contaminations within the Project area through a Phase I Environmental Site Investigation and/or receive oversight from a self-certified local agency, DTSC or the Regional Water Quality Control Board. If entering into one of DTSC’s voluntary agreements, please note DTSC uses a single standard Request for Lead Agency Oversight Application for all agreement types. Please apply for DTSC oversight using this link: Request for Agency Oversight Application.
Submittal of the online application includes an agreement to pay costs incurred during agreement preparation. If you have any questions about the application portal, please contact your Regional Brownfield Coordinator.
2. DTSC recommends that all imported soil and fill material should be tested to assess any contaminants of concern meet screening levels as outlined in DTSC's Preliminary Endangerment Assessment (PEA) Guidance Manual. Additionally, DTSC advises referencing the DTSC Information Advisory Clean Imported Fill Material Fact Sheet if importing fill is necessary. To minimize the possibility of introducing contaminated soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil and fill material are suitable for the intended land use. The soil sampling should include analysis based on the source of the fill and knowledge of prior land use. Additional information can be found by visiting DTSC’s Human and Ecological Risk Office (HERO) webpage.
3. If buildings or structures are to be demolished on any Project sites within the proposed Project, surveys should be conducted for the presence of lead-based paints or products, mercury, asbestos containing materials, and polychlorinated biphenyl caulk. Removal, demolition, and disposal of any of these chemicals should be conducted in compliance with California environmental regulations and policies. In addition, sampling near current and/or former buildings should be conducted in accordance with DTSC’s PEA Guidance Manual.
DTSC appreciates the opportunity to comment on the MND for the 789 Old County Road Project. Thank you for your assistance in protecting California’s people and environment from the harmful effects of toxic substances. If you have any questions or
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Lisa Costa Sanders
March 7, 2025
would like clarification on DTSC’s comments, please respond to this letter or via our CEQA Review email for additional guidance.
Sincerely,
Tamara Purvis
Associate Environmental Planner
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
cc: (via email)
Governor’s Office of Land Use and Climate Innovation
State Clearinghouse
[email protected]
Daniel Minkoff
Project Applicant
Bransten Road Associates, LLC
[email protected]
Rebecca Auld
Vice President
Lamphier-Gregory, Inc. / Consulting Firm
[email protected]
Dave Kereazis
Associate Environmental Planner
HWMP-Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
Scott Wiley
Associate Governmental Program Analyst
HWMP - Permitting Division – CEQA Unit
Department of Toxic Substances Control
[email protected]
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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
March 13, 2025
Lisa Costa Sanders, Principal Planner
City of San Carlos
600 Elm Street Planning Division
San Carlos, CA, 94070
[email protected]
Subject: 789 Old County Road Project, Mitigated Negative Declaration, SCH No. 2025020976, City of San Carlos, San Mateo County Dear Lisa Costa Sanders:
The California Department of Fish and Wildlife (CDFW) received a Notice of Intent to Adopt a Mitigated Negative Declaration (MND) from the City of San Carlos (City) for the 789 Old County Road Project (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.
Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.
Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.
CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)). CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species (Id., § 1802). Similarly for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources.
CDFW is also submitting comments as a Responsible Agency under CEQA (Pub.
Resources Code, § 21069; CEQA Guidelines, § 15381). To the extent implementation of the Project as proposed may result in “take” as defined by State law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.
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Lisa Costa Sanders, Principal Planner
City of San Carlos
March 13, 2025
Raptors and Other Nesting Birds
CDFW has authority over actions that may result in the disturbance or destruction of active nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include §§ 3503 (regarding unlawful take, possession or needless destruction of the nests or eggs of any bird), 3503.5 (regarding the take, possession or destruction of any birds-of-prey or their nests or eggs), and 3513 (regarding unlawful take of any migratory nongame bird). Migratory birds are also protected under the federal Migratory Bird Treaty Act.
PROJECT DESCRIPTION SUMMARY
Proponent: City of San Carlos
Objective: The objective of the Project is to construct two new office/research and development buildings, one of which would be a five-story, 179,665 square-foot building, and the other would be a four-story, 146,983 square-foot building, with maximum heights of approximately 85 and 69 feet, respectively. Additionally, a separate eight-level above-ground parking garage with a height of 71.5 feet would be built. The site modifications would also involve adjacent street and streetscape improvements.
Primary Project activities include demolition of all existing structures on the site and removal of 25 trees, construction of the new buildings and parking garage, undergrounding electrical lines, building new sidewalks, planting 113 new trees and installing street lights.
Location: 789 Old County Road, San Carlos, CA, 94070, San Mateo County, at the cross streets Bransten Road and Old County Road, Latitude 37.505442506, Longitude - 122.25613063.
Timeframe: Project construction activities, including interior build-out, are anticipated to span approximately two years.
COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources. Editorial comments or other suggestions may also be included to improve the document.
Project Description and Related Impact Shortcoming
Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or Docusign Envelope ID: 84F1383E-397F-497F-AC24-DA8E52BB83C1 11.a October 14, 2025 Packet Pg. 737
Lisa Costa Sanders, Principal Planner
City of San Carlos
March 13, 2025
special-status species in local or regional plans, policies, or regulations, or by CDFW or the U.S. Fish and Wildlife Service (USFWS)?
COMMENT 1: Exterior Windows
Issue: The glass used for exterior building windows of the proposed five- and four-story buildings could result in bird collisions, which can cause bird injury and mortality.
Evidence the impact would be significant: Birds are typically unable to visually perceive clear or reflective glass, such as building windows, and can collide with glass that reflects surrounding landscape and/or habitat features (Klem and Saenger 2013, Sheppard 2019). When birds collide with glass, they can be injured or killed. In the United States, the estimated annual bird mortality is between 365-988 million birds (Loss et al. 2014).
Recommendations to minimize significant impacts: CDFW recommends incorporating visual signals or cues to exterior windows to prevent bird collisions. Visual signals or cues include, but are not limited to, patterns to break up reflective areas, external window films and coverings, ultraviolet patterned glass, and screens. For best practices on how to reduce bird collisions with windows, please go to USFWS’ website for Buildings and Glass (https://www.fws.gov/birds/bird-enthusiasts/threats-tobirds/collisions/buildings-and-glass.php).
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations (Pub. Resources Code, § 21003, subd. (e)). Accordingly, please report any special-status species and natural communities detected during Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.
ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying project approval to be operative, vested, and final (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089).
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Lisa Costa Sanders, Principal Planner
City of San Carlos
March 13, 2025
CONCLUSION
CDFW appreciates the opportunity to comment on the MND to assist the City in identifying and mitigating Project impacts on biological resources.
Questions regarding this letter or further coordination should be directed to Shannon Husband, Environmental Scientist, at (707) 337-1364 or [email protected]; or Wes Stokes, Senior Environmental Scientist (Supervisory), at [email protected].
Sincerely,
Erin Chappell
Regional Manager
Bay Delta Region
cc: State Clearinghouse
REFERENCES
Klem, D. and P. G. Saenger. 2013. Evaluating the Effectiveness of Select Visual Signals to Prevent Bird-window Collisions. The Wilson Journal of Ornithology 125(2):406-411.
Loss, S.R., T. Will, S.S. Loss, and P.P. Marra. 2014. Bird-building collisions in the United States: estimates of annual mortality and species vulnerability. Condor 116: 8-23.
Sheppard, C. D. 2019. Evaluating the relative effectiveness of patterns on glass as deterrents of bird collisions with glass. Global Ecology and Conservation 20:e00795.
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March 23, 2025
San Carlos City Staff and City Council
Subject: Request for Further Analysis, Clarification, and EIR Regarding Environmental Impacts of the proposed development located at 789 Old County, San Carlos.
Dear San Carlos City Staff, Mayor, and City Council,
We are writing to formally submit comments and concerns regarding the environmental impacts that the project may have on the adjoining residential neighborhood and its residents on the Initial Study to evaluate the environmental impacts of the proposed 789 Old County Road Project and supporting documents. After reviewing the documents, we are concerned that several key environmental factors have been marked as not significantly affected, despite the likelihood of substantial impacts. We request further clarification, and additional mitigation measures on the following issues:
1. Land Use/Planning – Request for Compatibility Study
The project’s scale and design should be assessed to ensure compatibility with the surrounding residential area:
● The project height is too tall and will have negative impacts on privacy, shading, and access to natural light for nearby homes that are only 350 feet away. ● In addition to the height there is need for additional buffers, setbacks, and landscaping to reduce visual and environmental impacts.
● The study states that this development is consistent with the East Side Vision Plan, which is the guiding document for development in this area of East San Carlos. This statement is false and incorrect.
● The East Side vision plan was developed in order to guide the overall development of East San Carlos ensuring consistency in approach and compatibility with the residential neighborhood.
● The East Side Vision plan, and the discussions around the plan, specifically called for development height to lower as development approached the residential neighborhood. ● Taller buildings such as the ones in the Alexandria campus would be furthest away from the neighborhood and building height would decrease as projects came closer to the neighborhood.
● This project does the complete opposite. This project is using a planned development status to circumvent the 50 foot zoning restriction and is taller than proposed projects further away from the neighborhood.
A land use compatibility study should be conducted to evaluate these concerns and propose necessary design modifications.
2. Hazardous Waste Cleanup
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● The new development is on the site which according to the Environmental Assessment Reports contained former above and below-ground hazardous materials storage tanks, which contaminated the groundwater due to historical spills and leakage. This is a great opportunity to dig up the contaminated soil and transport it to another location, rather than cap the site, and risk additional runoff and adverse effects to Pulgas Creek, the groundwater, and the San Francisco Bay. We have the following questions, which we would like answers to:
● What are the specific cleanup procedures to be used?
● How will the project coordinate funding from the multiple property owners for ground contamination?
● GESC believes that capping the site for soil contamination is not a viable option. Will the developer cart off all contaminated soil and dispose of it properly? ● If capping the site is considered an option, what specific mitigations will be used to prevent toxic materials from leaching into surrounding soil and aquifers? ● Will the city hold the developer and property owners to do more than the bare minimum cleanup?
We urge the City to do the right thing to require complete clean up of the contaminated soils and spoils at this site, and not just cap it, during the once in a lifetime opportunity to clean up this legacy contamination from prior land uses.
3. Air Quality – Request for Further Analysis
The checklist does not identify Air Quality as a potentially significant environmental factor, yet the project’s construction and operation will likely result in increased air pollution due to:
● Construction-related dust and emissions from heavy machinery, which can exacerbate respiratory conditions for nearby residents.
● Increased vehicular emissions from construction-related traffic and long-term changes in traffic patterns.
● Lack of mitigation measures such as real-time air quality monitoring, dust suppression requirements, and use of cleaner construction equipment.
We request further analysis of the project’s air quality impacts, including localized monitoring data and a discussion of measures to minimize resident exposure.
4. Noise – Request for Revised Noise Impact Analysis
Despite the potential for significant noise pollution, Noise is not listed as an affected factor. However, concerns include:
● High-decibel construction activities (e.g., drilling, pile driving, and heavy machinery operations) that may disrupt residential areas.
● Operational noise from increased traffic, mechanical equipment, and potential commercial or industrial activities associated with the project. ● Lack of mitigation measures such as sound barriers, construction hour limitations, and noise monitoring protocols.
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We request a detailed noise impact study that includes projected decibel levels for nearby homes, along with specific mitigation measures.
5. Transportation – Request for Comprehensive Traffic Impact Study The checklist does not identify Transportation as a significant factor; however, the project will negatively affect local traffic conditions in the following ways:
● Increased congestion near the site, diverting traffic into residential streets, reducing safety, and causing longer commute times.
● Insufficient analysis and plan on the ways to mitigate increased traffic congestion. We request providing tenants with public transit benefit.
● Potential safety hazards for pedestrians and cyclists due to increased vehicle flow. ● The city continues to treat impacts from each development in an isolated manner and does not address the cumulative impacts of all of the foreseeable development on the east Side.
A more comprehensive transportation study should be conducted, including a traffic mitigation plan that prioritizes pedestrian safety and emergency access.
6. Extend bike lanes and sidewalks along Old County Road to complete the Eastside Connect plan
● The Mitigated Negative Declaration omits mention of the need to upgrade sidewalks and bike lanes along the perimeter/frontage of the project.
We urge consideration to complete the connection of sidewalks and bike lanes on Old County Road in accordance with the Eastside Connect Plan to facilitate future workers to have safe transit access, which is a goal of the City’s Transportation Demand Management Plan.
7. Public Services – Request for Emergency Response Assessment The project will impact emergency response times due to increased congestion and temporary road closures. Specific concerns include:
● Potential delays for fire, police, and medical services accessing affected neighborhoods. ● Lack of specific coordination plans between emergency services and project developers to maintain emergency access.
We request a detailed assessment of how the project will ensure emergency service response times remain unaffected.
Conclusion
The Initial Study Checklist appears to underestimate or overlook significant environmental impacts that could substantially affect the adjoining residential community. To ensure a thorough review process, we request further environmental analysis, including additional mitigation measures where necessary. Given these concerns, we urge the city to reconsider whether an Environmental Impact Report (EIR) should be required for this project.
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In addition to this letter, we would like to remind the city staff and council that the GESC board has already sent letters expressing our concerns about these issues in September 2023 and have had conversations with the developer and city staff sharing these same concerns over the course of the last two years. We continue to have the same concerns including the need for an EIR, the building height and impact on nearby residents and homes, not abiding by the zoning in place or 50 feet, not following the East Side Vision Plan in this project, parking and traffic, need for treescaping or tall trees in the project.
We appreciate your time in reviewing these concerns and look forward to your response regarding the requested clarifications. Please keep us informed of any further opportunities to participate in the review process.
Sincerely,
Jennifer Rosse, Sam Herzberg, Caroline Tudor, Max Snieder, Danny Ngyen, Daniel Zizmor, Paul Magenetti, Ben Fuller, Jeff Maley
cc: GESC Advisory Members/Board: Scot Marsters, Dimitri Vandellos
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From: Elisabeth Rossi <[email protected]>
Sent: Friday, March 28, 2025 3:08 PM
To: Lisa Costa Sanders <[email protected]> Subject: 789 Old County Neg Dec Comments-A
Hello,
I live at 1047 Hall St, near Old County. I am concerned about negative impacts on my property and quality of life from this project.
Unlike most residences on Hall St, there is a parking lot rather than a building behind my house. This makes me vulnerable to noise and vision impacts of the project. My concerns and questions are outlined below.
Noise
Our household is already subject to an uncomfortable amount of noise from the businesses on Terminal Way. Sometimes we are unable to be in our backyard due to noise.
It was a relief when the cement plant stopped operations but I am wary of the new buildings. I am concerned about the compressors on the building. Will they be noisy enough to hear at my house? I am also concerned about the noise from people talking and having parties on the terraces. Some of this may occur during noon and in the early evenings when we would be outside eating, which we do when the weather is good. How can my house be protected from being exposed to more background noise? Privacy
The master bedroom is on our 2nd floor. Although I have trees on the back of my property which I hope are tall enough to block sight of the buildings, they are deciduous. During the winter months, there will be nothing to block people from seeing into our bedroom. This feels like a major invasion of our privacy. Will our trees block me and my neighbor (who also has bedrooms on the 2nd floor) from view of the project? How can our privacy be maintained? Why isn't the developer required to maintain our privacy rather than relying on my trees, which are probably not adequate?
Light
The reason we planted deciduous trees is so we could benefit from the short period of winter morning sunlight in our 1st floor living spaces. This is the only direct sunlight we get in the front part of our house during the winter. We will lose this light due to the project. I don't see any way to mitigate this concern, so I'm just mentioning it.
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Other
> Will the lights remain on in the buildings all night? Will there be other exterior lights at the back of the building? I am concerned about light pollution and bird strikes. We enjoy looking at the moon when it is rising. I also have bird feeders in my backyard which bring me a lot of joy and I don't want the birds to be harmed. Will the glass be bird-friendly? > Will the western sun reflect off the glass into our house in the summer months? > I am, of course, not looking forward to the 2 years of construction. Is it possible to post the dates that construction will occur on Saturdays so we know if we can have people over on our patio during the day?
> I am also leery of the hazardous materials that will be used by the tenants but am hopeful that I have nothing to worry about. What will be the impact on the residents if there is a leak?
I am eager to engage with the City and project proponents about my questions and concerns. Thanks for your time.
Elisabeth Rossi
(650)398-8848
--
Elisabeth Rossi
Life is short and we don’t have much time to gladden the hearts of those who make the journey with us, so be swift to love, and make haste to be kind. (Henri-Frederic Amiel)
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August 25, 2025
Thank you for taking the time to talk with me last week. I am writing to share my concerns about the development and my requests to minimize these concerns.
Thank you for sharing the renderings on a large screen of what the project will look like from different houses on Hall Street. I am shocked that there is not a rendering from my house. Unlike other houses on the south side of Hall, my house backs up to a parking lot and not a building. Also, I have one of the few houses with a second story. Therefore, I expect my house to be the most affected by the development. I request a rendering of what the project will look like from my house, particularly from our 2nd story.
When we purchased our house in 2011, the light from the top of the cement stack shone brightly into our bedroom. This was a particular nuisance in the summer when we kept our windows and blinds open for cool air. To prevent a similar occurrence when the new structures are in place, I request that the outside lights are covered and point downward.
I am very concerned about privacy in our 2nd floor bedroom. I’m delighted that automatic window shades are included in the design. I request that the occupants be unable to override this feature. I also appreciate the developers offer to contribute toward trees for the residents. I request further clarification – how much will the developer contribute? How long is this offer open? I planted trees in our backyard to block the light from the cement plant and help protect us from the noise and sightlines from Terminal Way. I planted deciduous trees because the only winter sunlight we receive in the side of the house is when the sun is first rising. This now looks like a bad decision. The development will block that early morning winter sunlight and there will be less privacy when there are no leaves on the trees. Perhaps the best option is for high quality window film to be installed to my 2nd story window, including maintenance and replacement as needed for me and future owners of the home.
Also, in the interest of privacy I request that the trees on the 2nd floor pavilion be planted close enough together to completely screen the view of my house. Tall plants or hedges could be used to fill in the spaces between trees. Also, the plantings should be extended all the way to the eastern edge of the pavilion.
According to the staff report that was developed for the August 18 Planning and Transportation Commission meeting, the route to remove soil from the site includes Terminal Way. This is not an appropriate street for large trucks. It is narrow with active businesses and will cause additional noise and pollution for the residents on Hall. I request that Terminal Way be excluded as an option for hauling dirt.
Finally, during construction I request a contact person to answers questions and concerns from the Hall St. residents and when the development is finished, but still unoccupied, I request a tour for myself and affected neighbors so we can see what the occupants see of our houses.
I appreciate the Planning Department and the developer for the changes that have been made from the initial proposal to lessen the impact on me and my neighborhood.
Elisabeth Rossi
Hall Street
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From: DEBBIE DENTON <>
Sent: Friday, August 15, 2025 2:46 PM
To: *City Clerk's Office <[email protected]> Subject: In Support of the 789 Old County Road Project
Members of the San Carlos Planning Commission:
Daniel Minkoff, Will Birdsey, and Max Flower of the MInkoff group met with us early on as they began to envision their plans at the quarry at 789 Old County Rd. As a member of the Parks and Recreation Foundation of San Carlos and a resident, I was impressed by the artful and thoughtful design which lends itself so well to the southern east side of San Carlos. It offers needed green amenities, better connectivity for walkers and cyclists, an eye toward sustainability and a respect for the surrounding community and history of San Carlos. Please join me in supporting this project.
Thank you,
Debbie Denton, Secretary
Parks and Recreation Foundation of San Carlos
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August 14, 2025
Dear San Carlos Planning Commission:
I write to you in support of the Minkoff Group and their proposed project at 789 Old County Rd. in San Carlos. The team met with me early on in their outreach process and impressed me with their thoughtful approach to a location that is in need of improvement.
As a native San Carlan and mental health professional, I applaud the continuing focus on improved walkability, bike connectivity and the addition of trees and landscaping on our City's East Side. It's a benefit to residents and potential tenants alike and the proposed project demonstrates a commitment to these priorities.
Thank you for your consideration.
Suzanne Hughes
Executive Director
One Life Counseling Center
Suzanne Hughes, LMFT #35321 (exp. 6/30/26)
Executive Director, One Life Counseling Services
(415) 860-1475
www.onelifecounselingcenter.com
Need Our Services? (650) 394-5155
SMC Crisis Hotline 650-379-0350 or 988
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