with goals to reduce water demand by 10 percent to over 50 percent, respectively. Stage 1 measures include: 1) limiting landscape irrigation to specific times, 2) prohibit the application of potable water to outdoor landscapes within 48 hours of measurable rainfall, 3) restaurants may only serve water upon request, and 4) prohibit the use of potable water for decorative water features that do not recirculate water. Stage 5, designated as an emergency shortage, requires net zero demand increase on new water service connections and prohibits single-pass cooling systems. Stage 6, which is classified as an extreme shortage, enacts a moratorium on new water service connections and prohibits all landscape irrigation.

Cal Water – Development Offset Program
In 2021, Cal Water began implementation of a Development Offset Program for the three Peninsula Districts which rely on SFPUC supplies, which includes Cal Water-MPS that serves San Carlos. The purpose of the program is to ensure that there is enough water at all times to meet the basic needs of the communities and increase drought resiliency. The program requires any new residential, commercial, or industrial development that is projected to increase demand by more than 50 AFY to pay a special facilities fee, referred to as a developer offset fee, consisting of $15,400 per AF of net demand increase to offset its net increase in water demand. The net demand increase is defined as the project’s projected water demand minus the existing water demand, onsite credits (if available), and/or alternative sources of water supply. Alternative sources may include but are not limited to: 1) reused graywater, 2) reused blackwater, 3) reused mixed gray/blackwater, 4) captured rainwater/stormwater, and 5) air conditioning condensate.

The offset amount is determined using a detailed projection of total annual water demand resulting from the proposed development, excluding temporary demands for landscape establishment. The applicant may choose to comply by 1) paying Cal Water-MPS the required offset amount calculated according to the Policy, and/or 2) conducting other activities as defined in the Policy. Cal Water-MPS will verify compliance with the Policy (i.e., ensure that all payments for offsets and/or conservation offset measures are completed prior to establishing a water connection.

Mid-Peninsula Water District: Urban Water Management Plan The MPWD is the water purveyor for the City of Belmont and portions of the City of San Carlos, Redwood City and parts of unincorporated San Mateo County. MPWD adopted its current 2020 UWMP in September 2021 in compliance with the Urban Water Management Planning Act, the Water Conservation Act of 2009, and Sections 10610 to 10656 of the California Water Code. 10 All urban water
suppliers are required to prepare, adopt, and file a UWMP with DWR every five years. 10 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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The Water Conservation Act of 2009, also known as SBX7-7, requires that urban water suppliers reduce per capita water use by 20 percent by 2020. As reported in the UWMP, MPWD met this goal in 2020 with a per capita water demand of 97 gallons per capita per day (gpcd) as compared to the target goal of 121 gpcd.11
The 2020 UWMP describes water demands, water supply sources, and supply reliability for its service area in five-year increments for normal years, single dry years, and multiple dry years. The UWMP also provides water supply contingency planning in case of shortage emergencies, demand management measures to increase water use efficiency, and current and planned water conservation efforts. The UWMP states that there will be sufficient supplies to meet existing and future demands through 2045 for normal years, but that there could be a shortage of water supplies in single-dry years and multiple-dry years with adoption of the Bay Delta Plan Amendment. MPWD is currently updating its UWMP with a projected completion date of July 2026.

Mid-Peninsula Water District: Water Shortage Contingency Plan The MPWD 2020 UWMP includes the WSCP which outlines stages of response to water shortages caused by drought or supply interruptions.12 The primary objective of the WSCP is to ensure that the District has in place the necessary resources and management responses to protect health, minimize economic disruption, and preserve environmental and community assets during water supply shortages and interruptions.

Water shortage levels range from 1 to 6, with goals to reduce water demand by 10 percent to over 50 percent, respectively. Level 1 measures include: 1) limiting landscape irrigation to specific times, 2) all nonessential water use for public entities should cease, 3) restaurants may only serve water upon request, and 4) new irrigation systems must be equipped with rain sensors that shut off the system when it rains. Stage 5, designated as an emergency shortage, requires net zero demand increase on new water service connections and all landscape irrigation is prohibited. During Stage 6, which is classified as an extreme shortage, MPWD may discontinue service to consumers violating conservation provisions, prohibit decorative turf on all new construction, require removal and replacement of all decorative turf with drought-tolerant planting upon the sale of property.

Mid-Peninsula Water District: Water Efficient Landscape Ordinance MPWD adopted a Water Efficient Landscape Ordinance (WELO) Ordinance (No. 115) in 2015.13 MPWD requires completion of a water efficient landscape application for any new construction with 500 square feet or more of landscape, or rehabilitated landscape of 1,000 square feet or more that requires a 11 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan. 12 Mid-Peninsula Water District, September 2021, 2020 Water Shortage Contingency Plan. 13 Mid-Peninsula Water District, 2024, MPWD Legislation, https://www.midpeninsulawater.org/legislation, October 25, 2024.
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building permit, plan check, or design review. In coordination with the City, MPWD reviews landscape plans to verify compliance with the code requirements.14 Bay Delta Plan Amendment
The reliability of water supplies for Cal Water-MPS and MPWD is impacted if and when the Bay Delta Amendment is enacted, because the sole source of their water supplies is from the San Francisco Public Utilities Commission (SFPUC)’s Regional Water System (RWS). In December 2018, the SWRCB adopted amendments to the Water Quality Control Plan for the San Francisco Bay/Sacramento-San Joaquin Delta Estuary, known as the Bay-Delta Plan Amendment, to establish water quality objectives to maintain the health of the Bay-Delta ecosystem and increasing salmonid populations. The Bay-Delta Amendments requires the release of 30 to 50 percent of “unimpaired flow” for three San Joaquin River tributaries (the Stanislaus, Merced, and Tuolumne Rivers) from February through June during normal years and drought conditions.

If the Bay-Delta Plan Amendment is implemented, the SFPUC would be able to meet projected water demands for their retail customers in normal years but would experience supply shortages in single dry years and multiple dry years. This impacts the water supplies of both Cal Water-MPS and MPWD, as documented in their 2020 UWMPs for single dry years and multiple dry years. The SFPUC has initiated an Alternative Water Supply Planning Program to meet its retail and wholesale customer needs and limit rationing to a maximum of 20 percent system wide.

Since adoption of the Bay-Delta Plan Amendment, over a dozen lawsuits have been filed, in both State and federal courts, challenging the SWRCB’s adoption of the amendment. This litigation is in the early stages and there have been no court rulings as of this date. SFPUC is also in negotiations with the SWRCB to provide an “alternative” for a future amendment to the Bay-Delta Plan. Nevertheless, the Cal WaterMPS and MPWD 2020 UWMPs conservatively assume that the Bay-Delta Plan would be implemented in quantifying future water supplies and reliability.

San Francisco Public Utilities Commission Water System Improvement Plan The SFPUC’s Water System Improvement Plan is expected to mitigate the impacts of the Bay Delta Plan Amendment by undertaking a number of water supply projects to meet dry year demands with no greater than 20 percent system-wide rationing. These projects include the following:
 Calaveras Dam Replacement Project. The SFPUC constructed a new dam of equal height downstream of the existing dam to address seismic vulnerabilities. The project was completed in 2019.
 Alameda Creek Recapture Project. As part of the regulatory requirements, the SFPUC must implement bypass and instream flow releases for Alameda Creek. This project will recapture a portion of the water yield lost by these restrictions and return this yield to the RWS through facilities 14 Mid-Peninsula Water District, 2024, MPWD Water Efficient Landscape Ordinance (WELO), https://www.midpeninsulawater.org/article-details.php?id=71, accessed October 25, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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in Sunol Valley. Water that infiltrates from Alameda Creek will be recaptures into an existing quarry pond and pumped to the Sunol Valley Water Treatment Plant or to San Antonio Reservoir.  Lower Crystal Springs Dam Improvements. Improvements to Lower Crystal Springs Dam and the joint San Mateo/SFPUC Bridge Replacement Project have been completed so that the reservoir elevation can now be raised. However, the raising of the reservoir elevation is being delayed with the discovery of the endangered species, the Fountain Thistle. New plant populations must be restored before the reservoir elevation is raised.
 Regional Groundwater Storage and Recovery Project. SFPUC, Cal Water, Daly City, and San Bruno entered into a strategic partnership to conjunctively operate the south Westside Groundwater Basin.

During years of normal or heavy rainfall, the project provides additional surface water to the partner agencies in San Mateo County in lieu of groundwater pumping. Reduced pumping results in water storage through natural recharge of up to 20 billion gallons of new supply that is available during dry years. All phases of work have been completed, including Phase I, which consisted of the construction of 13 wells, and Phase 2 which involved three additional groundwater test wells and completion of the South San Francisco Main well and pipeline.

San Francisco Public Utilities Commission Alternative Water Supply Program The SFPUC is also exploring other projects that would increase overall water resilience through implementation of the Alternative Water Supply (AWS) Program. The AWS Program identifies a future water supply gap in dry years, both to meet existing and potential obligations to its customers, and to meet future customer demands. The future water supply gap is characterized as between 92 million gallons per day (MGD) to meet 2045 customer demands to 122 MGD to meet obligations. Based on SFPUC’s rationing policy, rationing could fill approximately 12 percent of the water supply gap. The remaining gap would need to be address through the development of new regional alternative water supply projects. Some of the projects include:
 Daly City Recycled Water Expansion would replace some of the groundwater pumping by using recycled water for irrigation customers, enhancing the reliability of the groundwater basin and providing in-lieu groundwater recharge that can be used in dry years.  PureWater Peninsula would treat wastewater effluent from the City of San Mateo and Silicon Valley Clean Water to drinking water standards at a new advanced water treatment plant, The purified water would be stored in Crystal Springs Reservoir where it would be blended with other RWS supplies
 ACWD-USD Purified Water would treat wastewater effluent from Union Sanitary District to drinking water standards at a new advanced water treatment plant and deliver the purified water to Alameda County Water District’s groundwater basin for recharge. The water can be extracted and treated again for use in dry years.
 South Bay Purified Water would treat wastewater effluent from the Regional Wastewater Facility in San Jose to drinking water standards at a new advanced water treatment plant. The new supply would be treated to new DPR regulations for distribution. While the project may produce water in all years for the region, the RWS is only expected to receive water in dry years. 2045 GENERAL PLAN RESET DRAFT EIR

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 Calaveras Reservoir Expansion Project would add additional storage to the reservoir to store excess RWS supplies or other source water during wet/normal years.  Groundwater Banking in the Modesto Irrigation District and Turlock Irrigation District service areas could be used to provide additional water supply to meet instream releases in dry years thus reducing water supply impacts to the SFPUC service area.

City of San Carlos Municipal Code
The San Carlos Municipal Code (SCMC) is the primary document that regulates the policies and practices of the City. The SCMC contains the Zoning Code, the Subdivision Ordinance, the Building and Construction Code, and other titles that are important in implementing the goals, policies, and actions of the General Plan. The SCMC includes various directives pertaining to water as follows:
 Chapter 8.60.120, Model Water Efficient Landscaping Ordinance Requirements, describes the MWELO requirements for anyone requiring a building or planning permit, plan check, or landscape design review for new construction with a landscape area greater than 500 square feet or rehabilitated existing landscape with a total landscape area greater than 2,500 square feet.  Chapter 15.04.070, Title 24, Part 5, California Plumbing Code with appendices, adopts the latest plumbing code for new construction.
 Chapter 15.04.125, Title 24, Part 11, California Green Building Standards Code (CALGreen), establishes CALGreen’s energy and water efficiency mandatory measures for new residential construction.
 Chapter 18.18.080, Water Efficient Landscaping, establishes water-efficient landscape and irrigation guidelines to promote the conservation and efficient use of water and minimize runoff with the use of automatic control systems. The SCMC requires the estimated total water use of a proposed landscaping not to exceed the maximum applied water allowance.

Existing Conditions
Most of the EIR Study Area is within the San Mateo Plain Subbasin of the Santa Clara Valley Groundwater Basin.
15 The southwestern portion of the EIR Study Area in the hills is not within a designated 15 San Mateo County, 2019, San Mateo County GIS open data: San Mateo Plain Subbasin, https://datasmcmaps.opendata.arcgis.com/datasets/san-mateo-plain-subbasin?geometry=-122.296%2C37.491%2C-122.242%2C37.503, accessed October 15, 2024.
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groundwater basin. The San Mateo Plain Subbasin is designated as a very low priority basin and therefore is not regulated under SGMA. This is because there is very little groundwater use in this basin (less than 2,700 acre-feet/year) and most of groundwater withdrawal is in the subbasin areas south of the EIR Study Area (Redwood City and Menlo Park).

There are two primary water purveyors that serve the EIR Study Area: Cal Water-MPS and MPWD. Cal Water-MPS serves most of the EIR Study Area and MPWD serves a small northern portion of the City between El Camino Real and Highway 101, adjacent to the City of Belmont. As discussed above, there is another small southern portion within the EIR Study Area that is provided with potable water by the City of Redwood City. However, this small area is already developed with residential properties and there is no anticipated development in this area. Therefore, the analysis provided below focuses on Cal WaterMPS and MPWD. Figure 4.17-1, Water Suppliers, depicts the boundaries of water districts and service areas of the San Carlos water suppliers. Both Cal Water-MPS and MPWD purchase all of their water supplies from SFPUC’s Regional Water System, which consists entirely of surface water.

Cal Water-MPS
Water Supply Sources
Cal Water is a subsidiary of the California Water Service Group and provides water to communities throughout California, organized into districts throughout the state. Cal Water purchases all its water from the San Francisco Regional Water System (RWS), which is operated by the SFPUC. The RWS supplies are shared between three Cal Water Districts: the MPS, the South San Francisco District, and the Bear Gulch District. Cal Water-MPS serves central San Mateo County and the communities of San Carlos, San Mateo, parts of unincorporated Redwood City, and adjacent unincorporated portions of San Mateo County, including The Highlands and Palomar Park. Approximately 85 percent of the water supply to the RWS originates in the Hetch Hetchy watershed. The remaining 15 percent of the water supply originates locally in the Alameda and Peninsula watersheds and is stored in the San Antonio, Calaveras, Crystal Springs, Pilarcitos, and San Andreas reservoirs.
16 Cal Water-MPS operates two Public Water Systems (PWS): the San Mateo PWS and the San Carlos PWS.

These systems include 35 storage tanks, 54 booster pumps, and 383 miles of pipeline that deliver roughly 12 million gallons of water per day to more than 35,000 service connections.17 All the water supplied by Cal Water-MPS is from surface water treated by SFPUC prior to delivery. There currently is no use of groundwater or recycled water and these sources are not anticipated to be available for future use through 2045.18
16 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District. 17 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District. 18 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District.

MIDPENINSULA
WATER

DISTRICT
Belmont
Channel
Smith Slough
Steinberger
Slough
Pond
Howard Ave
42Nd Ave
Harbor Blvd
W inslow St
Saint Francis Way
Redwood Shores Pky
Jeffer son Ave
Hopkins Ave
Ruth Ave
Old Cr Rd
Whipple Ave
Bauer Dr
Ralston Ave
Industrial Rd
Alameda
Laurel St
Hudson St
Crestview Dr
Valota Rd
Club Dr
Alameda
De
La
s
Pulgas
Brittan Ave
Bridge Pky
Wellington
D r
BeverlyDr
Industrial Way
Alameda
Edgewood Rd
SouthRd
Marine Pky
Far
m
Hill Blvd
BroadwaySt
Brewster Ave
Chula VistaDr
Canada Rd
C
pi
ria
n
B
i
lv d
Notre Dame A ve
Alameda De Las Pulgas
Hiller St
Roosevelt Ave
Pacific Blvd
ElmSt
Ce dar St
San Carlos Ave
Industrial Way
Shelford Ave
Holly St
Molitor Rd
Marine View St
Middle R d
Cordilleras Rd
Stafford St
Stanley St
Jefferson Ave
Pearl Ave
Devonshire B lvd
Mills Ave
Upland
Ave
Mele n dy Dr
Cordilleras Ave
Broadway
Hill
cre s t Rd
Arbo r Ave
82 82
/(101
280
Figure 4.17-1
Water Suppliers
Source: San Mateo County, 2017; City of San Carlos, 2024; PlaceWorks, 2024. 0 0.5 1
Miles
City Limit
Sphere of Influence
Creeks and Waterways
Northeast Area Specific Plan
Downtown Specific Plan

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2 0 4 5 G E N E R A L P L A N R E S E T D R A F T E I R

P L A C E W O R K S

CITY OF REDWOOD CITY

MUNICIPAL WATER DEPARTMENT
CAL WATER – MID-PENINSULA

DISTRICT
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Water Supply Assurance
The amount of water available to the SFPUC’s wholesale and retail customers is constrained by hydrologic conditions, physical facilities, and institutional parameters that allocate the water supply of the Tuolumne River. Because of these constraints, the SFPUC is dependent on reservoir storage to augment its water supplies. SFPUC has a Supply Assurance Agreement to provide 184 MGD to its wholesale customers. However, the Supply Assurance Agreement is subject to reduction during periods of water shortage due to drought, emergencies, or other scenarios. Each wholesale customer’s share of the 184 MGD is referred to as an Individual Supply Guarantee (ISG).

Cal Water’s ISG with SFPUC is shared among three Cal Water Districts: Bear Gulch, Mid-Peninsula, and South San Francisco. The ISG amount was originally 35.39 MGD. However, the acquisition of the Los Trancos Water District in 2005 resulted in the transfer of 0.11 MGD of ISG to Cal Water and in 2009 Cal Water acquired the Skyline County Water District, which also transferred its’ 0.181 MGD ISG to Cal Water. These acquisitions increased Cal Water’s total ISG to 35.68 MGD.19 Cal Water purchased an average of 29,38 MGD in 2020 and is projected to purchase 30.35 MGD in 2045, which is less than the ISG of 35.68 MGD.20
Water Supply and Demand
Because all three Cal Water Districts share one contractual SFPUC allocation of supply and manage their supplies collectively, this analysis for the Cal Water demand and supply includes all three Peninsula Cal Water Districts (i.e., Mid-Peninsula, Bear Gulch, and South San Francisco).21 The projected water demand for Cal Water from 2020 through 2045 is shown in Table 4.17-1, Cal Water Demands: 2020 to 2045 (AFY). The increase in water demand over a 25-year period is minimal, because Cal Water accounts for both active and passive water conservation measures in their future projections.

TABLE 4.17-1 CAL WATER DEMANDS: 2020 TO 2045 (AFY)
District 2020 2025 2030 2035 2040 2045
South San Francisco 6,936 7,016 6,956 7,108 7,473 7,896 Mid-Peninsula 14,563 14,418 14,530 14,786 14,977 15,279 Bear Gulch 12,972 12,796 12,699 12,730 12,675 12,694
Total 34,471 34,230 34,185 34,624 35,125 35,869
Source: Source: EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water Mid-Peninsula District, Draft January 2022.
19 EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water Mid-Peninsula District, Draft January 2022. 20 EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water Mid-Peninsula District, Draft January 2022. 21 EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water Mid-Peninsula District, Draft January 2022. 2045 GENERAL PLAN RESET DRAFT EIR

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Cal Water also provides the current and projected water supplies for its three districts, as shown in Table

4.17-2, Cal Water Supplies: 2020 to 2045 (AFY).

TABLE 4.17-2 CAL WATER SUPPLIES: 2020 TO 2045 (AFY)
District 2020 2025 2030 2035 2040 2045
Purchased (SFPUC) 32,932 32,383 32,338 32,777 33,278 34,022 Bear Gulch Reservoir 0 840 840 840 840 840
Groundwater 1,539 1,534 1,534 1,534 1,534 1,534
Total 34,471 34,757 34,712 35,151 35,652 36,396
Source: EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water MidPeninsula District, Draft January 2022.

Cal Water has also provided an updated water supply and demand assessment for normal, single dry years, and multiple dry years in recently prepared WSAs. 22 The projected water supplies account for purchased water from SFPUC, surface water from Bear Gulch Reservoir, and pumped groundwater. The results are provided in Table 4.17-3, Cal Water Supply and Demand Comparison: 2025 to 2045 (AFY).

TABLE 4.17-3 CAL WATER SUPPLY AND DEMAND COMPARISON: 2025 TO 2045 (AFY) 2025 2030 2035 2040 2045
Normal Year
Supply Totals 34,757 34,712 35,151 35,652 36,396
Demand Totals 34,230 34,185 34,624 35,125 35,869
Surplus 527 527 527 527 527
Single-Dry Year
Supply Totals 23,580 23,546 23,835 23,809 21,039
Demand Totals 35,455 35,401 35,851 36,364 37,126
Shortage (11,875) (11,855) (12,016) (12,555) (16,087)
Multiple-Dry Year
First Year
Supply Totals 23,615 23,483 23,647 23,762 20,954
Demand Totals 36,212 36,154 36,611 37,130 37,904
Shortage (12,597) (12,671) (12,964) (13,368) (16,950)
Second Year and Third Year
Supply Totals 20,492 20,383 20,313 20,594 20,954
Demand Totals 36,212 36,154 36,611 37,130 37,904
Shortage (15,720) (15,771) (16,298) (16,536) (16,950)
Fourth Year
Supply Totals 20,492 20,383 20,313 18,424 18,061
Demand Totals 36,212 36,154 36,611 37,130 37,904
Shortage (15,720) (15,771) (16,298) (18,706) (19,843)
22 EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water Mid-Peninsula District, Draft January 2022. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.17-3 CAL WATER SUPPLY AND DEMAND COMPARISON: 2025 TO 2045 (AFY) Fifth Year
Supply Totals 20,492 20,383 18,849 18,424 18,061
Demand Totals 36,212 36,154 36,611 37,130 37,904
Shortage (15,720) (15,771) (17,762) (18,706) (19,843)
Note: Volumes provided in acre-feet per year (AFY).

Source: EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water MidPeninsula District, Draft January 2022.

As shown in Table 4.17-3, Cal Water predicts that there will be sufficient water supplies to meet demands through 2045 during normal years. However, there could be a shortage of water supplies in single dry and multiple dry years, if the Bay Delta Plan Amendment is implemented, leading to a reduction in allocations of water from SFPUC. There are numerous uncertainties regarding implementation of the Bay Delta Plan Amendment and these water supply projections are a worst-case scenario. It assumes that the SFPUC and SWRCB do not reach a voluntary agreement and that SFPUC’s Alternative Water Supply Program is not implemented. As stated in the 2020 UWMP, if the Bay Delta Plan Amendment is not implemented, SFPUC would be able to supply 100 percent of the projected RWS demands through 2040 during normal, single dry, and multiple dry years.23 Cal Water-MPS has developed a WSCP, as described previously, that outlines policies and actions that will be implemented at various shortage levels ranging from up to 10 percent to greater than 50 percent.

In addition, as per California Water Code Section 10632.1, all urban water suppliers must submit to DWR by July 1st of each year an annual Water Supply and Demand Assessment. The assessment determines if the water supplier is likely to face water shortage and what actions the supplier will take to address any water shortages. Cal Water-MPS submitted the 2024 Annual Water Supply and Demand Assessment on June 14, 2024, which shows a 27 percent reduction in demand over the past four years. 24 Cal Water-MPS is also working to increase its water supply portfolio through: 1) investment in water conservation, 2) participation in the Regional Groundwater Storage and Recovery Project, and 3) development of a regional water supply reliability study to create a long-term supply reliability strategy through 2050.25 Additionally, Cal Water has implemented a Development Offset Program, which developer fees for projects that increase demand by more than 50 AFY will fund water supply projects and expanded conservation programs to improve sustainability.

Mid-Peninsula Water District
Water Supply Sources
MPWD purchases its entire water supply from the SFPUC, whose main source of water is surface water from the Hetch Hetchy Watershed in the Sierra Nevada mountains. The MPWD has a total of 20 pump 23 California Water Service, June 2021, 2020 Urban Water Management Plan, Mid-Peninsula District., 24 EKI Environment & Water, 2024, 2024 Annual Water Supply and Demand Assessment - Mid-Peninsula District. 25 EKI Environmental & Water, 2022, Water Supply Assessment for the Alexandria District for Science and Technology, prepared by Cal Water Mid-Peninsula District, Draft January 2022. 2045 GENERAL PLAN RESET DRAFT EIR

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stations, 11 water tanks, 13 regulating valves, 813 hydrants and 94 miles of water mains.26 MPWD mainly serves the City of Belmont and a small portion of the City of San Carlos. The MPWD’s sole source of potable water is from the SFPUC RWS and has 8,116 service connections.27 MPWD has one public water system that had a volume of 974 million gallons (mg). In 2020, MPWD served water to 27,560 people and 93% of MPWD’s connections were residential services.28 Within San Carlos, there are 181 total connections, with: 101 single-family, 30 multi-family, 43 commercial, 2 institutional, 5 irrigation accounts.29
Most of San Carlos is within the San Mateo Plain Subbasin of the Santa Clara Valley Groundwater Basin. 30 However, MPWD does not use groundwater, recycled water, or desalinated water. MPWD does not have an available, cost-effective supply of recycled water and does not have a conveyance system for accessing recycled water.31
Water Supply Assurance
The SFPUC has a perpetual commitment (Supply Assurance) to deliver 184 million gallons per day (mgd) to its 24 wholesale customers. The Supply Assurance is allocated through Individual Service Guarantees (ISGs), which represent each wholesale customer’s allocation. MPWD’s total ISG is 3.891 mgd.32 Water Supply and Demand
The MPWD 2020 UWMP includes a water supply reliability assessment for normal, single dry years, and multiple dry years. The results are provided in Table 4.17-4, MPWD Supply and Demand Comparison:
2025 to 2045 (MG).

TABLE 4.17-4 MPWD WATER SUPPLY AND DEMAND COMPARISON: 2025 TO 2045 (MG) 2025 2030 2035 2040 2045
Normal Year
Supply Totals 1,044 1,037 1,051 1,055 1,069
Demand Totals 1,044 1,037 1,051 1,055 1,069
Difference 0 0 0 0 0
Single-Dry Year
Supply Totals 668 661 668 672 580
Demand Totals 1,044 1037 1,051 1,055 1,069
Shortage (376) (376) (383) (383) (489)
26 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan, https://www.midpeninsulawater.org/documents, accessed March 7, 2024. 27 Mid-Peninsula Water District, 2021, 2020 Urban Water Management Plan. 28 Mid-Peninsula Water District, 2021, 2020 Urban Water Management Plan. 29 Mid-Peninsula Water District, 2021, 2020 Water Shortage Contingency Plan. 30 San Mateo County, 2019, San Mateo County GIS open data: San Mateo Plain Subbasin, https://datasmcmaps.opendata.arcgis.com/datasets/san-mateo-plain-subbasin?geometry=-122.296%2C37.491%2C-122.242%2C37.503, accessed October 15, 2024.
31 Mid-Peninsula Water District, 2021, 2020 Urban Water Management Plan. 32 Mid-Peninsula Water District, 2021, 2020 Urban Water Management Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 4.17-4 MPWD WATER SUPPLY AND DEMAND COMPARISON: 2025 TO 2045 (MG) 2025 2030 2035 2040 2045
Multiple-Dry Year
First Year
Supply Totals 668 661 668 672 580
Demand Totals 1,044 1037 1,051 1,055 1,069
Shortage (376) (376) (383) (383) (489)
Second Year and Third Year
Supply Totals 573 566 573 577 580
Demand Totals 1,044 1,037 1,051 1,055 1,069
Shortage (471) (471) (478) (478) (489)
Fourth Year
Supply Totals 573 566 573 507 496
Demand Totals 1,044 1,037 1,051 1,055 1,069
Shortage (471) (471) (478) (548) (573)
Fifth Year
Supply Totals 573 566 526 507 496
Demand Totals 1,044 1,037 1,051 1,055 1,069
Difference (471) (471) (526) (548) (573)
Note: Volumes provided in millions of gallons (MG).

Source: Mid-Peninsula Water District, 2021, Tables 7.3, 7-4, and 7.6 of 2020 Urban Water Management Plan. Assumes implementation of the Bay Delta Plan.

With implementation of the Bay Delta Plan, leading to a reduction in water allocations to SFPUC, MPWD predicts a water supply shortage in single- and multiple-dry year scenarios. There are numerous uncertainties regarding implementation of the Bay Delta Plan Amendment, and these water supply projections are a worst-case scenario. It assumes that the SFPUC and SWRCB do not reach a voluntary agreement and that the SFPUC’s Alternative Water Supply Program is not implemented. As stated in the 2020 UWMP, if the Bay Delta Plan Amendment is not implemented, SFPUC would be able to supply 100 percent of the projected RWS demands through 2045 during normal, single dry, and multiple dry years.33 Responses to water shortages are addressed in MPWD’s WSCP, which provides direction on specific actions to be taken by staff and customers in response to increasingly severe water supply shortage conditions. Within the plan, six water shortage levels are identified along with the shortage response actions. 34

STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant water supply impact if it would:
33 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan, https://www.midpeninsulawater.org/documents, accessed March 7, 2024. 34 Mid-Peninsula Water District, September 2021, 2020 Water Shortage Contingency Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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UTIL-1 Have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

UTIL-2 Require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects.

UTIL-3 In combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to water supply.

IMPACT DISCUSSION
UTIL-1 The proposed project would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

The current and projected water demands from Cal Water-MPS and MPWD’s 2020 UWMPs are provided in Tables 4.17-1 through 4.17-4. Because both water purveyors have service areas that extend beyond San Carlos, the projections in those tables include the water demands for each water purveyor’s service area, which includes San Carlos, Belmont, San Mateo and unincorporated areas of San Mateo County.

This discussion evaluates the increase in water demand within the EIR Study Area associated with future development within the buildout horizon of the proposed project as allocated within Cal Water-MPS and MPWD’s service areas.

As discussed in detail in Chapter 3, Project Description, of this Draft EIR, future development within the buildout horizon of the proposed project includes approximately 8,300 new dwelling units and 8,927,300 square feet of new non-residential land uses (i.e., commercial, office, research and development, and industrial). New construction would comply with the more stringent requirements of CALGreen, California Plumbing Code, and the City’s WELO. Only 1.1 percent of the current residences were built after 2010,
35 when the CALGreen Building Code was first implemented and the installation of waterconserving plumbing fixtures and fittings were mandated. Therefore, there are ample opportunities for retrofitting existing residences with low flow plumbing fixtures and all new construction of both residential and commercial land uses would typically achieve a reduction in water usage rates of 20 percent through compliance with the CALGreen Building Code. However, this analysis conservatively does not account for water demand reductions for new construction and water conservation measures for existing residences and commercial properties. The water demand factors used in this analysis were provided by Cal Water-MPS and MPWD.

Cal Water – Mid-Peninsula District
Based on mapping analysis and consultation with the water purveyors, projected development within Cal Water-MPS service area is estimated to be 6,769 new dwelling units (40 single-family units and 6,729 multi-family residences and accessory dwelling units [ADUs]) and 4,255,219 square feet of non35 Cal Water Service, 2021, 2020 Urban Water Management Plan, page 31. 2045 GENERAL PLAN RESET DRAFT EIR

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residential space, including commercial, office, research and development (R&D), and industrial land uses. The water demand factors for residential and commercial land uses were provided by Cal WaterMPS. 36 The calculations for the water demand increase with future development are provided in Table

4.17-5, Increase in Water Demand in Cal Water-MPS Service Area (2045).

TABLE 4.17-5 INCREASE IN WATER DEMAND IN CAL WATER-MPS SERVICE AREA (2045) Category
Number
(DUs or SF) Water Use Factor
Increase in Water
Demand (gpd)a
Increase in Water
Demand (AFY)
Single-Family Residential 40 197 gpd/DU 7,880 8.8
Multi-Family Residential 6,729 99 gpd/DU 666,171 746.2
Non-Residential 4,255,219
Commercial (626,878) 0.097 gpd/SF (60,807) (68.1)
Office 185,260 0.055 gpd/SF 10,189 11.4
R&D 5,322,337 0.18 gpd/SF 958,021 1,073.1
Industrial (625,500) 0.097 gpd/SF (60,674) (68.0)
Irrigation Demand for
Non-Residentialb 94.8
Distribution System
Losses 57.5 c
Total 1,605,453 1,856
Notes: DUs = dwelling units; SF = square feet; gpd = gallons per day; AFY = acre feet per year; gpcd = gallons per capita per day a. Demand calculations do not account for water conservation efforts and the effect of reduced water demand for new construction due to compliance with the CALGreen Building Code and the latest California Plumbing Code. Water demand for residential includes outdoor water usage. b Assumes outdoor water demand to be 10% of total demand. c. Losses determined as 3.2 percent of water demand, per Cal Water-MPS recent water loss audit.

Source: PlaceWorks, 2024, Cal Water, 2024.

A supply and demand analysis is provided in Table 4.17-6, Cal Water-MPS Projected Future- Water Demand (2045) (AFY).

TABLE 4.17-6 CAL WATER-MPS PROJECTED FUTURE WATER DEMAND (2045) (AFY) Category 2025 2030 2035 2040 2045
Cal Water-MPS 2020 UWMP 14,418 14,530 14,786 14,977 15,279 Proposed Project 0 0 0 0 0
Total 14,418 14,530 14,786 14,977 15,279
Note: AFY = acre-free per year
Source: PlaceWorks, 2024.

Although Table 4.17-5 shows that future development would result in a water demand of 1,856 AFY, there would be essentially no net increase in demand for the following reasons. All new projects would be subject to implementation of Cal Water’s Development Offset Program in that a net increase in water demand greater than 50 AFY for all new development must be offset so there is no net increase in water demand due to the project. Most of the projected water demand in Table 4.17-5 is associated with R&D land use, which typically consists of large projects with a water demand greater than 50 AFY that would 36 Cal Water-MPS, 2024. Email correspondence between Michael Bolzowski, Cal-Water, and Alexis Mena, PlaceWorks on September 16, 2024.
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be required to comply with Cal Water’s Development Offset Program. The other large water demand in Table 4.17-5 is for multi-family residences. Essentially all of the housing opportunity sites listed in the latest San Carlos Housing Element would replace existing land uses with existing water demands and would be subject to the CALGreen Building Code and water efficient landscape irrigation requirements, thus resulting in a net reduction in overall water demand.37 In addition, ongoing water conservation measures within Cal Water-MPS’ service area have resulted in a 27 percent reduction in demand over the past four years, according to the latest 2024 Annual Water Supply and Demand Assessment.38 Also, large projects that meet the criteria under SB 610 would need to prepare a WSA to ensure that there are sufficient water supplies for the project, and all project applicants would be required to obtain a will-serve letter from Cal Water-MPS prior to the issuance of building permits. Finally, Cal Water-MPS is accounting for an increase in water demand up to year 2045, as documented in the 2020 UWMP and future projections will be updated with publication of the 2025 UWMP.

However, as shown in Table 14.7-5, there will be a shortage of water supplies for single-dry and multipledry years with implementation of the Bay-Delta Plan. One way to offset the shortage of water supplies during normal and multiple dry years would be to continue implementing water conservation measures.

Cal Water-MPS enforces water waste prevention and water use restrictions, as authorized by the California Public Utilities Commission (CPUC) and coordinates its efforts with local governments. Cal Water-MPS meters all service connections and bills customers for water use on a monthly basis. All Cal Water Districts use conservation pricing with a three-tier increasing block rate for residential water use.

The water agency has a comprehensive public education and outreach program and conducts an annual distribution system audit to reduce water system losses.39 In addition, Cal Water-MPS operates rebate, give-away, and direct installation programs aimed at plumbing fixture replacement, irrigation equipment, and landscape efficiency. Cal Water-MPS has a rebate program for high-efficiency toilet replacement, high-efficiency urinal replacement, and highefficiency clothes washer replacement. Cal Water-MPS also has residential conservation kits that are free, with high-efficiency showerheads, bathroom and kitchen faucet aerators, toilet leak tables, and an outside full-stop hose nozzle. For outdoor water use, Cal Water-MPS provides rebates for smart irrigation controllers, high-efficiency sprinkler nozzles, large rotary nozzle replacement, spray bodies with pressure regulation and check valves, and turf replacement. Cal Water-MPS also provides landscape audits and sprinkler adjustments at no charge, technical assistance through the residential customer portal, and commercial water surveys. Because over 90 percent of the housing in the City of San Carlos was built prior to 2000, there are ample opportunities for retrofitting and replacement of inefficient water fixtures to reduce existing and future water demand. Implementation of these programs in the Cal Water-MPS service area over the last five years have resulted in water savings of approximately 772 AF.40 37 City of San Carlos, 2024. San Carlos 2023-2031 Housing Element, certified April 25, 2024. 38 EKI Environment & Water, 2024, 2024 Annual Water Supply and Demand Assessment - Mid-Peninsula District 39 California Water Service, 2021, 2020 Urban Water Management Plan. 40 California Water Service, 2021, 2020 Urban Water Management Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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Cal Water-MPS would also implement the WSCP during single- and multiple-dry years, with water restrictions ranging from 10 to >50 percent. If the water shortage is at a Stage 5 level (requiring a demand reduction of up to 50 percent), new water connections must have a net zero demand increase.

At a Stage 6 level (demand reduction greater than 50 percent), Cal Water-MPS has a moratorium on new water service connections.

Cal Water-MPS coordinates on an ongoing basis with SFPUC, Bay Area Water Supply and Conservation Agency (BAWSCA), City of San Carlos, City of San Mateo, San Mateo County, and other public and private entities to optimize the use of regional water supplies. Cal Water-MPS and the other Cal Water Districts are currently in the process of developing multiple regional water supply reliability studies using integrated resource planning to create a long-term supply reliability strategy through 2050. The studies will create long-term strategies to address water supply challenges including climate change, new regulatory requirements such as the Bay Delta Plan Amendment, and potential growth in demands due to new development. Cal Water-MPS is also included in the Bay Area Water Supply Reliability Analysis.41 Mid-Peninsula Water District
Based on mapping analysis and consultation with MPWD, future development within MPWD’s service area is estimated to be 1,531 new dwelling units (all multi-family residences and ADUs) and 4,672,081 square feet of non-residential land uses (i.e., commercial, office space, R&D and industrial land uses).

The water demand factors were obtained from MPWD. The calculations are provided in Table 4.17-7, Increase in Water Demand in MPWD Service Area (2045).

TABLE 4.17-7 INCREASE IN WATER DEMAND IN MPWD SERVICE AREA (2045) Category
Number
(DUs or SF) Water Use Factor
Increase in Water
Demand (gpd)a
Increase in Water
Demand (AFY)
Residential 1,531 104 gpd/DU 159,224 178.4
Non-Residential 4,672,081
Commercial 75,378 0.045 gpd/SF 3,392 3.8
Office 158,440 0.045 gpd/SF 7,130 8.0
R&D 3,154,263 0.18 gpd/SF 567,767 636.0
Industrial 1,284,000 0.022 gpd/SF 28,248 31.6
Irrigation Demand for
Non-Residentialb 67.9
Distribution System
Losses 40.7 c
Total 826,415 966.4
Notes: DUs = dwelling units; SF = square feet; gpcd = gallons per capita per day; gpd/SF = gallons per day per square foot; gpd = gallons per day; AFY = acre feet per year; R&D = research and development
a. Demand calculations do not account for water conservation efforts and the effect of reduced water demand for new construction due to compliance with the CALGreen Building Code and the latest California Plumbing Code. Water demand for residential includes outdoor water usage. b. Assumed to be 10 percent of total water demand, as per MPWD correspondence with PlaceWorks. c. Losses determined as 4.4 percent of water demand, from MPWD 2020 UWMP.

Source: MPWD, 2021, 2020 UWMP; PlaceWorks, 2024.
41 California Water Service, 2021, 2020 Urban Water Management Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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The calculations in Table 4.17-7 indicate an increase in water demand within the MPWD service area of 966.4 AFY with the proposed project. Table 4.17-8, MPWD Water Supply and Demand (2045), provides an analysis of the MPWD water supply and demand under normal conditions with the proposed project.

TABLE 4.17-8 MPWD WATER SUPPLY AND DEMAND (2045)
Normal Year Acre-Feet per Year
Existing Demand, from UWMP 3,281
Net Demand from Projected Buildout (2045) 966
Total System Demand 4,247
SFPUC Supply 4,358
Water Supply Surplus 111
Sufficient Water Supply with Proposed Project under Normal Conditions? Yes Source: MPWD, 2021, 2020 UWMP; PlaceWorks, 2024.

The calculations in Table 4.17-8 indicate that MPWD has sufficient water supplies to accommodate projected development within the MPWD service area under normal conditions. However, there will not be sufficient water supplies under single- and multiple-dry year conditions, assuming implementation of the Bay Delta Plan Amendment and SFPUC supply restrictions. This would be true even without the additional 966 AFY of water demand with the proposed project. SFPUC indicates that if the Bay Delta Plan Amendment is not implemented, there would be sufficient water supplies for all of its wholesale customers through 2045 with no restrictions. However, MPWD’s 2020 UWMP predicts a shortage of 110 AFY in the fourth and fifth year of drought conditions without implementation of the Bay Delta Plan. 42 As discussed above, MPWD would implement the WSCP during single- and multiple-dry years, with water restrictions ranging from 10 to 50 percent. MPWD coordinates on an ongoing basis with SFPUC, BAWSCA, City of San Carlos, City of Belmont, San Mateo County, and other public and private entities to optimize the use of regional water supplies. There also is the potential for water right transfers within the SFPUC Regional Water System. The Water Shortage Allocation Plan adopted by all BAWSCA agencies and the SFPUC provides the basis for voluntary transfers of water among BAWSCA agencies during periods when mandatory rationing is in place. Also, MPWD has two emergency interconnections—with California Water-MPS and Estero Municipal Improvement District—that would enable the short-term transfer of water due to disruptions in normal supply resulting from an earthquake or other emergency.43 In addition, MPWD has seen a 10 percent reduction in water demand over the past four years, as documented in the 2024 Water Shortage Report submitted to DWR.44 Summary
As discussed above, both Cal Water-MPS and MPWD are expected to have sufficient water supplies to meet demand under normal conditions with implementation of the proposed project. However, both 42 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan. 43 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management. 44 Mid-Peninsula Water District, 2024. Water Shortage Report submitted to DWR. https://wuedata.water.ca.gov/wsda_tool.asp?wuedata_plan_id=14430 accessed on November 2, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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water purveyors project water shortages during single- and multiple-dry year conditions, assuming implementation of the Bay Delta Plan and SFPUC supply restrictions.

Future development within the buildout horizon would be required to implement the water-efficient requirements specified in the CALGreen and California Plumbing Codes and the WELO requirements for water efficient landscaping. Cal Water-MPS also implements the Development Offset Program which requires all new developments that will have a net increase in demand of more than 50 AFY to offset the net increase in demand. Future projects that meet the criteria under California Water Code Section 10912 would be required to prepare a WSA that demonstrates that project water demands would not exceed water supplies. In addition, existing residential, commercial, and industrial land uses are expected to decrease their water demands in the future as a result of the implementation of water conservation practices. This can be seen in the reduction in total water demands for both Cal Water-MPS and MPWD over the past four years.

Additionally, the Environmental Management (EM) Element and Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to utilities and service systems, including water supplies and resources. The following General Plan goals, policies, and actions would serve to minimize potential adverse impacts to water supplies with future development:
 Goal EM-5: Assure a high level of domestic water quality, promote water conservation and reduce toxics in run-off, including storm- water and the sanitary sewer system.  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-5.6: 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-5.8: Work with water service providers to provide high quality domestic water.  Action EM-5.5: Establish water conservation goals for City buildings and operations.  Action EM-5.6: Evaluate potential incentives for the use of drought-tolerant landscaping and recycled water for landscape irrigation.
 Action EM-5.8: Develop a recycled water implementation plan, which would identify potential sources and uses of recycled water, environmental benefits, capital and operating costs and potential utility providers.
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 Goal ESPS-3: Agency Coordination: A resilient San Carlos is well prepared to minimize risks associated with wildfire.
 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;
 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.
 Goal ESPS-9: The City of San Carlos has a sustainable and resilient water supply despite the potential for more frequent and severe drought conditions.
 Policy ESPS-9.1: Support Cal Water’s efforts to increase water storage capacity and water supply reliability, including meeting fire flow requirements.
 Policy ESPS-9.2: Support and partner with Cal Water’s efforts to achieve water demand reductions of 10 percent below State requirements to reduce future constraints during droughts.  Action ESPS-9.1: Support Cal Water’s efforts to construct additional water storage tanks within City limits, if needed.
 Action ESPS-9.2: Upgrade City waste and wastewater systems to accommodate projected drought-induced changes in water quality and availability and ensure long-term integrity of water supplies.
 Action ESPS-9.3: Partner with Cal Water-MPS to increase customer participation in water conservation programs to reduce water use throughout San Carlos.  Action ESPS-9.4: Require all new development, reconstruction, and remodel projects to install water saving infrastructure and systems minimizing water use.  Action ESPS-9.5: Require public and private development projects to design sites, buildings, and structures that minimize water use and increase water recycling.  Action ESPS-9.6: Develop a San Carlos’ Recycled Water program to nonresidential users. 2045 GENERAL PLAN RESET DRAFT EIR

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 Action ESPS-9.7: Consider extending the recycled water pipes from Redwood City into East San Carlos.
 Action ESPS-9.8: Determine best methods to use recycled water to irrigate San Carlos public parks, medians, and other publicly owned landscaped areas.

The City would continue to coordinate with Cal Water-MPS and MPWD regarding conservation efforts, demand management measures promoted by the water districts, and implementation of water use restrictions as per the WSCPs. Implementation of Cal Water-MPS and MPWD’s WSCPs, compliance with WSA requirements, compliance with existing water conservation regulations, and implementation of the General Plan goals, policies, and actions would reduce water demand with respect to water supplies. In addition, Cal Water, MPWD, and SFPUC plan to implement alternative water supply programs by 2045 in conjunction with BAWSCA. The Bay Delta Plan Amendment may not be enacted in its current structure, making more water available than anticipated in the most recent UWMPs.45 The SFPUC has indicated that there will be sufficient supplies available to meet all demands of their water purveyors in both normal and drought conditions through 2045 if the Bay-Delta Plan is not implemented. The next iteration of Cal Water-MPS and MPWD UWMPs, due in 2026, will reflect the population projections of the proposed 2045 General Plan Reset and plan accordingly for future water supplies. Finally, compliance with the Cal Water Development Offset Program would provide additional assurance that impacts to water supply would be less than significant. As the City of San Carlos is not a water provider for the EIR Study Area and has limited capacity to directly control water use and water supply planning, the measures described above represent the best water conservation and water supply measures available and the impact would be less than significant.

Significance without Mitigation: Less than significant.

UTIL-2 The proposed project would not require or result in the relocation or construction of new or expanded water facilities, the construction or relocation of which could cause significant environmental effects.

As noted in impact discussion UTIL-1, Cal Water-MPS and MPWD have sufficient water supplies available under normal years and both Cal Water-MPS and MPWD would implement their WSCPs under singleyear and multiple-year dry conditions. The WSCPs contain water demand mitigation measures that would be implemented at each of the six water shortage levels and each water agency is required to submit an annual report to DWR to assess whether there will be a water shortage in the coming year and what water demand reduction measures will be adopted to address the shortages. It also should be noted that the 2020 UWMPs assume full implementation of the Bay Delta Plan Amendment, which is in a state of flux and most likely would not result in the severe water restrictions that are currently projected. In addition, Cal Water, MPWD, BAWSCA and SFPUC are working on alternative water supplies to address potential future water shortages. All water agencies that serve San Carlos and the SFPUC have an existing water distribution infrastructure that can supply the City without the need to expand their infrastructure facilities. Implementation of the Cal Water-MPS Development Offset Program would 45 San Francisco Public Utilities Commission, 2021, 2020 Urban Water Management Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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provide assurance that all future new projects would offset the net increase in water demand, ensuring water supply reliability.

In addition, each large future project would be required to demonstrate the availability of water to serve the development through preparation of a WSA as required by Section 10910 of the California Water Code. As the city is almost entirely built out, most of the new development would be infill projects that are replacing buildings with an existing water demand and water distribution system. Therefore, implementation of the proposed project would not result in the need to construct additional water supply or distribution systems.

Cal Water-MPS and MPWD purchase all of their water from SFPUC. The Harry Tracy Water Treatment Plant (HTWTP), which is owned and operated by SFPUC, filters and disinfects the water supplied from Crystal Springs Reservoir and San Andreas Reservoir before delivery to its wholesale customers on the Peninsula and its retail customers in the City of San Francisco. The HTWTP was recently upgraded and features five new filters, three new ozone generators, and a new seismically resistant 11.5-million-gallon treated water reservoir. The facility now has the capacity to provide 140 MGD for 60 days within 24 hours of a major earthquake. This was part of SFPUC’s Water System Improvement Plan to repair, replace, and seismically upgrade the Hetch Hetchy Regional Water System. As part of the upgrades, a new 78-inch treated water pipeline was installed to connect the HTWTP reservoir with the San Andreas Pipeline for delivery to SFPUC’s customers.46 Therefore, the SFPUC has the capability of supplying treated water to all of its wholesale and retail customers under existing and future conditions and no new water treatment facilities are required.

Furthermore, as discussed in impact discussion UTIL-1, the Environmental Management (EM) Element and Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to utilities and service systems, including water facilities. The General Plan goals, policies, and actions listed in impact discussion UTIL-1 would serve to minimize potential adverse impacts related to construction or expansion of water facilities.

In summary, no new water treatment or distribution facilities would be needed with implementation of the proposed project and Cal Water-MPS and MPWD have capital improvement projects to monitor and upgrade their water distribution systems to accommodate future development. In addition, compliance with the City’s requirements for new construction and water-efficient landscaping and implementation of the General Plan goals, policies, and actions listed in impact discussion UTIL-1 would result in lessthan-significant impacts with respect to the need for new and/or expanded water facilities.

Significance without Mitigation: Less than significant. 46 SFPUC, undated, The Harry Tracy Water Treatment Plant, https://baywork.org/wp-content/uploads/2017/08/HarryTracy-Water-Treatment-Plant-fact-sheet-020817.pdf, accessed October 29, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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UTIL-3 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to water supply.

The area considered for cumulative water supply impacts is the service areas of Cal Water-MPS and MPWD. Other future projects within MPWD’s service area would result in increases in water demand, although new projects within Cal Water-MPS’ service area would be required to offset net increases in water demand, thus resulting in no significant increase in overall water demand. Cumulative water demands are not anticipated to require building new water treatment facilities or expansion of existing facilities beyond what is currently planned. All new development projects that meet the SB 610 criteria, such as residential projects with more than 500 dwelling units, would be required to prepare WSAs. The City and the water purveyors would review such projects for adequacy of water supply and the water purveyors would update the UWMP every five years to ensure that there are adequate water supplies and contingency plans for future residents and customers. All new development under the proposed project would require implementing water efficiency and water conservation measures, as per the CALGreen Building Code and the WELO irrigation requirements. Water supply deficits in dry years would be met by implementing the WSCPs and other water conservation efforts.

All cumulative projects would be required to comply with federal, State, and local regulatory requirements, including City ordinances and General Plan goals, policies, and actions. These regulations, and the Cal Water-MPS Development Offset Program would result in a reduction in per capita water use over time, which would ensure that cumulative impacts with respect to water supply would be less than significant.

Significance without Mitigation: Less than significant.

4.17.2 WASTEWATER

ENVIRONMENTAL SETTING
Regulatory Framework
Federal Regulations
Clean Water Act
The CWA regulates the discharge of pollutants into watersheds throughout the nation. Under the CWA, the USEPA implements pollution control programs, sets wastewater standards, and makes it unlawful to discharge pollutants from a point source into any navigable waters without obtaining a permit. Point sources include any conveyances, such as pipes and man-made drainage channels, from which pollutants may be discharged.
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National Pollutant Discharge Elimination System
The National Pollutant Discharge Elimination System (NPDES) permit program was established as part of the CWA to regulate municipal and industrial discharges to surface Waters of the United States. Federal NPDES permit regulations have been established for broad categories of discharges, including pointsource municipal waste discharges and nonpoint-source stormwater runoff. NPDES permits generally identify effluent and receiving water limits on allowable connections and/or mass emissions of pollutants contained in the discharge; prohibitions on discharges not specifically allowed under the permit; and pollution prevention, self-monitoring, and other activities. Wastewater discharge is regulated under the NPDES permit program for direct discharges into receiving waters and by the National Pretreatment Program for indirect discharges to a wastewater treatment plant.

State Regulations
On May 2, 2006, the SWRCB adopted a General Waste Discharge Requirement (Order No. 2006-0003) and a monitoring and reporting program (Order No. WQ-2013-0058-EXEC) for all publicly owned sanitary sewer collection systems in California with more than one mile of sewer pipes. The order provides a consistent statewide approach to reducing sanitary sewer overflows (SSOs) by requiring public sewer system operators to take all feasible steps to control the volume of waste discharged into the system, to prevent wastewater from entering the storm drain system, and to develop a Sewer System Management Plan (SSMP). The General Waste Discharge Requirement also requires that SSOs be reported to the SWRCB using an online reporting system. The SWRCB has delegated authority to the nine RWQCBs to enforce these requirements within their regions.

The SSMP is required to include an evaluation of the existing sewer collection system and provide a framework for minimizing the frequency and impact of SSOs. The SSMP includes an overflow emergency response plan; a fats, oil, and grease control program; scheduled inspections and condition assessment; design and construction standards; capacity assessment and management; and a monitoring program.

Regional Regulations
The San Francisco Bay RWQCB (Region 2) was created as a result of the California Porter-Cologne Act.

The RWQCB issues and enforces NPDES permits within the EIR Study Area, which includes permits for wastewater treatment plants (WWTPs) and industrial waste discharges. NPDES permits allow the RWQCB to regulate where and how waste is disposed, including the discharge volume and effluent limits of waste and the monitoring and reporting responsibilities of the discharger. The RWQCB is also charged with conducting inspections of permitted discharges and monitoring permit compliance. The San Francisco Bay RWQCB reissued an NPDES permit in 2023 (Order No. R2-2023-0003) for the Silicon Valley Clean Water Treatment Plant.

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assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.17.2.3, Impact Discussion.

City of San Carlos Design Guidelines
Section 7 of the City’s Design Guidelines includes standards for the City’s sewer collection system. 47 These sewer guidelines apply to the construction, repair, and relocation of sanitary sewer facilities in the City, including mains, laterals, services, and all related appurtenances. Section 7 provides guidelines for the design, construction, and abandonment of sewer lines, including design criteria, materials, and installation. More stringent requirements based on specific project conditions may be imposed at the discretion of the Department of Public Works and Engineering Division.

City of San Carlos Sanitary Sewer Management Plan
The goal of the Sanitary Sewer Management Plan, prepared by the Department of Public Works, is to properly manage, operate, and maintain all parts of the sanitary sewer system. The plan provides procedures to reduce and prevent SSOs and mitigate any overflows that do occur. The SSMP describes 47 City of San Carlos, 2016, Design Guidelines,
https://cms3.revize.com/revize/sancarlos/Document%20Center/City%20Hall/Departments%20And%20Divisions/Public%20Wor ks/View%20Documents/Standards%20Specifications%20and%20Details/2016%20Design%20Guidelines.pdf, accessed October 29, 2024.
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how the sanitary sewer system is operated and maintained, efforts to minimize infiltration and inflow, design and performance standards, overflow emergency response plan, a fats, oil and grease control program, and monitoring and audit requirements. As required by law, the SSMP must be updated every five years and must be developed in compliance with the requirements of the SWRCB Waste Discharge Requirements Order No. 2006-003-DWQ, Amended Monitoring and Reporting Program Order No. WQ 2008-002-EXEC, and Order No. WQ 2013-0058-EXEC.48
City of San Carlos Sewer Collection System Master Plan
The Sewer Collection System Master Plan was prepared in 2013 and the City is currently in the process of updating this plan. The Master Plan presents results from modeling efforts to determine the capacity of the collection system, identify deficiencies in flow capacities to convey peak wet weather flows, and recommend capital improvement projects and rehabilitation/replacement programs to correct flow deficiencies.49
Silicon Valley Clean Water Wastewater Treatment Plant NPDES Permit Silicon Valley Clean Water (SVCW), formerly South Bayside System Authority, provides wastewater treatment for the City of San Carlos, Belmont, Redwood City, and parts of Menlo Park. Wastewater from the City’s sewer system is conveyed to the SVCW wastewater treatment plant (WWTP) located in the Redwood Shores area of Redwood City. The NPDES permit for SVCW was issued by the San Francisco RWQCB (Order No. R2-2023-0003; NPDES No. CA0038369). It was adopted on March 8, 2023 and will expire on April 30, 2028. The permit includes discharge prohibitions, effluent limitations and discharge specifications, receiving water limitations, monitoring and reporting requirements, and a pollution minimization program.
50 Existing Conditions
Wastewater Collection
The City of San Carlos owns and operates a sanitary sewer collection system consisting of approximately 104 miles of sewer pipelines and 6 sewer lift stations.51 The majority of the system is a gravity system that consists mainly of pipe diameters range from 5 inches to 36 inches, with the majority of the system being 6-inch pipes (70 percent). Most of the system was constructed in the 1940s and 1950s with the oldest portions of the system dating back to the 1920s. The primary pipe material is vitrified clay pipe, 48 City of San Carlos, updated April 30, 2021, Sanitary Sewer Management Plan, https://www.cityofsancarlos.org/home/showpublisheddocument/850/637565993327530000, accessed October 29, 2024. 49 RMC, 2013. City of San Calos Sewer Collection System Master Plan. Dated January 2013. 50 California Regional Water Quality Control Board San Francisco Bay Region, 2023, ORDER R2-2023-0003, https://svcw.org/wp-content/uploads/2024/05/NPDES-PERMIT-2023-2028-Order-R2-2023-0003.pdf, accessed on October 11, 2024.
51 City of San Carlos, updated April 30, 2021, Sanitary Sewer Management Plan, https://cms3.revize.com/revize/sancarlos/Document%20Center/City%20Hall/Departments%20And%20Divisions/Public%20Wor ks/View%20Documents/Sewer/Sewer%20System%20Management%20Pl.pdf, accessed October 29, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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with plastic pipe (HDPE or PVC) used in newer sewer construction and rehabilitation. The system also includes approximately 11,000 private sewer laterals that are maintained by the property owners.52 This system serves approximately 28,000 within the San Carlos city limits, plus adjacent areas in unincorporated San Mateo County and a small portion of the City of Belmont that are tributary to the City’s sewer system.53 This system is maintained by the City’s Public Works Department, and the wastewater flows are conveyed to SVCW’s WWTP.

The City is subject to infiltration and inflow (I/I) with groundwater and stormwater entering the collection system during storm events and resulting in high peak flows during wet weather events. As a result, SSOs have occurred in the past. In 2010, the City entered into a Consent Decree with the San Franciso Baykeeper, which requires the City to implement a number of measures targeted at reducing SSOs.

The City plans to upgrade the aging infrastructure as outlined in the Sewer System Management Plan through projects identified in their Capital Improvement Program.54 The projects focus on addressing Grade 4 and 5 defects within the collection system and replacing or rehabilitating failing segments of the City’s sewer mains. Near-term sewer improvement projects include the following: 55  2023 Sewer Rehabilitation Project, addressing defections system wide at various locations  2024 Sewer Lateral Replacement Project, various locations Wastewater Treatment
All collected wastewater is conveyed to the San Carlos Pump Station, which is owned and operated by SVCW. It is then pumped to the SVCW WWTP located in the City of Redwood City. The SVCW WWTP in Redwood City serves more than 220,000 residents and businesses in its service area.56 The existing volume of wastewater collected by the City and treated at the SVCW facility is approximately 2.85 million gallons per day (MGD).57
52 City of San Carlos, undated. The City of San Carlos Wastewater System, https://cms3.revize.com/revize/sancarlos/ Document%20Center/City%20Hall/Departments%20And%20Divisions/Public%20Works/View%20Documents/Sewer/San%20Ca rlos%20Sewer%20System%20Ge.pdf accessed on November 2, 2024. 53 City of San Carlos, 2013, Sewer Collection Master Plan, https://cms3.revize.com/revize/sancarlos/Document%20Center/ City%20Hall/Departments%20And%20Divisions/Public%20Works/View%20Documents/Sewer/Sewer%20Collection%20System %20Master%20Plan/San%20Carlos%20Sewer%20Collectio.pdf, accessed on October 29, 2024. 54 City of San Carlos, 2024, Public Works Projects, https://www.cityofsancarlos.org/city_hall/departments_and_ divisions/public_works/public_works_projects.php, accessed October 29, 2024. 55 City of San Carlos, 2024, Public Works Projects, https://www.cityofsancarlos.org/city_hall/departments_and_divisions/ public_works/public_works_projects.php, accessed October 29, 2024. 56 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan. 57 City of San Carlos, 2024. Correspondence between San Carlos Public Works Department, Evan Cai and Alexis Mena of PlaceWorks on October 23, 2024.
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The design capacity for the SVCW WWTP is 29 MGD (dry weather flow), and the total of all wastewater flows to the SVCW in 2020 was 12.6 MGD.58 SVCW’s projections estimate that the total wastewater flow in 2040 will be 17.9 MGD.
59 This is still well below its permitted capacity.

STANDARDS OF SIGNIFICANCE
The proposed project would have a significant impact related to wastewater service if it would:

UTIL-4 Require or result in the relocation or construction of new or expanded wastewater treatment facilities, the construction or relocation of which could cause significant environmental effects.

UTIL-5 Result in a determination by the wastewater treatment provider which serves or may serve the proposed project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

UTIL-6 In combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to wastewater.

IMPACT DISCUSSION
UTIL-4 The proposed project would not require or result in the relocation or construction of new or expanded wastewater treatment facilities, the construction or relocation of which could cause significant environmental effects.

Future development within the buildout horizon of the proposed project would result in an increase in wastewater with a population increase of 15,620 residents and 8,927,300 new square feet of nonresidential land use. For the EIR Study Area, wastewater generated by the proposed project would be collected by the City’s sanitary sewer system and conveyed to the SVCW WWTP. The wastewater generation factors for residential and non-residential land uses were provided by the City of San Carlos.

An estimate of the amount of additional wastewater generated by the proposed project was determined, as shown in Table 4.17-9, Proposed Project Wastewater Demand Increase.

TABLE 4.17-9 PROPOSED PROJECT WASTEWATER DEMAND INCREASE Category
Proposed Project
Net Change
(Population or SF)
Wastewater Use
Factor
Increase in
Wastewater Demand
(gpd)a
Increase in
Wastewater Demand
(MGD)
Residential 15,620 47 gpcd 734,140 0.73
Non-Residential 8,927,300 0.097 gpd/SF 865,948 0.87
Total 1,600,088 1.60
Notes: SF = square feet; gpcd = gallons per capita per day; gpd = gallons per day; MGD = millions of gallons per day Source: City of San Carlos, 2024; PlaceWorks, 2024.
58 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan. 59 Mid-Peninsula Water District, September 2021, 2020 Urban Water Management Plan. 2045 GENERAL PLAN RESET DRAFT EIR

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The increase in wastewater demand is estimated to be approximately 1.6 MGD. Combined with the existing average daily flow of 2.85 MGD, the estimated total wastewater discharge from the City of San Carlos in 2045 is estimated to be 4.45 MGD.

The SVCW WWTP has a design capacity of 29 MGD and a projected total wastewater flow of 17.9 MGD in 2040. Therefore, there is a residual projected treatment capacity of 11.1 MGD. The increase in wastewater generation with the proposed project of 1.6 MGD is well within the residual capacity of the SVCW WWTP. In addition, per capita wastewater flow rates are expected to decline with water conservation efforts. Therefore, the SVCW WWTP will be able to accommodate future wastewater flows from the City and other contributors of wastewater flows to the SVCW WWTP.

Additionally, the City of San Carlos implements sewer collection improvement projects as part of their CIP. The goal is to upgrade the aging sewer infrastructure, improve wet weather capacity, and reduce inflow and infiltration (I/I) by replacing existing sewers with larger pipes and rehabilitation/lining of existing sewer lines. Completion of the sewer system upgrades should minimize the potential for future SSOs and thus decrease wastewater flows during wet weather conditions. Also, property owners are required to pay an annual sewer service charge as part of the annual property tax bill. These collected fees are used to fund wastewater collection and treatment system improvements designated in the CIP.

The Environmental Management (EM) Element and Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to utilities and service systems, including wastewater collection systems and treatment facilities. The following General Plan goals, policies, and actions would serve to minimize potential adverse impacts to wastewater infrastructure with future development:
 Goal EM-5: Assure a high level of domestic water quality, promote water conservation and reduce toxics in run-off, including storm- water and the sanitary sewer system.  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.  Action EM-5.7: Amend the Municipal Code to codify the Outside Sewer Service policies for residential uses.
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 Goal ESPS-9: The City of San Carlos has a sustainable and resilient water supply despite the potential for more frequent and severe drought conditions.
 Action ESPS-9.2: Upgrade City waste and wastewater systems to accommodate projected drought-induced changes in water quality and availability and ensure long-term integrity of water supplies.
 Action ESPS-9.2: Work with responsible agencies to ensure the design and construction of utility infrastructure, including water supply, wastewater, and storm drain lines, and transportation infrastructure, including streets, trails, shared-use paths, and rail lines, can withstand projected increases in extreme precipitation and storm events.

Implementation of the proposed project would not require the construction or expansion of the SVCW WWTP or sewer collection system beyond what is already planned or under construction. Adherence to the SCMC requirements and the General Plan goals, policies, and actions would reduce wastewater generation rates over time, and therefore impacts associated with the sewer collection and treatment systems would be less than significant.

Significance without Mitigation: Less than significant.

UTIL-5 The proposed project would not result in a determination by the wastewater treatment provider which serves or may serve the proposed project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

As described in impact discussion UTIL-4, the SVCW WWTP is currently permitted to treat up to 29 MGD, and projects a wastewater flow rate to the facility of 17.9 MGD in 2040. The increase in wastewater demand for the City of San Carlos by 2045 is estimated to be 1.6 MGD, as shown in Table 4.17-9, which would result in a total treatment capacity of 19.5 MGD in 2040. This is well below the permitted capacity of 29 MGD. Therefore, the SVCW WWTP would have adequate capacity to serve the project’s demand in addition to existing commitments and future contributions to wastewater flow rates from areas outside of San Carlos.

New projects within the EIR Study Area would also be required to comply with the latest CALGreen and California Plumbing codes and implement active and passive water conservation measures.

Furthermore, as discussed in impact discussion UTIL-4, the Environmental Management (EM) Element and Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to utilities and service systems, including wastewater treatment capacity. The General Plan goals, policies, and actions listed in impact discussion UTIL-4 would serve to minimize potential adverse impacts related to wastewater collection and treatment capacity.

With continued compliance with applicable regulations, wastewater generated by the proposed project would not exceed the capacity of the SVCW WWTP. Also, the General Plan goals, policies, and actions listed in impact discussion UTIL-4 would ensure that future development would minimize impacts to 2045 GENERAL PLAN RESET DRAFT EIR

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wastewater collection and treatment capacity. Therefore, the proposed project would not result in a determination by the wastewater treatment provider that there is not adequate capacity to serve the EIR Study Area’s projected demand in addition to the demands of other wastewater dischargers.

Therefore, the impacts would be less than significant.

Significance without Mitigation: Less than significant.

UTIL-6 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to wastewater.

The context used for the cumulative assessment is the service area of the SVWC WWTP. In addition to wastewater discharged to the WWTP by the City, there are other dischargers, including Belmont, Redwood City, and portions of Menlo Park.

As discussed in impact discussion UTIL-4, the SVCW WWTP has a design capacity of 29 MGD and a projected total wastewater flow of 17.9 MGD in 2040. Therefore, there is a residual projected treatment capacity of 11.1 MGD and is expected to meet future growth in its service area.

Also, similar to the City of San Carlos, the other dischargers to the WWTP also have sewer collection system capital improvement programs. Future development within the City and WWTP service area would be required to comply with all applicable regulations and ordinances. Project applicants would have to pay wastewater capacity charges and property owners are required to pay an annual sewer service charge, which funds continued improvements to the wastewater collection and treatment system.

Therefore, with continued compliance with applicable regulations and future reductions in wastewater demands with water conservative efforts, cumulative development would not exceed wastewater collection or treatment capacities. Accordingly, the proposed project would not result in a cumulatively considerable impact related to wastewater, and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant.

4.17.3 SOLID WASTE

ENVIRONMENTAL SETTING
Regulatory Framework
Federal Regulations
The Resource Conservation and Recovery Act of 1976 (Title 40 of the Code of Federal Regulations), Part 258, contains regulations for municipal solid waste landfills and requires states to implement their own permitting programs incorporating the federal landfill criteria. The federal regulations address the 2045 GENERAL PLAN RESET DRAFT EIR

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location, operation, design (liners, leachate collection, run-off control, etc.), groundwater monitoring, and closure of landfills.

State Regulations
Integrated Waste Management Act
California’s Integrated Waste Management Act of 1989 (AB 939) requires that cities and counties divert 50 percent of all solid waste from landfills as of January 1, 2000 through source reduction, recycling, and composting. This act requires that each city and county prepare a Source Reduction and Recycling Element to be submitted to the Department of Resources Recycling and Recovery (CalRecycle), a department within the California Natural Resources Agency. AB 939 also establishes a goal for all California counties to provide at least 15 years of ongoing landfill capacity.

In 2007, SB 1016 amended AB 939 to establish a per capita disposal measurement system. The per capita disposal measurement system is calculated as a jurisdiction’s reported total disposal of solid waste divided by a jurisdiction’s population. CalRecycle sets a target per capita disposal rate for each jurisdiction. Each jurisdiction must submit an annual report to CalRecycle with an update of its progress in implementing diversion programs and its current per capita disposal rate.

Mandatory Commercial Recycling Act (AB 341)
AB 341 (Chapter 476) set a statewide solid waste diversion goal of 75 percent by 2020. AB 341, which was passed in 2011 and took effect July 1, 2012, mandates recycling for businesses producing four or more cubic yards of solid waste per week or multi-family residential dwellings of five or more units.

Under AB 341, businesses and multi-family dwellings of five or more units in the EIR Study Area must separate recyclables from trash and either subscribe to recycling services, self-haul their recyclables, or contract with a permitted private recycler.

Mandatory Organics Recycling Act (AB 1826)
AB 1826, which was enacted in 2014, mandates organic waste recycling for businesses and multifamily dwellings with five or more units. Starting January 1, 2020, all generators of 2 cubic yards or more of garbage, recycling, and compost combined per week must recycle organic waste. Organic waste includes food scraps, food-soiled paper waste, yard trimmings, and landscape materials. Organic waste can be recycled through composting, mulching, and anaerobic digestion which produces renewable energy and fuel. In addition to recycling food scraps, donating surplus food to local food banks can be part of the AB 1826 compliance effort. Multi-family dwellings do not need to have food-waste recycling on-site but must recycle yard and landscape materials. Recology San Mateo County offers these services to businesses and residences to comply with the requirements of AB 1826.

California Short-Lived Climate Pollutants Act (Senate Bill 1383) SB 1383 focuses on the elimination of methane gas created by organic materials in landfills and set targets to achieve a 50 percent reduction in the statewide disposal of organic waste by 2020 and a 75 percent reduction by 2025. Organic waste makes up half of what Californians send to landfills. SB 1383 2045 GENERAL PLAN RESET DRAFT EIR

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requires all businesses and residents to divert organic materials (including food waste, yard waste, and soiled paper products) from the landfill. The regulation took effect on January 1, 2022 and will require that organics collection service be provided to all residents and businesses. The collected organic waste must be recycled into new products, such as compost, mulch, biofuel, and electricity. Each city and county has an annual procurement target based on its population. Also, an edible food recovery program must be established by 2025 with the goal of recovering 20 percent of currently disposed edible food that would otherwise be sent to landfills to feed people in need. 60 Mandated food donors and food recovery organizations and services must keep records of the amount and dates of food donations and acceptances.

California Solid Waste Reuse and Recycling Access Act of 1991 The California Solid Waste Reuse and Recycling Access Act requires development projects to set aside areas for collecting and loading recyclable materials. This act required CalRecycle to develop a model ordinance for adoption by any local agency to provide adequate areas for the collection and loading of recyclable materials as part of development projects. Local agencies are required to adopt the model or an ordinance of their own that establishes standards, including space allocation, for the collection and loading of recyclable materials.

CALGreen Building Code
As previously described in Section 4.17.1.1 (Water Regulatory Setting) CALGreen establishes building standards for sustainable site development. Sections 4.408 and 5.408, Construction Waste Reduction Disposal and Recycling, mandate that, in the absence of a more stringent local ordinance, a minimum of 65 percent of nonhazardous construction and demolition debris generated during most new construction must be recycled or salvaged. CALGreen requires developers to prepare and submit a Construction and Demolition Recycling & Waste Reduction Plan, which is submitted to the City for approval, or use a waste management company with verifiable documentation. The waste management plan must:
 Identify the materials to be diverted from disposal by recycling, reuse on the project, or salvage for future use or sale.
 Specify if materials will be sorted on-site or mixed for transportation to a diversion facility.  Identify the diversion facility where the material collected can be taken.  Identify construction methods employed to reduce the amount of waste generated.  Specify that the amount of materials diverted shall be calculated by weight or volume, but not by both.
60 CalRecycle, 2021, SB 1383 Education and Outreach Resources, https://www.calrecycle.ca.gov/organics/slcp/education, accessed October 23, 2024.
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Regional Regulations
San Mateo County Environmental Health Division
San Mateo County Environmental Health Division (SMCEHD) is the State-certified Local Enforcement Agency for solid waste in San Mateo County. The Solid Waste Program under the SMCEHD ensures that businesses, garbage collection and disposal companies, and residents follow the federal, State, and local standards and permitting requirements for solid waste. Inspectors from the Solid Waste Program issue permits and inspect four transfer/material recovery facilities and one anaerobic digestion facility, as well as one active landfill, Ox Mountain, in Half Moon Bay.61 These facilities are monitored for compliance with State standards for the proper handling and disposal of solid waste. Seventeen closed landfills in different locations throughout the County are also monitored.

San Mateo County Office of Sustainability: Solid Waste Management San Mateo County Office of Sustainability: Solid Waste Management administers and implements the solid waste management and resource conservation programs and policies throughout the County. The Waste Reduction Program’s mission is to advance environmental sustainability by working with residents, businesses, and institutions throughout San Mateo County to encourage environmental stewardship, implement resource conservation programs and policies, and ensure compliance with the California solid waste regulations.62
RethinkWaste (South Bayside Waste Management Authority) RethinkWaste, also known as the South Bayside Waste Management Authority, is a joint powers authority formed by eleven local jurisdictions (Member Agencies) within San Mateo County, including the City of San Carlos. 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. RethinkWaste also provides oversight and management of service providers that collect, process, recycle, and dispose of materials and educates residents and businesses through waste reduction, recycling, and solid waste programs. South Bay Recycling operates the Shoreway Environmental Center on behalf of RethinkWaste. Recology San Mateo County provides recycle, compost, and garbage collection services for residents and businesses in San Mateo County.

Local Regulations
San Carlos General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and 61 San Mateo County Health, 2023, Solid Waste Program, https://www.smchealth.org/solidwaste, accessed October 23, 2024.
62 San Mateo County Office of Sustainability, 2024. Solid Waste Management, https://performance.smcgov.org/stories/s/Office-of-Sustainability-Solid-Waste-Management-40/nm65-ibfd/, accessed October 23, 2024.
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assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.17.3.3, Impact Discussion.

City of San Carlos Municipal Code
The SCMC is the primary document that regulates the policies and practices of the City. The SCMC contains the Zoning Code, the Subdivision Ordinance, the Building and Construction Code, and other titles that are important in implementing the goals, policies, and actions of the General Plan. The SCMC includes various directives pertaining to solid waste as follows:
 Chapter 8.04, Solid Waste, also known as the solid waste ordinance, contains provisions for solid waste collection and disposal. The chapter requires all residential, commercial, or industrial properties in the City to contract with a City franchisee for the removal and disposal of solid waste generated by the property. The franchisee is authorized to charge all customers a fee for the collection and transport of the solid waste.
 Chapter 8.05, Recycling And Diversion Of Construction And Demolition Debris, requires that each local jurisdiction in the State divert fifty percent of solid waste from landfill by December 31, 2000, through source reduction, recycling, and composting activities. This chapter establishes diversion rates for construction and demolition debris to meet the AB 939 mandates and reduce the amount of solid waste that is landfilled. In general, projects are required to divert at least 60 percent of all generated tonnage. Every project applicant must submit a waste management plan (WMP) to the Department of Planning and Building as part of the building permit process. The WMP shall include:
1) the estimated volume or weight of project construction and demolition debris, by materials type; 2) the maximum volume and weight of these materials that can feasibly be diverted via reuse or recycling; 3) the vendor or facility that will be used to collect or receive the material; and 4) the estimated volume or weight of construction and demolition debris that will be landfilled.  Chapter 8.24, Recycling and Collection of other Wastes, regulates the location, height, size and design features of recycling and trash enclosures and containers. These regulations are necessary in order to lengthen the life span of the landfill and decrease the cost of hauling to the landfill in addition to encourage the reuse of recyclable materials.  Chapter 8.25, Mandatory Commercial and Multifamily Residential Recycling, establishes requirements for the collection, recycling, and processing of recyclable and organic materials generated from commercial facilities, multi-family dwellings, and special events. These requirements are intended to assist the City in meeting the recycling and landfill diversion goals and reduce GHG emissions. Multi-family generators must participate in the programs covered by this chapter and segregate recyclable materials from garbage and deposit them in designated containers provided by the solid waste collector. These requirements apply to all commercial or multi-family solid waste customers that generate two cubic yards or more of garbage per week.  Chapter 8.60, Mandatory Organic Waste Disposal Reduction, includes the State regulations and mandatory requirements for organic waste recycling and reduction. 2045 GENERAL PLAN RESET DRAFT EIR

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City of San Carlos Model Disposable Food Service Ware Ordinance Adopted in October 2021 by the San Carlos City Council, the Model Disposable Food Service Ware Ordinance to reduce waste in the environment and litter in rivers and ocean, protect public health, and reduce dependence on plastic.63 This Ordinance will apply to food facilities that:
 Operate within the unincorporated areas of San Mateo County and cities in the county that adopt the County of San Mateo’s Disposable Food Service Ware Ordinance; and  Provide prepared food to the general public.

Existing Conditions
Solid Waste Collection
Recology San Mateo County (Recology) provides recycling, compost, and garbage collection in San Carlos and San Mateo County. Recology offers the following for commercial customers: 1) single-stream recycling including metal, plastic, paper, and glass; 2) compost collection, including food scraps, soiled paper products, and landscaping trimmings; and 3) landfill disposal for all other trash and garbage. All waste is transported to the Shoreway Environmental Center in the City of San Carlos, which consists of a transfer station, a materials recovery facility in which recyclable materials are retrieved from the waste stream and shipped to recyclers, and a public recycling facility. The facility also accepts construction and demolition debris. The Shoreway Environmental Center has a maximum permitted throughput of 3,000 tons/day.64
Solid Waste Disposal
South Bay Recycling (SBR) is the contractor hired by RethinkWaste to operate the Shoreway Environmental Center. SBR is responsible for the marketing and selling of recyclable materials to domestic and overseas markets, transporting loads of organic waste to Blossom Valley Organics in Vernalis and Newby Island in San Jose, transporting garbage to the Ox Mountain Landfill in Half Moon Bay, and delivering construction and demolition debris to Zanker Recycling in San Jose.65 63 County of San Mateo, 2022, Model Disposable Food Service Ware Ordinance Summary, https://www.smcsustainability.org/wp-content/uploads/Foodware_Aware_Summary_Final.pdf, accessed on October 1, 2024. 64 California Department of Resources Recovery and Recycling, 2024, Solid Waste Information System, SWIS Facility Detail:

Shoreway Environmental Center, https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1575?siteID=3236, accessed October 23, 2024.
65 RethinkWaste, 2022, Service Providers and Area Map, https://rethinkwaste.org/about/service-area-map-providers/, accessed November 2, 2022.
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Landfills
The majority of the solid waste generated in San Carlos is transported to the Corinda Los Trancos Landfill (Ox Mountain Landfill) near Half Moon Bay. 66 The landfill is expected to reach capacity in 2034. 67 The
Corinda Los Trancos Landfill has a daily maximum throughput of 3,598 tons per day and a remaining capacity of 22 million cubic yards.
68 After solid waste is collected and sorted at the San Carlos Transfer Station, it is transported to the Los Trancos Canyon (Ox Mountain) Landfill in Half Moon Bay. Table 4.17-10, Landfill Capacity, provides more information on the landfill capacity and closing date for the primary landfill that receives solid waste from the City of San Carlos.

TABLE 4.17-10 LANDFILL CAPACITY
Landfill Name and Location
Maximum
Permitted
Throughput,
tons/day
2023 Average
Disposal, a
tons/day
Residual
Disposal
Capacity,
tons/day
Remaining
Capacity,
cubic yards
Estimated
Closing Year
Ox Mountain Landfill
(Corinda Los Trancos)
Half Moon Bay, CA 94019
3,598 1,808 1,790 22,180,000 2034
Notes:
a. Average daily disposal is estimated based on 300 operating days per year, assuming the landfill is open six days per week except certain holidays.

Data is based on total 2020 tonnage for this landfill from CalRecycle’s Landfill Summary Tonnage Report and SWIS Facility/Site Activity Details.

Source: CalRecycle, 2023. Landfill Tonnage Reports, accessed on October 23, 2024 at https://www2.calrecycle.ca.gov/LandfillTipFees Solid Waste Diversion and Recycling
As of 2022, the latest year for which data are available, there were numerous solid waste diversion programs in San Carlos, including those for composting, Facility Recovery, household hazardous waste collection, policy incentives, public education, recycling, source reduction at businesses and government entities, and special waste materials such as tires, scrap metal, wood waste, and concrete/asphalt/rubble.
69 Compliance with the diversion requirement in AB 939 is measured in part by comparing actual disposal rates with target disposal rates; disposal rates at or below target rates are consistent with AB 939. For 2022, the target disposal rates for San Carlos were 7.5 pounds per day (ppd) per resident and 14.4 ppd 66 CalRecycle, 2024, Jurisdictional Disposal and Alternative Daily Cover (ADC) Tons by Facility. https://www2.calrecycle.ca.gov/LGCentral/DisposalReporting/Destination/DisposalByFacility, accessed October 23, 2024. 67 CalRecycle, 2024 (accessed), SWIS Facility/Site Activity Details - Corinda Los Trancos Landfill ( Ox Mtn) (41-AA-0002), https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223, accessed October 2, 2024. 68 CalRecycle, 2024 (accessed), SWIS Facility/Site Activity Details - Corinda Los Trancos Landfill ( Ox Mtn) (41-AA-0002), https://www2.calrecycle.ca.gov/SolidWaste/SiteActivity/Details/1561?siteID=3223, accessed October 2, 2024. 69 CalRecycle, 2024 (accessed), Jurisdiction Waste Diversion Program Summary, https://www2.calrecycle.ca.gov/LGCentral/DiversionProgram/JurisdictionSummary, accessed on October 4, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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per employee. The actual disposal rates in 2022were 6.8 ppd per resident and 10.7 ppd per employee, which are below target rates and thus are consistent with AB 939. 70 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant impact related to solid waste if it would:

UTIL-7 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.

UTIL-8 Be out of compliance with federal, State, and local management and reduction statutes and regulations related to solid waste.

UTIL-9 In combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to solid waste.

IMPACT DISCUSSION
UTIL-7 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.

Under the proposed project, the population is anticipated to increase by 46,450 residents and 47,320 jobs. As shown in Table 4.17-11, Increase in Solid Waste Generation (2045), this level of growth would result in an increase in solid waste of approximately 195 tons per day, or 71,210 tons per year. These numbers are conservative because, with continued recycling and waste reduction programs implemented by the City and ReThinkWaste, the waste generation rates would be reduced over time.

TABLE 4.17-11 INCREASE IN SOLID WASTE GENERATION RATES (2045) Category
Proposed Project
Net Change
(Population or SF)
Solid Waste
Generation Rate (ppd)
Increase in Solid
Waste (tons/day)
Increase in Solid
Waste (tons/year)
Residents 15,620 6.8 53 19,384
Jobs 26,540 10.7 142 51,826
Total 195 71,210
Source: CalRecycle, 2023; PlaceWorks, 2023.

As shown in Table 4.17-11, an increase of 195 tons/day with the proposed project would be about 11 percent of the current residual capacity of 1,790 tons/day at Ox Mountain Landfill. In addition, some of the solid waste from the City of San Carlos is transported to other landfills in the Bay Area and the majority of the waste generated in the City is diverted from landfill disposal through recycling and composting. This estimate conservatively assumes that all of the generated waste is landfilled. The 70 CalRecycle, 2022, Jurisdiction Diversion/Disposal Rate Detail, https://www2.calrecycle.ca.gov/LGCentral/DiversionProgram/JurisdictionDiversionPost2006, accessed on October 4, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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results in Table 4.17-11 show that the proposed project would not generate solid waste in excess of the capacity of the landfills that serve the City.

Furthermore, all new development pursuant to the proposed project would require compliance with Division 4.4 of the 2022 CALGreen Building Code, which requires that at least 65 percent of nonhazardous construction and demolition waste from residential and nonresidential construction operations be recycled and/or salvaged for reuse. New development and redevelopment would also need to comply with the requirements of AB 341 that mandates recycling for commercial and multifamily residential land uses.

The Environmental Management (EM) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to utilities and service systems, including solid waste. The following General Plan goal, policies, and actions would serve to minimize potential adverse impacts on solid waste:
 Goal EM-12: Reduce solid waste disposal and increase recycling.  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.  Action EM-12.1: Implement measures in the Climate Action Plan to reduce solid waste and increase recycling and reuse.
 Action EM-12.2: Consider incentives to households and businesses to reduce the volume of solid waste sent to the landfill.
 Action EM-12.3: Require adequate facilitation of recycling in all new development and new commercial tenancies.
 Action EM-12.4: Encourage recycling programs in existing multi-family buildings.  Action EM-12.5: Encourage building deconstruction in lieu of demolition. Require a construction and demolition debris waste plan to maximize recycling rates.  Action EM-12.6: Encourage the use of recycled pavement and/or permeable products for public and private parking lots and driveways.
 Action EM-12.7: Support the commercial food scraps and organics recycling program.  Action EM-12.8: Evaluate options for increasing ease of properly disposing household hazardous waste, including but not limited to electronics, fluorescent bulbs, thermometers, spent fire extinguishers and pharmaceuticals.
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With continued compliance with the applicable regulations, leading to increased recycling and waste diversion, and adherence to the General Plan goal, policies, and action listed above, anticipated rates of solid waste disposal from the proposed project would be less than significant with respect to permitted landfill capacity. In addition, the City is well below the CalRecycle target disposal rates and meets the regulatory requirements of AB 939. Therefore, implementation of the proposed project would not generate solid waste in excess of State and local standards, or in excess of the capacity of the landfills, or otherwise impair the attainment of solid waste reduction goals and the impact is less than significant.

Significance without Mitigation: Less than significant.

UTIL-8 The proposed project would not be out of compliance with federal, State, and local management and reduction statutes and regulations related to solid waste.

As discussed under impact discussion UTIL-7, Recology San Mateo County, which serves the EIR Study Area, complies with all State requirements to reduce the volume of solid waste through recycling and organic waste diversion. The City’s per capita disposal rates of 6.8 ppd per resident and 10.7 ppd per employee are well below the CalRecycle targets of 7.5 pounds per day (ppd) for residents and 14.4 ppd for employees. In addition, all future development would comply with Division 4.4 of the CALGreen Building Code, which requires that at least 65 percent of nonhazardous construction and demolition waste from nonresidential construction operations be recycled and/or salvaged for reuse.

Future development would also comply with AB 341, which mandates recycling for commercial and multifamily residential land uses as well as schools and school districts. Additionally, future businesses that generate organic waste in amounts over a certain threshold would be mandated to recycle organic matter in accordance with AB 1826. Therefore, the City and Recology would comply with all applicable federal, State, and local solid waste regulations, and impacts would be less than significant.

Significance without Mitigation: Less than significant.

UTIL-9 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to solid waste.

The area considered for cumulative impacts to solid waste disposal facilities is San Mateo County, which is serviced by Recology San Mateo County. As reported by ABAG, the total population of San Mateo County is expected to increase from 796,925 to 916,590 by 2040.71 Assuming that solid waste generation increases at the same rate as the population (15 percent), the increase in the amount of waste generated in the County by 2040 would be about 2,079 tons per day. 72 Conservatively assuming that all 71 ABAG, 2018. Plan Bay Area Projections 2040.
72 2023 Average Disposal to Ox Mountain Landfill x 0.15 = 1,808 tons/day x 0.15 = 2,079 tons/day. 2045 GENERAL PLAN RESET DRAFT EIR

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of this waste is landfilled, although the 2022 diversion rate by ReThinkWaste is about 65 percent73, the additional waste generated by San Mateo County, including the waste generated by San Mateo with the proposed project, would still be only about 63 percent of the daily residual capacity of Ox Mountain Landfill.

In addition, new development within San Mateo County would comply with Division 4.4 of the 2022 CALGreen Building Code, which requires that at least 65 percent of nonhazardous construction and demolition waste from residential and nonresidential construction operations be recycled and/or salvaged for reuse. This would also reduce the volume of solid waste transported to the landfills.

Continued compliance with the applicable regulations and an increase in recycling and landfill diversion rates would ensure that solid waste cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant.

4.17.4 STORMWATER INFRASTRUCTURE

ENVIRONMENTAL SETTING
Regulatory Framework
The regulatory framework for stormwater is described in detail in Chapter 4.9, Hydrology and Water Quality, of this Draft EIR. The regulatory requirements that pertain solely to storm drain systems are repeated below.

Federal Regulations
National Pollutant Discharge Elimination System
The NPDES permit program was established by the Clean Water Act to regulate municipal and industrial discharges to surface waters of the United States from their municipal separate storm water systems (MS4s). Under the NPDES program, all facilities that discharge pollutants into waters of the United States are required to obtain an NPDES permit. Requirements for stormwater discharges are also regulated under this program. The City is within the jurisdiction of the San Francisco Bay RWQCB (Region 2) and is subject to the waste discharge requirements of the Municipal Separate Storm Sewer System (MS4) Permit (Order No. R2-2022-0018 and NPDES Permit No. CAS612008).74 Under Provision C.3 of the MS4 Permit, the permittees use their planning authorities to include appropriate source control, site design, and stormwater treatment measures in new development and 73 ReThinkWaste, 2024, Annual Report 2023, https://rethinkwaste.org/wp-content/uploads/2024/05/2023-AnnualReport.pdf, accessed November 4, 2024. 74 California Regional Water Quality Control Board, San Francisco Bay Region, May 2022, Municipal Regional Stormwater NPDES Permit, Order No. R2-2022-0018, NPDES Permit No. CAS612008, https://www.waterboards.ca.gov/sanfranciscobay/water_issues/programs/stormwater/MRP/mrp5-22/R2-2022-0018.pdf, accessed October 21, 2024.
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redevelopment projects to address stormwater runoff pollutant discharges and prevent increases in runoff flows. This goal is accomplished primarily through the implementation of low impact development techniques.

State Regulations
On April 7, 2015, the SWQCB adopted an amendment to the Water Quality Control Plan for Ocean Waters of California to control trash. In addition, the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California added the section: Part 1, Trash Provisions. Together, they are collectively referred to as “the Trash Amendments.” The purpose of the Trash Amendments is to provide statewide consistency for the RWQCBs in their regulatory approach to protect aquatic life and public health beneficial uses, reduce environmental issues associated with trash in State waters, and focus limited resources on high-trash-generating areas.75 The Trash Amendments apply to all Phase I and II permittees under the NPDES municipal separate storm sewer systems (MS4) permits. Compliance with the Trash Amendment requires municipalities to install certified trash treatment control systems on all catch basins no later than December 2, 2030.76 Regional Regulations
San Mateo Countywide Water Pollution Prevention Program The San Mateo Countywide Water Pollution Prevention Program (SMCWPPP) is a partnership of the City/County Association of Governments (C/CAG), 20 incorporated Cities within the County, and the County of San Mateo, which share a common MS4 permit. This partnership also relies on each of the municipalities to implement local stormwater pollution prevention and control activities for its own local storm drain systems.

Post-construction stormwater quality requirements pursuant to the SMCWPPP are described in the C.3 Regulated Projects Guide (Version 1.0) issued in January 2020. The C.3 Regulated Projects Guide includes instructions for implementing site design measures, source controls, stormwater treatment measures, construction site controls, and low-impact development measures.

San Mateo County Stormwater Resource Plan
The San Mateo County Stormwater Resource Plan (SRP) is a comprehensive document that addresses specific stormwater runoff issues in the County with a watershed-based approach. The main goals of the SRP are to identify and prioritize opportunities to better utilize stormwater as a resource in San Mateo County through a detailed analysis of watershed processes, surface and groundwater resources, input 75 State Water Resources Control Board, April 7, 2015, Amendment to the Water Quality Control Plan for the Ocean Waters of California to Control Trash and Part 1 Trash Provisions of the Water Quality Control Plan for Inland Surface Waters, Enclosed Bays, and Estuaries of California, https://www.waterboards.ca.gov/water_issues/programs/trash_control/docs/01_final_sed.pdf, accessed October 21, 2024. 76 State Water Resources Control Board, 2023, Storm Water Program - Trash Implementation Program. https://www.waterboards.ca.gov/water_issues/programs/stormwater/trash_implementation.html, accessed October 21, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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from stakeholders and the public, and analysis of multiple benefits that can be achieved through strategically planned stormwater management projects.77 These projects aim to capture and manage stormwater more sustainably, reduce flooding and pollution associated with runoff, improve biological functioning of plants, soils, and other natural infrastructure, and provide many community benefits, including cleaner air and water and enhanced aesthetic value of local streets and neighborhoods. SB 985 (Pavley, 2014) requires SRPs to be developed to be eligible for funding from future State bond measures for stormwater and dry weather capture projects.78
Local Regulations
San Carlos General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.17.4.3, Impact Discussion.

City of San Carlos Citywide Storm Drain System Master Plan Adopted in 2017, the Citywide Storm Drain System Master Plan (SDMP) identified causes of flooding within the storm drain system and developed alternatives for improvements that address the flooding. 77 City/County Association of Governments of San Mateo, February 2017, Stormwater Resource Plan for San Mateo County, https://ccag.ca.gov/wp-content/uploads/2017/02/SMC-SRP-Report-FINAL-1.pdf, accessed October 21, 2024. 78 City/County Association of Governments of San Mateo, 2022, San Mateo Storm Water Resources Plan, https://ccag.ca.gov/srp/, accessed October 21, 2024.
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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 system, and backwater and overtopping from creeks.

The Storm Drain Master Plan was created to develop alternative improvement projects that would improve the capacity of the system. These alternatives were compared and ranked in order to develop a prioritized Capital Improvement Program (CIP) that addresses the capacity issues and seeks to prioritize the more severe flooding problems.79
City of San Carlos Storm Drain Standards
The City’s Storm Drain Standards provides guidelines for the design and construction of storm drain projects. The guidelines establish minimum acceptable design criteria. More stringent requirements based on specific project conditions may be imposed at the discretion of Public Works and Utilities Department.

City of San Carlos Green Infrastructure Plan
Adopted in 2019, the Green Infrastructure Plan describes how the City will, over time, transition its existing “gray” (i.e., traditional) infrastructure to “green” infrastructure. This document also provides guidance to meet stormwater pollutant load reduction goals and creates a process for prioritizing the integration of Green Infrastructure (GI) into CIP projects. Green infrastructure uses vegetation, soil, and other elements to capture, treat, infiltrate and slow urban runoff. GI measures could include stormwater planters, rain gardens, tree wells, pervious pavement, infiltration systems, and green roofs.80 Existing Conditions
The City of San Carlos maintains all stormwater facilities within the city. Stormwater runoff in the City of San Carlos is conveyed to San Francisco Bay via a network of 56 miles of storm drains, creeks and drainage channels, and three pump stations.81 The drainage pipes range in size between 4-inch to 72- inch diameter. San Carlos is responsible for maintenance of culverts under roadways and creek segments with easements. Inaccessible creek areas and upstream reaches in the hills are generally on private property and respective property owners are responsible for maintenance. The City addresses flooding constraints through their CIP, which prioritizes improvement projects for the drainage system.

The City’s drainage system is divided into five watersheds, as described in Chapter 4.9, Hydrology and Water Quality, of this Draft EIR (see Figure 4.9-1, San Carlos Watersheds). The five watersheds include Cordilleras Creek, Brittan Creek, Pulgas Creek, Lower Pulgas Creek and Belmont Creek.82 Pulgas and 79 City of San Carlos, 2017, Citywide Storm Drain System Master Plan, dated April 2017. 80 City of San Carlos, 2019, Green Infrastructure Plan, https://cms3.revize.com/revize/sancarlos/SanCarlos-GI-PlanFINAL06-2019-Rev2.pdf, accessed on October 11, 2024. 81 City of San Carlos, 2017, Citywide Storm Drain System Master Plan, dated April 2017. 82 City of San Carlos, 2017, Citywide Storm Drain System Master Plan, dated April 2017. 2045 GENERAL PLAN RESET DRAFT EIR

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Brittan Creeks are the two main creeks that are entirely within the City of San Carlos. The lengths of these creeks are mostly unhardened channels, with hardened channels in the upper reaches and the lower flatlands in eastern San Carlos, where Brittan Creek joins Pulgas Creek via an underground conduit (paralleling El Camino Real). Following the confluence of Pulgas Creek and Brittan Creeks, the combined flow drains into the Smith Slough, south of Bair Island.

STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant impact related to stormwater infrastructure if it would:

UTIL-10 Require or result in the relocation or construction of new or expanded stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects.

UTIL-11 In combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to stormwater infrastructure.

IMPACT DISCUSSION
UTIL-10 The proposed project would not require or result in the relocation or construction of new or expanded stormwater drainage facilities, the construction or relocation of which could cause significant environmental effects.

New development and/or redevelopment as part of the proposed project would result in an increase in impervious surfaces, which in turn could result in an increase in stormwater runoff, higher peak discharges to drainage channels, and the potential to cause nuisance flooding in areas without adequate drainage facilities. However, most of the City is already built out and future development sites are in infill areas that are already developed and paved. Therefore, new development on these sites should not create a significant increase in impervious surfaces.

Also, regulated projects that create or replace 5,000 square feet or more of impervious surface would be required to implement site design, source control, and stormwater treatment and runoff measures using specific numeric sizing criteria based on the volume and flow rate of stormwater that is generated. Each project undergoes review by City personnel to ensure that the regulatory requirements for temporary on-site stormwater runoff retention have been met. This would minimize the amount of stormwater runoff from future development in the EIR Study Area.

With the implementation of these provisions for future development, there should not be significant increases in stormwater runoff to the City’s storm drain system. The construction of new stormwater facilities through the CIP, implementation of best management practices and on-site stormwater control measures, and preparation of the required documents and review by the City would serve to minimize any potential impacts associated with stormwater.
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The Environmental Management (EM) Element and Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider impacts to utilities and service systems, including stormwater infrastructure. The following General Plan goals, policies, and actions would serve to minimize potential adverse impacts to water quality and stormwater discharge:
 Goal EM-2: Promote healthy streams and riparian corridors.  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.  Action EM-2.2: Consider establishing incentives to stabilize creek banks utilizing natural methods.
 Goal ESPS-2: Reduce hazards associated with flooding and inundation.  Policy ESPS-2.1: Improve and maintain City storm drainage infrastructure in a manner that reduces flood hazards.
 Policy ESPS-2.2: Maintain and prioritize restoration of a healthy riparian corridor in Citymaintained flood control channels such as Pulgas Creek and Belmont Creek to reduce the risk of flooding due to erosion, siltation, blockage, and heavy undergrowth; and increase community access to channels with improved stormwater and flood management strategies.  Policy ESPS-2.3: Maintain a strong and enforceable Stream Development and Maintenance Ordinance for all city creeks and their tributaries.
 Policy ESPS-2.4: Minimize impervious surfaces to reduce stormwater runoff and increase flood protection.
 Policy ESPS-2.7: Coordinate with neighboring jurisdictions on approaches to flooding and creek maintenance.
 Policy ESPS-2.10: Incorporate stormwater drainage systems in development projects to effectively control the rate and amount of runoff to prevent increases in downstream flooding potential.
 Action ESPS-2.2: Amend the Stream Development and Maintenance Ordinance to: (1) include all creeks and tributaries, including Pulgas Creek and Belmont Creek, to strengthen the effectiveness of existing policies and to create vital and accessible community open space with improved stormwater and flood management strategies; (2) increase the required setbacks and landscaping provisions from the existing creek top to improve stormwater detention capacity and to help address flooding issues and creek restoration; (3) prohibit general vehicle access along the creek within the Stream Development Ordinance overlay district.

Compliance with the regulatory provisions in the MS4 permit that limit runoff from new development and these General Plan goals, policies, and actions and would ensure that the implementation of the proposed project would not result in significant increases in runoff and would not contribute to the construction of new storm drain facilities or expansion of existing facilities that would cause significant 2045 GENERAL PLAN RESET DRAFT EIR

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environmental impacts. In addition, the City would continue to repair, rehabilitate, and upgrade the storm drain system through implementation of the CIP program. Therefore, impacts with respect to stormwater infrastructure would be less than significant.

Significance without Mitigation: Less than significant.

UTIL-11 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in significant cumulative impacts with respect to stormwater infrastructure.

The analysis of cumulative storm drainage impacts considers future development within the five watersheds that encompass the EIR Study Area. Cumulative projects could result in an incremental increase in impervious surfaces that could increase stormwater runoff and impact existing storm drain facilities. However, all cumulative projects would be required to comply with City and County ordinances and General Plan goals, policies, and actions, as well as the MS4 permit, which would minimize stormwater runoff.

Development within the EIR Study Area would require conformance with State and City policies that would reduce hydrology and infrastructure construction impacts to less than significant levels. Any new development in the city would be subject to the General Plan Reset goals, policies, and actions listed in impact discussion UTIL-10 and City ordinances, design guidelines, zoning codes, and other applicable City requirements that reduce impacts related to hydrology and stormwater drainage facilities. More specifically, potential changes related to stormwater flows, drainage, impervious surfaces, and flooding would be minimized by the implementation of stormwater control measures, retention, infiltration, and low-impact-development measures and review by the City’s Public Works Department to integrate measures to reduce potential stormwater drainage and flooding impacts.

All cumulative projects in unincorporated County land within the watershed areas would be subject to similar permit requirements and would be required to comply with various municipal codes and policies and County ordinances, as well as numerous water quality regulations that control construction-related and operational discharge of pollutants in stormwater. The water quality regulations implemented by the San Francisco Bay RWQCB take a basinwide approach and consider water quality impairment in a regional context. For example, the NPDES Construction Permit ties receiving water limitations and basin plan objectives to terms and conditions of the permit, and the MS4 Permit also applies to San Mateo County to manage stormwater systems and be collectively protective of water quality. For these reasons, impacts from future development within the EIR Study Area related to stormwater infrastructure construction are not cumulatively considerable.

In combination with past, present, and reasonably foreseeable projects, proposed development and redevelopment within the EIR Study Area would not result in a cumulatively considerable impact to stormwater infrastructure and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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4.17.5 ENERGY INFRASTRUCTURE

ENVIRONMENTAL SETTING
This section provides a general description of the regulatory setting addressing existing electric, natural gas and telecommunications infrastructure, supply, and demand in the City of San Carlos. Chapter 4.5, Energy, of this Draft EIR analyzes the proposed project’s potential impacts associated with energy usage.

This section focuses on the infrastructure systems associated with electricity, natural gas, and telecommunication services.

Regulatory Framework
The federal and State regulatory framework for energy is described in detail in Chapter 4.5, Energy, of this Draft EIR. The regulatory requirements that pertain solely to energy infrastructure are repeated below.

Federal Regulations
National Energy Policy
Established in 2001 by the National Energy Policy Development Group, the National Energy Policy is designed to help the private sector and state and local governments promote dependable, affordable, and environmentally sound production and distribution of energy for the future. Key issues addressed by the energy policy are energy conservation, repair and expansion of energy infrastructure, and ways of increasing energy supplies while protecting the environment.

Energy Policy Act of 2005
Passed by Congress in July 2005, the Energy Policy Act includes a comprehensive set of provisions to address energy issues. This Act includes tax incentives for energy conservation improvements in commercial and residential buildings, fossil fuel production and clean coal facilities, and construction and operation of nuclear power plants, among other things. Subsidies are also included for geothermal, wind energy, and other alternative energy producers.

Energy Independence and Security Act of 2007
Signed into law in December 2007, the Energy Independence and Security Act contains provisions designed to increase energy efficiency and the availability of renewable energy. The Act contains provisions for increasing fuel economy standards for cars and light trucks, while establishing new minimum efficiency standards for lighting as well as residential and commercial appliance equipment.

National Gas Pipeline Safety Act of 1968
The Natural Gas Pipeline Safety Act of 1968 authorizes the United States Department of Transportation to regulate pipeline transportation of flammable, toxic, or corrosive natural gas and other gases as well as the transportation and storage of liquefied natural gas. The Pipeline and Hazardous Materials Safety 2045 GENERAL PLAN RESET DRAFT EIR

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Administration within the Department of Transportation develops and enforces regulations for the safe, reliable, and environmentally sound operation of the nation's 2.6-million-mile pipeline transportation system. The regulations enacted under this act have been updated several times. The latest revision is dated May 2023 and includes additional safety regulations for gas transmission pipelines, including repair criteria, integrity management improvements, cathodic protection, and other inspection and maintenance procedures. The regulations are encoded in 49 Code of Federal Regulations, Part 192.

State Regulations
Warren-Alquist Act
Established in 1974, the Warren-Alquist Act created the California Energy Commission (CEC) in response to the energy crisis of the early 1970s and the state’s unsustainable growing demand for energy resources. The CEC’s core responsibilities include advancing State energy policy, encouraging energy efficiency, certifying thermal power plants, investing in energy innovation, developing renewable energy, transforming transportation, and preparing for energy emergencies. The Warren-Alquist Act is updated annually to address current energy needs and issues, and its latest revision is dated January 2022.

California Public Utilities Commission Long Term Energy Efficiency Strategic Plan Adopted in September 2008 and updated in January 2011, the California Public Utilities Commission (CPUC) Long Term Energy Efficiency Strategic Plan provides a framework for energy efficiency in California through the year 2020 and beyond. It articulates a long-term vision, as well as goals for each economic sector, identifying specific near-, mid-, and long-term strategies to assist in achieving these goals. The plan sets forth the following four goals, known as “Big Bold Energy Efficiency Strategies,” to achieve significant reductions in energy demand:
 All new residential construction in California will be zero net energy by 2020.  All new commercial construction in California will be zero net energy by 2030.  Heating, ventilation, and air conditioning will be transformed to ensure that its energy performance is optimal for California’s climate.
 All eligible low-income customers will be given the opportunity to participate in the low-income energy efficiency program by 2020.

The CPUC and CEC have adopted the following goals to achieve zero net energy levels by 2030 in the commercial sector:
 Goal 1: New construction will increasingly embrace zero net energy performance (including clean, distributed generation), reaching 100 percent penetration of new starts in 2030.  Goal 2: 50 percent of existing buildings will be retrofit to zero net energy by 2030 through achievement of deep levels of energy efficiency and with the addition of clean distributed generation.
 Goal 3: Transform the commercial lighting market through technological advancement and innovative utility initiatives.
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California Energy Code
The State of California provides a minimum standard for energy conservation through Title 24, Part 6 California Code of Regulations, commonly referred to as the California Energy Code. The California Energy Code was first adopted by the California Energy Resources Conservation and Development Commission (now the CEC) in June 1977. The standards are updated on a three-year cycle to allow for consideration and possible incorporation of new energy efficiency technologies and methods. In August 2021, the CEC adopted the 2022 California Energy Code, which went into effect on January 1, 2023. The 2022 standards require mixed-fuel single-family homes to be electric ready to accommodate replacement of gas appliances with electric appliances. In addition, the new standards also include prescriptive photovoltaic systems and battery requirements for high-rise, multifamily buildings (i.e., more than three stories) and noncommercial buildings such as hotels, offices, medical offices, restaurants, retail stores, schools, warehouses, theaters, and convention centers.83 The 2025 Building Energy Efficiency Standards were adopted in September 2024 and will become effective on January 1, 2026. The Building Energy and Efficiency Standards and CALGreen undergo a triennial update with a goal to achieve zero net energy for residential buildings by 2020 and nonresidential buildings by 2030.
2023 Integrated Energy Policy Report
The CEC published the 2023 Integrated Energy Policy Report to identify pathways to deeply decarbonize the state’s electricity system in response to meeting the SB 100 goal of zero-carbon by 2045. The report provides an analysis of electricity sector trends, building decarbonization and energy efficient, zeroemission vehicles, energy equity, climate change adaptation, electricity reliability, natural gas assessment, and electricity, natural gas, and transportation energy demand forecasts. The aim is to leverage California’s clean electricity system to decarbonize, or remove carbon from, other portions of the state’s energy system. SB 1389 (Chapter 568, Statutes of 2002) requires the CEC to conduct assessments and forecasts of all aspects of energy industry supply, production, transportation, delivery, distribution, electricity demand, and price to develop energy policies that conserve resources, protect the environment, ensure energy reliability, enhance the State’s economy, and protect public health and safety.

California Green Building Standards
On July 17, 2008, the California Building Standards Commission adopted the nation’s first green building standards. CALGreen (24 California Code of Regulations, Part 11) was adopted as part of the California Building Standards Code. It includes mandatory requirements for new residential and nonresidential buildings throughout California. CALGreen is intended to (1) reduce greenhouse gas (GHG) emissions from buildings; (2) promote environmentally responsible, cost-effective, healthier places to live and 83 California Energy Commission, 2021, Amendments to the Building Energy Efficiency Standards (2022 Energy Code) Draft Environmental Report. CEC-400-2021-077-D.
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work; (3) reduce energy and water consumption; and (4) respond to the directives by the governor. The latest 2022 CALGreen code became effective on January 1, 2023.

The CALGreen code includes provisions to reduce construction waste, make buildings more efficient in the use of materials and energy, and reduce environmental impact during and after construction.

CALGreen contains requirements for construction site selection, stormwater control during construction, construction waste reduction, indoor water use reduction, material selection, natural resource conservation, site irrigation conservation, etc. The code provides for design options, allowing the designer to determine how best to achieve compliance for a given site or building condition. The code also requires building commissioning, which is a process for verifying that all building systems (e.g., heating and cooling equipment and lighting systems) are functioning at their maximum efficiency.84 Appliance Efficiency Regulations
California’s Appliance Efficiency Regulations contain energy performance, energy design, water performance, and water design standards for appliances (including refrigerators, ice makers, vending machines, freezers, water heaters, fans, boilers, washing machines, dryers, air conditioners, pool equipment, and plumbing fittings) that are sold or offered for sale in California (California Code of Regulations Title 20, Parts 1600–1608). These standards are updated regularly to allow consideration of new energy efficiency technologies and methods.85
California Energy Benchmarking and Disclosure
The Building Energy Benchmarking Program is mandated under AB 802 and requires owners of large commercial and multifamily buildings to report energy use to the CEC by June 1 annually. This program applies to all buildings with more than 50,000 square feet of gross floor area and owners of multifamily residential buildings with more than 50,000 square feet and 17 or more utility accounts. The bill requires each utility, upon the request and authorization of the owner, owner’s agent, or operator of a building covered under the regulation, to deliver or provide aggregated energy usage data for a covered building.

The required energy usage shall be reported to the CEC through the Energy Star Portfolio Manager.

California Renewable Portfolio Standards
A major component of California’s Renewable Energy Program is the renewables portfolio standard established under SB 1078 (Sher) and SB 107 (Simitian). The standard requires that a specified percentage of the electricity that utilities provide comes from renewable resources. Renewable sources of electricity include wind, small hydropower, solar, geothermal, biomass, and biogas. SB 1020, signed into law on September 16, 2022, requires renewable energy and zero-carbon resources to supply 90 percent of all retail electricity sales by 2035 and 95 percent by 2040. Additionally, SB 1020 requires all 84 California Building Standards Commission, July 2022, 2022 California Green Building Standards Code, California Code of Regulations, Title 24, Part 11, https://codes.iccsafe.org/content/CAGBC2022P1/copyright, accessed October 22, 2024. 85 California Energy Commission, 2017, 2016 Appliance Efficiency Regulations, https://pdf4pro.com/cdn/2016-applianceefficiency-regulations-5104f7.pdf, accessed October 22, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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State agencies to procure 100 percent of electricity from renewable energy and zero-carbon resources by 2035.

CPUC Natural Gas Regulations
The CPUC regulates natural gas utility rates and services as well as the transportation of natural gas over the extensive transmission and distribution pipeline systems. The CPUC also regulates gas storage facilities. The Gas Safety and Reliability Branch of the CPUC ensures that natural gas pipeline systems are designed, constructed, operated, and maintained according to the safety standards set by the CPUC and the federal government. The regulations are provided in the CPUC General Order No. 112-E and the Natural Gas Pipeline Safety Act of 2011.

The proposed project would be all electric with the exception of gas cooking appliances for the restaurant.
 Chapter 15.16, Streamlined Permitting Process for Small Residential Rooftop Solar Systems, allows for an expedited, streamlined solar permitting process that complies with the Solar Rights Act and AB 2188 to achieve timely and cost-effective installations of small residential rooftop solar energy systems.
 Chapter 15.20, Streamlined Permitting Process for Electric Vehicle Charging Stations, promotes the use of electric vehicles by creating an expedited, streamlined permitting process for electric vehicle charging stations while promoting public health and safety on the installation and use of such charging stations.
 Chapter 18.24, Wireless Telecommunications Facilities, provides standards for the development of telecommunications facilities and the installation of antennas to protect the visual character of the 2045 GENERAL PLAN RESET DRAFT EIR

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city and protect its residents from the possible adverse health effects associated with electromagnetic exposure.

Existing Conditions
Electricity
Two electricity providers, Pacific Gas and Electric Company (PG&E) and Peninsula Clean Energy (PCE) serve the EIR Study Area. The City also encourages the installation of local renewable resources, such as rooftop solar energy systems, which will reduce the cost of electricity for residents and businesses and enhance the local economy. The City is also pursuing policies and building code changes that would require new and existing buildings to be all-electric and eliminate natural gas as an energy source. By expanding on-site electricity generation and storage, San Carlos will not only reduce greenhouse gas emissions but also minimize the impact of grid failures and power disruptions.

Peninsula Clean Energy
PCE was launched by San Mateo County and all twenty of its cities, including San Carlos, to meet local climate action goals. PCE is the default electricity provider for all communities and cities in San Mateo County and offers two electricity options, each with a different percentage of sustainable energy.86 Residents and businesses in San Carlos are automatically enrolled in PCE’s ECOplus service, which is distributed to customers through PG&E’s existing grid infrastructure. PCE also offers rebates of up to $3,000 for heat pump water heaters, up to $3,500 for heat pump heating, ventilation, and air conditioning (HVAC) systems, and no-cost electric appliance, energy efficiency upgrade, and home repairs to income-qualified residents of San Mateo County. Customers have the option to opt-out of PCE renewable energy sources and receive their energy service from PG&E. PG&E is responsible for maintaining transmission lines, handling customer billing, and responding to new service requests and emergencies within the PCE service area.

Pacific Gas and Electric Company
PG&E is a publicly traded utility company that generates, purchases, and transmits energy under contract with the CPUC. PG&E’s service territory is 70,000 square miles, roughly extending north to south from Eureka to Bakersfield, and east to west from the Sierra Nevada to the Pacific Ocean. PG&E’s electricity distribution system consists of 106,681 circuit miles of electric distribution lines and 18,466 circuit miles of interconnected transmission lines with approximately 5.5 million electric customer accounts.87
The electricity is generated by a combination of sources such as natural gas-fired power plants, nuclear power plants, and hydro-electric dams as well as newer sources of energy such as wind turbines and 86 City of San Mateo, 2024, Peninsula Clean Energy. https://www.cityofsanmateo.org/3261/Peninsula-Clean-Energy, accessed on October 22, 2024.
87 PG&E, 2024, Company Profile. https://www.pge.com/en/about/company-information/company-profile.html, accessed on October 22, 2024.
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photovoltaic plants, also known as solar farms. The electric grid is a network of high-voltage transmission lines that link power plants with the PG&E system. The distribution system, comprised of lower voltage secondary lines, is at the street and neighborhood level and consists of overhead or underground distribution lines, transformers, and individual service “drops” that connect to the individual customer.

In 2022, approximately 38 percent of PG&E’s energy generated came from renewable resources including biopower, geothermal, small hydroelectric, solar, and wind power. PG&E’s portfolio consisted of 49 percent nuclear generation, 8 percent large hydroelectric facilities, and 5 percent natural gas.88 PG&E also has 1,200 megawatts of battery storage capacity already connected to the electric grid and has contracts totaling more than 3,000 megawatts of capacity by 2025.89 PG&E’s projected average annual electricity demand growth (baseline-demand forecast) between 2023 and 2040 is approximately 2.0 percent. Total baseline-electricity consumption in PG&E’s service area was 107,394 gigawatt-hours per year in 2023 and is forecast to increase to 145,974 gigawatt-hours in 2040. 90 PG&E is expected to meet its electricity demands in 2040.

Natural Gas
PG&E is also the natural gas service provider for the City of San Carlos. The natural gas system includes approximately 50,000 miles of natural gas pipelines, including 6,700 miles of transmission pipelines and 42,000 miles of distribution pipelines.91 The transmission pipelines move natural gas from compressor stations and storage facilities to regulator stations. At the regulator station, the pressure in the pipeline is reduced before gas enters the distribution system, which consists of smaller diameter pipelines that deliver gas to residences and businesses. PG&E has approximately 4.5 million natural gas customer accounts.92
Natural gas demand statewide is projected to decline an average of 1.1 percent per year through 2035.93 This is primarily due to the goal of reducing greenhouse gas emissions and the ordinances of some cities for new construction to be all electric. Gas demand is expected to decrease from 5,298 million cubic feet of gas per day in 2022 to 4,857 million cubic feet per day by 2035. California’s gas storage facilities 88 Pacific Gas & Electric Company, 2024, Clean Energy Solutions, https://www.pge.com/en/about/corporate-responsibilityand-sustainability/taking-responsibility/clean-energy-solutions.html, accessed October 22, 2024. 89 Pacific Gas & Electric Company, 2024, Renewable Energy Storage, https://www.pgecorp.com/assets/pgecorp/localized/ en/sustainability/corporate-responsibility-sustainability/reports/2023/planet/clean-energy/renewable-energy-storage/, accessed October 22, 2024.
90 California Energy Commission, 2024, California Energy Demand Forecast, 2023-2040, https://www.energy.ca.gov/datareports/reports/integrated-energy-policy-report/2023-integrated-energy-policy-report/2023-1, accessed October 22, 2024. 91 PG&E, 2024, PG&E Gas Systems. https://www.pge.com/en/about/pge-systems/gas-systems.html#tabs-fc6b80548fitem-94036063d6-tab, accessed October 22, 2024. 92 Pacific Gas and Electric Company, 2024, Company profilehttps://www.pge.com/en/about/company-information/ company-profile.html, accessed October 22, 2024.
93 California Public Utilities Commission, 2022, 2022 California Gas Report, https://www.socalgas.com/sites/default/files/ Joint_Utility_Biennial_Comprehensive_California_Gas_Report_2022.pdf, accessed October 22, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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supplement pipeline gas supply during high demand periods and also provide supply reliability. The supplies of natural gas would meet the demand through year 2035.94 Telecommunications and Internet Providers
Telecommunications services include wireless internet, cell phone and land line telephone, cable television, and satellite television. There are numerous telecommunication and internet providers that serve the EIR Study Area. Telecommunication providers include AT&T, T-Mobile, Verizon, and others.

Internet providers include Spectrum, Xfinity, AT&T, T-Mobile, Earthlink, and others. Multiple choices give San Carlos residents and businesses a variety of options when choosing telecommunication providers.

The wireless networks consist of fiber-optic cables that connect major internet hubs over long distances.

In San Mateo County, these cables typically run north to south throughout the County. The networks can be expanded by using small cell facilities, which are small antennae placed on existing utility poles or streetlights along with small pole-mounted radios and other accessory equipment. In this manner, the fiber-optic network can be easily expanded to meet the demand for wireless services. The current infrastructure is in place and sufficient to serve existing and future customers in San Carlos and the surrounding area.

The City will continue to require franchises to underground utility service connections for new development and underground existing overhead lines, when justifiable. The City will also continue to work with PG&E and other utility providers to underground new and existing overhead infrastructure as opportunities and funding permit.

STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant impacts related to energy infrastructure if it would:

UTIL-12 Require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

UTIL-13 In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to electric power, natural gas, or telecommunications facilities.
94 California Public Utilities Commission, 2022, 2022 California Gas Report. https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_Gas_Report_2022.pdf, accessed October 22, 2024.
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IMPACT DISCUSSION
UTIL-12 Implementation of the proposed project would not require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.

Electrical service to the EIR Study Area would be provided by PCE and PG&E through connections to existing off-site electrical lines and new on-site infrastructure. As shown in Table 4.17-12, Year 2045 Forecast Electricity Consumption, electricity use in the EIR Study Area would increase by 93,696,832 kilowatt-hours per year. However, the per person electricity use would decrease by 526 kWh per year, which reflects the replacement of existing building stock with new development that meets the California Building Energy Efficiency Standards and CALGreen standards.

TABLE 4.17-12 YEAR 2045 FORECAST ELECTRICITY CONSUMPTION Land Use
Electricity Usage (kWh/year) a
Existing Conditions Proposed Project Net Change
Nonresidential 108,796,274 162,826,388 54,030,114
Residential 66,307,811 105,974,529 39,666,718
Total 175,104,085 268,800,917 93,696,832
Service Population 51,610 93,770 42,160
Per Service Population Annual Consumption 3,393 2,867 -526 Note:
a. Residential energy and nonresidential energy forecasts do not account for reductions due to increases in energy efficiency from compliance with the Building Energy Efficiency Standards and CALGreen.

Source: See Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR.

As shown in Table 4.17-13, Year 2045 Forecast Natural Gas Consumption, natural gas use with the proposed project would increase in the EIR Study Area by 4,662,431 therms annually, or approximately 57 percent, from existing conditions. The per service population natural gas consumption is estimated to slightly decrease from 159 therms per person per year in 2024 to 137 therms per person per year in 2045. This is conservative as many projects in the city would be subject to the SCMC code’s all-electric requirements.

TABLE 4.17-13 YEAR 2045 FORECAST NATURAL GAS CONSUMPTION Land Use
Natural Gas Usage (Therms per year) a
Existing Conditions Proposed Project Net Change
Nonresidential 2,527,969 3,783,403 1,255,433
Residential 5,695,217 9,102,215 3,406,998
Total 8,223,187 12,885,618 4,662,431
Service Population 51,610 93,770 42,160
Per Service Population Annual Consumption 159 137 -22
Note: Totals may not add up due to rounding.
a. Residential energy and nonresidential energy forecasts do not account for reductions due to increases in energy efficiency from compliance with the Building Energy Efficiency Standards and CALGreen.

Source: See Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR 2045 GENERAL PLAN RESET DRAFT EIR

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These energy consumption rates are modest increases when considered in the context of PCE’s and PG&E’s service territories. The increase in electricity usage for the EIR Study Area is approximately 0.2 percent of PG&E’s projected energy supply in 2040, and the increase in natural gas consumption for the EIR Study Area is less than 0.01 percent of PG&E’s natural gas supply in 2035. 95 PG&E also states that
there would be sufficient natural gas supplies to cover its service area in 2035 and electrical supplies to cover its service area in 2040.

In addition, future development would be required to comply with the current and future updates to the California Energy Code and the CALGreen Code, which would contribute to reducing energy demands.

New buildings would also use new energy-efficient appliances and equipment, pursuant to the Appliance Efficiency Regulations, which would ensure the use of efficient electricity and natural gas consumption.

New and replacement buildings in compliance with these standards would generally have greater energy efficiency than existing buildings. Also, San Carlos is in the process of requiring all-electric appliances for new development.

The Land Use (LU) Element, Environmental Management (EM) Element, and Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contain goals, policies, and actions that require local planning and development decisions to consider utilities and service systems, including energy efficiency and infrastructure impacts. The following General Plan goal, policies, and actions would serve to improve energy infrastructure:
 Goal LU-5: Support and maintain land uses that contribute to a vibrant and resilient local economy and support the fiscal well being of the City.
 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.  Goal LU-8: Ensure excellence in all development design.  Policy LU-8.17: Require telecommunications and utility facilities to be sensitively placed, shielded, screened or lessened from view to the greatest extent possible through design review.  Policy LU-8.18: Encourage “green building” practices in new development and redevelopment, such as those that make a building more energy efficient and reduces its effect on human health and the environment through better siting, design, construction, maintenance and operation.  Goal EM-9: Reduce energy consumed citywide.
 Policy EM-9.1: Provide assistance and support efforts for increased energy efficiency for businesses and residences through a combination of incentives and regulations.  Policy EM-9.2: Support on-site generation of energy through alternative forms of energy production such as solar panels, wind turbines and biomass facilities.  Policy EM-9.5: Design all new construction and major remodels of government agency buildings to relevant green building standards.
95 PG&E’s projected energy supplies for electricity do not extend beyond 2040 and for natural gas do not extend beyond 2035.
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 Policy EM-9.6: Encourage new private construction and major remodels to be designed to meet or exceed Green Uniform Building Code requirements.
 Policy EM-9.7: Implement energy efficiency in City-owned and -operated facilities to reduce municipal energy costs and serve as a model for the community.  Goal ESPS-3: Agency Coordination: A resilient San Carlos is well prepared to minimize risks associated with wildfire.
 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.  Goal ESPS-10: A community that is resilient during and after extreme heat and severe weather events.
 Policy ESPS-10.4: Improve utility and transportation infrastructure, if needed, to ensure functionality during and following extreme heat and severe weather events, which may bring extreme precipitation and flooding
 Goal ESPS-13: Ensure adequate public services and high-quality design of public facilities to make San Carlos a safe, enjoyable, and quality community in which to live, work and shop.  Policy ESPS-13.10: Require existing overhead utility lines be placed underground in new development and redevelopment through a phased program of conversion in existing overhead areas.

Compliance with federal, State, and local regulations (e.g., Building Energy Efficiency Standards, CALGreen, and Renewables Portfolio Standards) would increase building energy efficiency and reduce building energy demands. Additionally, the General Plan goals, policies, and actions listed above will contribute to minimizing building-related energy demands and demands on nonrenewable sources of energy. Implementation of the General Plan goal, policies, and actions in conjunction with and complementary to regulatory requirements, would ensure that energy demand associated with growth under the proposed project would not be inefficient, wasteful, or unnecessary, therefore avoiding the need for new or expanded electric power and natural gas facilities. In addition, the energy providers and telecommunications providers that serve the EIR Study Area indicate that they have the capability to serve future increases in population within their service areas without significant changes to the existing infrastructure. Therefore, implementation of the proposed project would not require or result in the relocation or construction of new or expanded electric power, natural gas, or telecommunications facilities and impacts would be less than significant.

Significance without Mitigation: Less than significant. 2045 GENERAL PLAN RESET DRAFT EIR

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UTIL-13 The proposed project would not, in combination with past, present, and reasonably foreseeable projects, result in a cumulatively considerable impact to electric power, natural gas, or telecommunications facilities.

The area considered for cumulative impacts are the service areas of PCE and PG&E for electricity and PG&E for natural gas. Other projects within the service areas would increase electricity and natural gas demands.

The CPUC has identified the Integrated Energy Policy Report as “the appropriate venue for considering issues of load forecasting, resource assessment, and scenario analyses, to determine the appropriate level and ranges of resource needs for load serving entities in California.” The Integrated Energy Policy Report shows that California’s electricity sector is leading efforts to reduce GHG emissions and there has been an increase in electricity consumption of only 10 percent while California’s economy grew by 54 percent between 2000 and 2018.96 Natural gas consumption is expected to level out between 2020 and 2030 with no significant increase due to energy savings from new building standards and the implementation of city and county ordinances that require new construction to have all-electric appliances and heating.

In addition, all future projects developed within the PCE and PG&E service areas would implement the requirements of the California Energy Code and CALGreen Building Code. New buildings would also use new energy-efficient appliances and equipment, pursuant to the Appliance Efficiency Regulations.

Counties and cities review project design plans against these codes and ensure compliance before issuing construction permits. These measures would reduce the overall consumption of electricity and natural gas.

The energy providers and telecommunications providers that serve the EIR Study Area indicate that they have the capability to serve future increases in population within their service areas without significant changes to the existing infrastructure. In addition, the proposed 2045 General Plan Reset includes goals, policies, and actions that would contribute to minimizing inefficient, wasteful, or unnecessary energy consumption and ensure compliance with State, regional, or local plans for renewable energy, therefore avoiding the need for new or expanded electric power and natural gas facilities. Therefore, the proposed project would not result in a cumulatively considerable impact to electric power, natural gas, or telecommunication facilities and cumulative impacts would be less than significant.

Significance without Mitigation: Less than significant. 96 California Energy Commission, 2020. Adopted 2019 Integrated Energy Policy Report. 2045 GENERAL PLAN RESET DRAFT EIR

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4.18 WILDFIRE
This chapter of the Draft Environmental Impact Report (EIR) describes the regulatory framework and existing conditions of the City of San Carlos related to wildfire, and the potential impacts of the project from adopting and implementing the proposed 2045 General Plan Reset, and from future development and activities that would occur within the buildout horizon of the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by a discussion of potential impacts and cumulative impacts related to implementation of the proposed project.

4.18.1 ENVIRONMENTAL SETTING

REGULATORY FRAMEWORK
Federal Regulations
National Cohesive Wildfire Management Strategy
In the Federal Land Assistance, Management, and Enhancement Act of 2009 (FLAME Act), Congress mandated the development of a National Cohesive Wildland Fire Management Strategy for all lands in the United States. Wildfire management is guided by the National Cohesive Wildland Fire Management Strategy, which has three primary goals—resilient landscapes, fire adapted communities, and safe and effective wildfire response.1 These three goals enable land managers to manage vegetation and fuels; protect homes, communities, and other values at risk; manage human-caused ignitions; and effectively and efficiently respond to wildfires. California is part of the Western Regional Strategy Committee, chartered to support and facilitate the implementation of the National Cohesive Wildland Fire Strategy.

National Fire Protection Association Standards
National Fire Protection Association (NFPA) codes, standards, recommended practices, and guides are developed through a consensus standards development process approved by the American National Standards Institute. NFPA standards are recommended (advisory) guidelines for fire protection that are referenced in the California Fire Code (CFC). Specific standards applicable to wildfire hazards include, but are not limited to:
 NFPA 1141, Fire Protection Infrastructure for Land Development in Wildlands  NFPA 1142, Water Supplies for Suburban and Rural Fire Fighting  NFPA 1143, Wildland Fire Management
 NFPA 1144, Reducing Structure Ignition Hazards from Wildland Fire  NFPA 1710, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations
1 United States Department of the Interior and United States Department of Agriculture, 2014, The National Strategy: The Final Phase of Development of the National Cohesive Wildland Fire Management Strategy, https://www.forestsandrangelands.gov/documents/strategy/strategy/CSPhaseIIINationalStrategyApr2014.pdf, accessed October 4, 2024.
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State Regulations
California Department of Forestry and Fire Protection
The California Department of Forestry and Fire Protection (CAL FIRE) is dedicated to the fire protection and stewardship of over 31 million acres of California’s privately-owned wildlands. CAL FIRE provides fire assessment and firefighting services for land in State Responsibility Areas (SRA), responds to an average of 550,000 emergencies each year, conducts educational and training programs, provides fire planning guidance and mapping, and reviews general plan safety elements to ensure compliance with State fire safety requirements. CAL FIRE staff, or a designee, also reviews building permit applications, parcel maps, and use permits for construction or development in SRAs and Local Responsibility Areas.

The Board of Forestry and Fire Protection is a government-appointed approval body within CAL FIRE. It is responsible for developing the general forest policy of the State, determining the guidance policies of CAL FIRE, and representing the State’s interest in federal forestland in California. The Board of Forestry and Fire Protection also promulgates regulations and approves general plan safety elements that are adopted by local governments for compliance with State statutes.

The California Office of the State Fire Marshal supports the mission of CAL FIRE by focusing on fire prevention. These responsibilities include regulating buildings in which people live, congregate, or are confined; controlling substances and products that may, in and of themselves or by their misuse, cause injuries, death, and destruction by fire; providing statewide direction for fire prevention within wildland areas; regulating hazardous liquid pipelines; developing and renewing regulations and building standards; and providing training and education in fire protection methods and responsibilities. These are accomplished through major programs, including engineering, education, enforcement, and support from the Board of Forestry and Fire Protection. For jurisdictions in SRAs or very high fire hazard severity zones (FHSZs), the Land Use Planning Program division of the Office of State Fire Marshal reviews safety elements during the update process to ensure consistency with California Government Code, Section 65302(g)(3).

Together, the Board of Forestry and Fire Protection, Office of State Fire Marshal, and CAL FIRE protect and enhance the forest resources of all wildland areas of California that are not under federal jurisdiction.

Fire Hazard Severity Zones and Responsibility Areas
CAL FIRE designates FHSZs as authorized under California Government Code Sections 51175 et seq.

FHSZs may be designated Very High, High, or Moderate. CAL FIRE considers many factors when designating FHSZs, including fire history, existing and potential vegetation fuel, flame length, blowing embers, terrain, and weather patterns for the area. CAL FIRE designates FHSZs in two types of areas depending on which level of government is financially responsible for fire protection.  Local Responsibility Area. Incorporated communities are financially responsible for wildfire protection.
 State Responsibility Area. CAL FIRE and contracted counties are financially responsible for wildfire protection.
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CAL FIRE Strategic Plan 2024: Transforming Tomorrow
CAL FIRE developed the CAL FIRE Strategic Plan 2024: Transforming Tomorrow with goals and objectives to guide the vision and direction of CAL FIRE over the next five years.2 The 2024 Strategic Plan focuses on a set of priorities and measuring progress towards future strategies that will drive improvement of the department. Priorities include improving the core capabilities of the department, enhancing internal operations, ensuring health and safety, and building an engaged, motivated, and innovative workforce. 2021 California Wildfire and Forest Resilience Action Plan The Governor’s Forest Management Task Force developed California’s Wildfire and Forest Resilience Action Plan, which is a framework for establishing healthy and resilient forests that can withstand and adapt to wildfire, drought, and climate change. This plan accelerates efforts to restore the health and resilience of California’s forests, grasslands, and natural places; improves the fire safety of communities; and sustains the economic vitality of rural forested areas. CAL FIRE, in partnership with the United States Forest Service, intends to scale up forest thinning and prescribed fire; integrate climate adaptation into the statewide network of regional forest and community fire resilience plans; improve the electricity grid resilience, and promote sustainable land use.

State Responsibility Area and Very High Fire Hazard Severity Zone Fire Safe Regulations California Code of Regulations (CCR) Title 14, Division 1.5, Chapter 7, Subchapter 2, SRA/Very High FHSZ Fire Safe Regulations, establishes minimum wildfire protection standards for construction and development in the SRA and Very High FHSZ and requires CAL FIRE to review development proposals and enact recommendations that serve as conditions of approval in these zones. These standards include basic emergency access and perimeter wildfire protection measures; signing and building numbering; private water supply resources for emergency fire use; and vegetation modification. These regulations apply to all residential, commercial, and industrial buildings in the SRA and Very High FHSZs, the siting of new mobile homes, all tentative and parcel maps, and applications for building permits approved before 1991 where these standards were not proposed. Fire Safe Regulations also include a minimum setback of 30 feet for all buildings from property lines and/or the center of a road. Section 1273.08, Dead-End Roads, of these standards provide regulations for the maximum lengths of single access roadways requiring the following:
 Parcels zoned for less than one acre: 800 feet
 Parcels zoned for 1 acre to 4.99 acres: 1,320 feet
 Parcels zoned for 5 acres to 19.99 acres: 2,640 feet
 Parcels zoned for 20 acres or larger: 5,280 feet
Fire Safe Regulations, Section 1299.03, Fire Hazard Reduction Around Buildings and Structure Requirements, provides defensible space requirements for areas within 30 feet of a structure (Zone 1) and between 30 and 100 feet from a structure (Zone 2). In Zone 1, all dead and dying plants must be 2 California Department of Forestry and Fire Protection (CAL FIRE). 2024. CAL FIRE Strategic Plan 2024: Transforming Tomorrow. https://www.fire.ca.gov/about/cal-fire-strategic-plan-2024, accessed October 4, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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removed, as must any flammable vegetation that could catch fire. In Zone 2, horizontal and vertical spacing among shrubs and trees must be created and maintained.

Public Resources Code Section 4291
Public Resources Code (PRC) Section 4291, Mountainous, Forest-, Brush- and Grass-Covered Lands, is intended for any person who owns, lease, controls, operates, or maintains a building or structure in a mountainous area, forest-covered lands, shrub-covered lands, grass-covered lands, or land that is covered with flammable material, regardless of whether the property is in an SRA or Very High FHSZ.

This section requires defensible space to be maintained within 100 feet from each side of a structure. An ember-resistant zone is also required within 5 feet of a structure and more intense fuel reduction between 5 and 30 feet of a structure.

California Building Standards Code
The California Buildings Standards Code (CBSC) (California Code of Regulations Title 24) provides 12 different codes for construction and buildings in California. This code is updated every three years, with the most recent version effective January 1, 2023.

Building Design Standards
The California Building Code (CBC), Part 2 of CCR Title 24, identifies building design standards, including those for fire safety. It is effective statewide, but a local jurisdiction may adopt more restrictive standards based on local conditions under specific amendment rules prescribed by the State Building Standards Commission. Buildings are plan checked by local city building officials for compliance with the CBC and any applicable local edits. Typical fire safety requirements of the CBC include the installation of sprinklers in buildings and other facilities; the establishment of fire-resistance standards for fire doors, building materials, and particular types of construction in high or very high FHSZs; requirements for smokedetection systems; exiting requirements; and the clearance of debris.

Materials and Methods for Exterior Wildfire Exposure
Chapter 7A of the CBC, Materials and Methods for Exterior Wildfire Exposure, prescribes building materials and construction methods for new buildings in a FHSZ or Wildland Urban Interface. Chapter 7A contains requirements for roofing; attic ventilation; exterior walls; exterior windows and glazing; exterior doors; decking; protection of underfloor, appendages, and floor projections; and ancillary structures.

Other requirements include vegetation management compliance, as prescribed in CFC Section 4906 and PRC Section 4291.

California Fire Code
The California Fire Code (CFC) incorporates, by adoption, the International Fire Code of the International Code Council, with California amendments. This is the official fire code for the State and all political subdivisions. It is found in 24 CCR Part 9 and, like the CBC, is revised and published every three years by the California Building Standards Commission. Also like the CBC, the CFC is effective statewide, but a local jurisdiction may adopt more restrictive standards based on local conditions. The CFC is a model 2045 GENERAL PLAN RESET DRAFT EIR

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code that regulates minimum fire safety regulations for new and existing buildings; facilities; storage; processes, including emergency planning and preparedness; fire service features; fire protection systems; hazardous materials; fire flow requirements; and fire hydrant locations and distribution. Typical fire safety requirements include installation of sprinklers in all buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures in wildfire hazard areas.

Fire Safety During Construction and Demolition
Chapter 33 of the CFC, Fire Safety During Construction and Demolition, provides requirements for fire safety precautions during construction and demolition of a development project. The purpose of this chapter is to provide reasonable safety to life and property from fire during construction and demolition operations, including those in underground locations. Specific requirements include a prohibition of smoking on-site, except for in approved areas; management of combustible materials and debris; cutting and welding; electrical wiring; and cooking. Additional requirements include the preparation of site safety plans prior to building permit issuance, providing fire watch during nonworking hours, and maintaining water supply for fire protection as soon as combustible materials arrive on a project site.

Wildland-Urban Interface Areas
Chapter 49, Requirements for Wildland Urban Interface Fire Areas, of the CFC applies to any geographical area identified as a FHSZ by CAL FIRE. It defines FHSZs, connects to the SRA/Very High FHSZ Fire Safe Regulation requirements for defensible space, and parallels requirements for wildfire protection building construction and hazardous vegetation fuel management in other sections of the CCR and the PRC.

Chapter 49 of the 2022 CFC includes a definition for the wildland-urban interface (WUI) and provides requirements for fire protection plans, landslide plans, long-term vegetation management, and creation and maintenance of defensible space for all new development within the WUI.

California Public Utilities Commission
In 2007, wildfires in southern California were ignited by overhead utility power lines and aerial communication facilities near power lines. In response, the California Public Utilities Commission (CPUC) began considering and adopting regulations to protect the public from fire hazards due to overhead power lines and nearby aerial communication facilities. The CPUC published a Fire Threat Map under Rulemaking 15-05-006 following procedures in Decision 17-01-009, revised by Decision 17-06-024, which adopted a work plan for the development of a utility High Fire Threat District where enhanced fire safety regulations in Decision 17-12-024 apply.3 The fire regulations require electric utilities to:4 3 California Public Utilities Commission, 2024, Decision Amending the Work Plan for The Development of Fire Map 2. https://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M191/K628/191628745.pdf, accessed October 4, 2024. 4 California Public Utilities Commission, 2017, ,CPUC Adopts New Fire-Safety Regulations. Press Release. http://docs.cpuc.ca.gov/PublishedDocs/Published/G000/M201/K352/201352402.PDF, accessed October 4, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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 Prioritize the correction of safety hazards.
 Correct nonimmediate fire risks in “Tier 2” (elevated fire threat) areas on the CPUC High Fire-Threat District within 12 months, and in “Tier 3” (extreme fire threat) areas within 6 months.  Maintain increased clearances between vegetation and power lines within the High Fire Threat District.
 Maintain stricter wire-to-wire clearances for new and reconstructed facilities in Tier 3 areas.  Conduct annual inspections of overhead distribution facilities in rural areas of Tier 2 and Tier 3 areas.  Prepare a fire prevention plan annually if overhead facilities exist in the High Fire Threat District.

California Environmental Quality Act
In November 2022, the California Attorney General issued the “Best Practices for Analyzing and Mitigating Wildfire Impacts of Development Projects Under the California Environmental Quality Act.” This guidance document was designed to help lead agencies comply with the California Quality Environmental Protection Act (CEQA) when considering whether to approve projects in wildfire-prone areas. These areas are often in the WUI area—i.e., the area where the built environment meets or intermingles with the natural environment. This guidance provides suggestions for how best to comply with CEQA when analyzing and mitigating a proposed project’s impacts on wildfire ignition risk, emergency access, and evacuation. The guidance is aimed at proposed development projects such as residential, industrial, or commercial developments. The extent to which it applies will vary by project based on project design and location. It does not impose additional requirements on local governments or alter any applicable laws or regulations but is intended to provide guidance on some of the issues, alternatives, and mitigation measures that should be considered during the environmental review process.

Regional Regulations
San Mateo–Santa Cruz Unit Strategic Fire Plan
CAL FIRE developed the San Mateo–Santa Cruz Unit 2023 Strategic Fire Plan, adopted in 2023, which covers an approximately 894-square-mile area and protects 572,160 acres of the SRA in both San Mateo and Santa Cruz Counties.5 The goal of this plan is to outline resource needs in the area by creating a list of all the initial attack resources in the unit and expanding these resources in at-risk communities. There is also an education section in the plan that encourages teaching the community at formal events and meetings.
5 California Department of Forestry and Fire Protection, updated May 2023, San Mateo–Santa Cruz Unit: 2023 Strategic Fire Plan, https://34c031f8-c9fd-4018-8c5a-4159cdff6b0d-cdn-endpoint.azureedge.net/-/media/osfm -website/what-we-do/community-wildfire-preparedness-and-mitigation/fire-plan/2023/2023-san-mateo-santa-cruz-unit-fire -plan.pdf?rev=f89a0764ea194b9fa9d26351c16d0f83&hash=1326CA209869D0FC23AE079668D6D146, accessed October 4, 2024.
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Santa Cruz San Mateo County Community Wildfire Protection Plan The Santa Cruz San Mateo County Community Wildfire Protection Plan identifies the risks created by wildfire across the landscape and provides strategies to mitigate wildfire risks and restore healthier, more resilient ecosystems and communities. The 2022 Santa Cruz San Mateo County Community Wildfire Protection Plan was developed through a collaborative effort with CAL FIRE’s San Mateo and Santa Cruz Unit, the Resource Conservation District for San Mateo County and Santa Cruz County, the San Mateo Resource Conservation District, and the United States Fish and Wildlife Service. The primary strategy for fire prevention in this plan is reducing structural ignitability through construction methods and materials, education, and defensible space. Additional methods include fuel reduction projects, shaded fuel breaks, and closing the gap on data needs for future vegetation management programs.

San Mateo County Multi-Jurisdictional Hazard Mitigation Plan The purpose of hazard mitigation planning is to reduce the loss of life and property by minimizing the impact of disasters. The San Mateo County Multi-Jurisdictional Hazard Mitigation Plan (MJHMP), updated in 2021 in accordance with the federal Disaster Mitigation Action of 2000 (DMA 2000), provides an assessment of natural hazards in the county and a set of short-term mitigation actions to reduce or eliminate the long-term risk to people and property from these hazards. The San Carlos Jurisdictional Annex of the MJHMP provides an assessment of hazards and vulnerabilities, and a set of mitigation actions for San Carlos specifically while considering the results from the countywide effort. In the context of an MJHMP, mitigation is an action that reduces or eliminates long-term risk to people and property from hazards, wildfire.
6 The MJHMP must be reviewed and approved by the Federal Emergency Management Agency (FEMA) every five years to maintain eligibility for disaster relief funding. As part of this process, the California Governor’s Office of Emergency Services reviews all local hazard mitigation plans in accordance with DMA 2000 regulations and coordinates with local jurisdictions to ensure compliance with FEMA’s Local Mitigation Plan Review Guide. As part of the proposed project, the MJHMP is adopted in its entirety into the proposed Safety Element by reference.

Local Regulations
San Carlos General Plan
As part of the proposed project, some existing General Plan goals, policies, and actions would be amended or new policies would be added. Applicable goals, policies, and actions are identified and assessed for their effectiveness and potential to result in an adverse physical impact later in this chapter under Section 4.18.3, Impact Discussion.
6 County of San Mateo, 2021, 2021 Multijurisdictional Local Hazard Mitigation Plan – Volume 2, https://www.smcgov.org/media/53476/download?inline=, accessed on October 11, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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City of San Carlos Municipal Code
The San Carlos Municipal Code (SCMC) is the primary document that regulates the policies and practices of the City. The SCMC contains the Zoning Code, the Subdivision Ordinance, the Building and Construction Code, and other titles that are important in implementing the goals, policies, and actions of the General Plan. The SCMC includes various directives pertaining to wildfire as follows:
 Chapter 12.08, Grading and Excavations, provide minimum standards to protect property and control erosion and sedimentation to reduce surface runoff and related environmental damage caused by construction-related activities. This chapter includes regulations for the design, construction, quality of materials, use, location and maintenance of grading, excavating and fill, land disturbances, land fill and soil storage in connection with the clearing and grading of land for construction within the city.
 Chapter 13.12, Underground Utility Districts, allows the City Council to call public hearings to decide whether designated areas of the city require the removal of existing poles, overhead wires, and associated overhead structures related to utility lines. If approved, these areas become Underground Utility Districts, and the utility and property owners shall work together to underground existing utilities.
 Chapter 15.04, Technical Building Codes, adopts the CBC and CFC with local amendments.  Chapter 15.04.040, Title 24, Part 2, California Building Code, Volumes 1 and 2, with appendices, amendments, and modifications, adopts the 2022 CBC with amendments and is referred to as the City of San Carlos Building Code.
 Chapter 15.04.110, Title 24, Part 9, California Fire Code, adopts the 2021 International Fire Code and the 2022 California Fire Code with amendments, referred to as the San Carlos Fire Ordinance.
 Chapter 15.56, Flood Damage Prevention, applies to all areas of special flood hazards within the City of San Carlos. This chapter contains requirements for construction, elevation, and floodproofing of buildings within special flood hazard areas identified by FEMA.  Chapter 18.12, Hillside (H) Overlay District, applies to all lots and sites that have a footprint slope of

19.9 percent or greater. It is intended to protect residents by establishing regulations for managing the development of hillside areas. One of the purposes of the H District is to “Protect public health and safety by minimizing hazards, including soil erosion and fire danger associated with development on hillsides.”
San Carlos Climate Mitigation and Adaptation Plan
The San Carlos Climate Mitigation and Adaptation Plan (CMAP), adopted in 2021, describes the hazards that may become more intense or occur more frequently due to climate change, including wildfire. The CMAP identifies strategies that support climate adaptation and resilience, including the following:
 Strategy 40: Disaster Preparedness Information. Provide disaster preparedness information to all residents and businesses in English, Spanish, Chinese, and other relevant languages. 2045 GENERAL PLAN RESET DRAFT EIR

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 Strategy 41: Community Wildfire Protection Plan. Develop a Community Wildfire Protection Plan, in coordination with San Mateo County Fire Department and CAL FIRE.  Strategy 42: Vegetation Management. Promote vegetation management and fire-resistant landscape design on residential properties and businesses within the wildland-urban interface and very high fire severity zone.
 Strategy 43: Fire Risk Reduction Assessment. Develop a fire risk reduction assessment that can be used by project applicants and City staff in the development review process to identify and reduce or avoid potential harm through site design or other mitigation techniques within the very high or high fire severity zones.

San Carlos Emergency Operations Plan
The City Council adopted the City of San Carlos Emergency Operations Plan (EOP) in March 2022. The EOP establishes the emergency management structure utilized for prevention, protection, response, and recovery of emergencies affecting San Carlos; the operational concepts and procedures associated with day-to-day field response to emergencies by City departments; and the policies and procedures for the San Carlos Emergency Center activities. The plan also identifies the policies, responsibilities, and procedures utilized to protect the health and safety of residents, public and private property, and the environmental effects of natural, technological, and man-made emergencies and disasters, as well as defines the procedures for a disaster recovery process.

EXISTING CONDITIONS
Wildfire Background
According to PRC Sections 4103 and 4104, the term “wildfire” refers to any uncontrolled fire spreading through vegetative fuels that threatens to destroy life, property, or resources. In recent years, wildfires have been moving from traditionally wildland areas with natural vegetation into more urban areas, that is, the WUI, threatening homes, businesses, and essential infrastructure. Though wildfires play an important role in the ecology of many natural habitats, risks to human safety and property increase as urban development moves into areas susceptible to wildfire hazards.

Types of Wildfires
There are three basic types of wildfires:
 Crown fires burn trees to their tops and are the most intense and dangerous wildland fires.  Surface fires burn surface litter and duff and are known for being the easiest fires to extinguish and causing the least damage. Brush and small trees enable surface fires to reach treetops, and so are referred to as ladder fuels.
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 Underground fires occur underground in deep accumulations of dead vegetation. These fires move very slowly and can be difficult to extinguish due to limited access.7 Wildfires burn in many types of vegetation—forest, woodland, scrub, chaparral, and grassland. Many species of native California plants are adapted to fire, and habitats such as chaparral shrubs and woodlands can recover from fire. For example, some species of chaparral plants, such as ceanothus, require intense heat for germination and therefore have flammable resins on leaves and roots that can quickly sprout up in burned areas.8 From 2020 to 2023, wildfires in California burned over 7.5 million acres of forest, grassland, desert, scrub and other vegetation types, in addition to development in the wildland-urban interface, with the greatest number of acres burned in 2020 and 2021.9 Wildfire Causes
Although the term wildfire suggests natural origins, a 2017 study that evaluated 1.5 million wildfires in the United States between 1992 and 2012 found that humans were responsible for igniting 84 percent of wildfires, accounting for 44 percent of acreage burned.10 The most common types of human-caused wildfires are burning of debris, equipment use and malfunction, negligently discarded cigarettes, and intentional acts of arson.11 Power lines can also ignite wildfires through downed lines, vegetation contact, conductors that collide, and equipment failures.12 Lightning is the most common cause of nature-induced wildfire.13
An analysis of Unites States Forest Service wildfire data from 1986 to 1996 determined that 95 percent of human-caused wildfires and 90 percent of all wildfires were within 0.5 mile of a road, and that about 61 percent of all wildfires and 55 percent of human-caused wildfires were within approximately 650 feet (200 meters) of a road. The study concluded that the increase in human-caused ignition greatly outweighs the benefits of increased access for firefighters.14 7 Western Fire Chief Association, 2024, “Understanding the Different Types of Wildfire,” https://wfca.com/wildfirearticles/types-of-wildfire/#pp-toc-6x9tjk18rl5u-anchor-3, accessed October 4, 2024. 8 National Park Service, 2018, “Wildland Fire in Chaparral: California and Southwestern United States,” https://www.nps.gov/articles/wildland-fire-in-chaparral.htm, accessed October 4, 2024. 9 CAL FIRE, Incidents by Year, https://www.fire.ca.gov/incidents, accessed October 4, 2024. 10 Balch, Jennifer, et al., March 14, 2017, Human-Started Wildfires Expand the Fire Niche Across the United States, Proceedings of the National Academy of Sciences 114 No. 11, https://www.pnas.org/content/pnas/114/11/2946.full.pdf, accessed October 4, 2024.
11 National Park Service, 2022, “Wildfire Causes and Evaluations.” https://www.nps.gov/articles/wildfire-causes-andevaluation.htm, accessed October 4, 2024. 12 Texas Wildfire Mitigation Project, 2018, How Do Power Lines Cause Wildfires? https://wildfiremitigation.tees.tamus.edu/faqs/how-power-lines-cause-wildfires, accessed October 4, 2024. 13 Balch, Jennifer, et al. 2017, Human-Started Wildfires Expand the Fire Niche Across the United States. Proceedings of the National Academy of Sciences 114 No. 11. https://www.pnas.org/content/pnas/114/11/2946.full.pdf, accessed October 4, 2024.
14 Pacific Biodiversity Institute, 2007, Roads and Wildfires, http://www.pacificbio.org/publications/wildfire_studies/Roads_And_Wildfires_2007.pdf, accessed October 4, 2024. 2045 GENERAL PLAN RESET DRAFT EIR

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There are three primary methods of wildfire spread:
 Embers. Embers are the most prolific cause of home ignition, at a rate of two out of every three homes destroyed. Embers are glowing or burning pieces of vegetation or construction debris that are lofted during a wildfire and can move up to a mile ahead of a wildfire, especially during high winds. These small embers or sparks may fall on the vegetation near a home (on dry leaves, needles, or twigs on the roof) and subsequently ignite the home. Embers can travel several miles during high wind events, such as the Santa Ana Winds, posing a potential risk to all structures without fireresistant landscaping and construction within a mile of the fire.15  Direct Flame Contact. Direct flame contact refers to the transfer of heat by direct flame exposure.

Direct contact will heat the building materials of the home, and if the time and intensity of exposure is severe enough, windows will break, and materials will ignite.  Radiant Heat. A house can catch fire from the heat that is transferred to it from nearby burning objects, even in the absence of direct flames or embers. By creating defensible space around homes, the risk from radiant heat is significantly reduced.

Secondary Effects of Wildfires
After a high intensity wildfire is suppressed, the burn scar is typically bare of its vegetative cover, which had supported the hillsides and steeper slopes. As a result, rainstorms increase the possibility of severe landslides and debris flow in these areas. The intense heat from the fire can also cause a chemical reaction in the soil that makes it less porous, causing water to run off during precipitation events, which can lead to flooding downstream.

In addition to damaging natural environments, wildfires can injure and cause fatalities of residents and firefighters as well as damage or destroy structures and personal property. Wildfires also deplete water reserves, down power lines, disrupt communication services, and block evacuation routes, which can isolate neighborhoods. Wildfires can also indirectly cause flooding if flood control facilities become inadequate to handle increases in stormwater runoff, sediment, and debris that are likely to be generated from burn scars. Regionally, smoke from wildfires creates poor air quality that can last for days or weeks, depending on the scale of the wildfire and wind patterns.

Wildfire in San Carlos
The geography, weather patterns, and vegetation in the City of San Carlos and surrounding areas provide ideal conditions for wildfires. As shown in Figure 4.18-1, Very High Fire Hazard Severity Zones, very high FHSZs are in the western portions of the city, which also coincide with the hillside and landslide-prone areas of the city.
15 CAL FIRE, 2019, Wildland Urban Interface, https://frap.fire.ca.gov/media/10300/wui_19_ada.pdf, accessed October 4, 2024.
82 101
82 280
101
82 82 84
101
101
Redwood
Creek
Corkscrew
Slough
Smith Slough
Steinberger
Slough
Pond
City of San Carlos
Source: California Board of Forestry and Fire Protection, 2007. 0 0.2 0.4 0.1
Miles
City Boundary
Parks and Open Space
Caltrain Line
Electrical Transmission Lines
Caltrain Station
Schools
Community Facilities
Fire Stations
Police Stations
Hospitals
Fire Hazard Severity Zones
Very High
High
Moderate
City of Belmont
City of Redwood City
County of San Mateo
Source: California Board of Forestry and Fire Protection, 2007. Figure 4.18-1 Very High Fire Hazard Severity Zones

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Wind is a major weather factor of wildfire behavior. Average wind speeds in San Carlos vary only slightly throughout the year, with the windier part of the year from February to July with average wind speeds of

8.8 miles per hour, and the calmer part of the year from August to January with average wind speeds of

7.5 miles per hour.16 Wind is most commonly from the west from February to November, with winds from the north from November to February.17
Diablo winds, which are a type of downslope, warm, northerly to northeasterly wind, flow over the Diablo Mountain range and have had reported speeds of up to 100 miles per hour.18 As wind speeds increase, the rate of fire spread, intensity, and ember spread potential also increases. Gusty and erratic wind conditions can cause a wildfire to spread irregularly, making it difficult to predict its path and effectively deploy fire suppression forces. Winds from the northeast in the late summer and fall compound with lower relative humidity, creating “red flag” conditions.19 Diablo winds and low humidity are especially dangerous because low humidity can dry out trees and other fuel that may also be weakened by the winds. This can increase wildfire conditions in the city. Wind shifts can also occur suddenly due to temperature changes and interactions with steep slopes or hillsides, causing fires to spread unpredictably. Fall has historically been one of the most dangerous times for wildfire risk, as periods of very high temperatures, low humidity, and strong wind increase, causing “red flag” warnings and extreme fire danger.

Fuel
The qualities of vegetation that directly influence fire risk include fuel type and size, loading, arrangement, chemical composition, and dead and live fuel moisture, which contributes to the flammability characteristics of the vegetation. As discussed in Chapter 4.3, Biological Resources, of the Draft EIR, San Carlos has seven different natural communities, including sparsely vegetated areas, aquatic habitat, wetlands, riparian habitats, oak woodlands, annual grasslands, and scrub. The oak woodland, annual grassland, and scrub habitats are in the western upland and park areas of the city.

Grasslands, woodlands, and scrublands are highly flammable, particularly leaf litter that is left to accumulate, ultimately dries, and provides fuel for potential fires.

Topography
Slope is a measure of land steepness, and wildfire intensity and rate of spread increase as slope increases due to the tendency of heat from a fire to rise via convection. For example, as slope increases from 20 to 40 percent, flame heights can double, and rates of fire spread can increase fourfold; from 40 to 60 percent, flame can become three times higher, and rates of spread can increase eightfold. The arrangement of vegetation throughout a hillside can also contribute to increased fire activity on slopes. 16 Weatherspark, “Climate and Average Weather Year Round in San Carlos,” accessed October 8, 2024, https://weatherspark.com/y/556/Average-Weather-in-San-Carlos-California-United-States-Year-Round. 17 Weatherspark, “Climate and Average Weather Year Round in San Carlos,” accessed October 8, 2024, https://weatherspark.com/y/556/Average-Weather-in-San-Carlos-California-United-States-Year-Round. 18 Liu, YC., P. Di, S. H. Chen, et al., November 28, 2020, Climatology of diablo winds in Northern California and their relationships with large-scale climate variabilities, accessed June 16, 2023, https://doi.org/10.1007/s00382-020-05535-5. 19 The National Weather Service issues “red flag” weather day warnings when certain weather elements such as low relative humidity and strong winds could lead to increased wildfire risk. 2045 GENERAL PLAN RESET DRAFT EIR

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As described in Chapter 4.6, Geology and Soils, of the Draft EIR, topography of the EIR Study Area includes moderate to steep slopes in the western neighborhoods and open space areas, sloping down to the eastern portion of the EIR Study Area near the San Francisco Bay.

Human actions
Most wildfires are ignited by human action, the result of direct acts of arson, carelessness, or accidents.

Many fires originate in populated areas along roads and around homes and are often the result of careless disposal of cigarettes, mowing of dead grass, electrical equipment malfunction, use of equipment, or burning of debris. Recreation areas with increased human activity that are in fire-prone areas also increase the potential for wildfires.

Climate Change
Climate change is likely to increase annual average temperatures in San Carlos from a historical 69.9 degrees Fahrenheit (o
F), to 74.1 oF by 2050 and 77.3oF by 2100.20 This will likely create warmer temperatures earlier and later in the year. Precipitation levels are projected to vary over the course of the century, changing from a historical annual average of 20.7 inches per year, to an annual average of

23.2 inches by 2050 and an annual average of 25.6 inches by 2099.21 Variations in precipitation patterns will also lead to an increase in frequency and intensity of heavy precipitation events as well as prolonged periods of drought. The combination of extreme heat and droughts can cause soils and vegetation to dry out, creating more fuel for wildfires. These factors are expected to increase wildfire conditions, creating a risk of more frequent and intense wildfires. Because wildfires burn the trees and other vegetation that help stabilize a hillside and absorb water, more areas burned by fire may also lead to an increase in landslides and floods. Wildfires are projected to increase to an annual average in the city of 155 acres burned by 2050 and 144 acres burned by 2100. 22
Fire Protection Resources
Fire protection services in San Carlos are provided by contract through the Redwood City-San Carlos Fire Department (RC-SCFD), which operates two fire stations in San Carlos:
 Fire Station No. 13 at 525 Laurel Street
 Fire Station No. 16 at 1280 Alameda de las Pulgas
The RC-SCFD has an Insurance Services Office rating of Class 1 and has a Fire Prevention Bureau focused on reducing wildfire hazards and risks. The Fire Prevention Bureau provides the following functions and programs to San Carlos:
 Fire Safety Plan Review
 Fire Inspection of new and existing construction
 Consultation with prospective developers and builders on public safety issues  Fire Investigation
20 Cal-Adapt, 2024, Annual Averages, accessed October 8, 2024, https://cal-adapt.org/tools/annual-averages/. 21 Cal-Adapt, 2024, Annual Averages, accessed October 8, 2024, https://cal-adapt.org/tools/annual-averages/. 22 Cal-Adapt, 2024, Wildfire, accessed October 8, 2024, https://cal-adapt.org/tools/wildfire. 2045 GENERAL PLAN RESET DRAFT EIR

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 Mitigating complaints and other fire hazards
 Fire Public Education
 Participate in community outreach programs
 Juvenile Fire Setter Intervention Program
Chapter 4.14, Public Services, of this Draft EIR, provides additional details about fire protection resources and services in San Carlos.

Evacuation and Access
Evacuation routes are designated roadways that allow many people to quickly leave an area due to a potential or imminent disaster. These routes should have sufficient capacity to accommodate the needs of the community, be safely and easily accessible, and allow people to travel far enough away to be safe from emergency conditions.

As shown on Figure 4.18-3, Evacuation Routes, San Carlos has several evacuation routes throughout the city, with primary evacuation routes including the following:
 Highway 101
 Interstate 280
 El Camino Real (State Route 82)
 Brittan Avenue
 Holly Street
 Industrial Road
 Old Country Road
 San Carlos Avenue
 Cañada Road
 Alameda de las Pulgas
 Crestview Drive
 Shoreway Road
 Howard Avenue
Several residential neighborhoods throughout the city only have one means of ingress/egress and are on single access roads. Figure 4.18-4, Evacuation-Constrained Areas, shows identified single access roadways in hazard zones throughout the city, including sites within wildfire hazard zones in the portion of the city. The City also uses Genasys, formerly known as Zonehaven, to determine the most efficient and effective evacuation routes based on the emergency type and location, provide real-time updates on changing conditions during an emergency, and allow residents to look up their evacuation zone by entering their address into an online platform.

Source: United States Census Bureau, 2019. City of San Carlos, County of San Mateo, Urban Footprint, 2020.

Figure 4.18-3
Evacuation Routes

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Source: United States Census Bureau, 2019. City of San Carlos, County of San Mateo, Urban Footprint, 2020.

Figure 4.18-4
Evacuation-Constrained Areas

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4.18.2 STANDARDS OF SIGNIFICANCE
The proposed project would result in a significant wildfire impact if it would:

WILD-1 Substantially impair an adopted emergency response plan or emergency evacuation plan.

WILD-2 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.

WILD-3 Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

WILD-4 Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

WILD-5 In combination with past, present, and reasonably foreseeable projects, result in cumulative wildfire resource impacts in the area.

4.18.3 IMPACT DISCUSSION
WILD-1 The proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan.

Adopted emergency response plans and emergency evacuation plans include those discussed under Section 4.18.1.1, Regulatory Framework, such as the San Carlos EOP. The proposed project could result in a significant impact if it substantially impairs the implementation of the EOP. Future development in the EIR Study Area could occur in very high FHSZs or WUI in western San Carlos as identified in the San Carlos 2023-2031 Housing Element Sites Inventory, as well as in the form of accessory dwelling units to single family residences.

Future development, regardless of whether it includes new development or redevelopment, is required to comply with adopted local, regional, and State plans and regulations addressing emergency access, response, and evacuation. Future development would be required to be consistent with the EOP to continue its facilitation in evacuation for the people living and working in wildfire-prone areas. Future development in very high FHSZs and/or the WUI would be required to comply with the Very High FHSZ Fire Safe Regulations, the CBSC, the CFC, and the SCMC, which have maximum requirements for lengths of single-access roads, minimum widths of roadways, and vegetation fuel management around roadways. In addition, implementation of the proposed 2045 General Plan Reset would not result in substantial changes to the circulation patterns or emergency access routes in the city that would conflict with or require changes to the EOP.

A temporary impact to emergency operations and evacuation under the proposed 2045 General Plan Reset could occur from construction of future development projects if they were to result in temporary lane closures that would potentially alter evacuation routes. Future development during the buildout 2045 GENERAL PLAN RESET DRAFT EIR

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horizon of the proposed project would also be required to comply with Very High FHSZ Fire Safe Regulations, the CBSC, the CFC, and the SCMC. These would be limited to the duration of the construction period, and direct impacts of construction would be evaluated during the permit review process by the City and RC-SCFD. Review and approval of temporary lane closures, if needed, for future development projects in the city would ensure that no inconsistencies with emergency evacuation plans would occur.

The Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset contains goals, policies, and actions that require local planning and development decisions to consider impacts to wildfire, including emergency response and evacuation. The following General Plan goals, policies, and actions would prepare for and facilitate evacuations caused by wildfires and other hazards:
 Goal ESPS-3: A resilient San Carlos is well prepared to minimize risks associated with wildfire.  Policy ESPS-3.1: Promote and improve, as necessary, inter-jurisdictional fire prevention assessment, planning, and projection; and consultation and communication regarding disaster or emergency plans of San Carlos and Mutual Aid 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.  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.  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.  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-3.5: Train and educate public volunteers in basic fire safety response.  Action ESPS-3.8: When a fire has occurred in the VHFHSZ, evaluate if street design and size can be reconfigured to improve emergency access and evacuation efficiency. 2045 GENERAL PLAN RESET DRAFT EIR

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 Action ESPS-3.9: If development is permitted within the VHFHSZ, 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 nonconforming 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-3.14: 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-3.17: Continue code enforcement programs requiring private and public property owners to maintain buildings and properties to prevent conditions, remove blighted excessive or overgrown vegetation (e.g., trees, shrubs, weeds), and remove litter, rubbish, and illegally dumped items from properties.
 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 nonconforming 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.
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 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.

Adherence to these General Plan goals, policies, and actions would collectively enhance San Carlos's preparedness for wildfire emergencies and improve evacuation protocols, increasing the effectiveness of the EOP. Implementation of the proposed 2045 General Plan Reset would not substantially impair an adopted emergency response plan or emergency evacuation plan. Thus, this impact is considered less than significant.

Significance without Mitigation: Less than significant.

WILD-2 The proposed project could, 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.

As discussed in Section 4.18.1.2, Existing Conditions, the topography in wildfire-prone areas of San Carlos consists of hilly to sleep slopes on the eastern edge of the Santa Cruz Mountains. These topographical features can create wind tunnels and canyons that can trap heat and embers, increasing fire intensity and accelerating the spread of wildfires. Construction of future development projects in these areas may require grading and site preparation activities that could change the slope of a single parcel or site.

Though most future development would occur in the eastern and shoreline areas of the city, development and redevelopment in San Carlos could also occur in the steeper western portions of the city. All future development in San Carlos in very high FHSZs or the WUI would be required to comply with the CBSC, Very High FHSZ Fire Safe Regulations, and SCMC Hillside Overlay District and Grading and Excavations requirements, which include standards to minimize the spread of wildfire and soil instability due to slopes. Compliance with the SCMC Hillside Overlay District and Grading and Excavation regulations require the minimization of soil erosion and fire danger associated with development on the hillsides. Additionally, the proposed 2045 General Plan Reset Environmental Safety and Public Services (ESPS) Element includes Policy ESPS-3.10, which enforces fire standards and regulations when reviewing building plans and conducting building inspections.

Wildfire smoke could potentially travel up a slope during a wildfire. Therefore, even with existing regulatory requirements, SCMC requirements, and General Plan goals, policies and actions, future development under the proposed 2045 General Plan Reset could expose people to the uncontrolled spread of wildfire or pollutant concentrations due to slope.

As discussed in Section 4.18.1.2, Existing Conditions, San Carlos is prone to Diablo winds in late fall through early spring. These winds have high speeds, with wind gusts of over 80 miles per hour, and can 2045 GENERAL PLAN RESET DRAFT EIR

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shift suddenly, and they are often accompanied by low humidity.23 They create dangerous conditions for starting and spreading wildfires during the drier months of the year. Diablo winds also spread wildfire smoke hazards, as can prevailing winds.

Section 4.18.1.1, Regulatory Framework, describes plans, policies, regulations, and procedures that help to reduce wildfire risks. The 2024 CAL FIRE Strategic Fire Plan, 2021 California Wildfire and Forest Resilience Action Plan, San Mateo County MJHMP, Santa Cruz San Mateo County Community Wildfire Protection Plan, San Carlos CMAP, and City of San Carlos EOP, are intended to reduce wildfire hazards and coordinate response to these hazards on a statewide, regional, and local scale. In addition, the Bay Area Air Quality Management District and San Mateo County Health Agency provide air quality alerts, advisories, and an interactive online map to view current air quality conditions in the region.

Furthermore, the proposed 2045 General Plan Reset Environmental Safety and Public Services (ESPS) Element includes Policy ESPS-10.1, which requires the city to consider establishing resilience hubs that offer refuge during extreme heat and severe weather events due to regional wildfire smoke.

Future development under the proposed 2045 General Plan Reset in the western portion of the city could exacerbate wildfire risks by adding people to wildfire-prone areas and exposing people in the city and surrounding jurisdictions to pollutant concentrations from a wildfire, especially during Diablo Wind events. A wildfire combined with Diablo winds could expose residents in the city to the uncontrolled spread of wildfire.

Other factors, such as vegetation, have the potential to exacerbate wildfire risks. The grassland, brush, and woodland areas of western San Carlos are easily ignited, especially during fall when temperatures and winds are high and relative humidity is low. During these conditions vegetation can dry out, particularly in areas with unirrigated vegetation, becoming extremely flammable and increasing wildfire risks.

As described in Section 4.18.1.1, Regulatory Framework, the San Mateo County MJHMP and San Carlos CMAP contain several vegetation management, fuel reduction and maintenance, and fuel break projects to reduce the uncontrolled spread of wildfire due to vegetation on both public and private land.

Additionally, all future development in wildfire-prone areas in San Carlos would be required to comply with Very High FHSZ Fire Safe Regulations, PRC Section 4291, the CFC, and the SCMC. These regulations have specific requirements for new and existing development to create defensible space and extensive fuel reduction within 100 feet of a structure, an ember-resistant zone within 5 feet of a structure, and the overall maintenance of properties to reduce the risk of uncontrolled fires or the spread of fires to other properties.

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 Goal ESPS-3: A resilient San Carlos is well prepared to minimize risks associated with wildfire.  Policy ESPS-3.7: Consider the preservation of undeveloped ridgelines to reduce fire risk and improve fire protection.
 Policy ESPS-3.9: Incorporate or require the incorporation of fire safety features in new development and redevelopment.
 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 to reduce wildfire hazard and improve defensibility (e.g., clustering lots, managed greenbelts, water storage, fuel modification zones, and vegetation setbacks).
 Action ESPS-3.9: If development is permitted within the VHFHSZ, require a Fire Protection Plan addressing risk analysis, fire response capabilities, fire safety requirements (defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for nonconforming fuel modification, and wildfire education maintenance and limitations. Include landscape/fuel modification installation and resident evacuation plans.  Action ESPS-3.13: Ensure new and existing public and privately owned properties are constructed and maintained to minimize fire hazard threats.  Action ESPS-3.14: Condition all new development and redevelopment to incorporate and maintain fire-safe design, including fuel modification zones and emergency vehicle access.  Action ESPS-3.16: Continue to enforce the brush clearance/weed abatement program for both private and public roads and City-owned open spaces.
 Action ESPS-3.20: Within the VHFHSZ, work with local fire departments and organizations to ensure the installation of fire protection water systems and long-term maintenance of defensible space.
 Goal ESPS-13: Ensure adequate public services and high-quality design of public facilities to make San Carlos a safe, enjoyable, and quality community in which to live, work and shop.  Policy ESPS-13.10: Require existing overhead utility lines be placed underground in new development and redevelopment through a phased program of conversion in existing overhead areas.

These policies would ensure that fire hazard reduction measures occur, vegetation is maintained to reduce wildfire risks, and that existing and new development in grassland, scrub, and woodland areas would incorporate vegetation management measures. However, even with existing regulatory requirements and the General Plan goals, policies, and actions, future development under the proposed 2045 General Plan Reset could expose people to the uncontrolled spread of wildfire or pollutant concentrations due to factors such as vegetation.

Adherence to the above building practices, fire safety regulations, and vegetation fuel management requirements would reduce the potential for exacerbating wildfire risks. However, due to the programmatic nature of this analysis, the unknown details and potential impacts of specific future 2045 GENERAL PLAN RESET DRAFT EIR

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development projects under the proposed 2045 General Plan Reset, and the potential for future development to be in wildfire-prone areas, impacts would still be potentially significant. Numerous preventative measures exist to reduce wildfire risks; however, as described below, no additional feasible measures are available beyond the proposed policies and actions included in the 2045 General Plan Reset to reduce this impact.

Impact WILD-2: Future development during the buildout horizon of the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.

Mitigation Measure WILD-2: None available.

Significance with Mitigation: Significant and unavoidable. The implementation of the proposed project could increase population, buildings, and infrastructure in areas prone to wildfires. Although the goals, policies, and actions outlined in the Environmental Safety and Public Services (ESPS) Element of the proposed 2045 General Plan Reset, along with mandatory state wildfire hazard reduction measures, reduce risks in these wildfire-prone areas, some impacts related to the potential increase in pollutant concentrations and the uncontrolled spread of wildfire would be reduced, but not to a less-than-significant level.

There are numerous preventative measures the City considers in wildfire-prone areas, from defensible space requirements to WUI building code requirements. The proposed 2045 General Plan Reset includes specific policies and actions that require both existing developments and new projects to establish and maintain fire-safe vegetation around structures and roadways, enforce firesafe standards, and create fuel breaks. Additionally, new developments will be mandated to prepare Fire Protection Plans, ensuring comprehensive measures are in place to address wildfire hazards.

These strategies represent the most effective wildfire hazard reduction measures available. However, to eliminate the risks associated with wildfires, it would be necessary to prohibit development in areas designated as very high fire hazard severity zones or in the wildland urban interface.

Prohibiting new development in this portion of San Carlos is not feasible or practical because the City has a responsibility to meet other, conflicting obligations, under different State laws, including increasing the number and type of housing available and allowing reconstruction of homes burned by wildfires. Therefore, this measure is considered and rejected, and there are no feasible mitigation measures beyond the policies and plans described above. Given the potential unknown impacts related to future development under the proposed project, impacts at the programmatic level are expected to remain significant and unavoidable. This conclusion does not rule out the possibility of finding less-than-significant impacts at the project-specific level.

WILD-3 The proposed 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.

Future development during the buildout horizon of the proposed 2045 General Plan Reset would not require the installation of new roadways as discussed in Chapter 4.15, Transportation, of this Draft EIR, 2045 GENERAL PLAN RESET DRAFT EIR

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but would include the development and construction of fuel breaks, emergency water sources, transmission lines, and other utilities to serve future development in San Carlos.  Fuel Breaks. Environmental Safety and Public Services (ESPS) Element Policies ESPS-3.10 and ESPS3.11, and Actions ESPS-3.9 and ESPS-3.14 require new development and redevelopment throughout the city, and in very high FHSZs to install greenbelts or fuel breaks, create and maintain defensible space, and conduct vegetation management through fuel modification zones. Policy ESPS-3.10 also requires new residential developments to establish greenbelt zones for fire resistant landscaping.

These activities would occur throughout the city, with additional activities required in very high FHSZs and the WUI areas in western San Carlos.
 Emergency Water Sources. Environmental Safety and Public Services (ESPS) Element Policy ESPS3.12 and Actions ESPS-3.12 and ESPS-3.13, ensure adequate water supply is available, specifically to meet fire-suppression needs of a project and through coordination with water suppliers to provide adequate water for peak fire flow. Action ESPS-3.20 requires the installation of fire protection water systems for new development, including fire sprinklers, suppression systems, and infrastructure for adequate fire flow.
 Power lines. Future development under the proposed 2045 General Plan Reset would require electrical line installations and connections to provide power to buildings and infrastructure.

Environmental Safety and Public Services (ESPS) Element Policy ESPS-13.10 requires existing overhead utility lines to be placed underground in new or redevelopment through a phased program of conversation in existing overhead areas throughout the city.  Other Utilities. Future development under the proposed 2045 General Plan Reset would also require the installation and maintenance of water systems, sewer systems, internet infrastructure, and stormwater systems in wildfire-prone areas.

These types of improvements would involve temporary construction and result in changes to the existing built environment. The installation and operation of new above-ground power transmission lines would create a higher risk of wildfire compared to other infrastructure. However, as stated above, proposed Policy ESPS-13.10 encourages the undergrounding of new and existing electrical transmission lines, which is consistent with SCMC Chapter 13.12, Undergrounding Utility Districts. Additionally, CPUC requires maintenance of vegetation around power lines, strict wire-to-wire clearances, annual inspections of above-ground power lines, and preparation of fire prevention plans for above-ground power lines in high-fire-threat districts. These measures would reduce the wildfire risks associated with the installation and maintenance of power lines.

Development in the wildfire-prone areas of western portion of San Carlos would also be required to comply with building and design standards in the California Standards Building Code and CFC, which include provisions for fire-resistant building materials, clearance of debris, and fire safety requirements during demolition and construction activities. Additionally, PRC Section 4291 requires a defensible space within 100 feet of a structure and an ember-resistant zone within 5 feet of a structure. Furthermore, Very High FHSZ Fire Safe Regulations would prevent structures from being within 30 feet of a roadway, reducing the potential for new roadways to exacerbate wildfire risks. These measures, along with proposed Policy ESPS-13.10 for the undergrounding of power lines, creation and maintenance of 2045 GENERAL PLAN RESET DRAFT EIR

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vegetation and defensible space, and ensuring the availability of adequate water supplies would minimize wildfire risks associated with the installation and maintenance of infrastructure.

Such infrastructure and maintenance activities would also be required to comply with the adopted State regulations, SCMC standards, and the General Plan policies to mitigate the impact of infrastructure on the environment. Therefore, impacts would be less than significant.

Significance without Mitigation: Less than significant.

WILD-4 The proposed 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.

Wildfires can trigger additional hazards like flooding and landslides, especially during the rainy season.

When fires occur on hillsides, they destroy vegetation that stabilizes the slopes and creates hydrophobic conditions, preventing water absorption. This can result in landslides, debris flows, and flooding. The proposed project would result in a significant impact if—due to slopes, drainage patterns, or postfire slope instability—it would expose people or structures to significant risks from landsides, debris flows, or flooding.

As discussed in Chapter 4.9, Hydrology and Water Quality, of this Draft EIR, parts of San Carlos are in the 100-year and 500-year floodplains. As shown on Figure 4.9-2, FEMA Flood Zones, in Chapter 4.9 of this Draft EIR, floodplains in the city generally follow the drainage patterns of the Pulgas Creek, Brittan Creek, and Cordilleras Creek, which flow east from the Santa Cruz Mountains towards the San Francisco Bay. 100-year and 500-year flood zones also occur along El Camino Real east towards the San Francisco Bay.

As discussed in Chapter 4.6, Geology and Soils, slopes in the eastern portion of the city are in areas with high landslide susceptibility, which also coincide with very high FHSZs. These areas are considered prone to earthquake and rainfall induced landslides. This overlap may cause areas outside of a flood hazard or landslide-susceptible zone to be affected by runoff, postfire slope instability, or drainages changes following a wildfire.

Future development under the proposed 2045 General Plan Reset could contribute to postfire slope instability or drainage changes upstream. However, all new development in the city is required to comply with State and local regulations, such as the CBC and SCMC, both of which have provisions to reduce flooding and landslides in existing and new development. For example, Section 1803 of the CBC requires a geotechnical investigation that must assess existing landslide susceptibility on a project site.

The following General Plan goals, policies, and action would serve to reduce wildfire risks associated with runoff, post-fire slope instability, or drainage changes:
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 Goal ESPS-1: Reduce the potential loss of life, injury, and property damage due to seismic and geologic hazards.
 Policy ESPS-1.1: The City Building Official shall verify geotechnical and soils reports for development in areas where potentially serious geologic risks exist. These reports shall address the degree of hazard, design parameters for the project based on the hazard, and appropriate mitigation measures. Based on the findings of these reports, the City shall require that new structures are designed and built to withstand the effects of seismically-induced ground failure.  Policy ESPS-1.2: Prohibit structural development in known areas where seismic and geological hazards cannot be mitigated.
 Policy ESPS-1.3: Continue to monitor and enforce mitigation measures to reduce risk for projects where geological and seismic hazards can be mitigated.
 Goal ESPS-2: Reduce hazards associated with flooding and inundation.  Policy ESPS-2.10: Incorporate stormwater drainage systems in development projects to effectively control the rate and amount of runoff to prevent increases in downstream flooding potential.
 Action ESPS-2.5: Work with private property owners who own creek frontage and educate the public on bio-engineering of creeks to stabilize banks and maintain natural creek forms.

New development complying with these policies of the San Carlos General Plan would not expose people or structures to downslope landslides or downstream flooding due to postfire hazards.

Furthermore, as identified in impact discussions WILD-2 and WILD-3, future development under the proposed 2045 General Plan Reset must also comply with best management practices regarding wildfire prevention, action, and recovery as outlined in the San Carlos EOP, San Carlos CMAP, and San Mateo County MJHMP. All future development, regardless of the location, is required to comply with adopted local, regional, and State plans and regulations addressing wildfire prevention, which would minimize risks of postfire hazards. Compliance with these policies and regulatory requirements would ensure that impacts from postfire instability would be less than significant.

Significance without Mitigation: Less than significant.

WILD-5 The proposed project would, in combination with past, present, and reasonably foreseeable projects, result in cumulative wildfire resources impacts in the area.

The cumulative setting includes future development in San Carlos and the surrounding region. Future development during the buildout horizon of the proposed 2045 General Plan Reset would not impair an adopted emergency response plan or emergency evacuation plan; would not exacerbate wildfire risks due to the installation or maintenance of infrastructure; and would not cause downslope or downstream post-fire flooding or landslide hazards. Cumulative development in the surrounding unincorporated county and local jurisdictions would be subject to the same State and regional regulations applicable to future projects over the buildout horizon of the proposed project. 2045 GENERAL PLAN RESET DRAFT EIR

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However, the proposed project would result in significant and unavoidable impacts where it would potentially expose project occupants to pollutant concentrations from wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors, as described in impact discussion WILD-2. The addition of other proposed development projects in adjacent jurisdictions in similar environments that are sloped and contain high fuel loads would have the potential to contribute to cumulative wildfire risks. These projects would have the potential to result in significant environmental impacts and they could also potentially expose project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors. These would potentially result in cumulatively considerable impacts when taken into consideration with the proposed project.

Future development in San Carlos and the surrounding region would be required to comply with the same State regulations, such as SRA and Very High FHSZ Fire Safe Regulations, PRC Section 4291, the CBSC, and CFC. Lands throughout San Mateo County would also implement wildfire reduction strategies through implementation of the Santa Cruz San Mateo County Community Wildfire Protection Plan and the San Mateo County MJHMP. However, the increase of development projects in surrounding areas within the very high FHSZ and WUI would result in a cumulatively significant impact due to the inherent risk of any increased human activity in these areas. Therefore, cumulative wildfire impacts would be considered significant. Numerous preventative measures exist to reduce wildfire risks; however, as described below, no additional feasible measures are available beyond the proposed policies and actions included in the 2045 General Plan Reset to reduce this cumulative impact.

Impact WILD-5: Future development during the buildout horizon of the proposed project could, in combination with other surrounding and future projects in the State Responsibility Areas, Very High Fire Hazard Severity Zones (FHSZ), or Wildland-Urban Interface (WUI), result in cumulative impacts associated with the exposure of project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.

Mitigation Measure WILD-5: None available.

Significance with Mitigation: Significant and unavoidable. As described for Impact WF-2, even with implementation of the General Plan goals, policies, and actions, the only way to fully avoid the cumulative wildfire impact is to prohibit development in the Very High FHSZs and WUI throughout the region. As a full prohibition of development in these areas is not feasible in the region, this impact is significant and unavoidable. Please see impact discussion WF-2 for additional discussion. 2045 GENERAL PLAN RESET DRAFT EIR

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Alternatives
The following discussion is intended to inform the public and decision makers of feasible alternatives to the proposed project that would avoid or substantially lessen any of the significant effects of the proposed project. The California Environmental Quality Act (CEQA) Guidelines set forth the intent and extent of alternatives analysis to be provided in an environmental impact report (EIR). Section 15126.6(a) of the CEQA Guidelines states that:

An EIR shall describe a range of reasonable alternatives to the project, or 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. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives, which are infeasible. The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.

5.1 INTRODUCTION
The alternatives evaluated in this Draft EIR were developed consistent with Section 15126.6(b) of the CEQA Guidelines, which states that:

Because an EIR must identify ways to mitigate or avoid the significant effects that a project may have on the environment (Public Resources Code Section 21002.1), 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 these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.

Section 15126.6(c) of the CEQA Guidelines states:

The range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic objectives of the project and could avoid or substantially lessen one or more of the significant effects. The EIR should briefly describe the rationale for selecting the alternatives to be discussed. The EIR should also identify any alternatives that were considered by the lead agency but were rejected as infeasible during the scoping process and briefly explain the reasons underlying the lead agency’s determination. Additional information explaining the choice of alternatives may be included in the administrative record. 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 impacts. 2045 GENERAL PLAN RESET DRAFT EIR

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5.2 PROJECT OBJECTIVES
The primary purpose of the proposed project is to plan for the growth of San Carlos over a 20-year time horizon and to:
 Allow for a mix of development to support the City’s economic resiliency and to sustain a robust local economy.
 Preserve, protect, and promote industrial, commercial, and office uses to maintain a thriving ecosystem of local businesses and to provide for local jobs.  Provide a mix of housing that meets the needs of a diverse community, as outlined in the 2023-2031 Housing Element and for future Housing Element cycles.
 Make minor updates to the 2030 General Plan to reference recent City initiatives, plans or new State regulations.

5.3 SIGNIFICANT AND UNAVOIDABLE IMPACTS
All the potential environmental impacts associated with adoption and implementation of the proposed project were found to be either less than significant without mitigation or less than significant with mitigation, except for impacts to air quality (AQ), greenhouse gas emissions (GHG), transportation (TRAN), and wildfire (WILD), which were found to be significant and unavoidable with mitigation measures at the program level. Although the proposed 2045 General Plan results in significant and unavoidable impacts, the identification of these program-level impacts do not preclude the finding of less-than-significant impacts for subsequent development proposals analyzed at the project level that do not exceed the applicable project-level thresholds. The significant and unavoidable impacts identified for the proposed project include the following:

Air Quality
Impact AQ-2.1: Construction of development projects within the buildout horizon of the proposed project would generate emissions that would exceed the Bay Area Air Quality Management District’s (BAAQMD) regional significance thresholds and cumulative contribute to the nonattainment designations of the San Francisco Bay Area Air Basin.

Impact AQ-2.2: Operation of development projects under the proposed project could generate operational emissions that exceed the Bay Area Air Quality Management District’s (BAAQMD) regional significance thresholds for volatile organic compounds (VOC) and nitrogen oxides (NOX).

Impact AQ-3: Construction emissions associated with future development projects could expose air quality-sensitive receptors to substantial toxic air contaminant concentrations and exceed the Bay Area Air Quality Management District’s (BAAQMD) project-level and cumulative significance thresholds. 2045 GENERAL PLAN RESET DRAFT EIR

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Greenhouse Gas Emissions
Impact GHG-1: Implementation of the proposed project would exceed the greenhouse (GHG) emissions threshold of no net increase from existing conditions and would therefore not make substantial progress toward the long-term GHG reduction goal under Senate Bill (SB) 32 or the carbon neutrality goal under Assembly Bill (AB) 1279.

Transportation
Impact TRAN-2: The proposed project could exceed the City’s VMT significance criteria by generating VMT per service population, per capita, and per employee that exceeds a threshold of 15 percent less than the regional average and by increasing total countywide VMT.

Wildfire
Impact WILD-2: Future development during the buildout horizon of the proposed project could increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.

5.4 OVERVIEW OF PROJECT ALTERNATIVES
Two project alternatives and the comparative merits of the alternatives are discussed in this section in accordance with the CEQA Guidelines.

The alternatives to be analyzed in comparison to the proposed project include:
 No Project Alternative
 Reduced Non-Residential Buildout Alternative
The first alternative is the CEQA-required “No Project” Alternative, which assumes the current General Plan 2030 remains in effect and is not replaced by the proposed project. The second alternative is the Reduced Non-Residential Buildout Alternative and is intended to reduce the projected non-residential square footage within the EIR Study Area.

5.4.1 ASSUMPTIONS AND METHODOLOGY
This alternatives analysis is presented as a comparative analysis to the proposed project. The development intensity for the alternatives varies from the proposed project. The estimated growth under each alternative, as well as the proposed project, is provided in Table 5-1, 2045 Development Projections for the Proposed Project and Project Alternatives. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 5-1 2045 DEVELOPMENT PROJECTIONS FOR THE PROPOSED PROJECT AND PROJECT ALTERNATIVES (NET

CHANGE)
Category
Proposed 2045 General
Plan Reset
No Project
Alternative
Reduced Non-Residential
Buildout Alternative
Housing Units 21,560 21,560 21,560
Population 46,450 46,450 46,450
Non-Residential Square Footage a 18,803,500 12,564,100 15,683,780 Jobs b 47,320 29,310 38,310
Notes: SOI = sphere of influence
a. Non-residential square footage includes commercial, office, research and development (R&D), and industrial square footage and does not include public uses.
b. Job numbers include commercial, office, R&D, industrial, and other jobs, including public jobs.

Source: PlaceWorks, 2024.

The alternatives analysis assumes that all applicable mitigation measures recommended for the proposed project and the General Plan goals, policies, and actions would apply to the Reduced NonResidential Buildout Alternative but would not apply to the No Project Alternative.

5.4.2 SUMMARY OF ALTERNATIVES EVALUATION
The following discussion compares the environmental impacts of the alternatives with those of the proposed project for each of the environmental topics analyzed in detail in Chapter 4, Environmental Analysis, of this Draft EIR. The impacts of each alternative are classified as less than (<), similar or comparable to (=), or greater than (>) the level of impacts associated with the proposed project. Table 5- 2, Comparison of Impacts of the Proposed Project and Project Alternatives, summarizes the relative impacts of each of the alternatives compared to the proposed project. 2045 GENERAL PLAN RESET DRAFT EIR

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TABLE 5-2 COMPARISON OF IMPACTS OF THE PROPOSED PROJECT AND PROJECT ALTERNATIVES Topic
Proposed
Project a
No Project
Alternative
Reduced Non-Residential
Buildout Alternative
Aesthetics LTS = =
Air Quality SU < <
Biological Resources LTS/M > =
Cultural Resources LTS < <
Energy LTS < =
Geology and Soils LTS < <
Greenhouse Gas Emissions SU = <
Hazards and Hazardous Materials LTS = =
Hydrology and Water Quality LTS = =
Land Use and Planning LTS = =
Noise LTS = <
Parks and Recreation LTS = =
Population and Housing LTS = =
Public Services LTS = =
Transportation SU < =
Tribal Cultural Resources LTS > <
Utilities and Service Systems LTS = =
Wildfire SU = =
Notes:
a. The impacts listed in this column represent the highest significance determination for each respective standard of significance.

LTS Less than Significant
LTS/M Less than Significant with Mitigation
SU Significant and Unavoidable
< Lessened impact in comparison to the proposed project = Similar impact in comparison to the proposed project
> Greater impact in comparison to the proposed project

5.5 NO PROJECT ALTERNATIVE (CURRENT GENERAL PLAN)

5.5.1 DESCRIPTION
Pursuant to CEQA Guidelines Section 15126.6(e)(1), the No Project Alternative is required as part of the “reasonable range of alternatives” to allow decision makers to compare the impacts of approving the proposed project with the impacts of taking no action or not approving the proposed project. Consistent with CEQA Guidelines Section 15126.6(e)(3)(A), when the project is the revision of a plan, as in this case, the no project alternative will be the continuation of the existing plan(s). Under the No Project Alternative, future development in San Carlos would continue to be subject to existing policies, regulations, development standards, and land use designations of the existing General Plan 2030.

As described in Chapter 3, Project Description, of this Draft EIR, the existing General Plan 2030 was adopted in 2009 and included a horizon year of 2030. Six elements of the General Plan 2030 (housing, safety, land use, circulation and scenic highways, environmental management, and noise) were amended in 2023. A focused update is necessary to respond to continued interest in new development throughout the city, including housing, and extend the planning horizon to 2045. 2045 GENERAL PLAN RESET DRAFT EIR

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Pursuant to CEQA Guidelines Section 15126.6(e)(3)(C), the City of San Carlos, acting as the lead agency, should analyze the impacts of the No Project Alternative by projecting what would reasonably be expected to occur in the foreseeable future if the proposed project were not approved, based on current plans and consistent with available infrastructure and community services. Under the No Project Alternative, none of the applicable mitigation measures recommended for the proposed project would apply, and none of the modified General Plan language would be adopted.

Buildout projections for the No Project Alternative are shown in Table 5-3, Development Projections Under the No Project Alternative. No Project Alternative assumes development of projects already in the development pipeline only and no additional non-residential growth or adoption of the Downtown Specific Plan (DTSP) or the Northeast Area specific Plan (NEASP). Overall residential growth would be the same as under the proposed project but, because the NEASP would not be adopted, new housing would not be introduced in the Northeast area.

5.5.2 IMPACT DISCUSSION
The potential environmental impacts associated with the No Project Alternative when compared to the proposed project are described herein.

AESTHETICS
As described in Chapter 4.1, Aesthetics, of this Draft EIR, the proposed project would not result in any significant impacts related to aesthetics and no mitigation measures are required.

Under both the proposed project and the No Project Alternative, new development would occur based on the City’s existing General Plan land use and zoning maps and regulations. Due to the built-out nature of the EIR Study Area, under both the proposed project and the No Project Alternative, new TABLE 5-3 DEVELOPMENT PROJECTIONS UNDER THE NO PROJECT ALTERNATIVE Existing Conditions
(2024)
No Project Alternative
Projected Net Change
(2024-2045)
No Project Alternative
Buildout (2045)
Category City SOI Total City SOI Total City SOI Total
Housing
Units 12,460 790 13,250 8,300 0 8,300 20,770 790 21,560 Population 28,890 1,940 30,830 15,620 0 15,620 44,510 1,940 46,450 NonResidential
Square
Footage a
9,776,200 100,000 9,876,200 2,687,900 0 2,687,900 12,464,100 100,000 12,564,100 Jobs b 20,410 370 20,780 8,530 0 8,530 28,940 370 29,310 Notes: SOI = sphere of influence
a. Non-residential square footage includes commercial, office, research and development (R&D), and industrial square footage and does not include public uses.
b. Job numbers include commercial, office, R&D, industrial, and other jobs, including public jobs.

Source: PlaceWorks, 2024.
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development would be concentrated in infill development sites. Thus, development would not be spread throughout the city and impacts to scenic vistas would be similar when compared to the proposed project.

There are no officially designated scenic view corridors, vistas, or State-designated scenic highways within, or in the vicinity of, the EIR Study Area. Therefore, like the proposed project, the No Project Alternative would not damage existing scenic resources associated with scenic view corridors, vistas, or State-designated scenic highways and impacts would be similar.

Under both the proposed project and the No Project Alternative, project approval would be required to comply with the applicable planning documents that govern scenic quality in the city, as described in Section 4.1.1.1, Regulatory Framework, in Chapter 4.1 of this Draft EIR. Thus, impacts would be similar to the proposed project.

Similar to the proposed project, the No Project Alternative would result in new lighting sources that could produce sources of glare. Future development under both the proposed project and the No Project Alternative would be required to comply with best management practices in CALGreen and the San Carlos Municipal Code (SCMC) provisions that ensure new land uses do not generate excessive light levels and that future development reduce light and glare spillover to surrounding land uses. Therefore, impacts related to light and glare would be similar when compared to the proposed project.

Overall, development in the EIR Study Area under the No Project Alternative would continue to be subject to the current policies and regulations that guide development in San Carlos. As such, impacts related to aesthetics would be similar when compared to the proposed project.

AIR QUALITY
As described in Chapter 4.2, Air Quality, of this Draft EIR, the proposed project would result in significant and unavoidable impacts during the construction and operational phases even with implementation of Mitigation Measures AQ-2.1, AQ-2.2, and AQ-3.

The No Project Alternative would continue to be subject to the current land use regulations that guide development in San Carlos and the general policy framework of the current 2030 General Plan. Similar to the proposed project, the No Project Alternative would not conflict with the 2017 Clean Air Plan and would not hinder the Bay Area Air Quality Management District (BAAQMD) from implementing the control measures in the 2017 Clean Air Plan. Additionally, like the proposed project, the No Project Alternative would not generate any substantial odors.

The No Project Alternative would continue development as allowed under the existing General Plan 2030, which would result in less development in the EIR Study Area compared to the proposed project.

Development under both the proposed project and the No Project Alternative would be subject to BAAQMD’s basic control measures for fugitive dust control and screening sizes. Additionally, future development under both the proposed project and the No Project Alternative could result in construction activities within 1,000 feet of residential and other sensitive land uses, thus, temporarily elevating concentrations of toxic air contaminants and diesel particulate matter in the vicinity of 2045 GENERAL PLAN RESET DRAFT EIR

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sensitive land uses. While future development under the No Project Alternative would be subject to the same regulations as the proposed project to mitigate construction impacts, less development—and thus reduced emission levels—would occur under the No Project Alternative; therefore, construction air quality impacts would be lessened when compared to the proposed project.

Under the No Project Alternative, reduced development would occur compared to the proposed project; therefore, reduced direct and indirect criteria air pollutant emissions from energy (e.g., natural gas use) and area sources (e.g., aerosols and landscaping equipment) would occur. Under both the proposed project and the No Project Alternative, subsequent environmental review of applicable development projects would be required to assess potential impacts under BAAQMD’s project-level thresholds. As shown in Appendix D, Transportation Data, of this Draft EIR, VMT per service population and VMT per employee would be higher under the proposed project than No Project Alternative conditions. Although both the proposed project and the No Project Alternative would reduce total VMT in comparison to existing conditions, the No Project Alternative would reduce VMT further than the proposed project in VMT per service population and VMT per employee and result in a lessened impact when compared to the proposed project.

Therefore, because there is less development and greater VMT reduction under the No Project Alternative, this alternative would result in lessened air quality impacts when compared to the proposed project.

BIOLOGICAL RESOURCES
As described in Chapter 4.3, Biological Resources, of this Draft EIR, the proposed project would not result in any significant impacts related to biological resources and no mitigation measures are required.

The EIR Study Area is not within any local, regional, or State habitat conservation plan areas. Therefore, neither the proposed project nor the No Project Alternative would conflict with the conservation strategy in any Habitat Conservation Plan or Natural Community Conservation Plan and impacts would be similar.

Under both the proposed project and the No Project Alternative, future development could potentially affect special-status species, riparian habitats, wetlands, and wildlife movement corridors. Adherence to the General Plan goals, policies, and actions, as all federal, State, and local regulations relating to biological resources would fully mitigate any potential impacts. Therefore, the impact of the No Project Alternative would be similar when compared to the proposed project.

Future development under the proposed project could potentially affect wildlife movement corridors.

The proposed project includes a new General Plan action to reduce effects to wildlife movement corridors by reducing bird strike impacts through designing development based on bird-safe design guidelines and best management practice strategies to reduce bird strikes. Therefore, impacts related to the movement of wildlife would be greater when compared to the proposed project.

San Carlos City CouncilMay 27, 2025

San Carlos City Council
May 27, 2025