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June 08, 2026 Packet Pg. 2304
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June 08, 2026 Packet Pg. 2305
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June 08, 2026 Packet Pg. 2306
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NOTE:STORM DRAIN SEGMENTS INDICATED TO BE UPSIZED ARE BASED ON THE 2017CITY OF SAN CARLOS STORM DRAIN MASTER PLAN.EXTENSIONS OF STORM DRAIN LINES ARE PROPOSED TO COLLECT RUNOFFFROM PROPOSED GREEN INFRASTRUCTURE MEASURES OR TO PROVIDE STORMDRAIN PIPES WITHIN STREETS WHICH CURRENTLY HAVE NO STORM DRAIN.STORM DRAIN EXTENSIONS SHALL BE COUPLED WITH IMPLEMENTATION OFGREEN INFRASTRUCTURE SO AS TO REDUCE PEAK FLOW-RATE COMPARED TOEXISTING CONDITIONS.
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NOTE:
PROPOSED PIPE SIZES NOTED ARE MINIMUMS. REFER TO CITY OF SAN CARLOSSANITARY SEWER MASTER PLAN FOR FULL DETAILS OF REQUIRED SANITARYSEWER INFRASTRUCTURE UPGRADES.
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NOTE:
ALL DOMESTIC WATER UPGRADES SHOWN ARE PRELIMINARY AND SHALL BECOORDINATED WITH MID-PENINSULA WATER DISTRICT AND CALIFORNIAWATER SERIVICE COMPANY.
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NOTE:
INDIVIDUAL DEVELOPMENT PROJECTS WILL BE REQUIRED TO UNDERGROUNDEXISTING OVERHEAD UTILITIES ALONG THE PROJECT FRONTAGE.
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June 08, 2026 Packet Pg. 2313
In ConsultaƟon with
Prepared by
Final EIR
Northeast Area Specific Plan
May 2026
SCH# 2024070063
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Northeast Area Specific Plan, SCH# 2024070063 i Administrative Draft Final EIR City of San Carlos May 2026
Table of Contents
Section 1.0 Introduction....................................................................................................................1 Section 2.0 Draft EIR Public Review Summary ..................................................................................2 Section 3.0 Draft EIR Recipients........................................................................................................3 Section 4.0 Responses to Draft EIR Comments.................................................................................4 Section 5.0 Draft EIR Text Revisions................................................................................................51 Appendix A: Draft EIR Comment Letters
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Northeast Area Specific Plan, SCH# 2024070063 1 Administrative Draft Final EIR City of San Carlos May 2026
Section 1.0 Introduction
This document, together with the Draft Environmental Impact Report (Draft EIR), constitutes the Final Environmental Impact Report (Final EIR) for the Northeast Area Specific Plan (referred to as the “Plan” herein).
1.1 Purpose of the Final EIR
In conformance with the California Environmental Quality Act (CEQA) and CEQA Guidelines, this Final EIR provides objective information regarding the environmental consequences of the proposed project. The Final EIR also examines mitigation measures and alternatives to the project intended to reduce or eliminate significant environmental impacts. The Final EIR is intended to be used by the City of San Carlos and any Responsible Agencies in making decisions regarding the project.
Pursuant to CEQA Guidelines Section 15090(a), prior to approving a project, the lead agency shall certify that:
(1) The Final EIR has been completed in compliance with CEQA; (2) The Final EIR was presented to the decision-making body of the lead agency, and that the decision-making body reviewed and considered the information contained in the final EIR prior to approving the project; and
(3) The Final EIR reflects the lead agency’s independent judgment and analysis.
1.2 Contents of the Final EIR
CEQA Guidelines Section 15132 specify that the Final EIR shall consist of:
a) The Draft EIR or a revision of the Draft;
b) Comments and recommendations received on the Draft EIR either verbatim or in summary; c) A list of persons, organizations, and public agencies commenting on the Draft EIR; d) The Lead Agency’s responses to significant environmental points raised in the review and consultation process; and
e) Any other information added by the Lead Agency.
1.3 Public Review
In accordance with CEQA and the CEQA Guidelines (Public Resources Code Section 21092.5[a] and CEQA Guidelines Section 15088[b]), the City shall provide a written response to a public agency on comments made by that public agency at least 10 days prior to certifying the EIR. The Final EIR and all documents referenced in the Final EIR are available for public review on the City’s website:
https://www.sancarlosnortheastplan.com/.
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Northeast Area Specific Plan, SCH# 2024070063 2 Final EIR City of San Carlos May 2026
Section 2.0 Draft EIR Public Review Summary
The Draft EIR for the Plan project, dated March 2026, was circulated to affected public agencies and interested parties for a 46-day review period from March 2, 2026 through April 16, 2026. The City undertook the following actions to inform the public of the availability of the Draft EIR:
• A Notice of Availability of Draft EIR was published on the City’s website (https://www.sancarlosnortheastplan.com/), in San Carlos City Hall, and in the San Mateo Daily Journal;
• A copy of the Notice of Availability of Draft EIR was emailed to an email list consisting of members of the public who had indicated interest or commented on the project; • Notification of the availability of the Draft EIR was mailed to property owners and tenants in the project-area and within a radius of 300 feet of the project boundary; • The Draft EIR was delivered to the State Clearinghouse on March 2, 2026, as well as sent to various governmental agencies, organizations, businesses, and individuals (see Section 3.0 for a list of agencies, organizations, businesses, and individuals that received the Draft EIR); and
• Copies of the Draft EIR were made available on the City’s website (https://www.sancarlosnortheastplan.com/), San Carlos City Hall, and San Carlos Library.
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Northeast Area Specific Plan, SCH# 2024070063 3 Final EIR City of San Carlos May 2026
Section 3.0 Draft EIR Recipients
CEQA Guidelines Section 15086 requires that a local lead agency consult with and request comments on the Draft EIR prepared for a project of this type from responsible agencies (government agencies that must approve or permit some aspect of the project), trustee agencies for resources affected by the project, adjacent cities and counties, and transportation planning agencies.
The NOA for the Draft EIR was sent to owners and occupants adjacent to the Plan area and to adjacent jurisdictions. The following agencies received a copy of the Draft EIR from the City or via the State Clearinghouse:
• AT&T
• Bay Area Air District
• Bay Area Association of Governments
• California Air Resources Board
• California Department of Transportation (Caltrans), District 4 • Caltrans Planning
• California Department of Fish and Wildlife
• California Department of Toxic Substances Control
• California Water Service Mid-Peninsula District
• City of Belmont
• City of Redwood City
• Comcast
• Mid-Peninsula Water District
• Native American Heritage Commission
• Office of Historic Preservation
• Pacific Gas & Electric Company
• Recology
• Rethink Waste
• San Carlos School District
• San Mateo County Environmental Health
• San Mateo County Planning and Building Division
• San Mateo County Transit District
• San Mateo Local Agency Formation
• San Francisco Regional Water Quality Control Board
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Northeast Area Specific Plan, SCH# 2024070063 4 Final EIR City of San Carlos May 2026
Section 4.0 Responses to Draft EIR Comments
In accordance with CEQA Guidelines Section 15088, this document includes written responses to comments received by the City of San Carlos on the Draft EIR.
Comments are organized under headings containing the source of the letter and its date. The specific comments from each of the letters and/or emails are presented with each response to that specific comment directly following. Copies of the letters and emails received by the City of San Carlos are included in their entirety in Appendix A of this document. Comments received on the Draft EIR are listed below.
Comment Letter and Commenter Page of Response
Federal and State Agencies................................................................................................................ 5 A. California Department of Transportation (dated April 13, 2026) ...................................... 5 Regional and Local Agencies............................................................................................................ 11 B. San Mateo County Environmental Health Services (dated March 5, 2026)..................... 11 C. Local Agency Formation Commission (dated April 15, 2026) .......................................... 12 D. City of Belmont (dated April 16, 2026)............................................................................. 13 Organizations, Businesses, and Individuals...................................................................................... 20 E. Lorelei Alli on behalf of the Amah Mutsun Tribal Band of San Juan Bautista (dated March 3, 2026) ................................................................................................................. 20 F. Allen Matkins Leck Gamble Mallory & Natsis LLP (dated April 2, 2026).......................... 21 G. Greater East San Carlos Neighborhood Board (dated April 6, 2026)............................... 30 H. Laurie Berger, Silicon Valley Law Group (dated April 16, 2026)....................................... 41
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Northeast Area Specific Plan, SCH# 2024070063 5 Final EIR City of San Carlos May 2026
Federal and State Agencies
A. California Department of Transportation (dated April 13, 2026) Comment A.1: Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the San Carlos Northeast Area Specific Plan (NEASP). The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the March 2026 DEIR.
Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only.
Project Understanding
The proposed project is to develop the NEASP, which will guide new development within the approximately 145-acre Plan area. The NEASP would be built out over an approximate 20-year period and would allow for a net increase of 1,890 residential units in the Plan area, where no residential units currently exist, as well as increase the net square footage of existing nonresidential land uses. The Plan also proposes multi-modal transportation improvements. The Plan area is located between U.S. Route 101 (U.S. 101) and State Route 82 (SR 82) and is bound by U.S. 101 on its eastern side.
Response A.1: This comment is a general summary of the proposed Plan and does not raise any specific issues about the adequacy of the Draft EIR; therefore, no further response is required.
Comment A.2: Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. For more information on how Caltrans assesses Vehicle Miles Traveled (VMT) analysis for land use projects, please review Caltrans’ Transportation Impact Study Guide (link).
The project’s VMT analysis and significance determination are undertaken in a manner consistent with the Office of Land Use and Climate Innovation’s (LCI) Technical Advisory or the City’s adopted VMT policy. Per the DEIR, this project is found to have a less than significant VMT impact.
Response A.2: The comment acknowledges that the Draft EIR’s analysis of Vehicle Miles Travelled (VMT) impacts was completed in accordance with best practices, including the City’s own VMT policy. Further, the comment accurately represents the Draft EIR’s finding of less than significant VMT impacts. The comment does not raise any specific issues about the adequacy of the Draft EIR.
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Northeast Area Specific Plan, SCH# 2024070063 6 Final EIR City of San Carlos May 2026
Comment A.3: Climate Change and Sea Level Rise
Please keep the Caltrans District 4 Climate Change Planning team informed of Sea Level Rise (SLR) and flooding considerations within the project area. Caltrans participates as a Technical Advisory Committee (TAC) member for the ongoing Redwood Shores SLR Protection Project and is particularly interested in continued discussions regarding resilience along both Belmont Creek and Pulgas Creek. Evidence indicates that, by 2100, flooding and associated flows may overtop U.S. 101 and extend to areas west of the highway. Caltrans also partners with OneShoreline to address flooding concerns affecting U.S. 101 along and near Belmont Creek.
Given the project’s intent to address flooding and SLR through resilience improvements along Belmont Creek (such as green stormwater infrastructure), Caltrans requests regular updates on proposed and implemented measures. Since the project area borders U.S.101 and Belmont Creek could convey flooding, stormwater, and tidal influence toward the State’s Right-of-Way (ROW), changes within the creek corridor and watershed may directly affect US-101 conditions downstream. Please keep Caltrans updated on planned improvements, design assumptions, and any monitoring results related to Belmont Creek resilience efforts. Please reach out to the Climate Change Branch at [email protected] for any questions or concerns.
Response A.3: The comment is acknowledged. As the EIR is programmatic in nature, no specific development project is proposed at this time. The City acknowledges Caltrans’ concerns regarding future impacts from sea level rise and flooding, in particular along U.S. 101. As indicated by the commenter, the Plan includes resiliency standards to address flooding risk and reduce impacts on existing drainage infrastructure (refer to pages 31 through 34 of the Draft EIR). The City will continue to coordinate with responsible agencies, as appropriate. The comment does not raise any specific issues about the adequacy of the Draft EIR.
Comment A.4: Hydrology
The developments proposed within the plan may impact the existing drainage systems along southbound U.S. 101. As part of the encroach permit application, please submit plan views, profiles, cross sections, and detailed drawings of all drainage facilities, along with hydrologic calculations comparing pre and post development conditions at this location.
The Office of Hydraulics would like to ensure that no surface runoff from the developments within this plan directly enters the roadside ditch located between the project site and southbound U.S. 101. Additionally, that discharge from the new developments does not adversely affect the existing U.S. 101 drainage system, particularly during the rainy season.
Response A.4: The comment is acknowledged. As the EIR is programmatic in nature, no specific development project is proposed at this time. Therefore, any future development in the Northeast Area Plan that requires an encroachment permit will need to provide detailed drawings of all drainage facilities to the satisfaction of Caltrans. The comment does not raise any specific issues about the adequacy of the Draft EIR.
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Northeast Area Specific Plan, SCH# 2024070063 7 Final EIR City of San Carlos May 2026
Comment A.5: Aeronautics
Given the program-level nature of the NEASP, the Office of Aeronautics would like to reiterate their previous comments to ensure these considerations are carried forward during plan implementation. As noted previously, one of the goals of the Caltrans Aeronautics Program, is to assist cities, counties, and Airport Land Use Commissions or their equivalent (ALUC), to understand and comply with the State Aeronautics Act pursuant to the California Public Utilities Code (PUC), Section 21001 et seq.
The proposed project is in Safety Zone 6 (Traffic Pattern Zone), with a portion of the Project site in Safety Zone 3 (Inner Turning Zone) of the San Carlos Airport, established by the San Mateo County ALUC pursuant to Section 21675(c). Therefore, the proposed Project shall adhere to the safety and land use criteria and restrictions defined in the Airport Land Use Compatibility Plan (ALUCP) formed by the ALUC pursuant to the PUC Section 21674 and Section 21676 and may be subject to review authority by the ALUC.
Response A.5: The Plan’s relationship to the Airport Land Use Computability Plan is described on pages 173, 174, 183, and 184 of the Draft EIR. As explained on page 183 of the Draft EIR, commercial (i.e., office and retail), manufacturing, R&D, industrial uses, and residential are all considered compatible uses in Safety Zone 6.
The comment does not raise any specific issues about the adequacy of the Draft EIR.
Comment A.6: A portion of the project site is also in the 60 decibel (dB) community noise level contour (CNEL) of the Future Conditions (2035) Aircraft Noise Contours for the San Carlos Airport per the ALUCP. Development in this area would be subject to the noise compatibility policies of the ALUCP. Of note, multi-family residential development in the 60 dB CNEL contour is conditionally compatible and must be capable of attenuating exterior noise levels to an interior noise level of CNEL 45 dB or lower.
Response A.6: As stated on page 183 of the Draft EIR and further discussed in Section 3.13 Noise, the eastern portion of the Plan lies within the 60 dBA CNEL noise contour, however the entire Plan Area is outside of the boundary for 65 CNEL.
Future residential development could potentially fall within the 55 dBA CNEL of the San Carlos Airport. The 2045 General Plan Reset EIR found that adherence to 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 ALUCP, would ensure aircraft noise impacts associated with implementation of the Plan are considered less than significant. Future development within the Plan would adhere to General Plan Policies NOI-1.11 and NOI-1.13, SCMC Sections 18.21.050-F and 18.21.150-C, as applicable, to ensure compatibility with aircraft noise. The comment does not raise any specific issues about the adequacy of the Draft EIR.
Comment A.7: PUC Section 21659 prohibits structural hazards near airports. Structures should not be at a height that will result in penetration of the airport imaginary surfaces. In accordance with Federal Aviation Regulation, Part 77 “Objects Affecting Navigable Airspace” a Notice of Proposed
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Northeast Area Specific Plan, SCH# 2024070063 8 Final EIR City of San Carlos May 2026
Construction or Alteration (Form 7460-1) may be required by the Federal Aviation Administration (FAA). For further information or a copy of Form 7460-1, please refer to the FAA website (link).
Response A.7: As stated on page 183-184 of the Draft EIR, future development proposals would be reviewed by the City/County Association of Governments (C/CAG) pursuant to General Plan Action ESPS-6.1. No buildings would be allowed within the Plan that exceed 155 feet from finished grade or above mean sea level, whichever is more restrictive. The comment does not raise any specific issues about the adequacy of the Draft EIR.
Comment A.8: Lastly, in accordance with PUC Section 21676 et seq., prior to the amendment of a general plan or specific plan, or the adoption or approval of a zoning ordinance or building regulation within the planning boundary established by the ALUC, the local agency shall first refer the proposed action to the ALUC. If the commission determines that the proposed action is inconsistent with the commission's plan, the referring agency shall be notified.
These comments reflect the areas of review by Caltrans Aeronautics with respect to airport-related noise, safety, and land use planning issues. Caltrans Aeronautics appreciates the opportunity to comment. Should you have any questions regarding these comments, please contact aeronautics[email protected].
Response A.8: As required by General Plan Policy ESPS-6.1, the proposed Plan was submitted to the San Mateo County Airport Land Use Commission for review/action, pursuant to California Public Utilities Code Section 21676(b). As a result, the San Mateo County Airport Land Use Commission found the Plan consistent with the Comprehensive Airport Land Use Compatibility Plan for the Environs of San Carlos Airport on April 23, 2026. The comment does not raise any specific issues about the adequacy of the Draft EIR.
Comment A.9: Construction-Related Impacts
Project work that requires movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans. To apply, please visit Caltrans Transportation Permits (link).
Prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan (TMP) to reduce construction traffic impacts to the State Transportation Network (STN).
Response A.9: The comment is acknowledged. As the EIR is programmatic in nature, no specific development project is proposed at this time. Therefore, any future developments in the Northeast Area Plan that require movement of oversized or excessive load vehicles on State roadways will be responsible for securing a transportation permit issued by Caltrans. The comment does not raise any specific issues about the adequacy of the Draft EIR.
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Northeast Area Specific Plan, SCH# 2024070063 9 Final EIR City of San Carlos May 2026
Comment A.10: Equitable Access
If any Caltrans facilities are impacted by the project, those facilities must meet Americans with Disabilities Act (ADA) Standards after project completion. As well, the project must maintain bicycle and pedestrian access during construction. These access considerations support Caltrans’ equity mission to provide a safe, sustainable, and equitable transportation network for all users.
Response A.10: The comment is acknowledged. As the EIR is programmatic in nature, no specific development project is proposed at this time. Therefore, any future development in the Northeast Area Plan that impact Caltrans facilities will be required to ensure that those facilities meet Americans with Disabilities Act (ADA) Standards after project completion. It is also acknowledged that future projects must maintain bicycle and pedestrian access during construction. The comment does not raise any specific issues about the adequacy of the Draft EIR.
Comment A.11: Equity and Public Engagement
We will achieve equity when everyone has access to what they need to thrive no matter their race, socioeconomic status, identity, where they live, or how they travel. Caltrans is committed to advancing equity and livability in all communities. We look forward to collaborating with the City to prioritize projects that are equitable and provide meaningful benefits to historically underserved communities.
Caltrans encourages the City to foster meaningful, equitable and ongoing public engagement in the NEASP development process to ensure future transportation decisions and investments reflect community interests and values. The public engagement process should include communitysensitive and equity-focused approaches seeking out the needs of individuals from underserved, Tribal, and low-income communities, the elderly, and individuals with disabilities.
Response A.11: The comment is acknowledged. The City has engaged in a lengthy public outreach process as part of developing the Northeast Area Specific Plan, including 12 outreach meetings between August of 2023 through November of 2024 that included community workshops, focus group meetings, and pop-ups.
Additionally, as part of the CEQA process, the City sent letters to tribes listed by the Native American Heritage Commission as having a potential affiliation to the Plan area. The City did not receive any requests from the tribes to consult pursuant to Senate Bill 18 or Assembly Bill 52 (refer to page 280 of the Draft EIR). The comment does not raise any CEQA-related issues; therefore, no further response is required.
Comment A.12: Encroachment Permit
Please be advised that any temporary or permanent work including traffic control that encroaches in, under, or over any portion of the State highway ROW requires a Caltrans-issued encroachment permit.
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Northeast Area Specific Plan, SCH# 2024070063 10 Final EIR City of San Carlos May 2026
The Office of Encroachment Permits requires 100% complete design plans and supporting documents to review and circulate the permit application package. The review and approval of encroachment projects is managed through the Encroachment Permits Office Process (EPOP) or the Project Delivery Quality Management Assessment Process (QMAP), depending on project scope, complexity, and completeness of the application. Please use the following resources to determine the appropriate review process:
- TR-0416 Applicant’s Checklist (link)
- Caltrans Encroachment Projects Processes – Information Video (link) - Flowchart, Figure 1.2 in Section 108, Overview of the Encroachment Review Process, of Chapter 100 – The Permit Function, Caltrans Encroachment Permit Manual (link) The permit approval typically takes less than 60 days, but may take longer depending on the project scope, size, complexity, completeness, compliance with applicable laws, standards, policies, and quality of the permit package submitted. Projects requiring exceptions to design standards, exceptions to encroachment policies, or external agency approvals may need more time to process.
To obtain more information and download the permit application, please visit Caltrans Encroachment Permits (link).
Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Mary McGee, Transportation Planner, via LDR[email protected]. For future early coordination opportunities or project referrals, please visit Caltrans LDR website (link) or contact [email protected].
Response A.12: The comment is acknowledged. As the EIR is programmatic in nature, no specific development project is proposed at this time. Therefore, any future development in the Northeast Area Plan that requires temporary or permanent work in, under, or over any portion of the State highway ROW will be responsible for securing an encroachment permit.
The City acknowledges and appreciates Caltrans’ participation in the environmental review process. The comment does not raise any CEQA-related issues; therefore, no further response is required.
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Regional and Local Agencies
B. San Mateo County Environmental Health Services (dated March 5, 2026) Comment B.1: San Mateo County Environmental Health Services (SMCEHS) received the Notice of Availability of the Draft EIR for the Northeast Area Specific Plan. Based on review of the Plan, it is evident that the area contains many properties where subsurface pollution from historical use are undergoing correction action (i.e. investigation, cleanup, or monitoring) or have received regulatory closure with contamination remaining in-place. Regulatory oversight for these cases is provided by either SMCEHS Groundwater Protection Program (GPP), Regional Water Quality Control Board (RWQCB), or Department of Toxic Substances Control (DTSC) staff. As redevelopment proceeds, lingering environmental issues at these sites will need to be addressed to ensure the proposed redevelopment does not pose an unacceptable risk to human health and the environment and that contaminated media generated during construction activities is properly managed and disposed of (through implementation of a Site Management Plan).
You can view properties of concern within the Northeast Area Specific Plan on the Geo Tracker (httP-s://geotracker. waterboards. ca.gov/) and EnviroStor (httP-s://www.envirostor.dtsc.ca.gov/PU blic/) databases.
Response B.1: Pages 174 through 178 of the Draft EIR provide an overview of the existing on-site and off-site sources of hazardous materials contamination in the Plan area. Consistent with the comment, the Draft EIR acknowledges the potential for impacted soil and/or groundwater due to the historical uses in the Plan, including disclosure of open cases and/or land use restrictions. As explained on pages 181 through 182 of the Draft EIR, the General Plan has policies (ESPS-5.3, ESPS-5.5 and ESPS-5.6) that would ensure that future developments under the Plan mitigate hazard exposure, prepare project-level site assessments, and/or remediate contamination under the authority of relevant regulatory agencies (i.e., San Mateo County Environmental Health Services (SMCEHS), the Regional Water Quality Control Board (RWQCB), or Department of Toxic Substances Control (DTSC)). The comment does not raise any specific issues about the adequacy of the Draft EIR, accordingly, no revisions to the Draft EIR are warranted.
Comment B.2: Please ensure that SMCEHS-GPP, RWQCB, and DTSC staff are contacted early in the redevelopment process for any property with subsurface contamination so that we can review the proposed development and determine appropriate environmental measures to be undertaken. The agency providing oversight at a site should be contacted first to provide feedback. SMCEHS-GPP staff, as the local agency, can provide guidance on any properties with newly discovered environmental issues or situations where off-site sourced contamination has impacted a property that requires environmental management during redevelopment.
We look forward to working with you as this area undergoes redevelopment.
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You can always reach out directly to me with any questions.
Response B.2: The comment is acknowledged. Consistent with the City’s current practice and General Plan policies noted above under response B.1, future development projects will be required to coordinate with the appropriate regulatory agencies when applicable to determine appropriate environmental measures to be undertaken based on the proposed land use. The comment does not raise any specific issues about the adequacy of the Draft EIR, accordingly, no revisions to the Draft EIR are warranted.
C. Local Agency Formation Commission (dated April 15, 2026) Comment C.1: Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Northeast Area Specific Plan and Final Draft of the Northeast Area Specific Plan (Plan).
The Local Agency Formation Commission (LAFCo) is a state mandated local agency established in every county to oversee the boundaries of cities and special districts. San Mateo LAFCo has jurisdiction over the boundaries of the 20 cities, 21 independent special districts, and many of the 34 active county and city governed special districts serving San Mateo County.
San Mateo LAFCo has the following comments on the DEIR and Plan:
1) In the DEIR and Plan identify that portions of the Northeast Area are served by Cal Water MidPeninsula District (a private company) and the Mid-Peninsula Water District (an independent special district). The DEIR and Plan states that the use of recycled water may be explored at a future date for the Northeast Area. The Proposed Infrastructure Narrative notes that the City of San Carlos and the Mid-Peninsula Water District (MPWD) may review the possibility of connecting to the City of Redwood City’s recycled water system.
Currently, MPWD provides potable water and water for fire suppression within the District’s boundaries. If MPWD was to provide recycled water service in the future, approval from LAFCo may be required in order for the District to provide a new or different service, such as recycled or reclaimed water (Government Code Section 56824.10 et seq). If recycled water services are proposed to be provided within MPWD’s service area, it is recommended that MPWD discuss the proposal with LAFCo to review if a LAFCo process would be required.
San Mateo LAFCo looks forward to reviewing all future documents related to the Draft Environmental Impact Report for the Northeast Area Specific Plan and Final Draft of the Northeast Area Specific Plan.
Response C.1: The comment is acknowledged. Mid-Peninsula Water District (MPWD) is a separate public agency from the City. MPWD would be responsible for obtaining any future recycled water approvals or reviews from LACFO and any other agencies with jurisdiction over use of recycled water. If recycled water becomes
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available in the Plan area, the City would ensure that future development projects incorporate recycled water. The comment does not raise any specific issues about the adequacy of the Draft EIR, accordingly, no revisions to the Draft EIR are warranted.
D. City of Belmont (dated April 16, 2026)
Comment D.1: The City of Belmont appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the San Carlos Northeast Area Specific Plan (NEASP). As you know, the City of Belmont is undertaking a Specific Plan process for the Harbor Industrial Area (HIA) in preparation for potential annexation of the area into the City. Belmont supports continued coordination between our agencies to address shared infrastructure systems and regional environmental challenges, and issues related to the ultimate redevelopment of the currently underutilized properties that impact our collective jurisdictions.
These comments are focused on key issues under the California Environmental Quality Act (CEQA) where additional clarification or analysis would be beneficial to ensure full disclosure and an accurate understanding of environmental impacts. We are submitting a companion letter that outlines other technical issues and opportunities for collaboration between Belmont, San Carlos, and other affected agencies (San Mateo County, Silicon Valley Clean Water, Mid-Peninsula Water District, etc.).
The City of Belmont offers the following CEQA comments:
I. Regional Nature of Belmont Creek Improvements
The DEIR characterizes several Belmont Creek improvement projects in a manner that could be interpreted as City of Belmont–specific infrastructure. Belmont requests clarification of the record related to this topic.
Response D.1: This comment is a general question on the proposed Plan and does not raise any specific issues about the adequacy of the Draft EIR. The Plan establishes standards for development within the Plan that would occur adjacent to Belmont Creek, including implementation of a 10-foot wide multi-use path along Belmont Creek (page 27 of the Draft EIR) and a 35-foot setback from the existing top of bank for development along the creek. The Plan assumes that future development along the south side of Belmont Creek will implement these improvements. It is unclear what Belmont-specific infrastructure the comment is referencing. It is noted that Appendix J of the Draft EIR references several background studies that have been prepared to evaluate flooding from Belmont Creek. These improvements to Belmont Creek are not part of the Plan nor did the EIR evaluate them. Build-out of the Plan could happen independently of these contemplated Belmont Creek improvements. Based on the Flood Impact Study prepared for the Plan (Appendix E of the Draft EIR), it was determined that 100-year
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runoff would decrease by three percent under the Plan compared to existing conditions. Therefore, the Plan would not result in any significant increase in flooding downstream.
Comment D.2: The County of San Mateo, City of Belmont, and City of San Carlos have worked collaboratively to address persistent flood risk, creek erosion, and water quality issues in the Belmont Creek watershed. This is evidenced by numerous collective efforts in recent years and documented in the Belmont Creek Funding Agreement, signed by Belmont, San Carlos and San Mateo County, and amended on November 12, 2024. The following projects are regional, multiagency efforts:
• Twin Pines Park Belmont Creek Restoration Project
• Twin Pines Park Stormwater Detention Basin
• Harbor Boulevard Bypass (long-term downstream capacity improvement) These projects are intended to function as integrated upstream and downstream system improvements. They address watershed-scale flooding, sedimentation, and water quality issues and provide documented benefits to San Carlos, Belmont, and unincorporated San Mateo County (Harbor Industrial Area). Belmont Creek is a regional system crossing jurisdictions, and flood risks and solutions are not confined to a single city.
Accordingly, the DEIR should:
• Avoid characterizing these improvements as Belmont-only obligations • Recognize their regional function and shared benefit
• Avoid reliance on these projects as committed mitigation to NEASP impacts without identifying appropriate cost-sharing and implementation responsibilities We believe that this better reflects the ten-plus years of coordinated planning among multiple agencies and clarifies the complexity and inter-relationship of the jurisdictions involved in the ultimate watershed infrastructure solutions.
Response D.2: Refer to response D.1 above on the Belmont Creek improvements.
Throughout the Draft EIR, it is explained that the Plan (i.e., future development) would implement a 10-foot wide multi-use path along Belmont Creek (page 27 of the Draf EIR) and a 35-foot setback from the existing top of bank for development along the creek. The Plan incorporates these standards in accordance with the City’s Pulgas Creek Watershed Management Plan and OneShoreline’s Planning Policy Guidance. The 35-foot buffer provides additional space and flexibility in the types of flood protection infrastructure that can be used to protect from increased storm runoff and sea level rise.
No other improvements to Belmont Creek are evaluated as part of the Plan, including any improvements that would be undertaken by the City of Belmont. As
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explained above under response D.1, the Plan could happen independently of the off-site Belmont Creek improvements and 100-year runoff would decrease under the Plan, thereby reducing downstream flooding impacts. The comment does not raise any specific issues about the adequacy of the Draft EIR, accordingly, no revisions to the Draft EIR are warranted.
Comment D.3: II. Storm Drainage and Flooding
The DEIR’s conclusions regarding flood impacts rely in part on assumptions regarding off-site infrastructure and watershed performance that would benefit from further clarification.
A. Reliance on Unfunded or Uncommitted Infrastructure
The DEIR references improvements within the Belmont Creek system that are not fully funded or implemented. While these projects are advancing, they are:
• Regional in nature
• Dependent on multi-agency coordination and funding
• Not solely within the control of the City of Belmont
The improvements lack clear funding sources or funding mechanisms, defined implementation responsibilities, and enforceable timing and sequencing. The impact analysis should not rely on this infrastructure and should be updated accordingly.
Response D.3: It is unclear what offsite infrastructure within the Belmont Creek system the commenter is referencing, refer to response D.1 and D.2 above. As explained on page 30 of the Draft EIR, future development under the Plan would be required to upsize several storm drain pipes or pay a fair share contribution to the improvement in accordance with the 2017 City of San Carlos Storm Drain Master Plan. These improvements would all occur within the Plan boundaries.
As discussed on page 197 through 199 of the Draft EIR, the Plan would not result in direct impacts to Belmont Creek. The Plan would implement a 35-foot setback from the existing top of bank and a 10-foot-wide multi-use path along Belmont Creek. It is anticipated that future development along Belmont Creek would implement the multi-use path. Alterations to the creek are not proposed as part of the Plan and future projects adjacent to the creek would be evaluated pursuant to CEQA once a project-level design is available.
Based on the Flood Impact Study prepared for the Plan (Appendix E of the Draft EIR), it was determined that 100-year runoff would decrease by three percent under the Plan compared to existing conditions. Therefore, the Plan would not result in any significant increase in flooding downstream.
As discussed on page 30 of the Draft EIR, all future development in the Plan would be required to prepare a project-specific hydrology and hydraulic analysis to
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demonstrate that peak stormwater flow is reduced compared to pre-development conditions at the point of connection to the existing storm drain system.
The Plan also incorporates resiliency standards (pages 31 through 34 of the Draft EIR) that would serve to avoid impacts related to impeding or redirecting flood flows.
Comment D.4: B. Need for Watershed-Based Analysis
Given that Belmont Creek is a shared system, the evaluation of flood impacts should reflect watershed-scale conditions rather than jurisdictional boundaries alone. The current analysis does not clearly demonstrate how changes in runoff, timing, or system performance may affect downstream areas, including the HIA.
Response D.4: The Flood Impact Study prepared for the Plan (Appendix E of the Draft EIR) determined that 100-year runoff resulting from properties within the Plan would decrease by three percent under the Plan compared to existing conditions.
Therefore, the Plan would not result in any significant increase in flooding downstream compared to baseline conditions within the Plan.
Comment D.5: III. Belmont Creek Ownership and Maintenance Responsibilities Belmont requests clarification in the DEIR that:
• Belmont Creek, particularly downstream of Old County Road, forms a boundary between jurisdictions
• Maintenance responsibilities are generally borne by adjacent property owners within each jurisdiction, not solely by a single city
This distinction is important to avoid mischaracterization of long-term operational responsibilities associated with creek improvements.
Response D.5: As stated on page 4 of the Draft EIR, “The Plan consists of approximately 145 acres, roughly bound by Belmont Creek, U.S. Highway 101 (U.S. 101), the western property lines of the residential parcels along Northwood Drive, the northeastern property lines of the residential parcels along Fairfield Drive, the southeast property line of the Palo Alto Medical Foundation (PAMF) and Old County Road in the City of San Carlos (City).” Accordingly, the Draft EIR appropriately characterizes the boundaries of the Plan with respect to Bellmont Creek and Old Country Road and no revisions to the Draft EIR are warranted.
As discussed on page 197 through 199 of the Draft EIR, the Plan would not result in direct impacts to Belmont Creek. The Plan would implement a 35-foot setback from the existing top of bank and a 10-foot-wide trail along Belmont Creek. It is anticipated that future development along Belmont Creek would implement the multi-use path. Alterations to the creek are not proposed as part of the Plan and
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future projects adjacent to the creek would be evaluated pursuant to CEQA once a project-level design is available. The Draft EIR does not attempt to describe or delineate long-term operational responsibilities associated with creek improvements outside of the Plan.
Comment D.6: IV. Consideration of Foreseeable HIA Governance Scenarios The DEIR does not evaluate a reasonably foreseeable scenario regarding the future governance of the HIA, specifically whether the HIA remains under County jurisdiction or is annexed to the City of Belmont. These scenarios could materially affect infrastructure demand, service responsibility, and environmental impacts. In particular:
• Annexation could shift infrastructure responsibility and service provision to Belmont • Alternatively, if the HIA remains under County jurisdiction, Belmont may experience indirect impacts without corresponding regulatory authority
Because these represent distinct impact pathways, the absence of this analysis limits full disclosure under CEQA.
Response D.6: The City understands that the City of Belmont is currently preparing a Draft EIR for the Harbor Industrial Area Specific Plan. At this time, the Draft EIR for the Harbor Industrial Area Specific Plan has not been circulated for public review.
The City has no authority over the HIA and whether it is governed by Belmont or the County, nor is the City equipped to evaluate the scenarios noted in the comment, as the City does not and would not serve the HIA under any of the scenarios. The City anticipates that the City of Belmont’s Draft EIR would evaluate the various governance scenarios described above and the associated infrastructure demand effects, whereas the Northeast Area Specific Plan Draft EIR is evaluating the environmental effects of the proposed Northeast Area Specific Plan, in combination with anticipated cumulative development. The CEQA Guidelines advise that a discussion of cumulative impacts should reflect both their severity and the likelihood of their occurrence (CEQA Guidelines Section 15130(b)). Table 3.0-1 of the Draft EIR identifies the approved (but not yet constructed or occupied) and pending projects in the project vicinity that are evaluated in the cumulative analysis, including the Harbor Industrial Area Specific Plan. The Water Supply Assessment prepared for the Northeast Area Specific Plan by the Mid-Peninsula Water District accounts for the water demand of the Harbor Industrial Area Specific Plan (refer to Appendix I of the Draft EIR).
Comment D.7: V. Deferral of Infrastructure Analysis
The DEIR relies on deferral of certain infrastructure evaluations to future project-level analysis.
Belmont is concerned that deferral may lead to unanticipated impacts that cannot be solved at a project level. We suggest that some level of watershed analysis be completed. As noted earlier in
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the discussion of storm drainage and flooding, the analysis appears to assume that the detention basin and bypass will be constructed. It does not appear to consider a no-project or delayed project scenario for these improvements.
Response D.7: The Draft EIR does not rely on the comment’s referenced detention basin or bypass. As explained in response D.1 above, Appendix J of the Draft EIR references several background studies that have been prepared to evaluate flooding from Belmont Creek. Build-out of the Plan could happen independently of these contemplated Belmont Creek improvements. Based on the Flood Impact Study prepared for the Plan (Appendix E of the Draft EIR), it was determined that 100-year runoff would decrease by three percent under the Plan compared to existing conditions.
The commenter asserts that the Draft EIR improperly defers analysis of required infrastructure improvements to future project-level review. This assertion is not supported by the record.
The Draft EIR for the preparation and implementation of a Specific Plan governing development over a 20-year period evaluates potential impacts related to infrastructure demand at a programmatic level, consistent with CEQA requirements.
It identifies the types of infrastructure improvements necessary to support future development (see page 30 of the Draft EIR). As discussed on page 198, implementation of these improvements is expected to reduce 10-year flood depths under full buildout of the Plan. In addition, the Plan incorporates Resiliency Standards requiring future development projects to prepare project-specific hydrology and hydraulic analyses demonstrating that peak stormwater flows at the point of discharge to the existing storm drain system would be reduced compared to pre-development conditions.
Where site-specific engineering details are not yet available, the Draft EIR appropriately provides for subsequent project-level studies to refine infrastructure design and verify consistency with established performance standards. Future discretionary projects will be required to either (1) construct the necessary infrastructure improvements, or (2) contribute a fair share toward planned improvements through applicable funding mechanisms, and those planned improvements would undergo project-level environmental review.
This approach ensures that required infrastructure improvements are clearly identified and will be implemented in a manner that avoids or mitigates significant impacts. The Draft EIR evaluates at a programmatic level the future infrastructure needs to support implementation of the Plan, and does not defer mitigation; rather, it establishes enforceable performance standards and a framework for implementation. Deferral of mitigation is impermissible for project-level environmental review, while programmatic CEQA documents such as the Draft EIR
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for the Plan appropriately identify the need for infrastructure to be designed and evaluated at a project-level during the timeframe of the Plan’s implementation.
Deferral of final design details to later project-level review is permissible under CEQA where, as here, the EIR commits to mitigation and provides sufficient standards to guide its execution.
Comment D.8: Relatedly, the EIR should consider the potential floodplain storage impacts of fill placement for future pad elevations that may occur with development in the NEASP that may impact flood elevations within the HIA.
Response D.8: A Flood Impact Study was prepared for the Plan (refer to Appendix E of the Draft EIR). As discussed on pages 199 through 199 of the Draft EIR, the Plan incorporates several resiliency project requirements that would ensure that future development under the Plan would not result in impacts related to impeding or redirecting flood flows. As redevelopment occurs in the Plan, fill will be placed to elevate building pads and structures above the base flood elevation plus sea level rise, providing some potential to displace the floodplain. For offsite flood flows to be increased, grading and building construction would have to block the active conveyance of flood flows through the project site. To meet the National Flood Insurance Program, future projects would need to demonstrate that they would not result in more than one foot of cumulative impact to the floodplain.
According to the Flood Impact Study, 100-year runoff with the Plan area would decrease by three percent under the Plan compared to existing conditions.
Therefore, the Plan would not result in any significant increase in flooding downstream.
Comment D.9: In conclusion, the City of Belmont supports continued collaboration with the City of San Carlos and other regional partners to address shared infrastructure systems. The requested clarifications are intended to: ensure an accurate description of regional infrastructure responsibilities; improve transparency regarding flood risk and watershed conditions; and support informed and coordinated planning across jurisdictions.
Belmont looks forward to continued coordination through both the CEQA process and parallel interagency discussions. Thank you for your consideration.
Response D.9: The City acknowledges and appreciates the City of Belmont’s participation in the environmental review process. Refer to responses D.1 through D.8. The comment does not raise any specific issues about the adequacy of the Draft EIR and no further response is required.
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Organizations, Businesses, and Individuals
E. Lorelei Alli on behalf of the Amah Mutsun Tribal Band of San Juan Bautista (dated March 3, 2026)
Comment E.1: Thank you for the information on the proposed project, and please see the attached documents with our recommendations. If you have any questions about the attached documents, or would like to set up a meeting to discuss consultation, please give us a call at 650-851-7489 or email us at [email protected]
Response E.1: On July 2, 2024, the City sent letters to tribes listed by the NAHC as having a potential affiliation to the Plan area. The City did not receive any requests from the tribes to consult pursuant to SB 18 or AB 52 (refer to page 280 of the Draft EIR), including from the Amah Mutsun Tribal Band of San Juan Bautista. The consultation period concluded on August 2, 2024.
The Amah Mutsun Tribal Band of San Juan Bautista responded to the NOP, which was issued on July 1, 2024. As part of the tribe’s comment letter on the NOP and Draft EIR, the tribe recommended that a Sacred Lands File and CHRIS record search be completed for the Plan area. As discussed on page 121 of the Draft EIR, a records search was completed for the Plan at the Northwest Information Center of the California Historical Resources Information System (CHRIS) on January 10, 2023. The archaeological resources were identified within the Plan or immediate vicinity. The Sacred Lands File results were negative. The comment does not raise any specific issues about the adequacy of the Draft EIR, accordingly, no revisions to the Draft EIR are warranted.
Comment E.2: Letter of Response Attachment
It is our pride and privilege to be of service for any Native American Cultural Resource Monitoring, Consulting and/ or Sensitivity Training you may need or require. We take our Heritage and History seriously and are diligent about preserving as much of it as we can. Construction is a constant in the Bay Area and with that new discoveries are bound to happen. If you choose our services, we will gladly guide all personnel through proper procedures to safely protect and preserve: Culture, Heritage, and History.
It is highly recommended, if not previously done, to search through Sacred Lands Files (SLF) and California Historical Resource Information Systems (CHRIS) as well as reaching out to the Native American Heritage Commission (NAHC) In order to determine whether you are working in a Cultural and/ or Historic sensitivity.
If you have received any positive cultural or historic sensitivity within 1 mile of the project area here are A.M.T.B Inc’s and Amah Mutsun Tribal Band of San Juan Bautista’s recommendations:
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• All Crews, Individuals and Personnel who will be moving any earth be Cultural Sensitivity Trained.
• A Qualified California Trained Archaeological Monitor is present during any earth movement.
• A Qualified Native American Monitor is present during any earth movement.
If further Consultation, Monitoring or Sensitivity Training is needed please feel free to contact A.M.T.B. Inc. or Myself Directly. A.M.T.B. Inc. 650-851-7747 Response E.2: Refer to response E.1 above regarding the CHRIS record search and Sacred Land File results. Accordingly, given the results were negative for both, monitoring is not required. The Draft EIR concluded that compliance with the General Plan policies LU-1.10, LU-12.1 and LU-12.5, which require preservation of archaeological resources and evaluation of cultural and tribal cultural resources as part of the development review process, as well as existing federal and state law, would protect unrecorded tribal cultural resources in the Plan 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. The comment does not raise any specific issues about the adequacy of the Draft EIR, accordingly, no revisions to the Draft EIR are warranted.
F. Allen Matkins Leck Gamble Mallory & Natsis LLP (dated April 2, 2026) Comment F.1: This office represents Hunter Partners, LLC, through its single purpose entity BP I SPE, LLC (collectively, “Hunter”), the owner of real property located at 151 Industrial Road (“Property”) in the City of San Carlos (“City”). These comments pertain to the proposed Northeast Area Specific Plan (“Plan”)1 and the Draft Environmental Impact Report (“DEIR”)2 for the Plan.
I. Background
Hunter owns and operates a self-storage facility on the Property. Self-storage uses provide a unique service that no other type of business can provide, including much-needed extra space for households living in smaller units with limited storage, and much-needed storage for small businesses including landscapers, general contractors, pharmaceutical representatives, home stagers, and a wide variety of other professionals. In turn, self-storage uses strengthen the economic vitality of the City. Self-storage uses are also a less-intensive land use as compared to other uses currently contemplated in the Plan area.
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Hunter seeks to redevelop the Property to increase the amount of self-storage capacity, but is currently prohibited from doing so, in part because of its legal nonconforming status.1 As detailed in our letter dated July 26, 2024, we requested that the Plan include, and the DEIR analyze, the ability to expand an existing lawful non-residential nonconforming use in the Plan area, subject to approval of a conditional use permit (“CUP”).
More specifically, we requested that the following provision be included in the Plan and analyzed in the DEIR: “Any existing lawful non-residential nonconforming use in the Specific Plan may be expanded in its occupancy, building floor area and height, in keeping with the Specific Plan development standards, including through demolition and new construction, subject to Planning and Transportation Commission approval of a conditional use permit in accord with Municipal Code Chapter 18.30, Use Permits.” We question why that request was not fulfilled, particularly since a substantial number of new businesses and residential units will be developed in the Plan area and would benefit from additional storage.
We reiterate that the existing lawful nonconforming self-storage use on the Property should be allowed to expand, subject to approval of a CUP. As you are aware, the purpose of the CUP process is to ensure that the project is “designed, located, and operated in a manner that will not interfere with the use and enjoyment of surrounding properties.” (City Municipal Code, § 18.30.010.) Furthermore, the Planning and Transportation Commission would need to make specified findings to approve the CUP, including that (i) the project will not be adverse to the public health, safety, or general welfare of the community, nor detrimental to surrounding properties or improvements; (ii) the project complies with design and development standards applicable to the zoning district and Plan area; (iii) the design, location, size, and operating characteristics of the expanded self-storage use are compatible with the existing and reasonably foreseeable future land uses in the vicinity and Plan area; and (iv) the project site is physically suitable for the type, density, and intensity of use being proposed, including access, utilities, and the absence of physical constraints. (City Municipal Code, § 18.30.060.) Thus, the City would retain control over such development proposals and would have the power to deny a proposal if it failed to meet the City’s requirements set forth above.
Response F.1: The comment provides general suggestions regarding the proposed Plan but does not raise issues related to the adequacy of the DEIR or present substantial evidence of an environmental impact requiring additional evaluation under CEQA. The comment is acknowledged; however, because it does not pertain to the environmental analysis or conclusions presented in the DEIR, no further response is warranted. Nonconforming uses will not be permitted to expand in floor area or height in the Plan, consistent with limitations on nonconforming uses 1 See City Municipal Code Chapter 18.19. The existing self-storage facility on the Property was constructed in circa 1997 before the Property was annexed into the City. The DEIR incorrectly states that the facility was constructed in 1974. (DEIR, p. 122.)
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citywide. In addition, public storage uses are not recommended as permitted or conditional uses in the Plan.
The EIR has been revised to reflect that the property located at 151 Industrial Road was constructed circa 1997, not 1974 (refer to Section 5.0 Draft EIR Text Revisions).
The text revisions do not constitute a “substantial revision” pursuant to CEQA Guidelines §15073.5 and recirculation of the EIR is not required.
Comment F.2: II. Comments on the Plan
Under the Plan, the Property would be rezoned from Industrial Professional (IP) to Production and Innovation (P-I)4 and located within the “allowed active use” corridor along Industrial Road and the “Creek Front Zone” adjacent to Belmont Creek.
A. Creek Front Zone & Public Open Space Requirements
The City’s existing Stream Development and Maintenance (SDM) Overlay District requires a 25-foot setback from the top of bank line of Belmont Creek. (City Municipal Code, Chapter18.14.) However, “[u]nder existing conditions, existing development in the Plan does not provide a 25-foot setback since most development pre-dates the City’s setback requirements.” (DEIR, p. 101.) Therefore, without proper redevelopment, the Plan would result in a disjunct of older buildings adjacent to the creek and new buildings up to 155 feet in height set back from the creek. (DEIR, pp. 14-15; Plan, §
4.14.)
As currently proposed, future development within the Creek Front Zone would be required to be set back 35 feet from the existing top of bank of Belmont Creek “to support stormwater detention for flooding events and sea level rise.”2(Plan, § 6.3.3.) The Plan further provides: “The first 25 feet from the top of bank shall comprise of native riparian vegetation” as “an interface between the creek and the terrestrial environment [which] supports diverse habitats and helps maintain water quality by preventing erosion and filtering pollutants.” (Plan, § 6.3.4). A “multi-use path for pedestrians and bicyclists shall be built along the riparian landscape” and “shall be at least 10 feet in width.” (Plan, § 6.3.5.)
It appears that the proposed 35-foot setback requirement is merely a guise to force developers to provide a 10-foot public path along the creek, in addition to the existing 25-foot setback requirement. The existing setback requirement has been deemed sufficient for purposes of the City’s SDM Overlay District, and we question whether there is a legitimate basis for extending that to 35 feet, and whether there is a nexus study to support that proposed requirement, which is a defacto dedication requirement. 2 We note that an “additional 15 feet is encouraged for a total of 50 feet.”
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Response F.2: The commenter is correct that under the City’s current requirements, developments along Belmont Creek are required to maintain a 25-foot setback from the top of bank (SCMC Section 18.144.040). General Plan Action EM-2.1 considers amendments to the City’s Riparian Ordinance to strengthen stream protection requirements and reduce potential for flooding, including increased setbacks. The 35-foot setback is further supported by applicable local and regional guidance, including the City’s Pulgas Creek Watershed Management Plan and OneShoreline’s Planning Policy Guidance, which recommend a 35-foot setback measured from the top of creek along the San Francisco Bay Shoreline.
3,4 The 35-foot buffer provides
additional space and flexibility in the types of flood protection infrastructure that can be used to protect from increased storm runoff and sea level rise. Further, as documented on pages 101 to 112 of the Draft EIR, the 35-foot setback would serve to reduce impacts to biological resources, including impacts to Belmont Creek and its riparian habitat. The comment is acknowledged; however, because it does not pertain to the environmental analysis or conclusions presented in the DEIR, no further response is warranted.
Comment F.3: The Plan also layers on public open space dedication requirements, which would apply to private property: “For lots greater than 15,000 sq. ft. (0.3 acres) but less than 1 acre, a minimum of 10% shall be required to be publicly accessible open or park space [and for] lots greater than 1 acre, a minimum of 15% shall be required to be publicly accessible.” (Plan, § 4.7.2.) In the Creek Front Zone, “[a]t least 50% of the open space shall directly abut the Belmont Creek Greenway [and all] open spaces shall be accessible to the public via the greenway.” (Plan, § 6.3.2.) There is no evidence of a nexus study that supports these proposed dedication requirements.
The foregoing requirements, in combination with Creek Front Zone requirements, would place a disproportionate burden on properties in the Plan area along Belmont Creek and would significantly limit redevelopment capacity. Furthermore, any additional setback requirements, multi-use path requirements, and open space requirements must factor in other development constraints, such as existing easements. For example, there is an existing PG&E easement on the Property, which already restricts development. We ask that the City revisit and justify these proposed requirements.
At a minimum, the City must have the ability to modify Plan requirements on a case-by-case basis.
As the City must be aware, its current approach fails to meet the constitutional nexus requirements under the Nollan/Dolan line of cases.
Response F.3: The comment provides general suggestions and opinions regarding nexus requirements regarding the proposed Plan but does not raise issues related to the adequacy of the DEIR or present substantial evidence of an environmental 3 City of San Carlos. Pulgas Creek Watershed Management Plan. March 24, 2025. Page 41. 4 OneShoreline. Planning Policy Guidance to Protect and Enhance Bay Shoreline Areas of San Mateo County. June 2023. Page 34.
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impact requiring additional evaluation under CEQA. The comment is acknowledged; however, because it does not pertain to the environmental analysis or conclusions presented in the DEIR, no further response is warranted. The increased setback along Belmont Creek, multi-use path requirements, and open space requirements will be applied uniformly to developments along Belmont Creek in the Plan area and not as individual exactions. These requirements also help offset impacts to Belmont Creek.
The Plan’s proposed 15-percent of open space for properties greater than one-acre is an incremental increase from minimum open space required in other mixed-use districts in the City (10 percent). This incremental increase is based on the Specific Plan's Guiding Principle to promote access to open space, as well as the greater community's vision for increased public open space in the City's east side.
Comment F.4: B. Permitted Uses
The Plan only currently provides a list of permitted active ground floor uses, which includes “Indoor Warehousing and Storage” with a CUP. (Plan, § 4.8, Table 6.) That use category includes the storage of commercial goods, industrial equipment, products and materials, cold storage, and freight storage, and as “an ancillary use, includes storage in small individual spaces exclusively and directly accessible to a specific tenant.” (City Municipal Code, § 18.40.050(H)(2).) We question why selfstorage uses would not also be conditionally permitted in the Plan area, as it is similar to, yet less intensive than, those permitted uses identified above. From a planning perspective, this use would support a substantial number of new businesses and residential units that will be developed in the Plan area and would benefit from additional storage.
The Property is located along the Industrial Road “allowed active use” corridor, the purpose of which is “[t]o create pedestrian and visual activity at the ground floor of new developments.” (Plan, § 4.8.1.) If the Property is redeveloped as a larger self-storage facility, active uses5could be provided along Industrial Road (e.g., “maker” spaces), which would be an improvement over existing conditions and consistent with the Plan’s goals.6 Response F.4: The comment provides general suggestions regarding the proposed Plan but does not raise issues related to the adequacy of the Draft EIR or present substantial evidence of an environmental impact requiring additional evaluation under CEQA. The comment is acknowledged; however, because it does not pertain 5 Principally permitted “active uses” would include (but not be limited to) custom manufacturing, general industry, specified research and development activities, and wholesale and distribution. (Plan § 4.8, Table 6.) 6 Ground floor active use spaces “shall provide usable spaces with a depth of at least twelve (12) feet without interior obstructions such as walls or partitions” and “shall extend to at least fifty-five percent (55%) of the length of the public street frontage.” (Plan, § 4.8.1.)
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to the environmental analysis or conclusions presented in the DEIR, no further response or revisions to the EIR are warranted.
Comment F.5: III. Comments on the DEIR
The DEIR should include an analysis of less-intensive non-residential land uses, such as self-storage uses. Currently, the alternatives analysis in the DEIR is legally inadequate because it contains a narrow range of alternatives, none of which would substantially lessen or avoid the following significant and unavoidable impacts:
• Impact AIR-3: Buildout of the Plan would result in annual and average daily emissions of ROG, NOx and PM10, and PM2.5 associated with operation of the Plan Area [that] would exceed the Bay Area Air District project-level significance thresholds. (DEIR, p. 323.) • Impact AIR-C: Buildout of the Plan would result in a cumulatively considerable net increase of criteria pollutant emissions. (Id.)
• Impact GHG-1: Implementation of the Plan would exceed the 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 SB 32 or the carbon neutrality goal under AB 1279. (DEIR, p. 325.)
• Impact GHG-C: Implementation of the Plan would result in a significant cumulative GHG impact. (Id.)
Response F.5: The Draft EIR evaluated a reasonable range of alternatives that were developed according to the objectives of the Plan. Pursuant to CEQA, the EIR should identify alternatives which “feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.” The Draft EIR evaluated a total of seven alternatives, including two reduced development alternatives and an alternative without residential uses and two alternatives that would reduce the overall scale of development. As discussed in Section 7.2 Project Alternatives on pages 315-327 in the DEIR, three alternatives were considered but rejected for further analysis (i.e., a Location alternative, All Employment Alternative, and GHG Reduction Alternative) and four alternatives were selected: two No Project alternatives, a Reduced Criteria Pollutant Emissions Alternative and an Enhanced TDM Alternative. CEQA dictates that an EIR must evaluate a “No Project” alternative (CEQA Guidelines Section 15126(e)1(1)).
CEQA does not establish a minimum number of alternatives to be evaluated, rather the CEQA Guidelines state that “the range of alternatives required in an EIR is governed by a rule of reason.” (CEQA Guidelines Section 15126.6(a) & (f)).7 As discussed on page 314 of the DEIR, the alternatives evaluated in this EIR were 7 See also Citizens of Goleta Valley v. Board of Supervisors (1990); Laurel Heights Improvement Association v.
Regents of the University of California (1988))
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selected because they would reduce and/or eliminate one or more of the significant and unavoidable impacts associated with the project. As such, the Draft EIR evaluated a reasonable range of alternatives that would fully avoid or partially reduce the project’s significant and unavoidable impacts.
The commenter suggests that the Draft EIR should evaluate less-intensive nonresidential land uses, such as self-storage uses. A non-residential alternative (All Employment Alternative) is presented on page 316 of the DEIR. As discussed in the DEIR, it is assumed that if this area remained Planned Industrial, it would be developed with up to 5,293,642 square feet of employment uses. None of the significant impacts of the project are directly related to the inclusion of housing in the Plan. Under this alternative, the scale of development would be similar to the Plan. Therefore, it is anticipated that this alternative would not avoid or substantially lessen any of the Plan’s significant impacts. One of project’s fundamental objectives to introduce housing in the Plan area to accommodate future population growth in San Carlos, some of which planned housing within the Plan area is intended to satisfy some of the City’s mandated housing during future RHNA cycles. Therefore, any alternative that does not include housing would not meet this fundamental objective.
The commenter also suggests that the Draft EIR should evaluate alternatives with less intensive non-residential land uses, such as self-storage or public storage uses.
On page 318 of the DEIR, the No Project, Existing Plans Alternative is presented.
Under this alternative, it is assumed that some level of redevelopment would occur in accordance with the existing land use and zoning requirements. The City anticipates that redevelopment would occur on approximately 27 acres within the Plan, resulting in up to 874,000 square feet of net new non-residential uses. As noted on page 318 of the Draft EIR, it is anticipated that the significant NOx and ROG impacts disclosed in Impact AIR-3 would be reduced to less than significant since the alternative would reduce the non-residential development by approximately 80 percent. All other significant and unavoidable impacts of the Plan would continue to result (i.e. rate of trip growth and GHG impacts), although at an incrementally reduced levels given the 80 percent reduction in development would lead to reduced criteria pollutants, and reduced GHG emissions from mobile sources. This alternative would not accomplish most of the Plan’s objectives.
Finally, the Draft EIR also evaluated a second reduced scale alternative, the Reduced Criteria Pollutant Emissions Alternative. Under this alternative, development would be reduced by 20 percent. As stated in the Draft EIR, this alternative would reduce the Plan’s significant NOx emissions disclosed in Impact AIR-3 to less than significant, however, the Plan’s ROG emissions, while reduced, would remain significant and unavoidable. All other environmental impacts under this alternative would be similar to the proposed Plan.
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While the comment raises concerns regarding the range of alternatives evaluated in the Draft EIR, the range of alternatives presented in the Draft EIR, as clarified above, was developed according to the rule of reason and satisfies CEQA. Accordingly, no revisions to the Draft EIR are warranted.
Comment F.6: The DEIR includes a “Reduced Criteria Pollutant Emissions Alternative,” but that alternative would not substantially lessen or avoid the foregoing significant and unavoidable impacts. (DEIR, pp. 322-325.) That alternative, which would reduce the Plan’s proposed development by 20%, would only reduce NOx emissions to avoid exceeding that threshold of significance. (DEIR, p. 320.) All other criteria pollutants would continue to exceed the applicable thresholds of significance. (Id.) Furthermore, the “Reduced Criteria Pollutant Emissions Alternative” would only “partially” meet each of the Project objectives and will presumably be rejected by the City for that reason. (DEIR, p. 326.)
Response F.6: The comment incorrectly concludes that the Reduced Criteria Pollutant Emissions Alternative would not substantially avoid or lessen significant and unavoidable impacts. As stated on page 320 of the Draft EIR, the Reduced Criteria Pollutant Emissions Alternative would reduce the project’s significant NOx impact to less than significant. While the ROG emissions would also be reduced under this alternative, the magnitude of ROG emissions would exceed the 10 tons per year threshold, and the impact would remain significant and unavoidable. The other significant and unavoidable impacts (i.e. rate of trip growth and GHG impacts) would not be avoided. There is not an alternative that would reduce the significant and unavoidable GHG impact, since there is no Plan alternative that can guarantee carbon neutrality by 2045, as disclosed under the GHG Reduction Alternative on page 316 of Draft EIR.
The City Council will ultimately decide the feasibility of project alternatives based on substantial evidence in the record including the analysis in the EIR.
Comment F.7: The DEIR explains that to reduce the Plan’s ROG emissions to below the significance threshold, the Plan’s development would need to be reduced by approximately 80%. (DEIR, p. 320.) Therefore, the DEIR readily dismisses that potential reduction and “instead focuses on the more achievable goal of avoiding the Plan’s significant NOx impact.” (Id.) That is not legally adequate. The DEIR must also consider an alternative with less-intensive non-residential land uses to substantially lessen or avoid the Project’s significant and unavoidable impacts due to GHG, ROG, PM10, and PM2.5 emissions.
As explained in the DEIR, the San Francisco Bay Area Air Basin is already a designated nonattainment area for federal and state air quality standards and the Bay Area Air District is focused on controlling precursor pollutants, including ROG, to reduce Ozone levels. (DEIR, p. 63.) In the Bay Area, particulate matter, including PM10, and PM2.5, is generated from activities such as combustion, factories, and motor vehicles. (Id.) Therefore, it stands to reason that less-intensive non-residential land uses would result in the reduced generation of problematic particulate matter.
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Our position is supported by CEQA, the CEQA Guidelines, and related case law. To wit:
• CEQA mandates that the City must not approve a project with a significant unavoidable impact if “there are feasible alternatives . . . that can substantially lessen or avoid those effects.” (Mountain Lion Foundation v. Fish & Game Commission (1997) 16 Cal.4th 105, 1343; Public Resources Code § 21002; emphasis added.)
• CEQA mandates that the EIR “shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and evaluate the comparative merits of the alternatives.” (CEQA Guidelines 15126.6; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553 and Laurel Heights Improvement Association v. Regents of the University of California (1988) 47 Cal.3d 376; emphasis added.)
• As explained by the California Supreme Court: “Without meaningful analysis of alternatives in the EIR, neither the courts nor the public can fulfill their proper roles under the CEQA process.” (Laurel Heights Improvement Association v. Regents of the University of California, supra, 47 Cal.3d, 403-04.)
• The DEIR fails to describe the City’s rationale for not including an alternative that would meet most of the Project objectives and substantially lessen or avoid the Project’s significant and unavoidable air quality impacts contrary to various related CEQA decisions (see, e.g., Center for Biological Diversity v. County of San Bernardino (2010) 185 Cal.App.4th 866; Watsonville Pilots Association v. City of Watsonville (2010) 183 Cal.App.4th 1059.) Response F.7: Refer to response F.6 for a detailed explanation of the reasonable range of alternatives required under CEQA. The comment suggests that the Draft EIR should consider an alternative with less-intensive non-residential land uses to substantially lessen or avoid the project’s significant and unavoidable impacts due to GHG, ROG, PM10, and PM2.5 emissions. As explained in response F.6, the No Project, Existing Plans Alternative would develop the Plan with less intensive non-residential uses (up to 874,000 square feet) in accordance with the existing land use and zoning requirements. This represents an 80 percent reduction in development, which would reduce the significant NOx and ROG impacts disclosed in Impact AIR-3 to less than significant. All other significant and unavoidable impacts of the Plan would continue to result (i.e. rate of trip growth and GHG impacts), although at incrementally reduced levels given the 80 percent reduction in development would lead to reduced criteria pollutants, and reduced GHG emissions from mobile sources. This alternative would only partially accomplish Project Objective 1, all other objectives would not be realized. A core principle of CEQA is that project alternatives should be capable of feasibly attaining most of the project’s basic objectives (which the No Project, Existing Plans Alternative largely would not) while avoiding or substantially reducing the project’s significant environmental impacts.
While the comment raises concerns regarding the evaluation of alternatives, the analysis in the Draft EIR, as clarified above, demonstrates that these concerns have
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been adequately addressed. Accordingly, no revisions to the Draft EIR are warranted.
Comment F.8: An alternative with less-intensive non-residential land uses, such as self-storage, would meet most of the Project objectives identified in the DEIR by (1) celebrating and maintaining the area’s industrial legacy, (2) still introducing housing in the Plan area, (3) supporting district-wide access by providing multi-modal infrastructure, (4) addressing flooding and sea level rise, and (5) planning for net new non-residential development through development standards and a community benefits framework.
Response F.8: The EIR is programmatic in nature covering the entire 145-acre Plan area, and no specific development project is proposed at this time. Specific uses, like self-storage or public storage, are not evaluated. Rather, the EIR evaluates residential and non-residential uses in accordance with the Plan’s proposed General Plan land us designations and zoning districts. Refer to responses F.6 through F.8 above for a detailed response on the adequacy of alternatives evaluated in the Draft EIR. Accordingly, no revisions to the Draft EIR are warranted. In addition, public storage uses will not be recommended as permitted or conditional uses in the Plan.
Comment F.9: The Plan area totals 145 acres, and the Plan would result in 1,890 residential units and 4,508,000 net new square feet of non-residential uses. (DEIR, p. 10.) The fact that only two alternatives were fully evaluated in the DEIR – aside from the “no project” alternatives – is blatantly inadequate. We respectfully urge that an alternative with less-intensive non-residential land uses (such as self-storage) must also be considered, and the DEIR must be recirculated.
Response F.9: Refer to response F.6 above for an explanation of the Draft EIR’s alternatives and the requirements under CEQA. As explained in response F.6, CEQA does not establish a minimum number of alternatives to be evaluated. Rather, the Draft EIR evaluated a reasonable range of alternatives that would avoid or partially reduce the project’s significant and unavoidable impacts. As noted above in response F.9, the Draft EIR is programmatic in nature and does not evaluate specific uses, such as self-storage. While the comment raises concerns regarding the range of alternatives, the analysis in the Draft EIR, as clarified above in responses F.6 through F.9, demonstrates that these concerns have been adequately addressed.
Accordingly, no revisions to the Draft EIR are warranted. Contrary to the comment, nothing has been raised that represents new significant information that would warrant recirculation of the Draft EIR pursuant to CEQA Guidelines Section 15088.5(a).
G. Greater East San Carlos Neighborhood Board (dated April 6, 2026) Comment G.1: These comments are regarding the Draft Environmental Impact Report (DEIR) prepared for the Northeast Area Specific Plan by the City of San Carlos. The purpose of the DEIR is to meet the standards set by the California Environmental Quality Act (CEQA) and its Guidelines,
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and to keep the public informed about relevant decision-making processes. The document covers the proposed plan but lacks sufficient evidence in parts of the environmental analysis. Additional clarification and analysis are necessary to ensure compliance with CEQA.
1. Adequacy of the Project Description
CEQA requires that an EIR contain a stable, finite, and accurate project description sufficient to allow meaningful evaluation of environmental impacts and alternatives (CEQA Guidelines §15124).
The project description for the Northeast Area Specific Plan appears to allow a wide range of development intensities, including substantial residential development, commercial uses, and building heights up to approximately 155 feet.
However, the DEIR does not clearly define the reasonable maximum development scenario that forms the basis of the environmental analysis. Without a clearly defined buildout scenario— including maximum residential units, commercial square footage, and infrastructure assumptions— it is difficult to determine whether the environmental analysis represents the project’s true worstcase impacts. The Final EIR should clarify the development envelope and ensure that all impact analyses reflect the maximum foreseeable development intensity.
Response G.1: Table 2.4-1 on page 10 of the Draft EIR presents the anticipated new development that would occur over the approximate 20-year period of the Plan. As stated in the EIR, the Plan would allow for an increase of 1,890 residential units and up to 4,508,00 net new non-residential square footage. This amount of development is consistently evaluated throughout the Draft EIR. Therefore, the commenter is mistaken that the EIR’s project description does not clearly define the buildout scenario and no further revisions to the EIR are warranted.
Comment G.2: 2. Transportation and Circulation Analysis The transportation analysis should more clearly evaluate cumulative vehicle miles traveled (VMT) impacts and potential congestion at key access points to U.S. Highway 101 and adjacent arterial roadways. Although CEQA has shifted from level-of-service metrics to VMT pursuant to SB 743, the DEIR must still adequately evaluate localized circulation constraints where safety or operational issues may arise.
Given the constrained roadway network in the northeast portion of San Carlos and the limited number of access points to the area, the DEIR should more fully analyze:
• peak-period access constraints to the highway network. • potential queuing and spillback impacts at key intersections • conflicts between truck traffic serving existing industrial uses and new residential uses. • the effectiveness and enforceability of proposed transportation demand management (TDM) measures
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• opportunity to enhance the northbound Highway 101 on ramp at Harbor with the City of Belmont and Caltrans, reducing congestion on the Holly Street overpass.
The EIR should also clarify whether mitigation measures are enforceable performance standards or merely policy recommendations.
Response G.2: A level of service analysis is provided on pages 275 through 278 of the Draft EIR. Peak hour (AM and PM) trip generation estimates are provided in Table 3.17-1 of the Draft EIR. Project-level analysis regarding potential truck conflicts cannot be identified at this time. However, future development projects implementing the Plan would be reviewed as part of the City’s discretionary permit process for potential conflicts.
As discussed on page 37 of the Draft EIR, all new development in the Plan would be subject to Transportation Demand Management (TDM) requirements, unless otherwise noted in Tables 2.4-8 and 2.4-9 of the Draft EIR. The City’s TDM requirements are codified in Chapter 18.25 of the SCMC. As part of the City’s requirements, developments that are subject to the TDM requirements must submit annual reports documenting TDM activities undertaken and their results. After a period of five years, the TDM program must be reviewed in terms of the overall effectiveness and is subject to Director’s review and approval.
The Plan does not propose any changes to the US 101 on- or off-ramp at Holly Street. The ongoing US-101/Holly Street Interchange Project proposes changing the existing interchange from a four-quadrant cloverleaf to a partial cloverleaf configuration with a separate pedestrian overcrossing. It also improves bicycle and pedestrian circulation through the interchange. The lane configuration changes proposed as part of this project were incorporated into the Cumulative without and Cumulative with Plan scenarios.
Given the EIR is programmatic in nature and no specific development project is proposed at this time, future development would be subject to the requirements of the Plan, as well as General Plan Policies. When individual projects or activities under the Plan are proposed, the City would examine the projects or activities to determine whether their effects were adequately analyzed in this EIR, as provided under CEQA Guidelines Sections 15168(c), 15168(d), 15182, and/or 15183.
Subsequent projects would be subject to all the requirements identified in the Plan and referenced in the Draft EIR.
Comment G.3: 3. Land Use Compatibility and Industrial–Residential Interface The proposed integration of residential development within an area traditionally designated for industrial and employment purposes presents potential compatibility issues. The DEIR should provide additional analysis regarding potential conflicts associated with truck circulation, noise, operational emissions, and hazardous materials associated with existing or future industrial uses.
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Because the Specific Plan area has historically supported light industrial and life-science activities, the EIR should evaluate whether future residents could create pressure to curtail lawful industrial operations. CEQA requires disclosure of such land-use conflicts where they may result in environmental effects.
Response G.3: The EIR is programmatic in nature covering the entire 145-acre Plan area, and no specific development project is proposed at this time. Therefore, project-level analysis regarding potential conflicts associated with specific projects cannot be identified at this time. While the EIR does not evaluate truck circulation at a project-level, transportation impacts are presented on pages 272 through 275 of the Draft EIR. As noted on page 272 of the Draft EIR, the Plan would not introduce any physical features that would create an obvious transportation safety hazard.
Further, future projects implementing the Plan would be reviewed for compliance with safety guidelines and standards as part of the development review process, including General Plan Policy CSH-3.5, CSH-4.2, and CSH-4.3. As discussed in Section
2.3.2 of the Draft EIR, the Plan would create or enhance connections to transit, pedestrian, and bicycle facilities. The Plan would also implement various intersection improvements and traffic calming measures.
Land use compatibility is presented on pages 205 through 207 of the Draft EIR. As discussed on page 206 of the Draft EIR, future development in the Plan would be subject to the design review and objective design standards compliance review process required by Section 18.29 of the Zoning Code, which requires design review for projects that require a permit for new construction, reconstruction, rehabilitation, or alteration. This review process ensures that all future redevelopment projects under the Plan would be evaluated for their compatibility with their surroundings, harmonious transitions in scale and character between different land uses, safety, integration of natural features, appropriate construction materials, and other aspects.
Noise impacts, including noise impacts to sensitive receptors (i.e., residences) are presented on pages 224 through 238 of the Draft EIR. The Draft EIR concluded that with adherence to SCMC requirements and General Plan goals, policies, and actions, stationary noise impacts associated with future development and activities under the Plan would be evaluated and mitigated as needed to meet General Plan and SCMC requirements as individual development projects undergo project-level environmental review.
Project-level operational air quality emissions are presented on pages 73 through 75 of the Draft EIR. As disclosed on page 74 of the Draft EIR, annual and average daily emissions of ROG and NOx associated with operation of the Plan Area would exceed the Bay Area Air District project-level significance thresholds (Impact Air 3). The Draft EIR concluded that future development projects would be subject to the 2045
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General Plan Reset EIR8 Mitigation Measure AQ-2.2, which requires that future development projects prepare and submit a technical assessment evaluating potential operational air quality impacts to the City for review and approval.
Hazardous materials impacts are presented on pages 180 through 186 of the Draft EIR. The use, storage, transport, and disposal of hazardous materials by future residents and commercial and industrial tenants/owners would be required to comply with existing regulations that apply to the uses that involve transporting, using, or disposing of hazardous materials include the Resource Conservation and Recovery Act, Comprehensive Environmental Response, Compensation, and Liability Act, and California Code of Regulations Title 22 (refer to Section 3.9.1.1 Regulatory Framework of the Draft EIR). SCMC Title 13 also requires that individual business plans for any facility subject to the hazardous materials inventory response program include a program for compliance. Further, the Draft EIR concluded that compliance with General Plan Policies ESPS-5.3, ESPS-5.5, and ESPS-5.6 would ensure that future development under the Plan does not create a significant hazard to the public or the environment through the disturbance of contaminated soil, soil vapor, and groundwater.
Comment G.4: 4. Flooding, Sea Level Rise, and Climate Resilience The project area’s proximity to Belmont Creek and the San Francisco Bay warrants a more detailed analysis of long-term flood risk, including projected sea-level rise scenarios. Given the long planning horizon of the Specific Plan, the DEIR should evaluate potential risks under multiple sea-level rise projections consistent with state guidance.
The EIR should also clarify:
• the design standards assumed for flood protection infrastructure • long-term maintenance responsibilities for flood control improvements • potential cumulative impacts related to regional sea-level rise adaptation planning • Without this information, it is difficult to determine whether proposed mitigation measures would adequately reduce potential impacts to a less-than-significant level.
Response G.4: CEQA requires the analysis of environmental impacts of a project (or plan) based on baseline conditions. The baseline conditions for the Plan area are the existing conditions of the Plan area at the time the Notice of Preparation was released (in July 2024). Per California Building Industry Association v. Bay Area Air Quality Management District, 62 Cal. 4th 369, effects of the environment (including 8 On May 27, 2025, the City Council certified the 2045 General Plan Reset Final EIR and adopted the 2045 General Plan Reset. The Final EIR considered buildout projections that included the anticipated growth in the Plan, but did not adopt land use changes in the Plan.
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future forecast conditions that could affect the Plan area) on the project are not considered CEQA impacts. Nevertheless, one of the objectives of the Plan is to address flooding and sea level rise through a robust resilience framework including improvements to Belmont Creek and green stormwater infrastructure. The Plan also includes additional standards in the Sea Level Priority Zone and Creek Front Zone (refer to pages 32 through 34 of the Draft EIR). The Sea Level Priority Zone encompasses the historic San Francisco Bay Shoreline, as shown on Figure 2.4 14 of the Draft EIR. As discussed on page 33 of the Draft EIR, individual future development projects in the Plan would be required to assess sea level rise risk for the site and elevate the finished floor elevation of the new building(s) further above the 100-year base flood evaluation to provide resiliency to future sea level rise (2050).
As explained on page 194 of the Draft EIR, along the shoreline of the City, sea levels are projected to rise approximately two feet by 2050. Elevations in the Plan area range from 13 to 50 feet above sea level. As explained on page 198 through 199 of the Draft EIR, with the incorporation of the above Plan resiliency standards, buildout under the Plan would not result impacts related to impeding or redirecting flood flows.
Chapter 7.3 of the Plan outlines the standards that would be implemented to protect future buildings and infrastructure in the Plan. These standards would require that future development projects in the floodplain perform a hydrology and hydraulic analysis to verify that proposed improvements will not adversely affect the floodplain or exacerbate flooding of other properties. Additionally, future applicants would be required to collaborate with OneShoreline, which provides voluntary planning guidance and design recommendations for tide-affected areas such as the Plan area to account for climate-driven flooding, sea level rise, and groundwater rise.
Comment G.5: 5. Parks
The Draft EIR clearly states that San Carlos is not meeting the standard established in the City’s Park Master Plan of 2.5 acres of traditional parkland for every 1,000 residents. The Plan proposes adding 1,890 residential units, but no new community park land is included. The current City Council discussion on the Northeast Plan differs from the City Park Master Plan 2026, which proposes building a new community center at Laureola Park for east side residents and recommends acquiring and improving Sequioa High School District lands near the park entrance. The current Draft EIR commits the city to no new parkland which needs to be reevaluated based on the current City Council recent recommendations and the City Park Master Plan. Where are the community benefits to the eastside community tied to development in the Northeast Plan that increases the quantity and quality of parks on the East side?
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However, the Specific Plan does identify the block bound by Glenn Way, Taylor Way, Old County Road, and Bragato Road as an opportunity site for a public park within the Northeast Area. This site would be rezoned to allow mixed use/residential. Because the City does not own this site, and due to State level protections for residential projects, the Specific Plan cannot guarantee a public park will be implemented here. These factors were discussed at the September 8, 2025 City Council Study Session. Nonetheless, the Specific Plan does call for privately-owned public open space throughout the Northeast Area (for both residential and nonresidential uses). While this does not reduce our deficiency in parkland, this does result in new publicly accessible open space throughout the Northeast Area.
Response G.5: Under CEQA, the relevant question is whether a project would increase the use of existing parks or require new or expanded park facilities, such that construction or physical changes to those facilities could result in significant environmental impacts. The City’s General Plan provides a comprehensive framework for the City, including goals and policies for parks and recreational facilities. As noted on page 257 of Draft EIR, growth from the General Plan (including the Plan) would decrease the ratio of parkland per 1,000 population to 1.34 acres of parks per 1,000 residents by 2045. The General Plan EIR concluded that adherence to SCMC Section 17.32.030 and SCMC Chapter 3.34, which requires residential subdivisions to either provide parkland or pay in-lieu fees to the City to dedicate parkland elsewhere and new residential projects to pay park facility development fees, would reduce impacts to less than significant. While no specific dedicated park facilities are included as part of the Plan, future projects in the Plan on sites greater than one acre would be required to dedicate 15 percent of the total site area toward public open space, as explained on page 257 of the Draft EIR. The Plan also proposes a 10-foot wide multi-use path along Belmont Creek which provides an additional walking route to connect Old County Road to Industrial Road and fosters greater access with the natural features.
Laureola Park and the Sequioa High School District site are outside of the Northeast Area Plan boundary. As indicated by the commenter, the Plan does acknowledge an opportunity site for a public park within the Northeast Area. However, given the City does not own this site, the Plan cannot guarantee a public park will be implemented here. 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. This comment does not raise issues related to the adequacy of the Draft EIR or present substantial evidence of an environmental impact requiring additional evaluation under CEQA.
Comment G.6: 6. Significant and Unavoidable Impacts
1. Air Quality 1
Full implementation of the Plan would raise daily trips by 203% and expand the service population by 193%, causing notable increases in program-level air pollutant emissions.
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How will the city track and control air pollution from the combined effects of the Northeast and Eastside Innovation Plans?
Response G.6: As explained on page 83 of the Draft EIR, in developing thresholds of significance for air pollutants, the Bay Area Air District considered the emission levels for which a project’s individual emissions would be cumulatively considerable.
If a project exceeds the identified significance thresholds, its emissions would be cumulatively considerable, resulting in significant adverse air quality impacts to the region’s existing air quality conditions. While at a Plan-level, the project would increase daily trips in excess of the increase in population and, therefore, result in a cumulatively considerable net increase of criteria pollutant emissions. The EIR’s determination that the Plan would exceed the Bay Area Air District project-level significance thresholds would not preclude future individual projects from having less than significant air quality impacts. As discussed on page 75 of the Draft EIR, future projects would either need to demonstrate they meet the Air District’s screening size to have less-than-significant operational air pollutant emissions or prepare a project-level air quality assessment in accordance with the Air District’s CEQA Air Quality Guidelines. Projects implementing the Plan or within the East Side Innovation District Vision Plan would be required to mitigate their impacts to less than significant (to the extent feasible) and a Mitigation Monitoring and Reporting Program would be adopted and implemented by the City.
Comment G.7: Air Quality 2
If fully implemented, the Plan may cause significant dust and diesel emissions unless controlled by specific regulations. The Northeast Plan is a Specific Plan. Provided the land meets the requirements specified in the Plan, it can be approved without undergoing discretionary review. Even with discretionary approvals, how will the City monitor and manage the reduction and elimination of dust and diesel emissions? No strategy is apparent.
Response G.7: As explained on page 76 of the Draft EIR, General Plan Policy EM-6.6 requires that future development projects implement the Bay Area Air District’s best management practices (listed on page 77 of the Draft EIR) to reduce fugitive dust impacts to less than significant. As described on page 38 of the Draft EIR, future development projects proposed under the Plan would be examined in light of the EIR to determine whether additional environmental review is needed, including preparation of a health risk assessment to evaluate the effects of diesel emissions.
When individual projects or activities under the Plan are proposed, the City would examine the projects or activities to determine whether their effects were adequately analyzed in this EIR, as provided under CEQA Guidelines Sections 15168(c), 15168(d), 15182, and/or 15183 (page 1 of the Draft EIR).
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Comment G.8: 2.Air Quality 3
If the Plan proceeds as designed, its development will lead to annual and average daily emissions of Rox and Nox exceeding the significance thresholds established by BAAQMD for projects. Because the Northeast Plan is a Specific Plan, any land use application that meets its requirements will be approved automatically, with no additional review or discretionary process. How will the City track and control Rox and Nox emissions after granting discretionary land use approvals? No strategy is apparent.
Response G.8: Neither the Plan nor the EIR establish a framework that would automatically approve future development applications, rather individual projects would be reviewed according to the development review processes established in the City’s Municipal Code. As explained throughout the Draft EIR, future projects would be subject to General Plan Mitigation Measures, Plan Requirements, General Plan Policies, and existing laws and regulations. If subsequent projects within the Northeast Area, consistent with the Plan, are found to be within the scope of this EIR, additional environmental documents may not be required. If a subsequent activity would have effects that were not identified in this Draft EIR, the City would require preparation of additional environmental review as applicable. Following completion of environmental review, projects would be subject to the City’s standard discretionary review process. Refer to response G.7 above for additional information on subsequent environmental review. Refer to response G.6 for additional information on air quality impacts of future projects.
Comment G.9: 3.Air Quality 4
If the Plan is implemented entirely, it will raise exposure to TACs and PM2.5 emissions. Since the Northeast Plan is a Specific Plan, any land use proposal that complies with its guidelines will receive automatic approval, eliminating the need for discretionary review. Even with discretionary approvals for land use review how will the City monitor and manage TAC and PM2.5 daily emissions? No strategy is apparent.
Response G.9: Refer to responses G.7 and G.8 above for additional information on subsequent environmental review. With regards to toxic air contaminants (TACs) and PM2.5 emissions, future development projects would be reviewed according to the development review processes established in the Municipal Code and required to implement the Bay Area Air District best management practices to reduce fugitive dust impacts to less than significant as explained in response G.7.
Comment G.10: 4. Hazards and Hazardous Materials
Please add mitigation language that the city as a policy encourages the removal of all toxics on site when redevelopment occurs, and not capping toxics in place which will result in historic and continuing adverse impacts to groundwater and the San Francisco Bay
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Response G.10: As described on pages 172, 173, 181, and 182 of the Draft EIR, the General Plan contains several policies that serve to mitigate hazards and hazardous materials impacts resulting from planned development within the City, including policies ESPS-5.3, ESPS-5-5, and ESPS-5.6. The specific manner in which a site would be remediated would be determined by the oversight agency, based on the specific circumstances of that site and the proposed land use. Compliance with these policies would ensure that future development under the Plan does not create a significant hazard to the public or the environment through the disturbance of contaminated soil, soil vapor, and groundwater.
Comment G.11: 7. Cumulative Impact Analysis
CEQA requires an EIR to analyze the cumulative effects of the project when combined with other past, present, and reasonably near future projects (CEQA Guidelines §15130). The DEIR should more clearly describe the cumulative development scenario assumed for San Carlos and surrounding communities, particularly development occurring along the U.S. 101 corridor.
For cumulative impact analysis, it is necessary to identify the projects included in the cumulative scenario and explain the methods used to assess impacts on transportation, infrastructure, and the environment within that context.
Response G.11: Section 15130(b) of the CEQA Guidelines provides that a cumulative impacts discussion should reflect both the severity of the impacts and the likelihood of their occurrence. To meet this standard, the Guidelines allow agencies to rely on either (1) a list of past, present, and probable future projects, or (2) projections contained in an adopted general plan or similar planning document.
Consistent with CEQA Guidelines Section 15130(b)(1), the EIR employs a combination of both approaches (refer to page 41 of the Draft EIR). Specifically, the EIR incorporates a list of related projects (refer to pages 42 through 43), as well as growth projections derived from the City’s planning documents. In this regard, the City of San Carlos certified the 2045 General Plan Reset EIR on May 27, 2025, which evaluated development anticipated under citywide buildout conditions through the planning horizon, including the proposed project. These projections provide a comprehensive and policy-consistent basis for evaluating cumulative conditions.
Accordingly, the cumulative impact analysis is consistent with CEQA Guidelines requirements and provides a reasonable and adequate assessment of cumulative conditions.
Comment G.12: 8. Alternatives Analysis
The alternatives analysis must show that the EIR thoroughly considered a reasonable selection of options, which could lessen major impacts and still fulfill most key project goals (CEQA Guidelines §15126.6). It is not clear whether the DEIR adequately evaluated alternatives would:
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• reduce the overall development intensity
• retain a larger portion of employment-focused land uses • modify the residential component to reduce transportation and compatibility impacts The Final EIR needs to thoroughly assess all alternatives so that both the city and the public can make well-informed decisions.
Response G.12: The Draft EIR evaluated a reasonable range of alternatives.
Pursuant to CEQA, the EIR should identify alternatives which “feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.” The Draft EIR evaluated a total of seven alternatives, including two reduced development alternatives and an alternative without residential uses and two alternatives that would reduce the overall scale of development. As discussed in Section 7.2 Project Alternatives on pages 315-327 in the DEIR, three alternatives were considered but rejected for further analysis (i.e., a Location alternative, All Employment Alternative, and GHG Reduction Alternative) and four alternatives were presented for consideration by the decision-makers: two No Project alternatives, a Reduced Criteria Pollutant Emissions Alternative and an Enhanced TDM Alternative. CEQA dictates that an EIR must evaluate a “No Project” alternative (CEQA Guidelines Section 15126(e)1(1)).
CEQA does not establish a minimum number of alternatives to be evaluated, rather the CEQA Guidelines state that “the range of alternatives required in an EIR is governed by a rule of reason.” (CEQA Guidelines Section 15126.6(a) & (f)). As discussed on page 314 of the DEIR, the alternatives evaluated in this EIR were selected because they would reduce and/or eliminate one or more of the significant and unavoidable impacts associated with the project. As such, the DEIR evaluated a reasonable range of alternatives that would fully avoid or partially reduce the project’s significant and unavoidable impacts, while achieving most basic Plan objectives.
The commenter questions whether the EIR adequately evaluated alternatives would reduce the overall development intensity, retain a larger portion of employmentfocused land uses, and modify the residential component to reduce transportation and compatibility impacts. Of the four alternatives carried forward for detailed evaluation, two would reduce the overall development density (No Project, Existing Plans Alternative and Reduced Criteria Pollutant Emissions Alternative).
As described on page 316 of the Draft EIR, an All Employment Alternative was considered but rejected. As described in the Draft EIR, the significant impacts identified for the project are not attributable to the inclusion of housing. Under this alternative, overall development intensity would remain generally similar to that of the Plan; therefore, it would not avoid or substantially lessen any of the significant environmental impacts identified. In addition, this alternative would not meet one
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of the project’s fundamental objectives, which is to introduce housing within the Plan area to accommodate anticipated population growth in the City of San Carlos.
The planned residential development also contributes toward meeting the City’s Regional Housing Needs Allocation (RHNA) obligations in future planning cycles.
Because this alternative would neither reduce significant impacts nor feasibly attain the basic objectives of the project, it was appropriately rejected from further consideration.
Lastly, the Draft EIR evaluated two alternatives that reduced the Plan’s residential development intensity (No Project, Existing Plans Alternative and Reduced Criteria Pollutant Emissions Alternative). It is unclear why the comment suggests an alternative that would reduce “transportation and compatibility impacts.” The Draft EIR did not identify any significant and unavoidable transportation or compatibility impacts arising from the planned residential uses.
While the comment raises concerns regarding the range of alternatives evaluated in the Draft EIR, the analysis in the Draft EIR, as clarified above, demonstrates that these concerns have been adequately addressed. Accordingly, no revisions to the Draft EIR are warranted.
Comment G.13: Conclusion
In summary, while the DEIR provides a useful starting point for environmental review, additional analysis and clarification are necessary to ensure compliance with CEQA and to allow meaningful public participation. The Final EIR should address the issues described above and provide substantial evidence supporting its conclusions regarding environmental impacts and mitigation effectiveness.
Response G.13: The comment is acknowledged and included in the record for the decision makers. The responses above demonstrate that the commenter’s concerns have been adequately addressed. Accordingly, no revisions to the Draft EIR are warranted.
H. Laurie Berger, Silicon Valley Law Group (dated April 16, 2026) Comment H.1: DISCUSSION
1. The Project Description is Incomplete
CEQA requires that an environmental impact report contain an accurate, stable and finite project description, and this is an indispensable prerequisite to a legally sufficient EIR. (See County of Inyo v. City of Los Angeles (1977) 71 Cal.App.3d 185,193 and 14 CCR 15124 which incorporates this requirement.) In Inyo, the court stated that without an accurate description on which to base the EIR’s analysis, CEQA’s objective of furthering public disclosure and informed environmental decision making is stymied. In San Joaquin Raptor/Wildflife Rescue Ctr. V. County of Stanislaus (1994) 27 Cal.
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App. 4th 713, 720, the court said, “an accurate project description is necessary for an intelligent evaluation of the potential environmental effects of a proposed activity.” Section 2.4 of the DEIR sets forth the project description. Section 2.4 describes the Proposed Land Use and Zoning Districts (2.4.1); General Plan Text Amendments (2.4.2); Circulation Improvements (2.4.3); Parking (2.4.4); Utility Improvements (2.45); Resilience Improvements (2.4.6) Transportation Demand Management (2.4.7); and Sustainable Design Features (2.4.8).
The Circulation Improvements is most relevant to the issues impacting Bragato LLC.
Bragato Extension
Road so that it will connect to Quarry Road, thereby adding another north/south road. However, the DEIR does not explain how this new road will be constructed. The description does not explain how it will impact the existing properties surrounding the new road. There is no discussion of the dimensions of the road and required setbacks, and there is no discussion as to how the City would acquire any property necessary for the construction of the road. This new road appears to directly abut the Bragato Property. The impacts of the construction of the road are not addressed in the DEIR. The Project Description needs to address the mechanism for how the City could install this additional road.
Response H.1: The EIR is programmatic in nature and no specific development project is proposed at this time, including the extension of Bragato Road. The Plan envisions that Bragato Road would be extended to Quarry Road. The conceptual roadway section, including dimensions and setbacks, is shown on Figure 2.4-6 of the Draft EIR. Since specific details about the construction of the road, including the manner in which property would be acquired, are not known at this time, it would be speculative for the Draft EIR to evaluate impacts from construction of the envisioned roadway extension. As stated in the EIR, the City would examine the projects or activities to determine whether their effects were adequately analyzed in this EIR, as provided under CEQA Guidelines Sections 15168(c), 15168(d), 15182, and/or 15183. For these reasons, no revisions to the Draft EIR are warranted.
Comment H.2: The Bragato Paseo
Bragato LLC purchased the Bragato Property in 2021 for use as a Honda Dealership. Bragato has worked extensively with the City of San Carlos Planning and Building Departments to build the dealership. In doing so, they have spent millions of dollars to transform a blighted industrial property into an attractive, state-of-the-art dealership that benefits the community.
The proposed Bragato Paseo as depicted in the DEIR and as described in the Plan, is a 36-foot-wide pedestrian walkway on the Bragato Property connecting Bragato Road to Industrial Road. This paseo would transect the Bragato property, and there is no discussion of this in the Project Description. Although the figures depicting the paseo may not be to scale, there is nowhere on the
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Bragato Property where this paseo could be built.
The DEIR contains several figures depicting the proposed Bragato Paseo, and in Section 2.4.3.2 there is a brief description of three paseos, but these descriptions do not provide enough information to allow for informed environmental decision making.
The only substantive description of the paseo is:
The Plan includes three pedestrian paseos, one along the new north-south street connecting Bragato Road to Industrial Road, one connecting the proposed Belmont Creek to Quarry Road, and one connecting Taylor Way to the Greater East Side Neighborhood to facilitate more connectivity and accessibility in the district.
The Bragato Paseo, as depicted, runs right through the Bragato Property. If the paseo is to be installed on the north end of Bragato Property, it is proposed where the newly built Honda Dealership is located. In the current configuration, the northern part of Bragato Property is an active work zone and fire lane. Cars are continually being parked and moved in this area. This area is in the back of the dealership, it is not customer-facing, and it is not safe for pedestrians or cyclists.
Furthermore, directly to the north on the adjacent property there is a utility ditch with an easement.
The paseo cannot be built here. The DEIR does not adequately analyze the foreseeable environmental impacts to the existing buildings that would be affected by implementation of the Project. The Project Description does not explain what buildings would be demolished, how the property would be acquired (eminent domain?), or the impact of the utility easement.
Decisionmakers cannot properly evaluate the environmental impacts without knowing if the construction is even possible, or without knowing what would happen to existing structures. Any acquisition will cause physical changes to the environment that need to be considered in the DEIR.
Response H.2: The EIR is programmatic in nature, and no specific development project is proposed at this time. The Plan envisions that development, including the proposed paseos, would occur over a 20-year period. Specific details about demolition and construction are not known at this time and would be speculative for the Draft EIR to evaluate. The Draft EIR evaluates full implementation of the Plan, which includes redevelopment of the Bragato site consistent with the proposed land use designation, and is assumed to also include the paseo. When individual projects or activities under the Plan are proposed, the City would examine the projects or activities to determine whether their effects were adequately analyzed in this EIR, as provided under CEQA Guidelines Sections 15168(c), 15168(d), 15182, and/or 15183. Also, the City anticipates implementation of the paseos through redevelopment over time and does not anticipate imposing implementation of paseos on existing uses. For these reasons, no revisions to the Draft EIR are warranted.
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Comment H.3: In addition to the fact that there is a newly renovated Honda Dealer on the Bragato Property, there are also environmental considerations that were not described in the Project Description. The Bragato Property is impacted by a decades-old release of polychlorinated biphenyls (“PCBs”) originating from a neighboring property. The U.S. EPA required the installation of a six-inch engineered asphalt cap to contain the PCBs. U.S. EPA has exclusive jurisdiction over the regulation of PCBs. Therefore, the City has no legal authority to build the Project insofar as the Project contemplates construction in the area under U.S. EPA’s exclusive jurisdiction.
This cap was installed by Bragato LLC in 2021-2022 in accordance with the requirements of the federal Toxic Substances Control Act (“TSCA”). This cap (“TSCA Cap”) may not be breached or modified without the approval of the U.S. EPA and is subject to a forthcoming Soil Management and Operation and Maintenance Plan and Land Use Covenant that will ensure the integrity of the cap.
These documents are not yet finalized, but they are critical to an understanding of how the Bragato Property may be developed.
The DEIR needs to contain a discussion of the TSCA Cap and the U.S. EPA’s oversight in the Project Description. The DEIR must be revised to fully and accurately reflect the existing environmental conditions which the Project intends to overlay so that future decisions will be based on actual conditions.
The Bragato Paseo cannot be constructed as proposed. It cannot be built where the Honda Dealership is, and it cannot be built near or on the TSCA cap. The Project Description must be revised to analyze these issues. Without a discussion of the real-world challenges associated with building the Project on a property with existing buildings and a TSCA Cap, the Project Description is flawed.
Response H.3: No specific project is proposed on the 494 Bragato Road property.
The Draft EIR evaluates full implementation of the Plan, which includes redevelopment of the Bragato site consistent with the proposed land use designation, and is assumed to also include the paseo. The commenter’s claim that a specific improvement cannot be built on a particular property does not make the Draft EIR deficient. CEQA allows a program-level EIR to analyze conceptual improvements and their reasonably foreseeable environmental effects. Detailed feasibility and site-specific design will be addressed during subsequent project-level review. Therefore, the Draft EIR appropriately evaluates the Plan’s environmental impacts at the program level. For these reasons, no revisions to the Draft EIR are warranted.
Refer to response H.4 below for additional information related to hazardous materials.
Comment H.4: 2. The Hazards & Hazardous Materials Impacts are Not Properly Evaluated
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The DEIR relies on the 2023 Cornerstone Screening Level Environmental Assessment (“EA”). This report is three years old and does not reflect current conditions. Importantly, the EA does not describe the TSCA Cap on the Bragato Property. At the outset, we do want to acknowledge that we understand how the EA and DEIR may have missed this important part of the environmental condition of the properties. Although sites regulated by local agencies and the Regional Water Quality Control Boards are readily accessible through Geotracker, and sites regulated by the Department of Toxic Substances Control are readily accessible through Envirostor, U.S. EPA TSCA sites are not publicly accessible via a similar public website. So, missing this important issue is understandable.
Given that there was no disclosure of the TSCA Cap, unsurprisingly, there is no analysis of the TSCA Cap. Any construction over the TSCA Cap will not be permitted without approval of U.S. EPA, and any construction and plans for this area need to consider the cap and the regulatory status of the properties, the costs, and enormous delays. The general mitigation measures do not account for the PCBs and regulatory status of the TSCA cap. The public and the decisionmakers need to be informed of the huge costs and delays a PCB cap alteration would entail. It is hard to believe these challenges could be overcome.
The DEIR should be amended to include an analysis of the requirement that U.S. EPA must be consulted before any development could occur that impacts the TSCA Cap. Any penetration of the TSCA Cap will require extensive efforts to ensure that potentially contaminated soil is properly handled and disposed of and that the surrounding community is protected. The DEIR relies on the Cornerstone Report attached as Appendix D, but that report fails to discuss the actual conditions at the Bragato Property.
Response H.4: A Screening Level Environmental Assessment (ESA) was prepared for the Plan and included as part of the Draft EIR as Appendix D. Given the programmatic nature of the Plan and the size of the Plan area (145 acres), a Screening Level ESA provides the appropriate level of documentation. It is neither practical nor feasible for the programmatic Draft EIR to evaluate and disclose conditions on all properties within the Plan area. The purpose of the Screening Level ESA is to provide a summary of the general environmental constraints and existing documented hazardous materials contamination. Table 3.9-1 on page 175 of the Draft EIR lists all known on-site sources of contamination in the Plan, including the property 495 Bragato Road. The Draft EIR acknowledges that the site is an Open Clean Up Program Site with potential contaminants of concern including polychlorinated biphenyls (PCBs), trichlorobenzenes (TCBs), petroleum, hydrocarbons, and volatile organic compounds (VOCs). As further explained on page 178 of the Draft EIR, at these parcels, characterization, monitoring and/or remediation activities are on-going and are being conducted under regulatory agency oversight. The Draft EIR goes on to explain on page 181 that future development within the Plan could encounter and disturb contaminated soil, soil vapor, and groundwater, and result in adverse effects on construction workers, existing residents and employees, and nearby sensitive receptors. In accordance
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with General Plan policies ESPS-5.3, ESPS-5.5 and ESPS-5.6, future development would be required to mitigate hazard exposure, prepare site-specific assessments, and be reviewed by appropriate regulatory agencies (when applicable).
Given the EIR is programmatic in nature and no specific development project is proposed at this time, the Draft EIR appropriately characterized known contamination at the 495 Bragato Road property. Any future redevelopment of this property would require subsequent site-specific environmental review including soil and groundwater evaluations in accordance with the City’s General Plan policies.
The Draft EIR has been revised to acknowledge the cap and the need for future coordination with the U.S. EPA (refer to Section 5.0 Text Revisions). The text revision does not constitute a “substantial revision” pursuant to CEQA Guidelines §15073.5 and recirculation of the EIR is not required.
Comment H.5: 3. The Air and Greenhouse Gases Impacts are Not Properly Evaluated The DEIR evaluates the project’s impacts to air and one of the transportation measures is:
TR9 – Bicycle and Pedestrian Access and Facilities:
Encourage planning for bicycle and pedestrian facilities in local plans, e.g., general and specific plans, fund bike lanes, routes, paths and bicycle parking facilities.
The DEIR says that the Plan would be consistent with the Bicycle and Pedestrian Master Plan in part because it includes “three pedestrian paseos, one along the new north-south street connecting Bragato Road to Quarry Road, and two along Bragato Road to facilitate more connectivity and accessibility in the District.” (DEIR, p. 67) The DEIR says in Table 3.3-5, that future development under the Plan would comply with all applicable 2017 CAP control measures. Therefore, the Plan would not conflict with or obstruct the implementation of an applicable air quality plan (DEIR, p. 69).
Similarly, when evaluating the greenhouse gas impact, the DEIR looked at whether the project conflicts within applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. One of the reduction goals/applicable strategies is Strategy 12 “Active Transportation” which prioritizes bicycling and walking as safe, practical, and attractive travel options citywide, as directed by the Bicycle and Pedestrian Master Plan. (DEIR, p. 163). The DEIR finds that the Plan would include the pedestrian paseos described above and finds that future development would be consistent with the above strategies.
But because, as explained above, one of the paseos is impossible to build, a mitigation based on three completed paseos is an analytical error.
Response H.5: CEQA requires an evaluation of whether a project would conflict with applicable plans, policies, or regulations that would in turn result in significant environmental impacts. The Draft EIR properly evaluates the Plan’s consistency with
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the Bicycle and Pedestrian Master Plan and related active transportation strategies.
The analysis identifies pedestrian and bicycle improvements, including the proposed paseos, and demonstrates that the Plan supports the goals and objectives of these plans. Even if a specific paseo cannot be implemented, this does not, by itself, create a CEQA conflict or environmental impact. The Draft EIR evaluates, at a programmatic level, the environmental impacts of implementing the Plan, and not the feasibility of implementing specific aspects of the Plan, such as the noted paseo. The comment does not provide any substantial evidence demonstrating that the Plan would, in fact, result in a conflict or significant environmental impact. Therefore, the Draft EIR’s conclusions regarding consistency with applicable plans and greenhouse gas reduction strategies are accurate and defensible.
Comment H.6: 4. The Land Use and Planning Impact are Not Properly Evaluated When analyzing whether the Project would divide an established community, the DEIR says that one of the primary objectives of the Plan is to improve mobility throughout the Plan area through the creation and enhancement of connections to transit, pedestrian and bicycle facilities. The DEIR again states that the three pedestrian paseos would facilitate more connectivity and accessibility in the district. As explained above, this is not possible and so the analysis of the connectivity and accessibility is incorrect.
Response H.6: CEQA requires an evaluation of whether a project would physically divide an established community or otherwise impede access. The Draft EIR demonstrates that one of the Plan’s primary objectives is to enhance mobility and connectivity throughout the Plan area by improving pedestrian, bicycle, and transit linkages. The proposed pedestrian paseos, roadway connections, and other circulation improvements are envisioned to increase access within and across the Plan area, thereby supporting the conclusion that the Plan would not physically divide the community. Therefore, the Draft EIR’s conclusion regarding community connectivity and accessibility is accurate, as it is based on what the Plan proposes, and defensible and the comment does not provide any substantial evidence that the Plan would result in a significant land use impact.
Comment H.7: 5. The Transportation Impacts are not Properly Evaluated The DEIR also relies on the paseos as potentially mitigating transportation impacts. The DEIR analyzed whether the project would conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian facilities. (DEIR, p. 272) The DEI again states the Plan would be consistent with the Bicycle and Pedestrian Master Plan and relies on the paseos.
As described in detail above, the DEIR is assuming the paseos could be built however it does not discuss the existing TSCA Cap which would prevent a paseo from being built between Bragato Road and Industrial Road. The DEIR cannot rely on paseos that cannot be built.
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Response H.7: CEQA requires analysis of whether a project, as proposed, would conflict with applicable plans, policies, or ordinances related to the circulation system, including transit, roadways, bicycle lanes, and pedestrian facilities. The Draft EIR evaluates, at a programmatic level, the environmental impacts of implementing the Plan, and not the feasibility of implementing specific aspects of the Plan, such as the noted paseo. The Draft EIR evaluates the Specific Plan’s proposed bicycle and pedestrian improvements and concludes there would be no conflict. The absence of these improvements would not, by itself, create a CEQA impact. Therefore, the analysis appropriately addresses the relevant CEQA question and reasonably concludes that the Plan would not conflict with any applicable circulation-related policies. Refer also to responses H.3 and H4.
Comment H.8: 6. The DEIR is a Program Level and limited Project Level environmental review that must accurately describe the environmental impacts
The DEIR provides both program-and limited project-level environmental review for the Plan. As stated in the DEIR, the DEIR will allow for streamlined environmental review of subsequent development projects consistent with the Plan and analysis in the DEIR. When individual projects or activities under the Plan are proposed, the City would examine the projects or activities to determine whether their effects were adequately analyzed in this EIR, as provided under CEQA Guidelines Sections 15168(c), 15168(d), 15182, and/or 15183.
CEQA requires that an EIR delineate the environmental conditions that exist at the time of the project to establish a baseline against which the projects’ impacts may be assessed. Cleveland National Forest Foundation v. San Diego Assn. of Governments (2017) 17 Cal. App. 5th 413, 440. If the description of the environmental setting is incomplete or inadequate, the EIR is legally inadequate as it fails to comply with Code Regs., tit. 14, § 15125(a). Cleveland ; Cadiz Land Co. v.
Rail Cycle (2000) 83 Cal. App. 4th 74.
If a program EIR fails to address known environmental conditions, impacts related to those conditions may escape analysis in subsequent, project specific environmental reviews. For that reason, CEQA requires that known impacts must be analyzed at the program level to avoid omission in future reviews. (See Cleveland at 440 where the court stated that unaddressed impacts in a program EIR could evade scrutiny in later-tiered EIRs undermining CEQA’s objectives.) Because the environmental setting normally supplies the baseline for significance determinations, a program EIR that does not fully address site condition risks fails to establish the baseline against which impacts are described and quantified. Cleveland, supra. Where the environmental setting is inaccurate, incomplete, or misleading, an EIR does not comply with CEQA and cannot be found to have adequately investigated and discussed environmental impacts. Cadiz at 87.
For these reasons, it is especially important that the DEIR adequately address the environmental conditions at the site.
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June 08, 2026 Packet Pg. 2363
Northeast Area Specific Plan, SCH# 2024070063 49 Final EIR City of San Carlos May 2026
Response H.8: The commenter suggests that the Draft EIR may lack adequate baseline information, such as site-specific conditions.
A program-level EIR is specifically designed to evaluate the broad, cumulative, and long-term effects of a plan or program, rather than project-specific impacts, particularly those pertaining to specific conditions on properties within the Plan.
CEQA Guidelines Section 15168 recognizes that a program EIR may be prepared for a series of actions that are related either geographically, as logical parts of a chain of contemplated actions, or as parts of a plan. For a Specific Plan with a 20-year buildout horizon, a program EIR is an appropriate and defensible approach because it allows for the assessment of overarching environmental issues, cumulative effects, and mitigation strategies while deferring detailed, site-specific analyses to subsequent project-level review as appropriate.
To the extent practicable for a 145-acre Specific Plan area covering multiple private properties for which the City did not have access, the Draft EIR identifies existing conditions to establish a baseline for analysis, consistent with CEQA Guidelines Section 15125. For example, Section 3.9 of the Draft EIR (Hazards and Hazardous Materials ) identifies all known sites within the Plan area that have documented contamination. Similarly, other sections of the Draft EIR summarize existing land use, biological resources, water quality, traffic conditions, and other relevant environmental factors. While program-level EIRs necessarily address conditions at a broader scale, the analysis provides a reasonable and adequate baseline from which to evaluate the environmental effects of the proposed Specific Plan and inform subsequent project-level review, at which point the then-current environmental conditions on a given site would be determined, and appropriate mitigation measures contained in the Draft EIR would be implemented for a given project.
For these reasons, the Draft EIR’s program-level approach covering the large geographic area of the Specific Plan is appropriate for a 20-year buildout horizon, and it provides a defensible baseline analysis that is sufficient for evaluating the Plan’s potential environmental effects. More detailed site-specific conditions will be addressed at a project level for each development project implementing the Plan, as required under CEQA. Further, the Plan incorporates General Plan policies and Specific Plan Requirements that would ensure that future development evaluates site-specific issues.
Comment H.9: CONCLUSION
We respectfully request, as a CEQA matter, that the City revise the DEIR, respond to our comments in the administrative record, and ensure CEQA compliance before approving the final EIR. More importantly, it is clear the drafters were not aware of the environmental regulatory challenges involved in proposing a paseo through a federally regulatory PCB capped site. The concept of the Bragato Paseo should be abandoned.
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June 08, 2026 Packet Pg. 2364
Northeast Area Specific Plan, SCH# 2024070063 50 Final EIR City of San Carlos May 2026
Response H.9: The comment is acknowledged. Refer to responses H.1 through H.8 above.
10.b
June 08, 2026 Packet Pg. 2365
Northeast Area Specific Plan, SCH# 2024070063 51 Final EIR City of San Carlos May 2026
Section 5.0 Draft EIR Text Revisions
This section contains revisions to the text of the Northeast Area Specific Plan Draft EIR dated March 2026. Revised or new language is underlined. All deletions are shown with a line through the text.
10.b
June 08, 2026 Packet Pg. 2366
SAN CARLOS CALTRAIN STATION
SAN CARLOS
AIRPORT
BELMONT CALTRAIN STATION
1/ 2 M ILE FROM BELM ONT CALTRAIN STATION
1/ 2 M ILE FROM SAN CARLOS CALTRAIN STATION
INDUSTRIAL ROAD
TAYLOR WAY
GLENN WAY BRAGATO ROAD
QUARRY ROAD
OLD COUNTY ROAD
HARBOR BLVD
TS YLL OH
R D DOO WHTR ON
R D NOTRE VI R
R DSSE NRE V NI
ELMER ST
FAIRFIELD DR
R D NAVL YS
R D DLEI F GNI RPS
US HIGHWAY 101
EL CAMINO REAL
BELMONT CREEK
NEW STREET
Mixed-Use 68-90 DUs/Acre
Mixed-Use 57-75 DUs/Acre
Planned Industrial
Project Boundary
Legend
PROPOSED LAND USE DESIGNATIONS FIGURE 2.4-1
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June 08, 2026 Packet Pg. 2367
Northeast Area Specific Plan, SCH# 2024070063 53 Final EIR City of San Carlos May 2026
Sea Level Rise Standard.
Sea Level Rise Future development shall assess sea level rise risk for the site and elevate the finished floor elevation of the new building further above the 100-year BFE to
provide resiliency to future sea level rise (2050).9
Health Risk Project Assessment Requirements
• Health Risk Assessments. Applicants proposing development of projects Projects within 1,000 feet of existing sensitive receptors or worker receptors as defined by the Bay Area Air District (e.g., residential, schools) shall submit prepare a site-specific construction and operational health risk assessment (HRA) prior to project planning application approval. If the HRA demonstrates, to the satisfaction of the City, that the health risk exposures for adjacent receptors will be less than Bay Area Air District project-level thresholds, then additional mitigation would be unnecessary. However, if the HRA demonstrates that health risks would exceed the Bay Area Air District project level thresholds, additional feasible onand off-site mitigation shall be analyzed incorporated to further reduce risks to the greatest extent practicable and to the satisfaction of the City.
Toxic Air Contaminant Project Requirements
• Projects developed within the Plan that are affected by air pollutant or toxic air contaminant (TAC) sources (shown on Figure 3.3-1 ) shall implement appropriate measures to minimize exposure to long-term TAC and annual PM2.5 particulate matter with a diameter of 2.5 micros or less (PM2.5) exposure for new to project occupants. Projects shall include either measures to reduce long-term exposure to TAC and PM2.5, as described below, or conduct a site-specific analysis prior to project approval to identify the level of exposure to TACs in terms of cancer risk and annual PM2.5 concentrations. The analysis shall use procedures prescribed by the Bay Area Air District (e.g., the Bay Area Air District CEQA Air Quality Guidelines) to predict these exposures. Where cancer risk exceeds 10 chances per million from any single source or 100 chances per million for cumulative sources (i.e., within 1,000 feet), where annual PM2.5 concentrations exceed 0.3 μg/m3from any single source or 9 All new development within the Northeast Area shall adhere to One Shoreline definition of Sea Level Rise Base Flood Elevation (SLR-BFE). SLR-BFE is defined as 3 feet above the project site’s Base Flood Elevation (BFE) on the FEMA Flood Insurance Rate Map in effect at the time of the Application Date. Where no BFE exists, the SLR-BFE shall be at least 3 feet above the existing grade. If the site is sloped, the average existing grade shall be used.
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June 08, 2026 Packet Pg. 2368
Northeast Area Specific Plan, SCH# 2024070063 54 Final EIR City of San Carlos May 2026
0.8 μg/m3for cumulative sources, and where HI exceed 1.0 from any single source or 10.0 for cumulative sources, the following measures shall be implemented:
o Design projects developments to limit exposure from sources of TACs and fine particulate matter (PM2.5) emissions.
o Install air filtration at units that have predicted cancer risk levels above 10 chances cases per million and PM2.5 concentrations above 0.3 µg/m3. Air filtration devices shall be rated Minimum Efficiency Reporting Value (MERV) 13 or higher. Alternately, at the approval of the City, equivalent control technology may be used if it is shown by a qualified air quality consultant or heating, ventilation, and air conditioning (HVAC) engineer that it would reduce risk below significance thresholds. o As part of implementing this measure, an ongoing maintenance plan for the building’s HVAC air filtration system shall be required. o Ensure that any lease agreements and other property documents (1) require cleaning, maintenance, and monitoring of the affected units for air flow leaks; (2) include assurance that new owners and tenants are provided information on the ventilation system; and (3) include provisions that fees associated with owning or leasing a unit(s) in the building include funds for cleaning, maintenance, monitoring, and replacements of the filters, as needed.
o Require that, prior to building occupancy, an authorized air pollutant consultant or HVAC engineer submit verification confirming the installation of all necessary measures to reduce cancer risk below 10 chances per million and PM2.5 concentrations below 0.3 µg/m3from any source to the satisfaction of the City.
Special-Status Species Project Requirements Migratory Bird Requirements • Avoid Nesting-Season Construction if Feasible. To the extent feasible, demolition and construction activities for sites containing trees shall be scheduled to avoid the nesting season. The nesting season for most birds in San Mateo County extends from February 1 through August 31, inclusive. If construction activities are scheduled to take place outside the nesting season, all impacts to nesting birds protected under the Migratory Bird Treaty Act (MBTA) and California Fish and Game Code would be avoided. • Conduct Pre-activity Survey for Active Nests. If it is not possible to schedule construction activities and/or tree removal between September 1 and January 31, preconstruction surveys for nesting birds shall be conducted by a qualified biologist to ensure that no nests shall be disturbed during project implementation. These surveys shall be conducted no more than seven days prior to the initiation of demolition or construction activities, including tree removal and pruning. During this survey, the biologist shall inspect all trees and other potential nesting habitats (e.g., trees, shrubs, ruderal grasslands, buildings) in and immediately adjacent to the impact areas for nests. Prior to any tree removal, or approval of any grading or demolition permits (whichever occurs first), the ornithologist biologist shall submit a report indicating the results of the survey and any designated buffer zones to the satisfaction of the City’s Planning Division Manager.
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June 08, 2026 Packet Pg. 2369
Northeast Area Specific Plan, SCH# 2024070063 55 Final EIR City of San Carlos May 2026
• Provide a Buffer around Active Nests. If an active nest (i.e., a nest with eggs or young) is found sufficiently close to work areas to be disturbed by these activities, the biologist shall determine the extent of a construction-free buffer zone to be established around the nest (typically 300 feet for raptors and 100 feet for other species), to ensure that no nests of species protected by the MBTA and California Fish and Game Code shall be disturbed during project implementation.
Roosting Bat Project Requirements
Consistent with General Plan Policy EM-1.2, if buildings identified shown as “Currently Suitable” and buildings identified as “Potentially Suitable if Building is Unoccupied” on Figure 3.4-2 are proposed to demolished or remodeled, the following Specific Plan Project Requirements pertaining to specialstatus roosting bats shall be implemented. Remodels could also result in such impacts if they affect areas where bats are present or if they block ingress or egress to roost sites. Remodels most likely to affect bats are those that physically alter the exteriors (including exterior walls), roofs, and atticlike spaces of buildings or that plug holes, cavities, or crevices that allow bats to enter or exit buildings supporting bats.
• Conduct Pre-Activity Surveys for Roosting Bats. A pre-activity habitat assessment and survey for roosting bats shall be conducted prior to removal or renovation of buildings. The habitat assessment and survey shall be conducted by a qualified biologist. If the biologist determines that a building provides no suitable bat roost sites, no bat survey would be necessary, but if suitable roost sites exist, a visual survey shall be conducted during the daytime to determine whether bats are present. During this survey, the biologist shall look for bats and evidence of their presence (e.g., guano or urine staining). If the visual survey cannot adequately determine whether bats are present, a dusk survey shall be conducted during suitable weather conditions for bat activity to determine whether bats enter or exit the roost. If no active roosts are found, then no further action is warranted. If a roost is present, a qualified biologist shall determine the species and number of individuals present and implement further measures as described below. Prior to any tree removal, or approval of any grading or demolition permits (whichever occurs first), the biologist shall submit a report indicating the results of the survey and avoidance requirements to the satisfaction of the City’s Planning DivisionManager.
• Avoid Disturbance of Active Roosts. If an occupied roost is found in a structure that would be disturbed or removed by proposed activities, the project may be redesigned to avoid the disturbance of the structure. If the roost is unoccupied at the time of the survey, the project proponent may have a qualified biologist install bat exclusion devices to prevent bats from taking up occupancy of the structure prior to the onset of the proposed activity. If avoidance is not feasible, the following measures shall be implemented. • Avoid Disturbance of Maternity Roosts. If an active maternity roost is present within the building to be demolished or disturbed and the project cannot be redesigned to avoid removal or disturbance of the occupied roost, disturbance shall not take place during the
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June 08, 2026 Packet Pg. 2370
Northeast Area Specific Plan, SCH# 2024070063 56 Final EIR City of San Carlos May 2026
maternity season (as determined by the qualified biologist, but approximately April 1 to August 31), and an appropriate disturbance-free buffer zone (also determined by the qualified biologist) shall be observed during this period to avoid disturbing the roosting bats.
Following the maternity season, bats can be excluded as described below. • Exclude Bats Prior to Disturbance. If disturbance of an active non-breeding roost cannot be avoided, the individuals shall be safely evicted outside the maternity season (as determined by the qualified biologist) between approximately September 1 and April 1. Exclusion methods may include the installation of one-way doors, use of ultrasonic deterrence devices, changing air flow and temperature regimes in the roost space, or other methods that would not trap bats or involve handling bats. One-way doors and/or deterrence devices should be left in place for a minimum of two weeks with a minimum of five fair-weather nights with no rainfall and temperatures no colder than 50°F.
Artificial Lighting Project Requirements
• The following measures will be implemented during any renovation or redevelopment under the Plan adjacent to Belmont Creek and other areas mapped as riparian, freshwater marsh, and aquatic riverine as shown on Figure 3.4-1 that involves new outdoor lighting or replacement of existing lighting with fixtures or luminaires that are not identical in intensity, wavelength, and directionality to those being replaced. o Through a combination of proper fixture selection, low mounting height, glare shielding, and orientation/aiming of light fixtures, the design team shall actively control undesirable spill of light toward sensitive habitat areas (i.e., Belmont Creek, other drainage channels and associated wetland and riparian habitat, or vegetated open space areas). All exterior lighting shall be fully shielded to block illumination from shining outward toward such sensitive habitat areas and to prevent the lit portions of these fixtures (i.e., the lamps) from being directed toward the sensitive habitat areas.
o Outdoor lighting fixtures shall incorporate lamps with a Correlated Color Temperature of 2700 Kelvin or less.
o Up-lighting shall be avoided, all fixtures shall have a backlight, uplight, and glare (BUG) up-light rating of U0, and the maximum vertical illuminance at any point in the plane of the property line will be 0.05 footcandle, unless the following conditions are met:
▪ All up-light is directed at building facades such that no light spills upwards past a structure (e.g., into the sky) or outwards into adjacent areas.
▪ The fixture is programmed to switch off between 10:00 p.m. and sunrise.
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June 08, 2026 Packet Pg. 2371
Northeast Area Specific Plan, SCH# 2024070063 57 Final EIR City of San Carlos May 2026
Bird Collision Project RequirementsBird Safe Design Requirements • Projects Renovation and redevelopment under the Plan shall implement the following birdsafe building design considerations for all buildings exceeding 40 feet above finished gradeground within 300 feet of Belmont Creek or any contiguous open space areas (including other drainages and future open space areas created by the Plan) two acres or larger that are dominated by vegetation or wetland/aquatic habitats:
o The extent of glass on the façades of new buildings and additions shall be minimized to the extent feasible.
o No more than 10 percent of the surface area of the façades of buildings (considering all facades combines) shall have untreated glazing between the ground and 60 feet above ground. Bird-safe glazing treatments may include fritting, netting, permanent stencils, frosted glass, exterior screens, and/or physical grids placed on the exterior of glazing or ultraviolet patterns visible to birds. Bird-safe glazing shall have the following specifications:
▪ Vertical elements of the window patterns will be at least ¼-inch wide at a maximum spacing of 4 inches, or have horizontal elements at least 1/8-inch wide at a maximum spacing of 2 inches; OR
▪ Bird-safe glazing shall have a Threat Factor less than or equal to 30. o No more than 10 percent of the surface area of any façades directly facing Belmont Creek or any open space areas two acres or larger that are dominated by vegetation or wetland/aquatic habitats, and/or façade areas within 12 vertical feet above and/or below landscaped terraces, shall have untreated glazing. o All glazing panels at corners of façades that face Belmont Creek or any open space areas two acres or larger that are dominated by vegetation or wetland/aquatic habitats, between the ground and 60 feet above ground and/or within 12 vertical feet above and/or below landscaped terraces (regardless of their height above ground), shall be 100 percent treated.
o To reduce reflections of clouds and vegetation in glass and help ensure that birdsafe treatments on the lower surfaces of glass are visible below any reflections, glazing shall have a visible reflectance of 15 percent or lower. o Glass skyways or walkways, freestanding glass walls, and transparent building corners between the ground and 60 feet above ground and/or within 12 vertical feet above and/or below landscaped terraces (regardless of their height above ground) shall not be allowed, unless the glazing is 100 percent treated. o Transparent glass should not be allowed at the rooflines of buildings, including in conjunction with green roofs, unless the glazing is 100 percent treated. o A project may receive a deviationwaiver from one or more of the requirements above if a qualified biologist documents that glazing in a particular area will not increase bird collision risk or documents why alternative bird-safe design measures would be at least as effective as the above requirements. Any such waiver decision must be approved by the City’s Planning Division.
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June 08, 2026 Packet Pg. 2372
Northeast Area Specific Plan, SCH# 2024070063 58 Final EIR City of San Carlos May 2026
Road, the year built will be revised as follows:
Address APN Year Built Age Building Type
495 Bragato Road 046-052-330 1956 67 Industrial (warehouse) 500 Bragato Road 046-052-280 1952 71 Commercial (warehouse and office space)
501 Bragato Road 046-052-340 1962 61 Industrial (manufacturing) 520 Bragato Road 046-052-280 1952 71 Industrial (warehouse) 535 Bragato Road 046-052-250 1969 54 Industrial (warehouse) 540-560 Bragato Road 046-052-280 1975 48 Commercial (office) 555 Bragato Road 046-052-200 1950 73 Industrial (manufacturing) 565 Bragato Road 046-053-180 1968 55 Industrial (manufacturing) 570 Bragato Road 046-052-280 1952 71 Industrial (warehouse) 110 Glenn Way 046-0533-50 1973 50 Industrial (warehouse) 111 Glenn Way 046-052-220 1966 57 Industrial (warehouse) 120 Glenn Way 046-053-350 1972 51 Industrial (warehouse) 131 Glenn Way 046-052-230 1966 57 Industrial (manufacturing) 161 Glenn Way 046-052-080 1968-1980 43-55 Commercial (office and warehouse)
170 Glenn Way 046-053-290 1974 49 Industrial (warehouse) 195 Glenn Way 046-052-070 1969 54 Commercial (office)
70 Glenn Way 046-053-190 1966 57 Industrial (warehouse) 71 Glenn Way 046-052-260 1967 56 Industrial (warehouse) 80 Glenn Way 046-053-160 1968 55 Industrial (warehouse) 90 Glenn Way 046-053-210 1968 55 Industrial (warehouse) 120 Industrial Road 046-021-080 1957,
renovated
1997
66 Industrial (research and
development)
150 Industrial Road 046-021-080 1957,
renovated
1997
66 Industrial (research and
development)
151 Industrial Road 046-020-450,
046-020-460, and
046-020-470
1974 1997 4929 Commercial (storage) and
adjacent paved easements
and parking lot
161 Industrial Road 046-020-120 1952 71 Industrial (warehouse) and rear parking lot
171 Industrial Road 046-020-260 and
046-020-430
1952 71 Commercial (auto body
shop)
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June 08, 2026 Packet Pg. 2373
Northeast Area Specific Plan, SCH# 2024070063 59 Final EIR City of San Carlos May 2026
Address APN Year Built Age Building Type
181 Industrial Road 046-020-300 1956 67 Industrial (warehouse) 191 Industrial Road 046-020-280 and
046-020-090
1952 71 Commercial (auto sales)
200 Industrial Road 046-022-010 1951 72 Industrial (warehouse and distribution)
210 Industrial Road 046-022-010 1951 72 Commercial (retail complex) 234 Industrial Road 046-022-010 1951 72 Commercial (auto repair) 236 Industrial Road 046-022-010 1951 72 Commercial (auto repair) 242 Industrial Road 046-022-010 1951 72 Commercial (metal manufacturing, auto repair)
244 Industrial Road 046-022-010 1951 72 Commercial (auto repair) 266 Industrial Road 046-052-270 1960 63 Industrial (manufacturing and distribution)
268 Industrial Road 046-052-330 1956 67 Commercial (auto sales) 270 Industrial Road 046-052-040,
046-052-100,
046-052-030, and
046-052-050
1956 67 Industrial (manufacturing)
300 Industrial Road 046-054-190 1969 54 Industrial (manufacturing) 320 Industrial Road 046-054-210 1971 52 Industrial (manufacturing and warehouse)
380 Industrial Road 046-054-390,
046-054-400, and
046-054-250
1975 48 Industrial (warehouse)
380–400 Industrial Road 046-054-400 and
046-054-250
1968 55 Parking lot and access road
389 Industrial Road 046-022-010 1951 72 Industrial (warehouse) 390 Industrial Road 046-054-020 1960 63 Industrial (manufacturing) 400 Industrial Road 046-054-010 1962 61 Industrial (warehouse) 150 Old County Road 046-041-380 1956 67 Industrial (warehouse) 1501 Old County Road 046-040-360 1963 60 Industrial complex containing 643, 645, and 650
Quarry Road)
151 Old County Road 046-041-380 1946-1956 67-77 Industrial (warehouses) and commercial (office)
205 Old County Road 046-040-300 1951 72 Industrial (service) 209 Old County Road 046-040-050 1952 71 Industrial (service) 235 Old County Road 046-053-170 1969 54 Industrial (warehouse)
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June 08, 2026 Packet Pg. 2374
Northeast Area Specific Plan, SCH# 2024070063 60 Final EIR City of San Carlos May 2026
Address APN Year Built Age Building Type
239 Old County Road 046-053-080 1958 65 Industrial (warehouse and shop)
243 Old County Road 046-053-070 1958 65 Industrial (warehouse) 247 Old County Road 046-053-060 1964 59 Commercial (retail) 251 Old County Road 046-053-310 1946 77 Commercial (retail) 301 Old County Road 046-054-100 1965 58 Industrial (warehouse) and commercial (retail)
303 Old County Road 046-054-100 and
046-054-090
1965 58 Parking lot adjacent to APN
046-054-100
335 Quarry Road 046-022-010 1951 72 Commercial (office) 345 Quarry Road 046-022-010 1951 72 Industrial (warehouse) 355 Quarry Road 046022010 1951 72 Industrial (warehouse and distribution)
361 Quarry Road 046-022-010 1951 72 Industrial (auto repair) 383 Quarry Road 046-022-010 1951 72 Industrial (auto repair) 385 Quarry Road 046-022-010 1951 72 Industrial (auto repair) 401 Quarry Road 046-040-320 1956 67 Industrial (manufacturing) 403 Quarry Road 046-040-320 1956 67 Industrial (manufacturing) 503 Quarry Road 046-040-320 1956 67 Industrial (warehouse) 591 Quarry Road 046-040-320 1956 67 Industrial complex
595 Quarry Road 046-040-320 1956 67 Parking lot and access road 597 Quarry Road 046-040-320 1956 67 Industrial (warehouse and manufacturing)
610 Quarry Road 046-041-370 1955 68 Industrial (manufacturing) 639 Quarry Road 046-040-370 1965 58 Industrial (auto repair) 642 Quarry Road 046-041-380 1956 67 Industrial (warehouse and office)
643 Quarry Road 046-040-360 1963 60 Industrial (warehouse) 645 Quarry Road 046-040-360 1963 60 Industrial (warehouse) 647 Quarry Road 046-040-360 1963 60 Industrial (auto repair) 541 Taylor Way 046-054-220 1972 51 Industrial (warehouse and office)
551 Taylor Way 046-054-310 and
046-054-260
1962 61 Industrial (warehouse) and
parking lot
590 Taylor Way 046-052-110,
046-052-060, and
046-052-090
1960 63 Industrial (warehouse) and
parking lot
601 Taylor Way 046-054-120 1964 59 Industrial (warehouse)
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June 08, 2026 Packet Pg. 2375
Northeast Area Specific Plan, SCH# 2024070063 61 Final EIR City of San Carlos May 2026
Address APN Year Built Age Building Type
611 Taylor Way 046-054-130 and
046-054-510
1977 46 Industrial (warehouse) and
parking lot
620 Taylor Way 046-053-290 1974 49 Industrial (warehouse and manufacturing)
675 Taylor Way 046-054-100 1965 58 Industrial (manufacturing) 551 Taylor Way 046-054-270 1962 61 Commercial (showroom)
following paragraph:
As shown in Table 3.9 1, identified contaminants have included VOCs, petroleum hydrocarbons, metals and/or PCBs. Several of the associated LUST and Cleanup Program cases have been closed by the overseeing regulatory agencies. One LUST case and four Cleanup Program cases remain open; at these parcels, characterization, monitoring and/or remediation activities are on-going and are being conducted under regulatory agency oversight. At the closed LUST and Cleanup Program sites, residual contamination may remain in soil, soil vapor and/or groundwater.
As shown in Table 3.9-1, the property at 495 Bragato Road (Map Id. 38) has potential contaminants of concern including PCBs, TCBs, petroleum hydrocarbons, and VOCs. A cap was installed on the property between 2021 and 2022 in accordance with the requirements of the TSCA and under the authority and oversight of the EPA. A Land Use Covenant will be established to ensure the integrity of the cap.
For the Delta Star property (Map Id. #9) at 270 Industrial Road, a Land Use Covenant was established for a portion of the property where soil with PCB concentrations exceeding the established cleanup standards was left in place and capped. Among other provisions, the Land Use Covenant prohibits certain sensitive uses of the property (e.g., residential, schools, hospitals, day care facilities, etc.) unless approved by the DTSC.
Resiliency Project Requirements:Flood Resiliency Requirements • All new development within the Plan, regardless of whether the site is located within the 100-year flood zone shall adhere to the San Carlos Municipal Code, Chapter 15.56 - Flood Damage Prevention.
• Critical site infrastructure (such as transformers and generators) shall be elevated to provide resilience to current and future flooding conditions in the area. • The City of San Carlos shall determine on a case by case basis if an individual project requires a building height variance to accommodate proposed finished floor elevations that have been elevated to provide flood resilience.
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June 08, 2026 Packet Pg. 2376
Northeast Area Specific Plan, SCH# 2024070063 62 Final EIR City of San Carlos May 2026
• For any new development within a 100-year flood zone, the project would be required to set the finished floor elevation above the 100-year base flood elevation (BFE). • Future development shall assess sea level rise risk for the site and elevate the finished floor elevation of the new building further above the 100-year BFE to provide resiliency to future sea level rise (2050).
Vibration Control Project Requirements:
• Projects shall submit aA construction vibration control plan shall be prepared by a qualified professional in accordance with industry-accepted methodology. The plan shall identify necessary construction vibration controls to reduce the potential of cosmetic damage to buildings and to minimize annoyance. Controls may include, but would not be limited to, the following measures:
o Submit aA list of all heavy construction equipment to be used for the project known to produce high vibration levels (tracked vehicles, vibratory compaction, jackhammers, hoe rams, etc.) shall be submitted to the City by the contractor. This list shall be used to identify equipment and activities that would potentially generate substantial vibration and to define the level of effort for reducing vibration levels below the thresholds. o Place operating equipment on the construction site as far as possible from vibrationsensitive receptors. o Use smaller equipment along project boundaries to minimize vibration levels below the limits.
o Avoid using vibratory rollers and tampers near sensitive areas. o Select demolition methods not involving impact tools. o Modify/design or identify alternative construction methods to reduce vibration levels below the limits.
o Avoid dropping heavy objects or materials near sensitive uses. o For projects requiring impact or vibratory pile driving, develop a vibration monitoring and construction contingency plan to identify structures where monitoring would be conducted, set up a vibration monitoring schedule, define structure-specific vibration limits, and address the need to conduct photo, elevation, and crack surveys to document before and after construction conditions. Construction contingencies shall be identified for when vibration levels approached the limits. Conduct a post-construction survey on structures where either monitoring has indicated high vibration levels or complaints of damage has been made. Make appropriate repairs or compensation where damage has occurred as a result of construction activities.
Vibration Control Measure Project Requirement:
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June 08, 2026 Packet Pg. 2377
Northeast Area Specific Plan, SCH# 2024070063 63 Final EIR City of San Carlos May 2026
• Projects incorporating Based on the setback distances presented in Error! Reference source not found., project-specific vibration analyses shall be prepared for residential buildings uses proposed along Old County Road within 75 feet of the nearest Caltrain track and for buildings with interiors sensitive to vibration (e.g., research labs) that are within 335 feet of the nearest Caltrain track shall submit project-specific vibration analyses. These studies should analyses shall include vibration measurements at the project sites and comparisons of the measurements to the established FTA Federal Transit Administration standards in order to verify vibration and land use compatibility consistent with 2030 General Noise Element (as amended by the 2045 General Plan Reset Project) Policies NOI-1.7 and NOI1.14.
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June 08, 2026 Packet Pg. 2378
Appendix A: Draft EIR Comment Letters
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June 08, 2026 Packet Pg. 2379
“Provide a safe and reliable transportation network that serves all people and respects the environment.” DISTRICT 4
OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
April 13, 2026 SCH #: 2024070063
GTS #: 04-SM-2024-00764
GTS ID: 33230
Co/Rt/Pm: SM/VAR/VAR
Rendell Bustos, Senior Planner
City of San Carlos
600 Elm Street
San Carlos, CA 94070-3085
Re: San Carlos Northeast Area Specific Plan ɔ Draft Environmental Impact Report (DEIR) Dear Rendell Bustos:
Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the San Carlos Northeast Area Specific Plan (NEASP).
The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the March 2026 DEIR.
Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only.
Project Understanding
The proposed project is to develop the NEASP, which will guide new development within the approximately 145-acre Plan area. The NEASP would be built out over an approximate 20-year period and would allow for a net increase of 1,890 residential units in the Plan area, where no residential units currently exist, as well as increase the net square footage of existing non-residential land uses. The Plan also proposes multimodal transportation improvements. The Plan area is located between U.S. Route 101 (U.S. 101) and State Route 82 (SR 82) and is bound by U.S. 101 on its eastern side.
Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. For more information on how Caltrans assesses Vehicle Miles Traveled (VMT) analysis for land use projects, please review Caltrans’ Transportation Impact Study Guide (link).
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June 08, 2026 Packet Pg. 2380
Rendell Bustos, Senior Planner
April 13, 2026
“Provide a safe and reliable transportation network that serves all people and respects the environment.” The project’s VMT analysis and significance determination are undertaken in a manner consistent with the Office of Land Use and Climate Innovation’s (LCI) Technical Advisory or the City’s adopted VMT policy. Per the DEIR, this project is found to have a less than significant VMT impact.
Climate Change and Sea Level Rise
Please keep the Caltrans District 4 Climate Change Planning team informed of Sea Level Rise (SLR) and flooding considerations within the project area. Caltrans participates as a Technical Advisory Committee (TAC) member for the ongoing Redwood Shores SLR Protection Project and is particularly interested in continued discussions regarding resilience along both Belmont Creek and Pulgas Creek.
Evidence indicates that, by 2100, flooding and associated flows may overtop U.S. 101 and extend to areas west of the highway. Caltrans also partners with OneShoreline to address flooding concerns affecting U.S. 101 along and near Belmont Creek.
Given the project’s intent to address flooding and SLR through resilience improvements along Belmont Creek (such as green stormwater infrastructure), Caltrans requests regular updates on proposed and implemented measures. Since the project area borders U.S.101 and Belmont Creek could convey flooding, stormwater, and tidal influence toward the State’s Right-of-Way (ROW), changes within the creek corridor and watershed may directly affect US-101 conditions downstream. Please keep Caltrans updated on planned improvements, design assumptions, and any monitoring results related to Belmont Creek resilience efforts. Please reach out to the Climate Change Branch at [email protected] for any questions or concerns.
Hydrology
The developments proposed within the plan may impact the existing drainage systems along southbound U.S. 101. As part of the encroach permit application, please submit plan views, profiles, cross sections, and detailed drawings of all drainage facilities, along with hydrologic calculations comparing pre and post development conditions at this location.
The Office of Hydraulics would like to ensure that no surface runoff from the developments within this plan directly enters the roadside ditch located between the project site and southbound U.S. 101. Additionally, that discharge from the new developments does not adversely affect the existing U.S. 101 drainage system, particularly during the rainy season.
Aeronautics
Given the program-level nature of the NEASP, the Office of Aeronautics would like to reiterate their previous comments to ensure these considerations are carried forward during plan implementation. As noted previously, one of the goals of the Caltrans
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June 08, 2026 Packet Pg. 2381
Rendell Bustos, Senior Planner
April 13, 2026
“Provide a safe and reliable transportation network that serves all people and respects the environment.” Aeronautics Program, is to assist cities, counties, and Airport Land Use Commissions or their equivalent (ALUC), to understand and comply with the State Aeronautics Act pursuant to the California Public Utilities Code (PUC), Section 21001 et seq.
The proposed project is in Safety Zone 6 (Traffic Pattern Zone), with a portion of the Project site in Safety Zone 3 (Inner Turning Zone) of the San Carlos Airport, established by the San Mateo County ALUC pursuant to Section 21675(c). Therefore, the proposed Project shall adhere to the safety and land use criteria and restrictions defined in the Airport Land Use Compatibility Plan (ALUCP) formed by the ALUC pursuant to the PUC Section 21674 and Section 21676 and may be subject to review authority by the ALUC.
A portion of the project site is also in the 60 decibel (dB) community noise level contour (CNEL) of the Future Conditions (2035) Aircraft Noise Contours for the San Carlos Airport per the ALUCP. Development in this area would be subject to the noise compatibility policies of the ALUCP. Of note, multi-family residential development in the 60 dB CNEL contour is conditionally compatible and must be capable of attenuating exterior noise levels to an interior noise level of CNEL 45 dB or lower.
PUC Section 21659 prohibits structural hazards near airports. Structures should not be at a height that will result in penetration of the airport imaginary surfaces. In accordance with Federal Aviation Regulation, Part 77 “Objects Affecting Navigable Airspace” a Notice of Proposed Construction or Alteration (Form 7460-1) may be required by the Federal Aviation Administration (FAA). For further information or a copy of Form 7460- 1, please refer to the FAA website (link).
Lastly, in accordance with PUC Section 21676 et seq., prior to the amendment of a general plan or specific plan, or the adoption or approval of a zoning ordinance or building regulation within the planning boundary established by the ALUC, the local agency shall first refer the proposed action to the ALUC. If the commission determines that the proposed action is inconsistent with the commission's plan, the referring agency shall be notified.
These comments reflect the areas of review by Caltrans Aeronautics with respect to airport-related noise, safety, and land use planning issues. Caltrans Aeronautics appreciates the opportunity to comment. Should you have any questions regarding these comments, please contact [email protected].
Construction-Related Impacts
Project work that requires movement of oversized or excessive load vehicles on State roadways requires a transportation permit that is issued by Caltrans. To apply, please visit Caltrans Transportation Permits (link).
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June 08, 2026 Packet Pg. 2382
Rendell Bustos, Senior Planner
April 13, 2026
“Provide a safe and reliable transportation network that serves all people and respects the environment.” Prior to construction, coordination may be required with Caltrans to develop a Transportation Management Plan (TMP) to reduce construction traffic impacts to the State Transportation Network (STN).
Equitable Access
If any Caltrans facilities are impacted by the project, those facilities must meet Americans with Disabilities Act (ADA) Standards after project completion. As well, the project must maintain bicycle and pedestrian access during construction. These access considerations support Caltrans’ equity mission to provide a safe, sustainable, and equitable transportation network for all users.
Equity and Public Engagement
We will achieve equity when everyone has access to what they need to thrive no matter their race, socioeconomic status, identity, where they live, or how they travel.
Caltrans is committed to advancing equity and livability in all communities. We look forward to collaborating with the City to prioritize projects that are equitable and provide meaningful benefits to historically underserved communities.
Caltrans encourages the City to foster meaningful, equitable and ongoing public engagement in the NEASP development process to ensure future transportation decisions and investments reflect community interests and values. The public engagement process should include community-sensitive and equity-focused approaches seeking out the needs of individuals from underserved, Tribal, and lowincome communities, the elderly, and individuals with disabilities.
Encroachment Permit
Please be advised that any temporary or permanent work including traffic control that encroaches in, under, or over any portion of the State highway ROW requires a Caltrans-issued encroachment permit.
The Office of Encroachment Permits requires 100% complete design plans and supporting documents to review and circulate the permit application package. The review and approval of encroachment projects is managed through the Encroachment Permits Office Process (EPOP) or the Project Delivery Quality Management Assessment Process (QMAP), depending on project scope, complexity, and completeness of the application. Please use the following resources to determine the appropriate review process:
- TR-0416 Applicant’s Checklist (link)
- Caltrans Encroachment Projects Processes – Information Video (link)
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June 08, 2026 Packet Pg. 2383
Rendell Bustos, Senior Planner
April 13, 2026
“Provide a safe and reliable transportation network that serves all people and respects the environment.” - Flowchart, Figure 1.2 in Section 108, Overview of the Encroachment Review Process, of Chapter 100 – The Permit Function, Caltrans Encroachment Permit Manual (link)
The permit approval typically takes less than 60 days, but may take longer depending on the project scope, size, complexity, completeness, compliance with applicable laws, standards, policies, and quality of the permit package submitted. Projects requiring exceptions to design standards, exceptions to encroachment policies, or external agency approvals may need more time to process.
To obtain more information and download the permit application, please visit Caltrans Encroachment Permits (link).
Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Mary McGee, Transportation Planner, via [email protected]. For future early coordination opportunities or project referrals, please visit Caltrans LDR website (link) or contact LDR[email protected].
Sincerely,
YUNSHENG LUO
Branch Chief, Local Development Review
Office of Regional and Community Planning
c: State Clearinghouse
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June 08, 2026 Packet Pg. 2384
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June 08, 2026 Packet Pg. 2385
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June 08, 2026 Packet Pg. 2386
COMMISSIONERS: VIRGINIA CHANG KIRALY, CHAIR, SPECIAL DISTRICT ƒ ANN DRAPER, VICE CHAIR, PUBLIC ƒ KATI MARTIN, SPECIAL DISTRICT ƒ DAVID J CANEPA, COUNTY ƒ DEBBIE RUDDOCK, CITYƒ STEPHEN RAINALDI, CITY ƒ JACKIE SPEIER, COUNTY ƒ ALTERNATES: NOELIA CORZO, COUNTY ƒ KATHRYN SLATER-CARTER, SPECIAL DISTRICT ƒ GREG WRIGHT, CITY ƒ COLLEEN YOU, PUBLIC STAFF: ROB BARTOLI, EXECUTIVE OFFICER ƒ SARAH FLAMM, MANAGEMENT ANALYST ƒ TIM FOX, LEGAL COUNSELƒ
DIANE ESTIPONA, CLERK
April 15, 2025
Sent Via Email
Rendell Bustos, Senior Planner
Community Development Department
City of San Carlos
600 Elm Street
San Carlos, CA 94070
Subject: Draft Environmental Impact Report for the Northeast Area Specific Plan and Final Draft of the Northeast Area Specific Plan
Dear Mr. Bustos,
Thank you for the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the Northeast Area Specific Plan and Final Draft of the Northeast Area Specific Plan (Plan).
The Local Agency Formation Commission (LAFCo) is a state mandated local agency established in every county to oversee the boundaries of cities and special districts. San Mateo LAFCo has jurisdiction over the boundaries of the 20 cities, 21 independent special districts, and many of the 34 active county and city governed special districts serving San Mateo County.
San Mateo LAFCo has the following comments on the DEIR and Plan:
1) In the DEIR and Plan identify that portions of the Northeast Area are served by Cal Water Mid-Peninsula District (a private company) and the Mid-Peninsula Water District (an independent special district). The DEIR and Plan states that the use of recycled water may be explored at a future date for the Northeast Area. The Proposed Infrastructure Narrative notes that the City of San Carlos and the Mid-Peninsula Water District (MPWD) may review the possibility of connecting to the City of Redwood City’s recycled water system.
Currently, MPWD provides potable water and water for fire suppression within the District’s boundaries. If MPWD was to provide recycled water service in the future, approval from LAFCo may be required in order for the District to provide a new or different service, such as recycled or reclaimed water (Government Code Section 56824.10 et seq). If recycled water services are proposed to be provided within MPWD’s service area, it is recommended that MPWD discuss the proposal with LAFCo to review if a LAFCo process would be required.
10.b
June 08, 2026 Packet Pg. 2387
Northeast Area Comment Letter
San Mateo LAFCo looks forward to reviewing all future documents related to the Draft Environmental Impact Report for the Northeast Area Specific Plan and Final Draft of the Northeast Area Specific Plan.
Sincerely,
Rob Bartoli
Executive Officer
San Mateo LAFCo
cc: Kat Wuelfing, General Manager, Mid-Peninsula Water District
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June 08, 2026 Packet Pg. 2388
One Twin Pines Lane, Belmont, CA 94002 | 650-595 -7408 | belmont.gov April 16, 2026
Rendell Bustos, Senior Planner
Community Development Department
City of San Carlos
600 Elm Street
San Carlos, CA 94070 via email: [email protected] RE: City of Belmont Comments on Northeast Area Specific Plan Draft Environmental Impact Report
Dear Rendell Bustos,
The City of Belmont appreciates the opportunity to comment on the Draft Environmental Impact Report (DEIR) for the San Carlos Northeast Area Specific Plan (NEASP). As you know, the City of Belmont is undertaking a Specific Plan process for the Harbor Industrial Area (HIA) in preparation for potential annexation of the area into the City. Belmont supports continued coordination between our agencies to address shared infrastructure systems and regional environmental challenges, and issues related to the ultimate redevelopment of the currently underutilized properties that impact our collective jurisdictions.
These comments are focused on key issues under the California Environmental Quality Act (CEQA) where additional clarification or analysis would be beneficial to ensure full disclosure and an accurate understanding of environmental impacts. We are submitting a companion letter that outlines other technical issues and opportunities for collaboration between Belmont, San Carlos, and other affected agencies (San Mateo County, Silicon Valley Clean Water, MidPeninsula Water District, etc.).
The City of Belmont offers the following CEQA comments:
I. Regional Nature of Belmont Creek Improvements
The DEIR characterizes several Belmont Creek improvement projects in a manner that could be interpreted as City of Belmont–specific infrastructure. Belmont requests clarification of the record related to this topic.
The County of San Mateo, City of Belmont, and City of San Carlos have worked collaboratively to address persistent flood risk, creek erosion, and water quality issues in the Belmont Creek
10.b
June 08, 2026 Packet Pg. 2389
CEQA Comments Page 2 of 4
watershed. This is evidenced by numerous collective efforts in recent years and documented in the Belmont Creek Funding Agreement, signed by Belmont, San Carlos and San Mateo County, and amended on November 12, 2024. The following projects are regional, multi-agency efforts:
x Twin Pines Park Belmont Creek Restoration Project
x Twin Pines Park Stormwater Detention Basin
x Harbor Boulevard Bypass (long-term downstream capacity improvement) These projects are intended to function as integrated upstream and downstream system improvements. They address watershed-scale flooding, sedimentation, and water quality issues and provide documented benefits to San Carlos, Belmont, and unincorporated San Mateo County (Harbor Industrial Area). Belmont Creek is a regional system crossing jurisdictions, and flood risks and solutions are not confined to a single city.
Accordingly, the DEIR should:
x Avoid characterizing these improvements as Belmont-only obligations x Recognize their regional function and shared benefit
x Avoid reliance on these projects as committed mitigation to NEASP impacts without identifying appropriate cost-sharing and implementation responsibilities We believe that this better reflects the ten-plus years of coordinated planning among multiple agencies and clarifies the complexity and inter-relationship of the jurisdictions involved in the ultimate watershed infrastructure solutions.
II. Storm Drainage and Flooding
The DEIR’s conclusions regarding flood impacts rely in part on assumptions regarding offsite infrastructure and watershed performance that would benefit from further clarification.
A. Reliance on Unfunded or Uncommitted Infrastructure
The DEIR references improvements within the Belmont Creek system that are not fully funded or implemented. While these projects are advancing, they are:
x Regional in nature
x Dependent on multi-agency coordination and funding
x Not solely within the control of the City of Belmont
The improvements lack clear funding sources or funding mechanisms, defined implementation responsibilities, and enforceable timing and sequencing. The impact analysis should not rely on this infrastructure and should be updated accordingly.
B. Need for Watershed-Based Analysis
Given that Belmont Creek is a shared system, the evaluation of flood impacts should reflect watershed-scale conditions rather than jurisdictional boundaries alone. The
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June 08, 2026 Packet Pg. 2390
CEQA Comments Page 3 of 4
current analysis does not clearly demonstrate how changes in runoff, timing, or system performance may affect downstream areas, including the HIA.
III. Belmont Creek Ownership and Maintenance Responsibilities Belmont requests clarification in the DEIR that:
x Belmont Creek, particularly downstream of Old County Road, forms a boundary between jurisdictions
x Maintenance responsibilities are generally borne by adjacent property owners within each jurisdiction, not solely by a single city
This distinction is important to avoid mischaracterization of long-term operational responsibilities associated with creek improvements.
IV. Consideration of Foreseeable HIA Governance Scenarios The DEIR does not evaluate a reasonably foreseeable scenario regarding the future governance of the HIA, specifically whether the HIA remains under County jurisdiction or is annexed to the City of Belmont. These scenarios could materially affect infrastructure demand, service responsibility, and environmental impacts. In particular:
x Annexation could shift infrastructure responsibility and service provision to Belmont
x Alternatively, if the HIA remains under County jurisdiction, Belmont may experience indirect impacts without corresponding regulatory authority Because these represent distinct impact pathways, the absence of this analysis limits full disclosure under CEQA.
V. Deferral of Infrastructure Analysis
The DEIR relies on deferral of certain infrastructure evaluations to future project-level analysis. Belmont is concerned that deferral may lead to unanticipated impacts that cannot be solved at a project level. We suggest that some level of watershed analysis be completed. As noted earlier in the discussion of storm drainage and flooding, the analysis appears to assume that the detention basin and bypass will be constructed. It does not appear to consider a no-project or delayed project scenario for these improvements.
Relatedly, the EIR should consider the potential floodplain storage impacts of fill placement for future pad elevations that may occur with development in the NEASP that may impact flood elevations within the HIA.
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June 08, 2026 Packet Pg. 2391
CEQA Comments Page 4 of 4
In conclusion, the City of Belmont supports continued collaboration with the City of San Carlos and other regional partners to address shared infrastructure systems. The requested clarifications are intended to: ensure an accurate description of regional infrastructure responsibilities; improve transparency regarding flood risk and watershed conditions; and support informed and coordinated planning across jurisdictions.
Belmont looks forward to continued coordination through both the CEQA process and parallel inter-agency discussions. Thank you for your consideration.
Sincerely,
Laura C. Russell Edric Kwan, P.E.
Deputy Community Development Director Public Works Director
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June 08, 2026 Packet Pg. 2392
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June 08, 2026 Packet Pg. 2393
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June 08, 2026 Packet Pg. 2397
CERTIFICATE OF LIABILITY INSURANCE DATE (MM/DD/YYYY)
01/14/2025
THIS CERTIFICATE IS ISSUED AS A MATTER OF INFORMATION ONLY AND CONFERS NO RIGHTS UPON THE CERTIFICATE HOLDER.
THIS CERTIFICATE DOES NOT AFFIRMATIVELY OR NEGATIVELY AMEND, EXTEND OR ALTER THE COVERAGE AFFORDED BY THE POLICIES BELOW. THIS CERTIFICATE OF INSURANCE DOES NOT CONSTITUTE A CONTRACT BETWEEN THE ISSUING INSURER(S), AUTHORIZED REPRESENTATIVE OR PRODUCER, AND THE CERTIFICATE HOLDER.
IMPORTANT: If the certificate holder is an ADDITIONAL INSURED, the policy(ies) must be endorsed. If SUBROGATIONIS WAIVED, subject to the terms and conditions of the policy, certain policies may require an endorsement. A statement on this certificate does not confer rights to the certificate holder in lieu of such endorsement(s).
PRODUCER
ALLIED BROKERS INSURANCE AGCY INC
57101434
591 LYTTON AVENUE
PALO ALTO CA 94301
CONTACT
NAME:
PHONE
(A/C, No, Ext):
(866) 467-8730 FAX
(A/C, No):
(888) 443-6112
E-MAIL
ADDRESS:
INSURER(S) AFFORDING COVERAGE NAIC#
INSURED
AMTB LLC
2451 TYROLEAN WAY
SACRAMENTO CA 95821-4809
INSURER A : Hartford Underwriters Insurance Company 30104 INSURER B :
INSURER C :
INSURER D :
INSURER E :
INSURER F :
COVERAGES CERTIFICATE NUMBER: REVISION NUMBER:
THIS IS TO CERTIFY THAT THE POLICIES OF INSURANCE LISTED BELOW HAVE BEEN ISSUED TO THE INSURED NAMED ABOVE FOR THE POLICY PERIOD INDICATED.NOTWITHSTANDING ANY REQUIREMENT, TERM OR CONDITION OF ANY CONTRACT OR OTHER DOCUMENT WITH RESPECT TO WHICH THIS
CERTIFICATE MAY BE ISSUED OR MAY PERTAIN, THE INSURANCE AFFORDED BY THE POLICIES DESCRIBED HEREIN IS SUBJECT TO ALL THE TERMS, EXCLUSIONS AND CONDITIONS OF SUCH POLICIES. LIMITS SHOWN MAY HAVE BEEN REDUCED BY PAID CLAIMS.
INSR
LTR TYPE OF INSURANCE ADDLINSR
SUBR
WVD POLICY NUMBER POLICY EFF(MM/DD/YYYY)
POLICY EXP
(MM/DD/Y YYY) LIMITS
A
COMMERCIAL GENERAL LIABILITY
57 SBM BM9HAR 01/14/2025 01/14/2026
EACH OCCURRENCE $1,000,000
CLAIMS-MADE X OCCUR DAMAGE TO RENTED
PREMISES (Ea occurrence) $1,000,000
X General Liability MED EXP (Any one person) $10,000
PERSONAL & ADV INJURY $1,000,000
GEN'L AGGREGATE LIMIT APPLIES PER: GENERAL AGGREGATE $2,000,000 X POLICY PROJECT LOC PRODUCTS - COMP/OP AGG $2,000,000 OTHER:
A
AUTOMOBILE LIABILITY
57 SBM BM9HAR 01/14/2025 01/14/2026
COMBINED SINGLE LIMIT
(Ea accident) $1,000,000
ANY AUTO BODILY INJURY (Per person)
ALL OWNED
AUTOS
SCHEDULED
AUTOS BODILY INJURY (Per accident)
X HIRED
AUTOS X NON-OWNEDAUTOS
PROPERTY DAMAGE
(Per accident)
UMBRELLA LIAB
EXCESS LIAB
OCCUR
CLAIMSMADE
EACH OCCURRENCE
AGGREGATE
DED RETENTION $
WORKERS COMPENSATION
AND EMPLOYERS' LIABILITY
ANY
PROPRIETOR/PARTNER/EXECUTIVE
OFFICER/MEMBER EXCLUDED?
(Mandatory in NH)
If yes, describe under
DESCRIPTION OF OPERATIONS below
N/ A
PER
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Provisions to Address Discovery of a Tribal Cultural Resource During Construction Tribal Cultural Resources Sensitivity Training. The project sponsor, in consultation with any Cultural Resources Team if one is available, shall retain the services of an Ohlone Native American representative and/or archeological consultant from the Qualified List of Archaeological Consultants to provide cultural sensitivity and archeological awareness training to all work crews who will be involved in ground disturbing activities at the project site. The training shall inform all project contractors, subcontractors and work crew members to be on the alert for evidence of the presence of potential tribal cultural resource(s), of how to identify the evidence of such a resource(s), and of stop work, resource protection, and notification requirements in the event of suspected discovery of a tribal cultural resource by construction crew members.
Stop Work and Notification Upon Discovery. Should any indication of a tribal cultural resource be encountered during any soils-disturbing activity of the project, the project Head Foreperson and/or project sponsor shall immediately notify tribe and shall immediately suspend any soils-disturbing activities in the vicinity of the discovery until the Cultural Monitor and a qualified archeological consultant from the Qualified Archeological Consultants List have assessed the find and the respective parties have determined whether and what additional measures should be undertaken.
Preservation in Place. In the event of the discovery of a tribal cultural resource, the cultural resource team (if one is present on job), the project sponsor, the archeological consultant, and the Ohlone representative shall consult to determine whether preservation in place would be feasible and effective in preserving the values represented by the resource. The archeological consultant, in consultation with the Ohlone representative, shall document the find to current professional standards. The tribe may also require that the project sponsor immediately implement a site security program if the resource is at risk from vandalism, looting, or other damaging actions.
If it is determined that preservation-in-place of the tribal cultural resource would be both feasible and effective, the archeological consultant shall prepare a Resource Preservation Plan (RPP) in consultation with the Ohlone representative, for review, which shall be implemented by the project sponsor during construction.
If it is determined that preservation in place would not be feasible or effective, then archeological assessment and treatment shall be implemented and in consultation with the Ohlone representative, as detailed below.
Archeological Treatment. If it is determined, in consultation with the Ohlone representative and the project sponsor, determines that preservation-in-place of the tribal cultural resources is not a sufficient or feasible option to preserve the values represented by the resource, then the archeological consultant, in consultation with the Ohlone representative, shall conduct archeological assessment to determine
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the significance of the find and determine whether it retains sufficient integrity to warrant additional treatment. If the tribal cultural resource is determined to be a significant archeological resource, the archeological consultant, in consultation with the Ohlone representative, shall recommend appropriate archeological treatment to preserve the data and values of the tribal cultural resource, which may include archeological data recovery. Data recovery shall be implemented in consultation with the Ohlone representative and shall include appropriate analyses and reporting. If an archeological interpretive, monitoring, and/or testing program is required, it shall be consistent with Standard guidelines for such programs and shall be implemented immediately.
Human Remains and Funerary Objects. The treatment of any human remains, and funerary objects discovered during any soils disturbing activity shall comply with applicable State laws, including Section 7050.5 of the Health and Safety Code and Public Resources Code 5097.98. If human remains or suspected human remains are encountered during construction, the contractor and project sponsor shall ensure that ground-disturbing work within 50 feet of the remains is halted immediately and shall arrange for the protection in place of the remains until appropriate treatment and disposition have been agreed upon and implemented in accordance with this section. The project sponsor shall immediately notify the Medical Examiner of the County in which the job resides and the Tribe of the find. In the event of the Medical Examiner’s determination that the human remains are Native American in origin, the Medical Examiner will notify the California State Native American Heritage Commission (NAHC) within 24 hours and all provisions of Public Resources Code 5097.98 will be followed.
Interpretive Program. If it is determined, in consultation with Ohlone representative and the project sponsor, determines that preservation-in-place of the tribal cultural resource is not a sufficient or feasible option, the project sponsor, in consultation with local Native American representatives, shall prepare a Cultural Resources Public Interpretation Plan (CRPIP) to guide the interpretive program. The CRPIP shall be submitted for review and approval prior to implementation of the program. The interpretive program may but is not limited to artist installations, preferably by local Native American artists, oral histories with local Native Americans, cultural displays, educational panels, or other interpretive elements agreed upon by the sponsor, and Ohlone Native American representatives, and shall include an on-site acknowledgement that the project is built on traditional Ohlone land. The plan shall identify, as appropriate, proposed locations for installations or displays, the proposed content and materials of those displays or installation, the producers or artists of the displays or installation, and a long-term maintenance program. Upon approval of the CRPIP and prior to project occupancy, the interpretive program shall be implemented by the project sponsor. The project sponsor shall work with the tribal representative to identify the scope of work by the tribal representative to fulfill the requirements of this mitigation measure, which may include participation in preparation and review of deliverables (e.g., plans, interpretive materials, artwork). Tribal representatives shall be compensated for their work as identified in the agreed upon scope of work.
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Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
Three Embarcadero Center, 12th Floor | San Francisco, CA 94111-4074 Telephone: 415.837.1515 | Facsimile: 415.837.1516
www.allenmatkins.com
Caroline G. Chase
E-mail: [email protected]
Direct Dial: 415.273.7455 File Number: 393243.00001/4923-1100-4829.1 Los Angeles | Orange County | San Diego | Century City | San Francisco | New York Allen Matkins
Via Electronic Delivery
April 2, 2026
Planning and Transportation Commission
City of San Carlos
600 Elm Street
San Carlos, CA 94070
Re: Northeast Area Specific Plan and DEIR
Dear Commissioners:
This office represents Hunter Partners, LLC, through its single purpose entity BP I SPE, LLC (collectively, “Hunter”), the owner of real property located at 151 Industrial Road (“Property”) in the City of San Carlos (“City”). These comments pertain to the proposed Northeast Area Specific Plan (“Plan”)1 and the Draft Environmental Impact Report (“DEIR”)2 for the Plan.
I. Background
Hunter owns and operates a self-storage facility on the Property. Self-storage uses provide a unique service that no other type of business can provide, including much-needed extra space for households living in smaller units with limited storage, and much-needed storage for small businesses including landscapers, general contractors, pharmaceutical representatives, home stagers, and a wide variety of other professionals. In turn, self-storage uses strengthen the economic vitality of the City. Self-storage uses are also a less-intensive land use as compared to other uses currently contemplated in the Plan area.
Hunter seeks to redevelop the Property to increase the amount of self-storage capacity, but is currently prohibited from doing so, in part because of its legal nonconforming status.3 As detailed in our letter dated July 26, 2024, we requested that the Plan include, and the DEIR analyze, the 1 As of the date of this letter, the most recent version of the Plan is from May 2025. 2 SCH # 2024070063.
3 See City Municipal Code Chapter 18.19. The existing self-storage facility on the Property was constructed in circa 1997 before the Property was annexed into the City. The DEIR incorrectly states that the facility was constructed in 1974. (DEIR, p. 122.)
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April 2, 2026
ability to expand an existing lawful non-residential nonconforming use in the Plan area, subject to approval of a conditional use permit (“CUP”).
More specifically, we requested that the following provision be included in the Plan and analyzed in the DEIR: “Any existing lawful non-residential nonconforming use in the Specific Plan may be expanded in its occupancy, building floor area and height, in keeping with the Specific Plan development standards, including through demolition and new construction, subject to Planning and Transportation Commission approval of a conditional use permit in accord with Municipal Code Chapter 18.30, Use Permits.” We question why that request was not fulfilled, particularly since a substantial number of new businesses and residential units will be developed in the Plan area and would benefit from additional storage.
We reiterate that the existing lawful nonconforming self-storage use on the Property should be allowed to expand, subject to approval of a CUP. As you are aware, the purpose of the CUP process is to ensure that the project is “designed, located, and operated in a manner that will not interfere with the use and enjoyment of surrounding properties.” (City Municipal Code, § 18.30.010.) Furthermore, the Planning and Transportation Commission would need to make specified findings to approve the CUP, including that (i) the project will not be adverse to the public health, safety, or general welfare of the community, nor detrimental to surrounding properties or improvements; (ii) the project complies with design and development standards applicable to the zoning district and Plan area; (iii) the design, location, size, and operating characteristics of the expanded self-storage use are compatible with the existing and reasonably foreseeable future land uses in the vicinity and Plan area; and (iv) the project site is physically suitable for the type, density, and intensity of use being proposed, including access, utilities, and the absence of physical constraints. (City Municipal Code, § 18.30.060.) Thus, the City would retain control over such development proposals and would have the power to deny a proposal if it failed to meet the City’s requirements set forth above.
II. Comments on the Plan
Under the Plan, the Property would be rezoned from Industrial Professional (IP) to Production and Innovation (P-I)4
and located within the “allowed active use” corridor along Industrial Road and the “Creek Front Zone” adjacent to Belmont Creek.
A. Creek Front Zone & Public Open Space Requirements
The City’s existing Stream Development and Maintenance (SDM) Overlay District requires a 25-foot setback from the top of bank line of Belmont Creek. (City Municipal Code, Chapter 4 This zoning district “is intended to foster a mix of industrial workshops, warehouses, commercial recreation, research and development, office, and retail.” (Plan, § 4.2.2.)
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Attorneys at Law
April 2, 2026
18.14.) However, “[u]nder existing conditions, existing development in the Plan does not provide a 25-foot setback since most development pre-dates the City’s setback requirements.” (DEIR, p. 101.) Therefore, without proper redevelopment, the Plan would result in a disjunct of older buildings adjacent to the creek and new buildings up to 155 feet in height set back from the creek. (DEIR, pp. 14-15; Plan, § 4.14.)
As currently proposed, future development within the Creek Front Zone would be required to be set back 35 feet from the existing top of bank of Belmont Creek “to support stormwater detention for flooding events and sea level rise.”5 (Plan, § 6.3.3.) The Plan further provides: “The first 25 feet from the top of bank shall comprise of native riparian vegetation” as “an interface between the creek and the terrestrial environment [which] supports diverse habitats and helps maintain water quality by preventing erosion and filtering pollutants.” (Plan, § 6.3.4). A “multi-use path for pedestrians and bicyclists shall be built along the riparian landscape” and “shall be at least 10 feet in width.” (Plan, § 6.3.5.)
It appears that the proposed 35-foot setback requirement is merely a guise to force developers to provide a 10-foot public path along the creek, in addition to the existing 25-foot setback requirement. The existing setback requirement has been deemed sufficient for purposes of the City’s SDM Overlay District, and we question whether there is a legitimate basis for extending that to 35 feet, and whether there is a nexus study to support that proposed requirement, which is a de-facto dedication requirement.
The Plan also layers on public open space dedication requirements, which would apply to private property: “For lots greater than 15,000 sq. ft. (0.3 acres) but less than 1 acre, a minimum of 10% shall be required to be publicly accessible open or park space [and for] lots greater than 1 acre, a minimum of 15% shall be required to be publicly accessible.” (Plan, § 4.7.2.) In the Creek Front Zone, “[a]t least 50% of the open space shall directly abut the Belmont Creek Greenway [and all] open spaces shall be accessible to the public via the greenway.” (Plan, § 6.3.2.) There is no evidence of a nexus study that supports these proposed dedication requirements.
The foregoing requirements, in combination with Creek Front Zone requirements, would place a disproportionate burden on properties in the Plan area along Belmont Creek and would significantly limit redevelopment capacity. Furthermore, any additional setback requirements, multi-use path requirements, and open space requirements must factor in other development constraints, such as existing easements. For example, there is an existing PG&E easement on the Property, which already restricts development. We ask that the City revisit and justify these proposed requirements. At a minimum, the City must have the ability to modify Plan requirements on a case-by-case basis. As the City must be aware, its current approach fails to meet the constitutional nexus requirements under the Nollan/Dolan line of cases. 5 We note that an “additional 15 feet is encouraged for a total of 50 feet.”
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Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
April 2, 2026
B. Permitted Uses
The Plan only currently provides a list of permitted active ground floor uses, which includes “Indoor Warehousing and Storage” with a CUP. (Plan, § 4.8, Table 6.) That use category includes the storage of commercial goods, industrial equipment, products and materials, cold storage, and freight storage, and as “an ancillary use, includes storage in small individual spaces exclusively and directly accessible to a specific tenant.” (City Municipal Code, § 18.40.050(H)(2).) We question why self-storage uses would not also be conditionally permitted in the Plan area, as it is similar to, yet less intensive than, those permitted uses identified above. From a planning perspective, this use would support a substantial number of new businesses and residential units that will be developed in the Plan area and would benefit from additional storage.
The Property is located along the Industrial Road “allowed active use” corridor, the purpose of which is “[t]o create pedestrian and visual activity at the ground floor of new developments.” (Plan, § 4.8.1.) If the Property is redeveloped as a larger self-storage facility, active uses6 could be provided along Industrial Road (e.g., “maker” spaces), which would be an improvement over existing conditions and consistent with the Plan’s goals.7 III. Comments on the DEIR
The DEIR should include an analysis of less-intensive non-residential land uses, such as self-storage uses. Currently, the alternatives analysis in the DEIR is legally inadequate because it contains a narrow range of alternatives, none of which would substantially lessen or avoid the following significant and unavoidable impacts:
x Impact AIR-3: Buildout of the Plan would result in annual and average daily emissions of ROG, NOx and PM10, and PM2.5 associated with operation of the Plan Area [that] would exceed the Bay Area Air District project-level significance thresholds. (DEIR, p. 323.)
x Impact AIR-C: Buildout of the Plan would result in a cumulatively considerable net increase of criteria pollutant emissions. (Id.)
6 Principally permitted “active uses” would include (but not be limited to) custom manufacturing, general industry, specified research and development activities, and wholesale and distribution. (Plan § 4.8, Table 6.) 7 Ground floor active use spaces “shall provide usable spaces with a depth of at least twelve (12) feet without interior obstructions such as walls or partitions” and “shall extend to at least fifty-five percent (55%) of the length of the public street frontage.” (Plan, § 4.8.1.)
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Attorneys at Law
April 2, 2026
x Impact GHG-1: Implementation of the Plan would exceed the 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 SB 32 or the carbon neutrality goal under AB 1279. (DEIR, p. 325.)
x Impact GHG-C: Implementation of the Plan would result in a significant cumulative GHG impact. (Id.)
The DEIR includes a “Reduced Criteria Pollutant Emissions Alternative,” but that alternative would not substantially lessen or avoid the foregoing significant and unavoidable impacts. (DEIR, pp. 322-325.) That alternative, which would reduce the Plan’s proposed development by 20%, would only reduce NOx emissions to avoid exceeding that threshold of significance. (DEIR, p. 320.) All other criteria pollutants would continue to exceed the applicable thresholds of significance. (Id.) Furthermore, the “Reduced Criteria Pollutant Emissions Alternative” would only “partially” meet each of the Project objectives and will presumably be rejected by the City for that reason. (DEIR, p. 326.)
The DEIR explains that to reduce the Plan’s ROG emissions to below the significance threshold, the Plan’s development would need to be reduced by approximately 80%. (DEIR, p. 320.) Therefore, the DEIR readily dismisses that potential reduction and “instead focuses on the more achievable goal of avoiding the Plan’s significant NOx impact.” (Id.) That is not legally adequate. The DEIR must also consider an alternative with less-intensive non-residential land uses to substantially lessen or avoid the Project’s significant and unavoidable impacts due to GHG, ROG, PM10, and PM2.5 emissions.
As explained in the DEIR, the San Francisco Bay Area Air Basin is already a designated nonattainment area for federal and state air quality standards and the Bay Area Air District is focused on controlling precursor pollutants, including ROG, to reduce Ozone levels. (DEIR, p. 63.) In the Bay Area, particulate matter, including PM10, and PM2.5, is generated from activities such as combustion, factories, and motor vehicles. (Id.) Therefore, it stands to reason that less-intensive non-residential land uses would result in the reduced generation of problematic particulate matter.
Our position is supported by CEQA, the CEQA Guidelines, and related case law. To wit:
x CEQA mandates that the City must not approve a project with a significant unavoidable impact if “there are feasible alternatives . . . that can substantially lessen or avoid those effects.” (Mountain Lion Foundation v. Fish & Game Commission (1997) 16 Cal.4th 105, 1343; Public Resources Code § 21002; emphasis added.) x CEQA mandates that the EIR “shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the
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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.” (CEQA Guidelines 15126.6; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553 and Laurel Heights Improvement Association v.
Regents of the University of California (1988) 47 Cal.3d 376; emphasis added.) x As explained by the California Supreme Court: “Without meaningful analysis of alternatives in the EIR, neither the courts nor the public can fulfill their proper roles under the CEQA process.” (Laurel Heights Improvement Association v. Regents of the University of California, supra, 47 Cal.3d, 403-04.) x The DEIR fails to describe the City’s rationale for not including an alternative that would meet most of the Project objectives and substantially lessen or avoid the Project’s significant and unavoidable air quality impacts contrary to various related CEQA decisions (see, e.g., Center for Biological Diversity v. County of San Bernardino (2010) 185 Cal.App.4th 866; Watsonville Pilots Association v. City of Watsonville (2010) 183 Cal.App.4th 1059.)
An alternative with less-intensive non-residential land uses, such as self-storage, would meet most of the Project objectives identified in the DEIR by (1) celebrating and maintaining the area’s industrial legacy, (2) still introducing housing in the Plan area, (3) supporting district-wide access by providing multi-modal infrastructure, (4) addressing flooding and sea level rise, and (5) planning for net new non-residential development through development standards and a community benefits framework.
The Plan area totals 145 acres, and the Plan would result in 1,890 residential units and 4,508,000 net new square feet of non-residential uses. (DEIR, p. 10.) The fact that only two alternatives were fully evaluated in the DEIR – aside from the “no project” alternatives – is blatantly inadequate. We respectfully urge that an alternative with less-intensive non-residential land uses (such as self-storage) must also be considered, and the DEIR must be recirculated.
Regards,
Caroline G. Chase
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Allen Matkins Leck Gamble Mallory & Natsis LLP
Attorneys at Law
April 2, 2026
cc:
City Council
Albert Savay, Community and Economic Development Director Andrea Mardesich, Assistant Community Development Director Advance Planning
Todd Trekell, Development Manager, Hunter Properties
David Blackwell, Esq.
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June 08, 2026 Packet Pg. 2407
1 Date: April 6, 2026
To: Rendall Bustos, Advanced Planning Division
City of San Carlos
600 Elm Street
San Carlos, CA 94070
Subject: Greater East San Carlos (GESC) Neighborhood Board Comments on Draft Environmental Impact Report for the Northeast Area Specific Plan Dear Mr. Bustos,
These comments are regarding the Draft Environmental Impact Report (DEIR) prepared for the Northeast Area Specific Plan by the City of San Carlos. The purpose of the DEIR is to meet the standards set by the California Environmental Quality Act (CEQA) and its Guidelines, and to keep the public informed about relevant decision-making processes.
The document covers the proposed plan but lacks sufficient evidence in parts of the environmental analysis. Additional clarification and analysis are necessary to ensure compliance with CEQA.
1. Adequacy of the Project Description
CEQA requires that an EIR contain a stable, finite, and accurate project description sufficient to allow meaningful evaluation of environmental impacts and alternatives (CEQA Guidelines §15124). The project description for the Northeast Area Specific Plan appears to allow a wide range of development intensities, including substantial residential development, commercial uses, and building heights up to approximately 155 feet.
However, the DEIR does not clearly define the reasonable maximum development scenario that forms the basis of the environmental analysis. Without a clearly defined buildout scenario—including maximum residential units, commercial square footage, and infrastructure assumptions—it is difficult to determine whether the environmental analysis represents the project’s true worst-case impacts. The Final EIR should clarify the development envelope and ensure that all impact analyses reflect the maximum foreseeable development intensity.
2. Transportation and Circulation Analysis
The transportation analysis should more clearly evaluate cumulative vehicle miles traveled (VMT) impacts and potential congestion at key access points to U.S. Highway 101 and adjacent arterial roadways. Although CEQA has shifted from level-of-service
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2 metrics to VMT pursuant to SB 743, the DEIR must still adequately evaluate localized circulation constraints where safety or operational issues may arise.
Given the constrained roadway network in the northeast portion of San Carlos and the limited number of access points to the area, the DEIR should more fully analyze:
• peak-period access constraints to the highway network. • potential queuing and spillback impacts at key intersections • conflicts between truck traffic serving existing industrial uses and new residential uses.
• the effectiveness and enforceability of proposed transportation demand management (TDM) measures
• opportunity to enhance the northbound Highway 101 on ramp at Harbor with the City of Belmont and Caltrans, reducing congestion on the Holly Street overpass.
The EIR should also clarify whether mitigation measures are enforceable performance standards or merely policy recommendations.
3. Land Use Compatibility and Industrial–Residential Interface The proposed integration of residential development within an area traditionally designated for industrial and employment purposes presents potential compatibility issues. The DEIR should provide additional analysis regarding potential conflicts associated with truck circulation, noise, operational emissions, and hazardous materials associated with existing or future industrial uses.
Because the Specific Plan area has historically supported light industrial and lifescience activities, the EIR should evaluate whether future residents could create pressure to curtail lawful industrial operations. CEQA requires disclosure of such landuse conflicts where they may result in environmental effects.
4. Flooding, Sea Level Rise, and Climate Resilience
The project area’s proximity to Belmont Creek and the San Francisco Bay warrants a more detailed analysis of long-term flood risk, including projected sea-level rise scenarios. Given the long planning horizon of the Specific Plan, the DEIR should evaluate potential risks under multiple sea-level rise projections consistent with state guidance.
The EIR should also clarify:
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3 • the design standards assumed for flood protection infrastructure • long-term maintenance responsibilities for flood control improvements • potential cumulative impacts related to regional sea-level rise adaptation planning Without this information, it is difficult to determine whether proposed mitigation measures would adequately reduce potential impacts to a less-than-significant level.
5. Parks
The Draft EIR clearly states that San Carlos is not meeting the standard established in the City’s Park Master Plan of 2.5 acres of traditional parkland for every 1,000 residents.
The Plan proposes adding 1,890 residential units, but no new community park land is included. The current City Council discussion on the Northeast Plan differs from the City Park Master Plan 2026, which proposes building a new community center at Laureola Park for east side residents and recommends acquiring and improving Sequioa High School District lands near the park entrance. The current Draft EIR commits the city to no new parkland which needs to be reevaluated based on the current City Council recent recommendations and the City Park Master Plan. Where are the community benefits to the eastside community tied to development in the Northeast Plan that increases the quantity and quality of parks on the East side?
6. Significant and Unavoidable Impacts
1. Air Quality 1
Full implementation of the Plan would raise daily trips by 203% and expand the service population by 193%, causing notable increases in program-level air pollutant emissions. How will the city track and control air pollution from the combined effects of the Northeast and Eastside Innovation Plans? Air Quality 2
If fully implemented, the Plan may cause significant dust and diesel emissions unless controlled by specific regulations. The Northeast Plan is a Specific Plan. Provided the land meets the requirements specified in the Plan, it can be approved without undergoing discretionary review. Even with discretionary approvals, how will the City monitor and manage the reduction and elimination of dust and diesel emissions? No strategy is apparent.
2. Air Quality 3
If the Plan proceeds as designed, its development will lead to annual and average daily emissions of Rox and Nox exceeding the significance
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4 thresholds established by BAAQMD for projects. Because the Northeast Plan is a Specific Plan, any land use application that meets its requirements will be approved automatically, with no additional review or discretionary process.
How will the City track and control Rox and Nox emissions after granting discretionary land use approvals? No strategy is apparent.
3. Air Quality 4
If the Plan is implemented entirely, it will raise exposure to TACs and PM 2.5 emissions. Since the Northeast Plan is a Specific Plan, any land use proposal that complies with its guidelines will receive automatic approval, eliminating the need for discretionary review. Even with discretionary approvals for land use review how will the City monitor and manage TAC and PM 2.5 daily emissions? No strategy is apparent.
4. Hazards and Hazardous Materials
Please add mitigation language that the city as a policy encourages the removal of all toxics on site when redevelopment occurs, and not capping toxics in place which will result in historic and continuing adverse impacts to groundwater and the San Francisco Bay
7. Cumulative Impact Analysis
CEQA requires an EIR to analyze the cumulative effects of the project when combined with other past, present, and reasonably near future projects (CEQA Guidelines §15130). The DEIR should more clearly describe the cumulative development scenario assumed for San Carlos and surrounding communities, particularly development occurring along the U.S. 101 corridor.
For cumulative impact analysis, it is necessary to identify the projects included in the cumulative scenario and explain the methods used to assess impacts on transportation, infrastructure, and the environment within that context.
8. Alternatives Analysis
The alternatives analysis must show that the EIR thoroughly considered a reasonable selection of options, which could lessen major impacts and still fulfill most key project goals (CEQA Guidelines §15126.6). It is not clear whether the DEIR adequately evaluated alternatives would:
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5 • reduce the overall development intensity
• retain a larger portion of employment-focused land uses • modify the residential component to reduce transportation and compatibility impacts The Final EIR needs to thoroughly assess all alternatives so that both the city and the public can make well-informed decisions.
Conclusion
In summary, while the DEIR provides a useful starting point for environmental review, additional analysis and clarification are necessary to ensure compliance with CEQA and to allow meaningful public participation. The Final EIR should address the issues described above and provide substantial evidence supporting its conclusions regarding environmental impacts and mitigation effectiveness.
Thank you for the opportunity to provide comments on this important planning effort.
Sincerely,
Sam Herzberg and Jennifer Rosse, Co-Presidents
Greater East San Carlos Neighborhood Board
CC: San Carlos City Council
GESC Board Members – Scot Marsters, Dimitri Vandellos, Ben Fuller, Danny Nguyen, Max Schneider, Caroline Tudor, Jeff Maley, Daniel Zizmor, Rosario Fernandez
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April 16, 2026
Via Email: [email protected]
Rendell Bustos, Senior Planner
Community Development Department
City of San Carlos
600 Elm Street
San Carlos, CA 94070
Re: 495 Bragato LLC’ s Comments Regarding Northeast Area Specific Plan Draft Environmental Impact Report
Dear Mr. Bustos:
This firm represents 495 Bragato, LLC (“Bragato LLC”) who owns the property located at 268 Industrial Road, San Carlos, CA (“Bragato Property”). Honda San Carlos operates a Honda dealership on the Bragato Property. The Bragato Property was formerly known as 495 Bragato Road and is within the boundary of the Northeast Area Specific Plan (“Plan”). This letter sets forth Bragato LLC’s comments on the Draft Environmental Impact Report for the Northeast Area Specific Plan dated March 2026 (“DEIR”).
Although Bragato LLC supports the Northeast Area Specific Plan Project, and it appreciates the efforts of the City to develop the area, the DEIR is deficient in several ways:
1. It fails to provide an accurate project description and environmental setting. The Project Description (Section 2.4) fails to adequately describe the proposed paseo connecting Bragato Road to Industrial Road (“Bragato Paseo”), and it fails to adequately describe how the City intends to install the new road extending Bragato Road to Quarry Road (“Bragato Extension”)
2. It fails to accurately analyze the Hazardous and Hazardous Materials Impacts because it does not mention the 6-inch engineered cap that was installed on the Bragato Property under the direction of the United States Environmental Protection Agency (“U.S. EPA”).
3. The Bragato Paseo is used as a mitigation factor in the analysis of the Air, Greenhouse Gas, Land Use and Transportation impacts, but this is deficient mitigation as it relies on construction of the paseo which is virtually impossible to build.
4. It is essential that a program EIR analyze known impacts at the program level to avoid omission in future reviews and that requires consideration of the TSCA PCB Cap.
The DEIR needs to be revised to comply with CEQA.
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Letter to Rendell Bustos
April 16, 2026
10716935.DOCX
DISCUSSION
1. The Project Description is Incomplete
CEQA requires that an environmental impact report contain an accurate, stable and finite project description, and this is an indispensable prerequisite to a legally sufficient EIR. (See County of Inyo v.
City of Los Angeles (1977) 71 Cal.App.3d 185,193 and 14 CCR 15124 which incorporates this requirement.) In Inyo, the court stated that without an accurate description on which to base the EIR’s analysis, CEQA’s objective of furthering public disclosure and informed environmental decision making is stymied. In San Joaquin Raptor/Wildflife Rescue Ctr. V. County of Stanislaus (1994) 27 Cal. App. 4th 713, 720, the court said, “an accurate project description is necessary for an intelligent evaluation of the potential environmental effects of a proposed activity.” Section 2.4 of the DEIR sets forth the project description. Section 2.4 describes the Proposed Land Use and Zoning Districts (2.4.1); General Plan Text Amendments (2.4.2); Circulation Improvements (2.4.3); Parking (2.4.4); Utility Improvements (2.45); Resilience Improvements (2.4.6) Transportation Demand Management (2.4.7); and Sustainable Design Features (2.4.8).
The Circulation Improvements is most relevant to the issues impacting Bragato LLC.
Bragato Extension
Bragato Road so that it will connect to Quarry Road, thereby adding another north/south road. However, the DEIR does not explain how this new road will be constructed. The description does not explain how it will impact the existing properties surrounding the new road. There is no discussion of the dimensions of the road and required setbacks, and there is no discussion as to how the City would acquire any property necessary for the construction of the road. This new road appears to directly abut the Bragato Property.
The impacts of the construction of the road are not addressed in the DEIR. The Project Description needs to address the mechanism for how the City could install this additional road.
The Bragato Paseo
Bragato LLC purchased the Bragato Property in 2021 for use as a Honda Dealership. Bragato has worked extensively with the City of San Carlos Planning and Building Departments to build the dealership. In doing so, they have spent millions of dollars to transform a blighted industrial property into an attractive, state-of-the-art dealership that benefits the community.
The proposed Bragato Paseo as depicted in the DEIR and as described in the Plan, is a 36-footwide pedestrian walkway on the Bragato Property connecting Bragato Road to Industrial Road. This paseo would transect the Bragato property, and there is no discussion of this in the Project Description.
Although the figures depicting the paseo may not be to scale, there is nowhere on the Bragato Property where this paseo could be built.
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The DEIR contains several figures depicting the proposed Bragato Paseo, and in Section 2.4.3.2 there is a brief description of three paseos, but these descriptions do not provide enough information to allow for informed environmental decision making.
The only substantive description of the paseo is:
The Plan includes three pedestrian paseos, one along the new north-south street connecting Bragato Road to Industrial Road, one connecting the proposed Belmont Creek to Quarry Road, and one connecting Taylor Way to the Greater East Side Neighborhood to facilitate more connectivity and accessibility in the district.
The Bragato Paseo, as depicted, runs right through the Bragato Property. If the paseo is to be installed on the north end of Bragato Property, it is proposed where the newly built Honda Dealership is located. In the current configuration, the northern part of Bragato Property is an active work zone and fire lane. Cars are continually being parked and moved in this area. This area is in the back of the dealership, it is not customer-facing, and it is not safe for pedestrians or cyclists. Furthermore, directly to the north on the adjacent property there is a utility ditch with an easement.
The paseo cannot be built here. The DEIR does not adequately analyze the foreseeable environmental impacts to the existing buildings that would be affected by implementation of the Project.
The Project Description does not explain what buildings would be demolished, how the property would be acquired (eminent domain?), or the impact of the utility easement. Decisionmakers cannot properly evaluate the environmental impacts without knowing if the construction is even possible, or without knowing what would happen to existing structures. Any acquisition will cause physical changes to the environment that need to be considered in the DEIR.
In addition to the fact that there is a newly renovated Honda Dealer on the Bragato Property, there are also environmental considerations that were not described in the Project Description. The Bragato Property is impacted by a decades-old release of polychlorinated biphenyls (“PCBs”) originating from a neighboring property. The U.S. EPA required the installation of a six-inch engineered asphalt cap to contain the PCBs. U.S. EPA has exclusive jurisdiction over the regulation of PCBs. Therefore, the City has no legal authority to build the Project insofar as the Project contemplates construction in the area under U.S. EPA’s exclusive jurisdiction.
This cap was installed by Bragato LLC in 2021-2022 in accordance with the requirements of the federal Toxic Substances Control Act (“TSCA”). This cap (“TSCA Cap”) may not be breached or modified without the approval of the U.S. EPA and is subject to a forthcoming Soil Management and Operation and Maintenance Plan and Land Use Covenant that will ensure the integrity of the cap. These documents are not yet finalized, but they are critical to an understanding of how the Bragato Property may be developed.
The DEIR needs to contain a discussion of the TSCA Cap and the U.S. EPA’s oversight in the Project Description. The DEIR must be revised to fully and accurately reflect the existing environmental conditions which the Project intends to overlay so that future decisions will be based on actual conditions.
The Bragato Paseo cannot be constructed as proposed. It cannot be built where the Honda Dealership is, and it cannot be built near or on the TSCA cap. The Project Description must be revised to
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analyze these issues. Without a discussion of the real-world challenges associated with building the Project on a property with existing buildings and a TSCA Cap, the Project Description is flawed.
2. The Hazards & Hazardous Materials Impacts are Not Properly Evaluated The DEIR relies on the 2023 Cornerstone Screening Level Environmental Assessment (“EA”).
This report is three years old and does not reflect current conditions. Importantly, the EA does not describe the TSCA Cap on the Bragato Property. At the outset, we do want to acknowledge that we understand how the EA and DEIR may have missed this important part of the environmental condition of the properties. Although sites regulated by local agencies and the Regional Water Quality Control Boards are readily accessible through Geotracker, and sites regulated by the Department of Toxic Substances Control are readily accessible through Envirostor, U.S. EPA TSCA sites are not publicly accessible via a similar public website. So, missing this important issue is understandable.
Given that there was no disclosure of the TSCA Cap, unsurprisingly, there is no analysis of the TSCA Cap. Any construction over the TSCA Cap will not be permitted without approval of U.S. EPA, and any construction and plans for this area need to consider the cap and the regulatory status of the properties, the costs, and enormous delays. The general mitigation measures do not account for the PCBs and regulatory status of the TSCA cap. The public and the decisionmakers need to be informed of the huge costs and delays a PCB cap alteration would entail. It is hard to believe these challenges could be overcome.
The DEIR should be amended to include an analysis of the requirement that U.S. EPA must be consulted before any development could occur that impacts the TSCA Cap. Any penetration of the TSCA Cap will require extensive efforts to ensure that potentially contaminated soil is properly handled and disposed of and that the surrounding community is protected. The DEIR relies on the Cornerstone Report attached as Appendix D, but that report fails to discuss the actual conditions at the Bragato Property. a. Section 3.9.1.1 Regulatory Framework
the purpose of avoiding or mitigating hazardous and hazardous materials impacts from development.
Most relevant are the following:
x ESPS-5.3 Mitigate hazard exposure to and from new development projects through the environmental review process, design criteria and standards enforcement. x ESPS-5.5 Where deemed necessary, based on the history of land use, require site assessment for hazardous and toxic soil contamination prior to approving development project applications. x ESPS-5.6 Require that new development proposals are reviewed for legally required. remediation by authorities with jurisdictional authority over groundwater and surface water contamination including but not limited to San Mateo County Environmental Health, State Water Quality Control Board and the Army Corps of Engineers, where waters of the United States are involved, and collaborate with authorities to ensure all relevant remediation requirements are met.
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Table 3.9-1 of the DEIR mentions the Bragato Property and describes it as an “Open Cleanup Program Site” with soil and groundwater as the potential medium of concern. Although this is a correct characterization of the Regional Water Quality Control Board oversight, nowhere does the EIR address the six-inch thick TSCA Cap covering the PCBs that was installed by Bragato LLC as required by U.S.
EPA.
b. Section 3.9.2 Impact Discussion
The DEIR identifies the following significant Hazards and Hazardous Materials impact (HAZ-1):
Future development within the Plan could encounter and disturb contaminated soil, soil vapor, and groundwater, and result in adverse effects on construction workers, existing residents and employees, and nearby sensitive receptors.
This boilerplate does not disclosure the enormity of the problem. The DEIR says that this impact is significant without mitigation, and certain General Plan policies would reduce the impacts to less than significant. The City has no authority over the PCBs, much less authority in its General Plan to mitigate PCB impacts. The DEIR looked at the following impacts;
1) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
2) Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
3) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? 4) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
5) For a project located within 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, result in a safety hazard or excessive noise for people residing or working in the project area? 6) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
7) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
Again, this is all standard boilerplate and does not address the significant environmental risk of working with known PCBs. The DEIR identifies several General Plan policies that reduce impacts associated with contaminated soil from future development in the Plan (p. 181) It cites general policies
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and states that ESPS-5.6 requires that new development proposals are reviewed for legally required remediation by authorities with jurisdictional authority over groundwater and surface water contamination including but not limited to San Mateo County Environmental Health, State Water Quality Control Board and the Army Corps of Engineers, where waters of the United States are involved.
The DEIR acknowledges that future development of the sites listed in Table 3.9-1 could encounter and disturb soil, soil vapor, and groundwater contaminated with petroleum hydrocarbons, metals, VOCs and PCBs. The DEIR concludes that compliance with the General Plan policies listed would ensure that future development under the Plan does not create a significant hazard to the public or the environment through the disturbance of contaminated soil, soil vapor, and groundwater, and finds that there will be a less than significant impact. This is simply wrong. The General Plan does not have authority to deal with PCBs or a U.S. EPA approved remedy.
3. The Air and Greenhouse Gases Impacts are Not Properly Evaluated The DEIR evaluates the project’s impacts to air and one of the transportation measures is:
TR9 – Bicycle and Pedestrian Access and Facilities:
Encourage planning for bicycle and pedestrian facilities in local plans, e.g., general and specific plans, fund bike lanes, routes, paths and bicycle parking facilities.
The DEIR says that the Plan would be consistent with the Bicycle and Pedestrian Master Plan in part because it includes “three pedestrian paseos, one along the new north-south street connecting Bragato Road to Quarry Road, and two along Bragato Road to facilitate more connectivity and accessibility in the District.” (DEIR, p. 67) The DEIR says in Table 3.3-5, that future development under the Plan would comply with all applicable 2017 CAP control measures. Therefore, the Plan would not conflict with or obstruct the implementation of an applicable air quality plan (DEIR, p. 69).
Similarly, when evaluating the greenhouse gas impact, the DEIR looked at whether the project conflicts within applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. One of the reduction goals/applicable strategies is Strategy 12 “Active Transportation” which prioritizes bicycling and walking as safe, practical, and attractive travel options citywide, as directed by the Bicycle and Pedestrian Master Plan. (DEIR, p. 163). The DEIR finds that the Plan would include the pedestrian paseos described above and finds that future development would be consistent with the above strategies.
But because, as explained above, one of the paseos is impossible to build, a mitigation based on three completed paseos is an analytical error.
4. The Land Use and Planning Impact are Not Properly Evaluated When analyzing whether the Project would divide an established community, the DEIR says that one of the primary objectives of the Plan is to improve mobility throughout the Plan area through the creation and enhancement of connections to transit, pedestrian and bicycle facilities. The DEIR again states that the three pedestrian paseos would facilitate more connectivity and accessibility in the district.
As explained above, this is not possible and so the analysis of the connectivity and accessibility is incorrect.
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5. The Transportation Impacts are not Properly Evaluated The DEIR also relies on the paseos as potentially mitigating transportation impacts. The DEIR analyzed whether the project would conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadways, bicycle lanes, and pedestrian facilities. (DEIR, p. 272) The DEI again states the Plan would be consistent with the Bicycle and Pedestrian Master Plan and relies on the paseos.
As described in detail above, the DEIR is assuming the paseos could be built however it does not discuss the existing TSCA Cap which would prevent a paseo from being built between Bragato Road and Industrial Road. The DEIR cannot rely on paseos that cannot be built.
6. The DEIR is a Program Level and limited Project Level environmental review that must accurately describe the environmental impacts
The DEIR provides both program- and limited project-level environmental review for the Plan.
As stated in the DEIR, the DEIR will allow for streamlined environmental review of subsequent development projects consistent with the Plan and analysis in the DEIR. When individual projects or activities under the Plan are proposed, the City would examine the projects or activities to determine whether their effects were adequately analyzed in this EIR, as provided under CEQA Guidelines Sections 15168(c), 15168(d), 15182, and/or 15183.
CEQA requires that an EIR delineate the environmental conditions that exist at the time of the project to establish a baseline against which the projects’ impacts may be assessed. Cleveland National Forest Foundation v. San Diego Assn. of Governments (2017) 17 Cal. App. 5th 413, 440. If the description of the environmental setting is incomplete or inadequate, the EIR is legally inadequate as it fails to comply with Code Regs., tit. 14, § 15125(a). Cleveland ; Cadiz Land Co. v. Rail Cycle (2000) 83 Cal. App. 4th 74.
If a program EIR fails to address known environmental conditions, impacts related to those conditions may escape analysis in subsequent, project specific environmental reviews. For that reason, CEQA requires that known impacts must be analyzed at the program level to avoid omission in future reviews. (See Cleveland at 440 where the court stated that unaddressed impacts in a program EIR could evade scrutiny in later-tiered EIRs undermining CEQA’s objectives.) Because the environmental setting normally supplies the baseline for significance determinations, a program EIR that does not fully address site condition risks fails to establish the baseline against which impacts are described and quantified. Cleveland, supra. Where the environmental setting is inaccurate, incomplete, or misleading, an EIR does not comply with CEQA and cannot be found to have adequately investigated and discussed environmental impacts. Cadiz at 87.
For these reasons, it is especially important that the DEIR adequately address the environmental conditions at the site.
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CONCLUSION
We respectfully request, as a CEQA matter, that the City revise the DEIR, respond to our comments in the administrative record, and ensure CEQA compliance before approving the final EIR.
More importantly, it is clear the drafters were not aware of the environmental regulatory challenges involved in proposing a paseo through a federally regulatory PCB capped site. The concept of the Bragato Paseo should be abandoned.
Please contact me if you have any questions.
Very truly yours,
_______________________________
Laurie Berger
SILICON VALLEY LAW GROUP
A Law Corporation
Cc:
Planning Commissioner Twisha Anand ([email protected]) Planning Commissioner Summer Bundy ([email protected]) Planning Commissioner Kristen Clements ([email protected]) Planning Commissioner Frank Kenniasty ([email protected]) Planning Commissioner Jorge Tapias ([email protected]) Mayor Pranita Venkatesh ([email protected]) Vice Mayor Adam Rak ([email protected])
Council Member John Dugan ([email protected])
Council Member Neil Layton ([email protected]) Council Member Sara McDowell ([email protected]) Al Savay, Community & Economic Development Director)
Andrey Kamenetsky, Putnam Automotive Dealership Group
Kent Putnam, Putnam Automotive Dealership Group
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1 EXHIBIT C: FINDINGS OF FACT
Findings Regarding Significant Impacts
Pursuant to Public Resources Code Section 21081 and California Environmental Quality Act (CEQA) Guidelines Section 15091, the City of San Carlos hereby makes these findings with respect to the potential for significant environmental impacts from approval and implementation of the proposed Northeast Area Specific Plan (“Plan” or "proposed project") and the means for mitigating those impacts many of which tier off of the 2045 General Plan Reset Environmental Impact Report (certified on May 25, 2025), which considered buildout projections from the Northeast Area Specific Plan. For the purpose of these findings, the term “Environmental Impact Report” (EIR) refers to the Draft EIR and Final EIR documents collectively, unless otherwise specified.
These findings do not attempt to describe the full analysis of each environmental impact contained in the EIR. Instead, the findings provide a summary description of each impact, describe the applicable mitigation measures identified in the EIR and adopted by the City, and state the findings on the significance of each impact after imposition of the adopted mitigation measures. A full explanation of these environmental findings and conclusions can be found in the EIR. These findings hereby incorporate by reference the discussion and analysis in the EIR that support the EIR’s determinations regarding significant project impacts and mitigation measures designed to address those impacts. The facts supporting these findings are found in the record as a whole for the project.
In making these findings, the City ratifies, adopts, and incorporates into these findings the analysis and explanation in the EIR, and ratifies, adopts, and incorporates into these findings the determinations and conclusions of the EIR relating to environmental impacts and mitigation measures, except to the extent that any such determinations and conclusions are specifically and expressly modified by these findings. As shown below, the following impacts would have a significant and unavoidable impact.
AIR QUALITY
Impact AIR-1: Buildout of the Plan would increase daily trips by 203 percent, and increase the service population by 193 percent. Since the rate of increase in population would be exceeded by the rate of increase in daily trips, the Plan would have a significant criteria air pollutant emissions impact.
Finding: Pursuant to the plan-level thresholds of significance for criteria air pollutant emissions and their precursors shown in Table 3.3-2 of the Draft EIR, plans that would increase vehicle miles traveled (VMT) at a rate that would exceed the rate of population increase, are considered to have a significant and unavoidable criteria air pollutant emissions impact. As shown in Table 3.3-6 of the Draft EIR, the number of daily trips in the Plan would increase by 203 percent whereas the population (employees plus residents) would increase by 193 percent. The rate of traffic growth would increase at a rate that would exceed the rate of population increase.
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2 Rationale for Finding: As discussed in Section 3.17 Transportation in the Draft EIR, the Plan is located in a transit priority area (TPA) and therefore, future development projects would result in a less than significant VMT impact. Therefore, the project would not contribute to a significant cumulative VMT impact. Further, all new development in the Plan, with certain exceptions, would be subject to Transportation Demand Management (TDM) requirements. Consistent with C/CAG’s TDM Policy, it is assumed that all new development, with noted exceptions, would achieve a minimum 25 percent vehicle trip reduction (this reduction is assumed in the 203 percent rate of trip growth). However, large projects must achieve up to a 35 percent vehicle trip reduction. While the Plan includes measures to reduce trips, the Plan’s rate of traffic growth (assuming the minimum 25 percent trip reduction) would increase at a rate that would exceed the rate of population increase. Given the programmatic nature of the Plan, there is no mitigation that would reduce this impact.
Resulting Significance: Significant and Unavoidable
Impact AIR-3: Buildout of the Plan would result in annual and average daily emissions of reactive organic gases (ROG) and nitrogen oxides (NOx) associated with operation of the Plan that would exceed the Bay Area Air District project-level significance thresholds.
Finding: As shown in Table 3.3-7 of the Draft EIR, annual and average daily emissions of ROG and NOx associated with operation of the Plan area would exceed the Bay Area Air District project-level significance thresholds. The 2045 General Plan Reset EIR concluded that implementation of Mitigation Measure AQ-2.2 would reduce air pollutant emissions to the extent practicable. However, due to the programmatic nature of the General Plan Reset EIR, the impact was found to be significant and unavoidable.
Rationale for Finding: Operational air emissions from the project would be generated primarily from autos driven by future residents and employees. Evaporative emissions from architectural coatings and maintenance products (classified as consumer products) are typical ROG emissions from these types of land uses. Table 3.3-7 of the Draft EIR reports the predicted emissions from complete buildout of the Plan in terms of annual emissions in tons and average daily operational emissions, assuming 365 days of operation per year. Net emissions between the Plan and existing uses are also shown.
As shown in this Table, annual and average daily emissions of ROG and NOx associated with operation of the Plan Area would exceed the Bay Area Air District project-level significance thresholds.
Resulting Significance: Significant and Unavoidable
Impact AIR-C: Buildout of the Plan would result in a cumulatively considerable net increase of criteria pollutant emissions.
Finding: Buildout of the Plan would contribute to a significant cumulative impact with respect to air quality.
Rationale for Finding: The geographic area for cumulative air quality impacts is the San Francisco Bay Area Air Basin. Past, present, and future development projects contribute to the region’s adverse air quality impacts. No single project is sufficient in
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3 size, by itself, to result in non-attainment of ambient air quality standards. Instead, a project’s individual emissions contribute to existing cumulatively significant adverse air quality impacts.
Resulting Significance: Significant and Unavoidable
GREENHOUSE GAS (GHG) EMISSIONS
Impact GHG-1: Implementation of the Plan would exceed the 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 SB 32 or the carbon neutrality goal under AB 1279.
Finding: Consistent with the 2045 General Plan Reset EIR, development under the Plan would exceed the 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 SB 32 or the carbon neutrality goal under AB 1279.
Rationale for Finding: The 2045 General Plan Reset EIR committed the City to implement the following mitigation measure. The General Plan Reset EIR concluded that implementation of Mitigation Measure GHG-1 would ensure that the City prepares a Climate Mitigation and Adaptation Plan (CMAP) update to achieve the long-term year 2045 GHG reduction goal and State's carbon neutrality goal set by AB 1279. However, it is unknown at this time whether targets contained in the future CMAP update will be achieved and therefore GHG emissions are considered significant and unavoidable.
Resulting Significance: Significant and Unavoidable
Impact GHG-C: Implementation of the Plan would result in a significant cumulative GHG impact.
Finding: Buildout of the Plan would contribute to a significant cumulative impact with respect to GHG emissions.
Rationale for Finding: Because GHG emissions have a broader global impact, if a project would result in a significant project-level GHG impact, it would also result in a significant cumulative GHG impact. Because the Plan would have a significant GHG emissions impact. Under Impact GHG-1, the project would result in a cumulatively considerable contribution to a significant cumulative GHG emissions impact.
Resulting Significance: Significant and Unavoidable
Findings Regarding Project Alternatives
The CEQA Guidelines require that an EIR describe a reasonable range of alternatives that would feasibly attain most of the basic project objectives but would avoid or substantially lessen any of the significant environmental effects of the project, and then evaluate the comparative merits of such alternatives (CEQA Guidelines Section 15126(a)). For the purpose of these findings, the term “EIR” refers to the Draft EIR and Final EIR documents collectively, unless otherwise specified.
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4 SIGNIFICANT IMPACTS
Based on the analyses in Section 7 Alternatives of the Draft EIR, the City has determined that the proposed project’s potentially significant environmental effects may not be avoidable or reduced to less-than-significant levels through implementation of the mitigation measures described in the EIR.
ALTERNATIVES CONSIDERED
Through the environmental review process, the City identified four potential project alternatives for consideration. The following alternatives are evaluated in Section 7, Alternatives, of the EIR:
▪ No Project, No New Development Alternative. Under the No Project/No New Development Alternative, the Plan area would remain as it is today (i.e., 2,617,497 square feet of light industrial, office, and institutional uses). Because the No Project, No New Development Alternative would not result in changes to existing conditions, this alternative would avoid all of the significant environmental impacts of the Plan. However, under this alternative, the beneficial environmental resiliency standards that would be required under the Plan would not be implemented. For example, the existing setbacks to Belmont Creek would remain as they currently are, while the Plan would increase the setback from Belmont Creek for properties undergoing redevelopment adjacent to Belmont Creek to 35 feet from top of bank. Further, since no redevelopment would occur under this alternative, new publicly accessible open space would not be established. The No Project, No New Development Alternative would be environmentally superior but not meet any of the project’s objectives.
▪ No Project, Existing Plans Alternative. The No Project, Existing Plans Alternative, assumes what would be reasonably expected to occur in the foreseeable future if the Plan were not approved, based on current plans, i.e. the existing adopted General Plan. Under this alternative, it is assumed that the Plan area would be redeveloped with up to 874,000 square feet of net new non-residential uses. This alternative would not introduce new housing within the Plan area and, as a result, would not fulfill the Plan’s objective of accommodating future population growth in the City or meeting housing needs identified through future Housing Element cycles. The No Project, Existing Plans Alternative would lessen some of the environmental impacts of the Plan. However, this alternative would not accomplish most of the Plan’s objectives. Similar to the No Project, No New Development Alternative, this alternative would also not accomplish any of the Plan’s environmental benefits (i.e., enhanced creek setbacks and flooding improvements). ▪ Reduced Criteria Pollutant Emissions Alternative. The Reduced Criteria Pollutant Emissions Alternative would reduce NOx emissions by 20 percent in order to reduce emissions below the threshold of 10 tons per year. In order to achieve this level of reduction in emissions, the Plan’s development would need to be reduced by an equivalent of 20 percent. Assuming that both the residential and non-residential development included in the Plan were reduced by 20 percent, this equates to a Plan that would allow up to 3,606,400 square feet of non-residential building area and 1,512 residential units. To reduce the Plan’s ROG emissions below the threshold of 10 tons per year would require an approximately 80 per reduction in the amount of new development, and therefore this alternative instead focuses on the more achievable goal of avoiding the Plan’s significant NOx impact. The Reduced Criteria Pollutant Emissions Alternative would reduce the Plan’s significant NOx
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5 emissions disclosed in Impact AIR-3 to less than significant, however, the Plan’s ROG emissions, while reduced, would remain significant and unavoidable. All other environmental impacts under this alternative would be similar or less than the proposed Plan. ▪ Enhanced TDM Alternative. The purpose of the Enhanced TDM Alternative is to further reduce daily trips in the Plan by an additional five percent (i.e. increasing from 25 percent to 30 percent) in order to match the rate of population growth. Having the rate of VMT growth match the rate of service population growth would lead the Plan to comply with the Air District Plan-level threshold, thereby reducing the Plan’s significant and unavoidable criteria air pollutant emissions impacts (Impact AIR-1). As discussed in Section 2.3.6 Transportation Demand Management of the EIR, all new development in the Plan would be subject to TDM requirements that would achieve a 25 percent vehicle trip reduction. Under this alternative, future development would need to achieve an additional five percent reduction of daily vehicle trips, for a total reduction of 30 percent in vehicle trips. This alternative assumes that the Plan would be redeveloped with the same amount of development as proposed by the Plan, i.e. up to 4,508,000 square feet of non-residential and up to 1,890 residential units.
The Enhanced TDM Alternative would reduce Impact AIR-1 to less than significant. All other environmental impacts under this alternative would be similar to the proposed Plan.
However, the feasibility of future development under the Plan being able to achieve a 30 percent trip reduction is unknown.
The primary purpose of an EIR’s alternative analysis is to identify and evaluate possible alternatives to the proposed project that can avoid or substantially lessen the project’s significant environmental effects while still achieving the basic objectives of the project. The City has developed the following project objectives:
▪ Celebrate and maintain the area’s industrial legacy by continuing to allow for light industrial, research and development, including offices, in a way that supports both existing and new businesses within the overall district and supports economic development and fiscal stability. ▪ Introduce housing in the district to balance the needs of living wage jobs, while accommodating future population growth in San Carlos to meet housing needs as part of future Housing Element cycles.
▪ Support district wide access for all users, employees – future residents – and visitors alike, by providing multi-modal infrastructure that supports walkability, bikeability, public transportation, and vehicular transportation.
▪ Address flooding and sea level rise through a robust resilience framework including improvements to Belmont Creek and green stormwater infrastructure. ▪ Plan for the anticipated 4.5 million square feet of net new non-residential development through development standards and a community benefits framework that leverages public open space, street and trail improvements, and financial contributions that deliver tangible amenities that serve the district and broader community.
ENVIRONMENTALLY SUPERIOR ALTERNATIVE
The environmentally superior alternative is the alternative that would be expected to generate fewer significant impacts. In addition to the discussion and comparison of impacts of the project and the alternatives, Section 15126.6 of the CEQA Guidelines requires that an “environmentally superior” alternative be identified. Identification of the environmentally superior alternative is an
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6 informational procedure and the alternative identified may not be the alternative that best meets the goals or needs of the City of San Carlos.
The environmentally superior alternative would be the No Project, No New Development Alternative. This Alternative would avoid all the environmental impacts of the Plan. However, this alternative would not accomplish any of the Plan’s environmental benefits nor would it meet any of the Plan’s objectives.
FINDINGS REGARDING ALTERNATIVES
As further set forth below, the City has considered the possible alternatives identified and analyzed in the EIR and has elected to approve the proposed project described in Section 2, Project Information and Description, of the Draft EIR. Only one alternative would meet all the project objectives, however, the City finds that all alternatives would be infeasible for specific economic, social, or other considerations pursuant to CEQA Sections 21002 and 21081(a)(3), and CEQA Guidelines Section 15091(a)(3). Based on the evaluation and analysis of project alternatives set forth in Chapter 7 of the Draft EIR, and on the entire record of proceedings for the proposed project, the City hereby makes the following findings:
▪ No Project, Existing Plans Alternative. The City considered a No Project, Existing Plans Alternative and declines to adopt it because it is inconsistent with the project objectives.
Under the No Project, Existing Plans Alternative, the proposed project would not be implemented. This Alternative would not allow transformation of the existing industrial neighborhood into a modern, mixed-use neighborhood that advances the life sciences and biotechnology sectors as contemplated in the proposed project. This Alternative also would not allow development of housing that would further capacity to accommodate the City’s Regional Housing Needs Allocation into the future. Lastly, the intended benefits of the proposed project including new streetscape designs, pedestrian improvements, and open space enhancements would not be realized. For these reasons, this alternative is infeasible as it fails to meet any of the project’s objectives, as supported by the administrative record for the proposed project.
▪ Reduced Criteria Pollutant Emissions Alternative. The City considered a Reduced Criteria Pollutant Emissions Alternative and declines to adopt it because it is inconsistent with the project objectives. The Alternative would reduce the project’s significant NOx emissions disclosed in Impact AIR-3 to less than significant, however, the Plan’s ROG emissions, while reduced, would remain significant and unavoidable. All other environmental impacts under this alternative would be similar to the proposed project, while project objectives would be largely achieved, although with 20% less development, not to the extent as the proposed project. The intended benefits of the proposed project would also be proportionally reduced due to the reduced development. For these reasons, this Alternative is infeasible as it only partially meets the project’s objectives, as supported by the administrative record for the proposed project.
▪ Enhanced TDM Alternative. The City considered a Enhanced TDM Alternative and declines to adopt it because it is inconsistent with the project objectives. This Alternative would reduce Impact AIR-1 to less than significant. All other environmental impacts under this alternative would be similar to the proposed project. However, the feasibility of all future development under the Plan being able to achieve a 30 percent trip reduction is unknown.
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7 Given this uncertainty, this Alternative is infeasible while it may meet the project’s objectives, as supported by the administrative record for the proposed project.
10.b
June 08, 2026 Packet Pg. 2427
MITIGATION MONITORING AND REPORTING PROGRAM
Northeast Area Specific Plan
SCH # 2024070063
May 2026
10.b
June 08, 2026 Packet Pg. 2428
Page | 1
PREFACE
Section 21081.6 of the California Environmental Quality Act (CEQA) requires a Lead Agency to adopt a Mitigation Monitoring and Reporting Program (MMRP) whenever it approves a project for which measures have been required to mitigate or avoid significant effects on the environment.
The purpose of the monitoring and reporting program is to ensure compliance with the mitigation measures during project implementation.
The Environmental Impact Report (EIR) completed for the Northeast Area Specific Plan concluded that the implementation of the Plan could result in significant effects on the environment and mitigation measures were incorporated into the proposed Plan or are required as a condition of approval of future development projects implementing the Plan. This MMRP addresses those measures in terms of how and when they will be implemented by future development projects.
This document does not discuss those subjects for which the EIR concluded that the impacts from implementation of the project would be less than significant.
10.b
June 08, 2026 Packet Pg. 2429
Page | 2
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
AIR QUALITY
Impact AIR-1: Buildout of the Plan would increase daily trips by 203 percent, and increase the service population by 193 percent. Since the rate of increase in population would be exceeded by the rate of increase in daily trips, the Plan would have a significant program-level criteria air pollutant emissions impact General Plan Policies to Reduce Criteria Air
Pollutant Emissions
The following General Plan goals and policies
would serve to minimize potential adverse
impacts related to these long-term, regional
criteria air pollutant emissions:
• Policy CSH-2.3: Access to public
transportation facilities should be
convenient and designed to encourage use
of public transit.
• Policy CSH-3.3: Support the
incorporation of Transportation Demand
Measures in new development to reduce
traffic impacts.
• 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
Applicants shall
implement applicable
General Plan Policies.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Verify
implementation of
applicable policies
as part of the
project-level
CEQA analysis.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2430
Page | 3
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
• Policy EM-11.4: Provide an integrated
network of bicycle and pedestrian
thoroughfares that connects jobs and
housing to other city destinations, as
recommended in the San Carlos Bicycle
and Pedestrian Master Plan.
• Policy EM-11.6: Encourage employers to
incentivize employee use of mass transit
and alternative modes of transportation.
• Policy EM-11.9: Coordinate with major
employers, neighboring municipalities,
transit agencies and providers to enhance
regional transit and shuttle service.
Impact AIR-2: Future construction under the Plan, if uncontrolled, could result in temporary dust and diesel exhaust impact to nearby receptors or exceed acceptable levels for projects. In addition, NOx emissions during grading and soil import/export for large projects may exceed the Bay Area Air District NOx emission thresholds for projects.
General Plan Mitigation Measures
Mitigation Measure AQ-2.1: Prior to
discretionary approval by the City for
development projects subject to CEQA, review
(i.e., discretionary, nonexempt projects), future
project applicants shall prepare and submit a
technical assessment evaluating potential project
construction-related air quality impacts to the City
for review and approval. The evaluation shall be
Project applicant shall
prepare and submit a
technical assessment
evaluating potential
project constructionrelated air quality impacts
to the City for review and
approval. If emissions
exceed thresholds,
applicant shall implement
At the time of
project-level
CEQA and prior
to discretionary
permit approval.
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve the
construction air
quality technical
assessment.
Ensure mitigation
measures are
incorporated into
project as
recommended
At the time of
project-level
CEQA and
prior to
discretionary
permit
approval.
10.b
June 08, 2026 Packet Pg. 2431
Page | 4
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
prepared in conformance with current BAAQMD
methodology for assessing air quality impacts
identified in BAAQMD’s CEQA Air Quality
Guidelines. If construction-related criteria air
pollutants are determined to have the potential to
exceed the BAAQMD-adopted thresholds of
significance, the City shall require feasible
mitigation measures to reduce air quality
emissions. Measures shall require implementation
of current BAAQMD Best Management Practices
for construction-related fugitive dust emissions.
measures to reduce
emissions below
applicable BAAQMD
construction thresholds.
within the
technical
assessment.
Impact AIR-3: Buildout of the Plan would result in annual and average daily emissions of ROG and NOx associated with operation of the Plan Area would exceed the Bay Area Air District project-level significance thresholds.
General Plan Mitigation Measures
Mitigation Measure AQ-2.2: Prior to
discretionary approval by the City for
development projects subject to California
Environmental Quality Act (CEQA) review (i.e.,
nonexempt projects), future project applicants
shall prepare and submit a technical assessment
evaluating potential project operational air quality
impacts to the City for review and approval. The
evaluation shall be prepared in conformance with
Air District methodology in assessing air quality
impacts identified in the Air District’s current
Project applicant shall
submit a technical
assessment and
incorporate mitigation
measures to reduce
operational emissions
below thresholds.
At the time of
project-level
CEQA and prior
to discretionary
permit approval.
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve the
operation air
quality technical
assessment.
Ensure mitigation
measures are
incorporated into
project as
recommended
within the
technical
assessment.
At the time of
project-level
CEQA and
prior to
discretionary
permit
approval.
10.b
June 08, 2026 Packet Pg. 2432
Page | 5
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
CEQA Air Quality Guidelines at the time that the
project is considered.
If operation-related air pollutants are determined
to have the potential to exceed the Districtadopted thresholds of significance, the City shall require the project applicant(s) to incorporate
mitigation measures to reduce air pollutant
emissions to comply with applicable significance
threshold standards during operational activities.
The identified measures shall be included as part
of the conditions of approval or a mitigation
monitoring and reporting plan adopted for the
project as part of the project CEQA review.
Possible mitigation measures to reduce long-term
emissions could include, but are not limited to the
following:
o Implementing commute trip reduction
programs.
o Unbundling residential parking costs from
property costs.
o Expanding bikeway networks.
o Expanding transit network coverage or
hours.
o Using cleaner-fueled vehicles.
o Exceeding the current Title 24 Building
Envelope Energy Efficiency Standards.
10.b
June 08, 2026 Packet Pg. 2433
Page | 6
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
o Establishing on-site renewable energy
generation systems.
o Requiring all-electric buildings.
o Replacing gas-powered landscaping
equipment with zero-emission
alternatives.
o Implementing organics diversion
programs.
o Expanding urban tree planting.
Impact AIR-4: Implementation of the Plan could result in uses that would result in significant exposures of TACs and PM2.5.
Health Risk Project Requirements
Projects within 1,000 feet of existing sensitive
receptors or worker receptors as defined by the
Bay Area Air District (e.g., residential, schools)
shall submit a site-specific construction and
operational health risk assessment (HRA) prior to
planning application approval. If the HRA
demonstrates, to the satisfaction of the City, that
the health risk exposures for adjacent receptors
will be less than Bay Area Air District projectlevel thresholds, then additional mitigation would be unnecessary. However, if the HRA
demonstrates that health risks would exceed the
Bay Area Air District project level thresholds,
additional feasible on- and off-site mitigation
Applicants shall submit a
site-specific construction
and operational health risk
assessment (HRA). If the
HRA demonstrates that
health risks would exceed
the Bay Area Air District
project level thresholds,
additional feasible on- and
off-site mitigation shall be
incorporated.
At the time of
project-level
CEQA and prior
to discretionary
permit approval.
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve the
HRA. Ensure
mitigation
measures are
incorporated into
project if
recommended
within the HRA.
At the time of
project-level
CEQA and
prior to
discretionary
permit.
10.b
June 08, 2026 Packet Pg. 2434
Page | 7
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
shall be incorporated to further reduce risks to the
greatest extent practicable and to the satisfaction
of the City.
BIOLOGICAL RESOURCES
Impact BIO-1: Future construction activities associated with build out under the Plan could result in the loss of fertile eggs, nesting raptors or other migratory birds, or nest abandonment.
Migratory Bird Requirements
• Avoid Nesting-Season Construction if
Feasible. To the extent feasible,
demolition and construction activities for
sites containing trees shall be scheduled
to avoid the nesting season. The nesting
season for most birds in San Mateo
County extends from February 1 through
August 31, inclusive. If construction
activities are scheduled to take place
outside the nesting season, all impacts to
nesting birds protected under the
Migratory Bird Treaty Act (MBTA) and
California Fish and Game Code would be
avoided.
Schedule demolition and
habitat removal between
September 1st and
January 31st of any given
year. Applicant shall
include a note on the
grading or demolition
plan (whichever is first)
stating such.
Outside the
nesting bird
season
(September 1st
through February
1 st).
City of San Carlos
Building Division
and Planning
Division.
Confirm the
grading or
demolition plan
includes a note
that construction
activities are
scheduled outside
of the nesting
season. If
construction starts
during nesting
season, surveys
are required.
Prior to
issuance of the
grading or
demolition
permit
(whichever is
first).
• Conduct Pre-activity Survey for Active
Nests. If it is not possible to schedule
Submit a report by a
qualified biologist
Surveys shall be
conducted no
City of San Carlos
Building Division
Receive, review,
and approve the
Prior to tree
removal, or
10.b
June 08, 2026 Packet Pg. 2435
Page | 8
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
construction activities and/or tree removal
between September 1 and January 31,
preconstruction surveys for nesting birds
shall be conducted by a qualified biologist
to ensure that no nests shall be disturbed
during project implementation. These
surveys shall be conducted no more than
seven days prior to the initiation of
demolition or construction activities,
including tree removal and pruning.
During this survey, the biologist shall
inspect all trees and other potential
nesting habitats (e.g., trees, shrubs,
ruderal grasslands, buildings) in and
immediately adjacent to the impact areas
for nests. Prior to any tree removal, or
approval of any grading or demolition
permits (whichever occurs first), the
biologist shall submit a report indicating
the results of the survey and any
designated buffer zones to the satisfaction
of the City’s Planning Division.
indicating the results of
the pre- activity surveys
and any designated buffer
zones to the City’s
Planning Division.
more than seven
days prior to the
initiation of
demolition or
construction
activities,
including tree
removal and
pruning, and
submitted prior to
any tree removal,
or approval of any
grading or
demolition
permits
(whichever occurs
first).
and Planning
Division.
pre-activity
nesting bird
survey report.
issuance of
grading or
demolition
permit.
• Provide a Buffer around Active Nests.
If an active nest (i.e., a nest with eggs or
young) is found sufficiently close to work
areas to be disturbed by these activities,
Submit a report indicating
designated buffer zones to
the City’s Planning
Division Director.
Prior to tree
removal, or
issuance of
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve the
designated buffer
zone report.
Prior to tree
removal, or
issuance of
grading or
10.b
June 08, 2026 Packet Pg. 2436
Page | 9
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
the biologist shall determine the extent of
a construction-free buffer zone to be
established around the nest (typically 300
feet for raptors and 100 feet for other
species), to ensure that no nests of species
protected by the MBTA and California
Fish and Game Code shall be disturbed
during project implementation.
grading or
demolition permit.
demolition
permit.
Impact BIO-2: Future demolition activities under the Plan could result in direct physical disturbance of any roosting bats that may be present, possibly resulting in injury or mortality, as well as the loss of roosting sites.
Roosting Bat Requirements
Consistent with General Plan Policy EM-1.2, if
buildings identified shown as “Currently Suitable”
and buildings identified as “Potentially Suitable if
Building is Unoccupied” on Figure 3.4-2 are
proposed to be demolished or remodeled, the
following Specific Plan Project Requirements
pertaining to special-status roosting bats shall be
implemented. Remodels could also result in such
impacts if they affect areas where bats are present
or if they block ingress or egress to roost sites.
Remodels most likely to affect bats are those that
physically alter the exteriors (including exterior
walls), roofs, and attic-like spaces of buildings or
Applicant shall submit a
pre-activity habitat
assessment and survey for
roosting bats conducted
by a qualified biologist.
The report shall indicate
the results of the survey
and avoidance
requirements, if bats are
present.
Prior to any
demolition or
building permits
(whichever occurs
first).
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve the
report indicating
the results of the
survey and
avoidance
requirements.
Prior to
approval of
any demolition
or building
permits
(whichever
occurs first).
10.b
June 08, 2026 Packet Pg. 2437
Page | 10
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
that plug holes, cavities, or crevices that allow
bats to enter or exit buildings supporting bats.
• Conduct Pre-Activity Surveys for
Roosting Bats. A pre-activity habitat
assessment and survey for roosting bats
shall be conducted prior to removal or
renovation of buildings. The habitat
assessment and survey shall be conducted
by a qualified biologist. If the biologist
determines that a building provides no
suitable bat roost sites, no bat survey
would be necessary, but if suitable roost
sites exist, a visual survey shall be
conducted during the daytime to
determine whether bats are present.
During this survey, the biologist shall
look for bats and evidence of their
presence (e.g., guano or urine staining). If
the visual survey cannot adequately
determine whether bats are present, a
dusk survey shall be conducted during
suitable weather conditions for bat
activity to determine whether bats enter or
exit the roost. If no active roosts are
found, then no further action is warranted.
If a roost is present, a qualified biologist
10.b
June 08, 2026 Packet Pg. 2438
Page | 11
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
shall determine the species and number of
individuals present and implement further
measures as described below. Prior to any
tree removal, or approval of any grading
or demolition permits (whichever occurs
first), the biologist shall submit a report
indicating the results of the survey and
avoidance requirements to the City’s
Planning Manager.
• Avoid Disturbance of Active Roosts. If an
occupied roost is found in a structure that
would be disturbed or removed by
proposed activities, the project may be
redesigned to avoid the disturbance of the
structure. If the roost is unoccupied at the
time of the survey, the project proponent
may have a qualified biologist install bat
exclusion devices to prevent bats from
taking up occupancy of the structure prior
to the onset of the proposed activity. If
avoidance is not feasible, the following
measures shall be implemented.
• Avoid Disturbance of Maternity Roosts.
If an active maternity roost is present
within the building to be demolished or
10.b
June 08, 2026 Packet Pg. 2439
Page | 12
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
disturbed and the project cannot be
redesigned to avoid removal or
disturbance of the occupied roost,
disturbance shall not take place during the
maternity season (as determined by the
qualified biologist, but approximately
April 1 to August 31), and an appropriate
disturbance-free buffer zone (also
determined by the qualified biologist)
shall be observed during this period to
avoid disturbing the roosting bats.
Following the maternity season, bats can
be excluded as described below.
• Exclude Bats Prior to Disturbance. If
disturbance of an active non-breeding
roost cannot be avoided, the individuals
shall be safely evicted outside the
maternity season (as determined by the
qualified biologist) between
approximately September 1 and April 1.
Exclusion methods may include the
installation of one-way doors, use of
ultrasonic deterrence devices, changing
air flow and temperature regimes in the
roost space, or other methods that would
not trap bats or involve handling bats.
10.b
June 08, 2026 Packet Pg. 2440
Page | 13
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
One-way doors and/or deterrence devices
should be left in place for a minimum of
two weeks with a minimum of five fairweather nights with no rainfall and temperatures no colder than 50°F.
Impact BIO-3: Future development under the Plan would introduce new sources of artificial lighting that could impact wildlife.
Artificial Lighting Requirements
• The following measures will be
implemented during any renovation or
redevelopment under the Plan adjacent to
Belmont Creek and other areas mapped as
riparian, freshwater marsh, and aquatic
riverine as shown on Figure 3.4-1 that
involves new outdoor lighting or
replacement of existing lighting with
fixtures or luminaires that are not
identical in intensity, wavelength, and
directionality to those being replaced.
o Through a combination of proper
fixture selection, low mounting
height, glare shielding, and
orientation/aiming of light fixtures,
the design team shall actively control
undesirable spill of light toward
sensitive habitat areas (i.e., Belmont
Applicant shall submit
design plans that
implement all measures
listed under “Artificial
Light Project
Requirements” to the City
of San Carlos Community
Development Department.
At the time of
project-level
CEQA and prior
to issuance of a
planning permit.
City of San Carlos
Building Division
and Planning
Division.
Confirm design
plans incorporate
appropriate
lighting to satisfy
the requirements.
At the time of
project-level
CEQA and
prior to
issuance of a
planning
permit.
10.b
June 08, 2026 Packet Pg. 2441
Page | 14
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
Creek, other drainage channels and
associated wetland and riparian
habitat, or vegetated open space
areas). All exterior lighting shall be
fully shielded to block illumination
from shining outward toward such
sensitive habitat areas and to prevent
the lit portions of these fixtures (i.e.,
the lamps) from being directed
toward the sensitive habitat areas.
o Outdoor lighting fixtures shall
incorporate lamps with a Correlated
Color Temperature of 2700 Kelvin or
less.
o Up-lighting shall be avoided, all
fixtures shall have a backlight,
uplight, and glare (BUG) up-light
rating of U0, and the maximum
vertical illuminance at any point in
the plane of the property line will be
0.05 footcandle, unless the following
conditions are met:
▪ All up-light is directed at
building facades such that no
light spills upwards past a
structure (e.g., into the sky)
10.b
June 08, 2026 Packet Pg. 2442
Page | 15
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
or outwards into adjacent
areas.
▪ The fixture is programmed to
switch off between 10:00
p.m. and sunrise.
Impact BIO-4: Future development under the Plan could result in bird collisions, causing injury or death.
General Plan Policies that Reduce Impacts
from Bird Collisions
In accordance with General Plan Action EM-1.5,
future developments would be required to
minimize the potential risk of bird collisions
through the use of the latest bird-safe design
guidelines and best management practices.
• Action EM-1.5: Require that new
buildings and taller structures that extend
above the existing surrounding urban
fabric and height of the tree canopy be
designed to minimize the potential risk of
bird collisions using input from the latest
bird-safe design guidelines and best
management practice strategies to reduce
bird strikes.
The project plans shall
incorporate the latest birdsafe design guidelines and
best management practice
strategies to reduce bird
strikes, to be submitted to
the City of San Carlos
Community Development
Department.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve
design plans.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2443
Page | 16
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
Bird safe-design measures and best management
practices may include:
• Avoid the use of highly reflective glass as
an exterior treatment, which appears to
reproduce natural habitat and can be
attractive to some birds,
• Limit reflectivity and prevent exterior
glass from attracting birds in building
plans by utilizing low-reflectivity glass
and providing other non-attractive surface
treatments,
• Use low-reflectivity glass or other glazing
treatments for the entirety of the
building’s glass surface, not just the lower
levels,
• For commercial buildings, interior light
“pollution” should be reduced during
evening hours through the use of a
lighting control system,
• Exterior lighting should be directed
downward and screened to minimize
illuminating the exterior of the building at
night, except as needed for safety and
security,
10.b
June 08, 2026 Packet Pg. 2444
Page | 17
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
• Glass skyways or walkways, freestanding
glass walls, and transparent building
corners should not be allowed,
• Transparent glass should not be allowed
at the rooflines of buildings, including in
conjunction with green roofs, and
• All roof mechanical equipment should be
covered by low-profile angled roofing so
that obstacles to bird flight are minimized.
Bird Safe Design Requirements
• Projects under the Plan shall implement the
following bird-safe building design
considerations for all buildings exceeding 40
feet above finished grade within 300 feet of
Belmont Creek or any contiguous open space
areas (including other drainages and future
open space areas created by the Plan) two
acres or larger that are dominated by
vegetation or wetland/aquatic habitats:
o The extent of glass on the façades of new
buildings and additions shall be
minimized to the extent feasible.
o No more than 10 percent of the surface
area of the façades of buildings
(considering all facades combines) shall
Project plans shall
implement the required
bird-safe building design
considerations listed.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve
design plans.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2445
Page | 18
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
have untreated glazing between the
ground and 60 feet above ground. Birdsafe glazing treatments may include fritting, netting, permanent stencils,
frosted glass, exterior screens, and/or
physical grids placed on the exterior of
glazing or ultraviolet patterns visible to
birds. Bird-safe glazing shall have the
following specifications:
▪ Vertical elements of the
window patterns will be at
least ¼-inch wide at a
maximum spacing of 4
inches, or have horizontal
elements at least 1/8-inch
wide at a maximum spacing
of 2 inches; OR
▪ Bird-safe glazing shall have a
Threat Factor less than or
equal to 30.
o No more than 10 percent of the surface
area of any façades directly facing
Belmont Creek or any open space areas
two acres or larger that are dominated by
vegetation or wetland/aquatic habitats,
and/or façade areas within 12 vertical feet
10.b
June 08, 2026 Packet Pg. 2446
Page | 19
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
above and/or below landscaped terraces,
shall have untreated glazing.
o All glazing panels at corners of façades
that face Belmont Creek or any open
space areas two acres or larger that are
dominated by vegetation or
wetland/aquatic habitats, between the
ground and 60 feet above ground and/or
within 12 vertical feet above and/or below
landscaped terraces (regardless of their
height above ground), shall be 100
percent treated.
o To reduce reflections of clouds and
vegetation in glass and help ensure that
bird-safe treatments on the lower surfaces
of glass are visible below any reflections,
glazing shall have a visible reflectance of
15 percent or lower.
o Glass skyways or walkways, freestanding
glass walls, and transparent building
corners between the ground and 60 feet
above ground and/or within 12 vertical
feet above and/or below landscaped
terraces (regardless of their height above
ground) shall not be allowed, unless the
glazing is 100 percent treated.
10.b
June 08, 2026 Packet Pg. 2447
Page | 20
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
o Transparent glass should not be allowed
at the rooflines of buildings, including in
conjunction with green roofs, unless the
glazing is 100 percent treated.
o A project may receive a deviation from
one or more of the requirements above if
a qualified biologist documents that
glazing in a particular area will not
increase bird collision risk or documents
why alternative bird-safe design measures
would be at least as effective as the above
requirements. Any such decision must be
approved by the City’s Planning Division.
CULTURAL RESOURCES
Impact CUL-1: Future development projects under the Plan could indirectly or directly impact known and unknown historic buildings and structures by removing historic buildings and structures, or altering the setting for historic properties.
General Plan Policies that Reduce Impacts to
Historic Resources
Future development projects would comply with
the following General Plan policies and actions
pertaining to historic resources.
• Policy LU-12.1:Evaluate historical,
cultural, and tribal cultural resources early
in the development review process
Applicant shall
implement, as part of the
project, applicable
General Plan Policies at
the time of projectspecific CEQA review.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Verify
implementation of
applicable policies
as part of the
planning
application
approval.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2448
Page | 21
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
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-12.3: Ensure that
modifications to identified historic
resources are consistent with the U.S.
Secretary of the Interior’s Standards for
the Treatment of Historic Properties.
• Policy LU-12.4: Encourage continued use
and adaptive reuse of designated historic
resources through application of the U.S.
Secretary of the Interior's Standards and
Guidelines for rehabilitation,
reconstruction and restoration.
• Policy LU-12.6: Promote the
maintenance, restoration and
rehabilitation of historical resources
through but not limited to the use of
Federal Rehabilitation Tax Credits, State
incentives including the Mills Act and the
California Cultural and Historical
Endowment and the California State
Historical Building Code.
10.b
June 08, 2026 Packet Pg. 2449
Page | 22
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
• Action LU-12.1: Ensure thorough
compliance with the provisions of the
California Environmental Quality Act
(CEQA) relating to potential impacts to
cultural and historical resources.
Impact CUL-2: Future development projects under the Plan could inadvertently discover unknown archaeological resources during construction.
General Plan Policies that Reduce Impacts to
Archaeological Resources
• Policy LU-1.10: Require that
development within the Pulgas, Brittan
and Cordilleras Creek watersheds shall
preserve watershed integrity, including
natural vegetation, soil and slope stability,
water quality, scenic values and potential
archaeological resources.
• Policy LU-12.1: Evaluate historical,
cultural, and tribal cultural resources early
in the development review process
through consultation with interested
parties.
Applicant shall
implement, as part of the
project, applicable
General Plan Policies at
the time of projectspecific CEQA review.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Verify
implementation of
applicable policies
as part of the
planning
application
review.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
Impact CUL-3: Future development projects under the Plan could inadvertently discover human remains during construction.
10.b
June 08, 2026 Packet Pg. 2450
Page | 23
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
General Plan Policies that Reduce Impacts to
Human Remains
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.
Applicant shall comply
with Policy LU-12.5 if
human remains are
discovered onsite.
Applicant shall notify the
Planning Division
Director if human remains
are discovered.
During ground
disturbance.
City of San Carlos
Building Division
and Planning
Division.
Confirm applicant
has complied with
all applicable laws
related to human
remains.
During ground
disturbance.
GEOLOGY AND SOILS
Impact GEO-1: Future development under the Plan could directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving liquefaction.
General Plan Policies that Reduce Impacts
from Liquefaction
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 seismicallyinduced ground failure.
Applicants shall submit
reports addressing the
degree of hazard, design
parameters for the project
based on the hazard and
appropriate mitigation
measures.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division.
Receive, review,
and approve the
geotechnical and
soils reports.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2451
Page | 24
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
GREENHOUSE GASES
Impact GHG-1: Implementation of the Plan would exceed the 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 SB 32 or the carbon neutrality goal under AB 1279.
General Plan Mitigation Measures
• Mitigation Measure GHG-1: The City
of San Carlos shall prepare an update to
its Climate Mitigation and Adaptation
Plan (CMAP) to chart a trajectory to
achieve the long-term GHG reduction
goal set by AB 1279. The updated CMAP
shall be completed within three years of
certification of the General Plan EIR. The
updated CMAP shall be updated every
five years to ensure the City is monitoring
the CMAP’s progress toward achieving
the City’s GHG reduction target(s), and
the City shall amend the CMAP if it is not
achieving such targets. The CMAP update
shall consider a trajectory consistent with
the GHG emissions reduction goal
established under AB 1279 for year 2045,
and the latest applicable statewide
legislative GHG emission reduction that
may be in effect at the time of the CMAP
update.
The CMAP update shall include the
following:
N/A. N/A. City of San Carlos
Community
Development
Department.
City shall prepare
an update to its
Climate
Mitigation and
Adaptation Plan
(CMAP) to chart a
trajectory to
achieve the longterm GHG
reduction goal set
by AB 1279.
The updated
CMAP shall be
completed
within three
years of
certification of
the General
Plan EIR. The
CMAP shall be
updated every
five years.
10.b
June 08, 2026 Packet Pg. 2452
Page | 25
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
o GHG inventories of existing and
forecast year GHG levels.
o Tools and strategies for reducing
GHG emissions to ensure a
trajectory with the long-term
GHG reduction goal and carbon
neutrality goal for year 2045 of
AB 1279.
o Plan implementation guidance
that includes, at minimum, the
following components consistent
with the CMAP update:
▪ Administration and
Staffing
▪ Finance and Budgeting
▪ Timelines for Measure
Implementation
▪ Community Outreach and
Education
▪ Monitoring, Reporting,
and Adaptive
Management
▪ Tracking Tools
HAZARDS AND HAZARDOUS MATERIALS
Impact HAZ-1: Future development within the Plan could encounter and disturb contaminated soil, soil vapor, and groundwater, and result in adverse effects on construction workers, existing residents and employees, and nearby sensitive receptors.
10.b
June 08, 2026 Packet Pg. 2453
Page | 26
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
General Plan Policies that Reduce Impacts
The following General Plan policies would reduce
impacts associated with contaminated soil, soil
vapor and/or groundwater from future
development in the Plan:
• ESPS-5.3: Mitigate hazard exposure to
and from new development projects
through the environmental review
process, design criteria and standards
enforcement.
• ESPS-5.5: Where deemed necessary,
based on the history of land use, require
site assessment for hazardous and toxic
soil contamination prior to approving
development project applications.
• ESPS-5.6: Require that new development
proposals are reviewed for legally
required remediation by authorities with
jurisdictional authority over groundwater
and surface water contamination
including but not limited to San Mateo
County Environmental Health, State
Water Quality Control Board and the
Army Corps of Engineers, where waters
of the United States are involved, and
collaborate with authorities to ensure all
Applicant shall submit a
site assessment for
hazardous and toxic soil
contamination.
Applicant shall obtain
approval for remediation
by authorities with
jurisdictional authority
over groundwater and
surface water
contamination.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division,
Planning Division.
Verify
implementation of
applicable policies
as part of the
planning
application
approval.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2454
Page | 27
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
relevant remediation requirements are
met.
NOISE AND VIBRATION
Impact NOI-1: Future construction associated with development under the Plan could result in temporary construction noise impacts General Plan Polices that Reduce Impacts
In accordance with General Plan Policy NOI-1.8,
future development projects under the Plan would
implement the following noise control strategies
and construction BMPs.
NOI-1.8: 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. Such measures shall include,
but not be limited to, the following to reduce
construction noise levels as low as practical:
Submit grading and
building construction
plans that demonstrate
that noise and vibration
reduction measures and
best management
practices are included as
part of project
construction.
Prior to issuance
of demolition,
grading, and/or
building permits
(whichever occurs
earlies).
City of San Carlos
Building Division
and Planning
Division.
Review and
approve the
development
plans.
Prior to
issuance of
demolition,
grading, and/or
building
permits
(whichever
occurs
earliest).
10.b
June 08, 2026 Packet Pg. 2455
Page | 28
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
• Limit construction activity to weekdays
between 8:00 a.m. and 5:00 p.m. and
weekends between 9:00 a.m. and 5:00
p.m., with no construction on the
following holidays: New Year’s Day,
Martin Luther King Jr. Day, President’s
Day, Memorial Day, Juneteenth, 4th of
July, Labor Day, Veteran’s Day,
Thanksgiving Day and Christmas Day;
• Utilize "quiet" models of air compressors
and other stationary noise sources where
such technology exists;
• Equip all internal combustion enginedriven equipment with mufflers, which are in good condition and appropriate for
the equipment;
• Locate all stationary noise-generating
equipment, such as air compressors and
portable power generators, as far away as
possible from adjacent land uses;
• Locate staging areas and construction
material areas as far away as possible
from adjacent land uses;
• Prohibit all unnecessary idling of internal
combustion engines;
10.b
June 08, 2026 Packet Pg. 2456
Page | 29
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
• If impact pile driving is proposed,
multiple-pile drivers shall be considered
to expedite construction. Although noise
levels generated by multiple pile drivers
would be higher than the noise generated
by a single pile driver, the total duration
of pile driving activities would be
reduced;
• If impact pile driving is proposed,
temporary noise control blanket barriers
shall shroud pile drivers or be erected in a
manner to shield the adjacent land uses.
Such noise control blanket barriers can be
rented and quickly erected;
• If impact pile driving is proposed,
foundation pile holes shall be pre-drilled
to minimize the number of impacts
required to seat the pile. Pre-drilling
foundation pile holes is a standard
construction noise control technique. Predrilling reduces the number of blows required to seat the pile. Notify all
adjacent land uses of the construction
schedule in writing;
• Designate a “disturbance coordinator”
who would be responsible for responding
to any local complaints about construction
10.b
June 08, 2026 Packet Pg. 2457
Page | 30
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
noise. The disturbance coordinator will
determine the cause of the noise
complaint (e.g., starting too early, bad
muffler, etc.) and will require that
reasonable measures warranted to correct
the problem are implemented.
• Conspicuously post a telephone number
for the disturbance coordinator at the
construction site and include it in the
notice sent to neighbors regarding the
construction.
Impact NOI-2: Future development under the Plan could result in interior noise levels in excess of 45 dBA.
General Plan Policies that Reduce Operational
Noise Impacts
NOI-1.6 and NOI-1.10: New developments within
the Plan Area shall be required to comply with
City noise standards set forth in the General Plan
and SCMC. To ensure compliance with the
operational noise level thresholds required in the
General Plan and SCMC, a qualified acoustical
consultant shall be retained to review mechanical
equipment systems during final design of the
proposed project consistent with standards City
practice. The consultant shall review selected
equipment and determine specific noise reduction
measures necessary to reduce noise to comply
with the City’s noise level requirements. Noise
Applicants shall submit a
noise report by a qualified
acoustical consultant to
determine specific noise
reduction measures.
Prior to issuance
of a building
permit.
City of San Carlos
Building Division
and Planning
Division.
Review and
approve the noise
study.
Prior to
issuance of a
building
permit.
10.b
June 08, 2026 Packet Pg. 2458
Page | 31
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
reduction measures could include, but are not
limited to, selection of equipment that emits low
noise levels and/or installation of noise barriers,
such as enclosures and parapet walls, to block the
line-of-sight between the noise source and the
nearest receptors. Additionally, enclosures and
interior wall treatments shall be considered to
reduce noise exposure within the on-site units.
Alternate measures may include locating
equipment in less noise-sensitive areas, where
feasible.
Impact NOI- 3: Future construction associated with development under the Plan could result in damage to existing buildings from temporary construction vibration.
Vibration Control Requirements:
• Projects shall submit a construction vibration
control plan prepared by a qualified
professional in accordance with industryaccepted methodology. The plan shall identify necessary construction vibration controls to
reduce the potential of cosmetic damage to
buildings and to minimize annoyance.
Controls may include, but would not be
limited to, the following measures:
o Submit a list of all heavy construction
equipment to be used for the project
known to produce high vibration
levels (tracked vehicles, vibratory
Applicants shall submit a
construction vibration
control plan prepared by a
qualified professional.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Review and
approve the
construction
vibration control
plan.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2459
Page | 32
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
compaction, jackhammers, hoe rams,
etc.) shall be submitted to the City by
the contractor. This list shall be used
to identify equipment and activities
that would potentially generate
substantial vibration and to define the
level of effort for reducing vibration
levels below the thresholds.
o Place operating equipment on the
construction site as far as possible
from vibration-sensitive receptors.
o Use smaller equipment along project
boundaries to minimize vibration
levels below the limits.
o Avoid using vibratory rollers and
tampers near sensitive areas.
o Select demolition methods not
involving impact tools.
o Modify/design or identify alternative
construction methods to reduce
vibration levels below the limits.
o Avoid dropping heavy objects or
materials near sensitive uses.
o For projects requiring impact or
vibratory pile driving, develop a
vibration monitoring and construction
contingency plan to identify
structures where monitoring would be
10.b
June 08, 2026 Packet Pg. 2460
Page | 33
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
conducted, set up a vibration
monitoring schedule, define structurespecific vibration limits, and address the need to conduct photo, elevation,
and crack surveys to document before
and after construction conditions.
Construction contingencies shall be
identified for when vibration levels
approached the limits. Conduct a
post-construction survey on structures
where either monitoring has indicated
high vibration levels or complaints of
damage has been made. Make
appropriate repairs or compensation
where damage has occurred as a
result of construction activities.
Impact NOI-4: Future residential uses under the Plan could potentially fall within the 55 dBA CNEL of the San Carlos Airport.
General Plan Policies that Reduce Project
Impacts
In accordance with General Plan Policies NOI1.11 and NOI-1.13, future residential development within the 55 dBA CNEL would
implement mitigation measures to reduce noise
impacts from aircraft operations.
• NOI-1.11: Ensure that proposed noise
sensitive land uses include appropriate
Applicants shall submit a
noise analysis completed
by a qualified noise
consultant.
At the time of
project-level
CEQA and prior
to planning
application
approval.
City of San Carlos
Building Division
and Planning
Division.
Receive, review,
and approve the
noise analysis.
At the time of
project-level
CEQA and
prior to
planning
application
approval.
10.b
June 08, 2026 Packet Pg. 2461
Page | 34
Source: City of San Carlos. Northeast Area Specific Plan Final EIR. March 2026.
Northeast Area Specific Plan
SCH # 2024070063
MITIGATIONS MONITORING AND REPORTING PROGRAM
Documentation of Compliance
[Project Applicant/Proponent
Responsibility]
Documentation of Compliance
[Lead Agency Responsibility]
Method of Compliance
Or Mitigation Action
Timing of
Compliance
Oversight
Responsibility Actions/Reports
Monitoring
Timing or
Schedule
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.
• 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.
10.b
June 08, 2026 Packet Pg. 2462
RESOLUTION NO. 2026 – ____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF SAN CARLOS
AMENDING THE SAN CARLOS GENERAL PLAN LAND USE MAP, LAND USE ELEMENT,
CIRCULATION AND SCENIC HIGHWAYS ELEMENT, ENVIRONMENTAL MANAGEMENT ELEMENT, AND ENVIRONMENTAL SAFETY AND PUBLIC SERVICES ELEMENT.
WHEREAS, the City Council adopted the 2022 Strategic Work Plan that included a Strategic Objective for preparation of the Northeast Area Specific Plan and reaffirmed this Strategic Objective in subsequent Strategic Work Plans including the 2026 Strategic Work Plan; and
WHEREAS, in September 2022 the City Council approved a professional services agreement with Perkins&Will for consulting services to prepare a Northeast Area Specific Plan (“Specific Plan”) and Environmental Impact Report (“EIR”), in response to the City Council’s Strategic Objective to develop a plan that includes policies and strategies for development and housing in the northeast area; and
WHEREAS, between February 2023 through July 2025, 30 different civic engagement opportunities inclusive of focus group meetings, pop-up events, open-houses, community workshops, and study sessions with the City Council and Planning and Transportation Commission were held to receive input on the Specific Plan; and WHEREAS, on February 12, 2024, the City Council endorsed the preferred land use scenario for the Northeast Area Specific Plan that determines the anticipated buildout of land uses in the Northeast Area Specific Plan boundary through the year 2045 that introduces housing to advance a vision for a new mixed use district; and
WHEREAS, a Public Draft of the Northeast Area Specific Plan was available for public review in April 2025 and was presented to the Planning and Transportation Commission in April 2025 and to the City Council in May 2025 and September 2025 who directed modifications to the Specific Plan; and
WHEREAS, the proposed amendments to the Land Use Map, Land Use Element, Circulation and Scenic Highways Element, Environmental Management Element, and Environmental Safety and Public Services Element of the General Plan (herein referred to as “General Plan Amendments”) have been developed to be internally consistent and prepared consistent with the Specific Plan; and
WHEREAS, the proposed amendments to the Land Use Map are consistent with the preferred land use scenario endorsed by the City Council; and WHEREAS, the General Plan Amendments also address the redefinition of the “Harbor Industrial Area” into the “Northeast Area” consistent with the boundaries identified in the Northeast Area Specific Plan accompanied by policy revisions to ensure consistency with the vision and guiding principles of the Specific Plan; and
WHEREAS, in accordance with the California Government Code Section 65300 et seq., the General Plan Amendments have been developed to be comprehensive, internally consistent, and long term; and
10.b
June 08, 2026 Packet Pg. 2463
WHEREAS, in July 2024, the City provided written notification of the proposed Northeast Area Specific Plan, EIR, and General Plan Amendments to the list of tribes provided by the Native American Heritage Commission and to other entities listed pursuant to Assembly Bill 52 and Senate Bill 18, and no tribes requested consultation; and WHEREAS, on May 18, 2026, the Planning and Transportation Commission held a duly noticed public hearing and adopted Resolution No. PTC2026-04 recommending that the City Council adopt a Resolution to amend the General Plan Amendments; and WHEREAS, on May 28, 2026, the City mailed a public notice to all property owners and occupants/tenants within the Specific Plan boundary and within 300 feet of the Specific Plan boundary informing stakeholders of the proposed adoption of the Northeast Area Specific Plan project; and
WHEREAS, on May 29, 2026, a legal notice was published in the local newspaper informing stakeholders of the proposed adoption of the Northeast Area Specific Plan project; and
WHEREAS, on June 8, 2026, the City Council adopted a Resolution certifying the Environmental Impact Report for the Northeast Area Specific Plan; and WHEREAS, on June 8, 2026, the City Council held a duly noticed public hearing to consider the Planning and Transportation Commission’s recommendation to adopt a Resolution to amend the General Plan Land Use Map, Land Use Element, Circulation and Scenic Highways Element, Environmental Management Element, and Environmental Safety and Public Services Element.
NOW, THEREFORE BE IT RESOLVED by the San Carlos City Council that:
1. Findings
a. The above recitals and findings are hereby incorporated by this reference and are hereby approved.
b. The General Plan Amendments are necessary to ensure consistency between the proposed Northeast Area Specific Plan’s overall vision, guiding principles, policies, and development standards and the General Plan. The Specific Plan serves as an extension to the General Plan and provides more specific standards for the northeast area over the next 20 years. The General Plan Amendments are minor and nature, with one integral amendment to allow residential uses as delineated in the Specific Plan where residential uses are currently prohibited.
c. The proposed General Plan Land Use amendment for parcels bound by Glenn Way, Taylor Way, Old County Road, and Bragato Road (from Planned Industrial to Mixed Use, 68-90 du/ac) and parcels bound by Industrial Road, Taylor Way, Old County Road, and the rear parcel lines of properties along Northwood Drive and Fairfield Drive (from Planned Industrial to Mixed Use 57-75 du/ac) allows the development of residential uses, which increases housing opportunities in support of a vibrant mixeduse neighborhood. The proposed minimum and maximum densities are also consistent with the preferred land use scenario endorsed by the City Council on
10.b
June 08, 2026 Packet Pg. 2464
February 12, 2024.
2. Adoption
a. The City Council hereby adopts the amendments to the General Plan Land Use Map as set forth in Exhibit A.
b. The City Council hereby adopts the amendments to the General Plan Land Use Map, Land Use Element, Circulation and Scenic Highways Element, Environmental Management Element, and Environmental Safety and Public Services Element as set forth in Exhibit B.
* * * * *
I, City Clerk Crystal Mui, hereby certify that the foregoing Resolution was duly and regularly passed and adopted by the City Council of the City of San Carlos at a scheduled meeting thereof held on the 8th day of June 2026, by the following vote:
________________________________
CITY CLERK of the City of San Carlos
APPROVED:
___________________________
MAYOR of the City of San Carlos
Exhibits:
A. San Carlos General Plan Land Use Map Amendment
B. San Carlos General Plan Amendments
AYES, COUNCILMEMBERS:
NOES, COUNCILMEMBERS:
ABSENT, COUNCILMEMBERS:
10.b
June 08, 2026 Packet Pg. 2465
BRAGATO RD
OLD COUNTY RD TAYLOR WY
GLENN WY
QUARRY RD
BRAGATO RD
F ST RIVERTON DR
FAIRFIELD DR
INVERNESS DR
TAYLOR WY
SPRING ST
STATE HIGHWAY 82
LAUREL ST
FAIRFIELD DR
SYLVAN DR
LAUREL ST
SPRING ST ELM ST
INDUSTRIAL RD
NORTHWOOD DR OLD COUNTY RD
HULL DR
LAUREL ST RIVERTON DR
HOLLY ST
ELM ST
US HIGHWAY 101
US HIGHWAY 101
SHOREWAY RD
US HIGHWAY 101 US HIGHWAY 101
EL CAMINO REAL
BRAGATO RDGLENN WY
SPRINGFIELD DR SYLVAN DR
INVERNESS DR BAYPORT CT
HOLLY ST CHESTNUT ST CEDAR ST
CHESTNUT ST
CEDAR ST
SPRINGFIELD DR
OLD COUNTY RD
INDUSTRIAL RD
INDUSTRIAL RD
US HIGHWAY 101
BRAGATO RD
TAYLOR WY
GLENN WY
QUARRY RD
BRAGATO RD
F ST RIVERTON DR
FAIRFIELD DR
INVERNESS DR
TAYLOR WY
SPRING ST
STATE HIGHWAY 82
LAUREL ST
FAIRFIELD DR
SYLVAN DR
LAUREL ST
SPRING ST ELM ST
INDUSTRIAL RD
NORTHWOOD DR OLD COUNTY RD
HULL DR
LAUREL ST RIVERTON DR
HOLLY ST
ELM ST
US HIGHWAY 101
US HIGHWAY 101
SHOREWAY RD
US HIGHWAY 101 US HIGHWAY 101
CHESTNUT ST
CEDAR ST
SPRINGFIELD DR
OLD COUNTY RD
INDUSTRIAL RD
INDUSTRIAL RD
EL CAMINO REAL
BRAGATO RDGLENN WY
SPRINGFIELD DR SYLVAN DR
INVERNESS DR BAYPORT CT
HOLLY ST CHESTNUT ST CEDAR ST
1031
135
26 590
964
301
1000
1003
992
1051
42-44
551
965
221
1056
90 351
159
279
259
551
970
1036
1007
1008
975
1200
33 266
151
1028
21 551
120
210
1011
1060
999
66 7
83 327
54 1027
335 1023
96 1020
331
686
17 355
989
476
1040
81 240
147
307
917
58 81
1015
1032
50 1039
1250
1210
935
5 633
301
1 90
100
1043
946
315
995
12 161
349
354
1011
58 57
1048
195
73 40
291
1011
317
90 1003
1036
1003
620
1004
1015
1016
641
287-A
1501
595
243
57 1039
100
1008
285
1040
991
996
217
1201
1016
1052
1000
188
41 219
1043
370
1048
75 145
34 41
992
84 991
41 1055
64 1048
50 71
987
1047
1 201
1016
923
958
1027
235
11 363
500-550
80 1007
280
1044
1011
1019
73 26
1052
111
9 1027
952
1020
1015
251
1040
49 300
555
1020
405
1028
57 156
1032
1012
1211
1011
995
1015
303
601
1004
58 150
1020
1036 112
66 60
1035
34 585
1051
585
370
239
80 270
100
1024
18-20
247
979
1028
1027
1035
72 1007
151
611
580
610
89 1056
370
50 151
1047
999
988
311
195
1023
74 1032
983
1044
934
1035
1003
359
181
81 1321
1016
360
1019
255
129 17
1031
995
1008
988
1000
1008
907
65 180
70 1330
309 8
74 1007
996
319
999
1 49
128
24 1340
380
1012
49 1048
101
2 928
11 987
999
323
100
1023 96
979
1004
360
1047
380
191
295
1052 976
1056
50 947
63 18
82 25
1036
251
339
1012
1035
1310
367
1055
941
991
1039
988
996
1015
371
1004
343
1044
1024
1019
980
1044
1023
1055
906
41 1024
66 26
611
299
1020
58 71
1320
1350
390
65 307
161
23 78
333
1043
1031
201
1007
1016
75-125
565
171
315
987
1031
541
95 305
1012
333
984
990
983
1056
400
311
320
1019
4 1024
1032
1051
10 209
67 295
34 66
131
79 959
1040
984
1023
940
1024
445
87 1052
205
42 347
1028
929
982
1360
360
171
283
591
1019
1043
1028
90 171
1032
1039
535
550
1036
953
33 268
501
Proposed General Plan Amendment
Planned Industrial
General Commercial / Industrial
Multi-Family 75 -100 DUs/acre
From: Planned Industrial
To: Mixed Use 57-75 DUs/acre
Mixed Use 68-90 DUs/acre
Northeast Area Specific Plan Boundary
APRIL 2026
Source: City of San Carlos, 2026; CALCAD, 2026
Mixed Use 90-120 DUs/acre
Single Family, 6DUs/acre
Belmont
10.b
June 08, 2026 Packet Pg. 2466
Northeast Area Specific Plan General Plan Amendments
Header, Policy,
or Action
Number
Existing Proposed
Introduction
2045 General
Plan Reset (pg.
14)
The General Plan Reset was initiated in
2023 to amend the buildout capacity of the
2030 General Plan. As part of the 2045
General Plan Reset, concurrent long range
planning initiatives were considered into
the citywide buildout capacity. Ongoing
initiatives within San Carlos included the
Northeast Area Specific Plan and the
Downtown Specific Plan. The 2045
General Plan Reset was more focused
than a complete General Plan Update and
did not include any changes to General
Plan land use designations or major policy
changes; instead the focus was to adjust
development projections to the year 2045.
The community was informed and engaged
in the project through updates on the City
website, newsletters, e-news, stakeholder
meetings, and study sessions and public
hearings at City Council and Planning and
Transportation Commission.
The General Plan Reset was initiated in
2023 to amend the buildout capacity of the
2030 General Plan. As part of the 2045
General Plan Reset, concurrent long range
planning initiatives were considered into
the citywide buildout capacity. Ongoing
These initiatives within San Carlos included
the Northeast Area Specific Plan (adopted
MONTH 2026), and the Downtown
Specific Plan (adopted January 2026), and
the Downtown Streetscape Master Plan
(adopted April 2025). The 2045 General
Plan Reset was more focused than a
complete General Plan Update and did not
include any changes to General Plan land
use designations or major policy changes;
instead the focus was to adjust
development projections to the year 2045.
The community was informed and engaged
in the project through updates on the City
website, newsletters, e-news, stakeholder
meetings, and study sessions and public
hearings at City Council and Planning and
Transportation Commission.
Land Use Element
San Carlos East
Side Area
(pg. 23)
The Land Use Element frequently refers to
an area known as the “East Side” area.
The East Side area includes all areas of
San Carlos east of the Caltrain right-ofway. Included in the East Side area are a diversity of land uses, including the
Laureola residential neighborhood, the San
Carlos airport, businesses serving the
building industry, light industrial
businesses, and retail uses. Three
Landmark Sites in the East Side area were
designated for redevelopment at major
entries to the city. One of the Landmark
Sites, located at the south end of the city
on Industrial Road, has been redeveloped
as office and hotel. Recently, the Palo Alto
Medical Foundation hospital, was approved
for development on Industrial Road. The
East Side area also has seen recent
growth in regional-serving retail uses. The
The Land Use Element frequently refers to
an area known as the “East Side” area.
The East Side area includes all areas of
San Carlos east of the Caltrain right-ofway. Included in the East Side area are a diversity of land uses, including the
Laureola residential neighborhood, the San
Carlos airport, businesses serving the
building industry, light industrial
businesses, and retail uses. Three
Landmark Sites in the East Side area were
designated for redevelopment at major
entries to the city. One of the Landmark
Sites, located at the south end of the city
on Industrial Road, has been redeveloped
as office and hotel. Recently, the Palo Alto
Medical Foundation hospital, was approved
for development on Industrial Road. The
East Side area also has seen recent
growth in regional-serving retail uses. The
10.b
June 08, 2026 Packet Pg. 2467
San Carlos Marketplace project, located on
Industrial Road at Howard Avenue, added
over 100,000 square feet of additional retail
and commercial space to the area. Key
issues for the East Side area that are
addressed in this General Plan include:
preserving existing residential
neighborhoods; maintaining existing
industrial uses, promoting “green”
businesses; redeveloping the two
remaining Landmark Sites on Industrial
Road, north and south of Holly Street and
adjacent to Highway 101; and encouraging
additional retail development along
Highway 101 to generate additional sales
tax revenue for the City.
The Harbor Industrial area (HIA) is also
located in the East Side area of the City.
This subarea comprises large
manufacturing businesses, biotechnical
and biomedical firms and light and heavy
industrial uses. The majority of the area
(from Belmont Creek to north of Holly
Street) was annexed in 1997 after a
petition for annexation was received from
over 80 percent of the property owners in
the HIA.
The balance of the HIA to the north
remains unincorporated under a
compromise known as “ABC” reached
between the Cities of San Carlos and
Belmont and the HIA property owners in
1997. The ABC Compromise requires San
Carlos or Belmont to meet certain
conditions in order to annex the remaining
unincorporated portions of the HIA. The
portion of the HIA that was annexed to San
Carlos conforms to both County and City
industrial zoning regulations. Existing land
use regulations strongly discourage
housing, commercial, retail and nonindustrial uses in this area.
San Carlos Marketplace project, located on
Industrial Road at Howard Avenue, added
over 100,000 square feet of additional retail
and commercial space to the area. Key
issues for the East Side area that are
addressed in this General Plan include:
preserving existing residential
neighborhoods; maintaining existing
industrial uses, promoting “green”
businesses; redeveloping the two
remaining Landmark Sites on Industrial
Road, north and south of Holly Street and
adjacent to Highway 101; and encouraging
additional retail development along
Highway 101 to generate additional sales
tax revenue for the City.
The Harbor IndustrialNortheast area (HIA)
is also located in the East Side area of the
City. This subarea comprises large
manufacturing businesses, biotechnical
and biomedical firms and light and heavy
industrial uses. The majority of the area
(from Belmont Creek to north of Holly
Street) was annexed in 1997 after a
petition for annexation was received from
over 80 percent of the property owners in
the area formerly known as the Harbor
Industrial Area (HIA).
The balance of the HIA area to the north of
the Northeast area remains unincorporated
under a compromise known as “ABC”
reached between the Cities of San Carlos
and Belmont and the HIA property owners
in 1997. The ABC Compromise requires
San Carlos or Belmont to meet certain
conditions in order to annex the remaining
unincorporated portions of the HIA. The
portion of the HIA that was annexed to San
Carlos conforms to both County and City
industrial zoning regulations. Existing land
use regulations strongly discourage
housing, commercial, retail and nonindustrial uses in this area.
The City Council adopted the Northeast
Area Specific Plan on (MONTH, DAY),
2026 to guide development of a mixed-use
district combining housing and commercial
uses while preserving existing industrial
legacy within the Northeast area
Downtown
(pg. 23)
Note: The City is also preparing a new
specific plan for the northeast area, which
is on schedule to be adopted by the end of
2026.
Note: The City is also preparing a new
specific plan for the northeast area, which
is on schedule to be adopted by the end of
2026.
10.b
June 08, 2026 Packet Pg. 2468
General Plan
Map (pg. 29)
- (See the attached revised map)
General Plan
Land Use
Designation (pg.
30)
- Mixed Use, 57-75 du/ac permits both
commercial and multifamily residential
uses at residential densities of 57-75
dwelling units per acre.
General Plan
Land Use
Designation (pg.
30)
- Mixed Use, 68-90 du/ac permits both
commercial and multifamily residential
uses at residential densities of 68-90
dwelling units per acre.
East and West
Side Specific
Plans (pg. 34)
Note: In 2022, the City initiated the
development of two specific plans, one in
the northeast area and one in the
downtown; both of which will be adopted in
2025.
Note: In 2022, the City initiated the
development of two specific plans, one in
the Nnortheast area and one in the
Ddowntown area; both of which will be
adopted in 2025.. The Downtown Specific
Plan was adopted on November 24, 2025.
The Northeast Area Specific Plan was
adopted on (DATE).
Goal LU-6 Strengthen the economic vitality of the East
Side of the city by encouraging a diversity
of commercial uses while protecting and
preserving existing industrial uses.
Strengthen the economic vitality of the East
Side of the city by encouraging a diversity
of commercial uses while protecting and
preserving existing industrial uses and
further the vision for the Northeast area by
supporting redevelopment consistent with
the Northeast Area Specific Plan.
Policy LU-6.2
(pg. 50)
Prohibit the conversion of property
designated for industrial/commercial land
on the East Side to
nonindustrial/commercial uses.
a. Ensure proposed new uses in the East
Side do not introduce land use conflicts
that would adversely impact
industrial/commercial activities.
Prohibit the conversion of property
designated for industrial/commercial land
on the East Side to
nonindustrial/commercial uses, except as
provided below..
a. Ensure proposed new uses in the East
Side do not introduce land use conflicts
that would adversely impact
industrial/commercial activities.
a.b. Allow the redevelopment of land to
include residential uses in accordance
with the Northeast Area Specific Plan.
Policy LU-6.9
(New)
- Encourage lot consolidation in the
Northeast area that supports
comprehensive site planning and efficient
land use in accordance with the Northeast
Area Specific Plan.
Action LU-6.6
(New)
- Continue to implement the Northeast Area
Specific Plan adopted on (Date)
(Resolution 2026-###)
Figure 3-3,
Major Developed
Areas In San
Carlos (pg. 55)
- (See the attached revised Figure)
East Side Area
(pg. 57-58)
Since 2015, the City of San Carlos has
experienced an unprecedented amount of
private sector investment, including
Since 2015, the City of San Carlos has
experienced an unprecedented amount of
private sector investment, including
10.b
June 08, 2026 Packet Pg. 2469
business and employment growth in the life
sciences and biotechnology sectors in the
area of East Side defined by Holly Street,
Brittan Avenue, Old County Road, and
Highway 101. To plan for these changes,
the City Council adopted the East Side
Innovation District Vision Plan in October
2021. A Specific Plan is currently underway
for the San Carlos Northeast Area, near the
border of Belmont and the City of San
Carlos.
business and employment growth in the life
sciences and biotechnology sectors in the
area of East Side defined by Holly Street,
Brittan Avenue, Old County Road, and
Highway 101. To plan for these changes,
the City Council adopted the East Side
Innovation District Vision Plan in October
2021 and the Northeast Area Specific Plan
in (MONTH) 2026.. A Specific Plan is
currently underway for the San Carlos
Northeast Area, near the border of Belmont
and the City of San Carlos.
Harbor Industrial
Area (pg. 58)
The Harbor Industrial area (HIA), located
between the city limit to the north, Highway
101 to the east, Old County Road to the
west and as far south as Holly Street on
the eastern edge, is a subarea within the
East Side area (Figure 3-3). This subarea
comprises large manufacturing businesses,
biotechnical and biomedical firms and light
and heavy industrial uses. The majority of
the area (from Belmont Creek to north of
Holly Street) was annexed in 1997 after a
petition for annexation was received from
over 80 percent of the property owners in
the HIA. The balance of the HIA to the
north remains unincorporated under a
compromise known as “ABC” reached
between the Cities of San Carlos and
Belmont and the HIA property owners in
1997. The ABC compromise requires San
Carlos or Belmont to meet certain
conditions in order to annex the remaining
unincorporated portions of the HIA. The
portion of the HIA that was annexed to San
Carlos conforms to both County and City
industrial zoning regulations. Existing land
use regulations strongly discourage
housing, commercial, retail and nonindustrial uses in this area.
The Harbor IndustrialNortheast area (HIA),
located between the city limit to the north,
Highway 101 to the east, Old County Road
to the west and as far south as the Holly
Street on the eastern edgerear parcel lines
of properties along Northwood Drive and
Fairfield Drive, is a subarea within the East
Side area (Figure 3-3). This subarea
comprises large manufacturing businesses,
biotechnical and biomedical firms and light
and heavy industrial uses. The majority of
the area (from Belmont Creek to north of
Holly Street) was annexed in 1997 after a
petition for annexation was received from
over 80 percent of the property owners in
this area, formerly known as the Harbor
Industrial Area (HIA). The balance of the
HIA area to the north of the Northeast area
remains unincorporated under a
compromise known as “ABC” reached
between the Cities of San Carlos and
Belmont and the HIA property owners in
1997. The ABC compromise requires San
Carlos or Belmont to meet certain
conditions in order to annex the remaining
unincorporated portions of the HIA. The
portion of the HIA that was annexed to San
Carlos conforms to both County and City
industrial zoning regulations. Existing land
use regulations strongly discourage
housing, commercial, retail and nonindustrial uses in this area.
The City Council adopted the Northeast
Area Specific Plan on (MONTH, DAY),
2026 to guide development of a mixed-use
district combining housing and commercial
uses while preserving existing industrial
legacy within the Northeast area.
Circulation and Scenic Highways Element
10.b
June 08, 2026 Packet Pg. 2470
Streets and
Sidewalk
Standards
(pg. 89)
Local conditions may necessitate
modification and flexibility of street and
sidewalk standards where topography,
location, or other conditions warrant.
Detailed standards for street and sidewalk
improvements, including street trees and
landscaped strips are set forth in San
Carlos Subdivision Ordinance and
Standard Details, Downtown Specific Plan,
Downtown Streetscape Master Plan, and
San Carlos Bicycle and Pedestrian Master
Plan.
Local conditions may necessitate
modification and flexibility of street and
sidewalk standards where topography,
location, or other conditions warrant.
Detailed standards for street and sidewalk
improvements, including street trees and
landscaped strips are set forth in San
Carlos Subdivision Ordinance and
Standard Details, Downtown Specific Plan,
Downtown Streetscape Master Plan, and
San Carlos Bicycle and Pedestrian Master
Plan, and Northeast Area Specific Plan.
Policy CSH-2.2
(pg. 98)
Provide for adequate pedestrian and
bicycle facilities as viable transportation
modes in San Carlos, as set forth in the
Downtown Specific Plan, Downtown
Streetscape Master Plan, and San Carlos
Bicycle and Pedestrian Master Plan.
Provide for adequate pedestrian and
bicycle facilities as viable transportation
modes in San Carlos, as set forth in the
Downtown Specific Plan, Downtown
Streetscape Master Plan, and San Carlos
Bicycle and Pedestrian Master Plan, and
Northeast Area Specific Plan.
Environmental Management Element
Action EM-2.7
(new)
- Require future development projects to
implement the measures of the Creek
Front Zone of the Northeast Area Specific
Plan adopted on (Date) (Resolution 2026-
###).
Environmental Safety and Public Services Element
Action ESPS-2.8
(new)
- Require future development projects to
implement environmental resilience
measures as contained within the
Northeast Area Specific Plan adopted on
(Date) (Resolution 2026-###).
10.b
June 08, 2026 Packet Pg. 2471
BELMONT
PULGAS
RIDGE
BAIR
ISLAND
REDWOOD
CITY
PALOMAR
PARK
CRESTVIEW DR
EDGEWOOD RD
BRAGATO RD
OLD COUNTY RD TAYLOR WY
GLENN WY
CEDAR ST
ARROYO AVE
TAMARACK AVE
GREENWOOD AVE
ORANGE AVE
CAPRINO WY
BELLE AVE
TULIP LN
BRITTAN AVE
PORTOFINO CT
EL SERENO CORTE
CHESTNUT ST ORANGE AVE
E TULIP LN
WALNUT ST
CRESTVIEW DR
CLOVER LN
SUNSET DR
ALAMEDA DE LAS PULGAS
HEWITT DR
BELMONT AVE
OAKHURST AVE
ROCKRIDGE RD
NANETTE DR
PARK AVE
MELENDY DR
CLOVER LN SUNSET DR EATON AVE
ELM ST
LILY LN
HOWARD AVE DAYTON AVE ST FRANCIS WY
GOVER LN CORDILLERAS AVE
BRITTAN AVE EDGEHILL DR
CEDAR ST
SUNNYDALE AVE
WILDWOOD AVE BRITTAN AVE ROGERS AVE PORTO ROSA WY
CRESTVIEW DR ST FRANCIS WY
SUNNYDALE AVE CHESTNUT ST ALAMEDA DE LAS PULGAS
SAN SIMEON WY
PARK AVE
LEWIS RANCH RD
PORTOFINO DR
BROOK ST
OAKHURST AVE
MELENDY DR
CRESTVIEW DR EATON AVE
STANFORD LN HEWITT DR
ALAMEDA DE LAS PULGAS
NORMANDY CT
SUNSET DR
LAUREL ST HILLCREST RD KIRKWOOD WY
BRITTAN AVE
INDUSTRIAL RD
SAN CARLOS AVE
PHELPS RD
WELLINGTON DR
CARMELITA AVE
FAY AVE
MANOR DR
TAMARACK AVE
DOLTON AVE DEVONSHIRE BLVD
DEVONSHIRE CIR CENTER ST
ALLEY
ARROYO AVE
TRILLIUM LN
BELLE AVE
HEMLOCK ST
GLASGOW LN
ALLEY
WOODLAND AVE
STATE HIGHWAY 82
BAUER CT
HYDE PARK AVE
CLIFTON AVE
PALM AVE
COMMERCIAL ST
OLD COUNTY RD
CLUB DR
BEVERLY DR
EXETER AVE
BAYTREE RD
WOODLAND AVE
CENTER ST
BAYSIDE BLVD
CEDAR ST
MEADOWSWEET LN MAYFLOWER LN LYNTON AVE
ROSEWOOD AVE
WHITE OAK WY ELM ST BIRCH AVE
WALNUT ST
KINGS CT
HYDE PARK AVE WINDING WY
ST FRANCIS WY
PROSPECT ST
CHERRY ST
CHESTNUT ST STATE HIGHWAY 82
ALLEY
OLIVE ST
CEDAR ST
HOWARD AVE
ALLEY
LAUREL ST
BELLE AVE
RUTHERDALE AVE
BRITTAN AVE
WALNUT ST
TAMARACK AVE
CORDILLERAS AVE CEDAR ST
DAFFODILL LN
BELVEDERE AVE
CARMELITA AVE
INDUSTRIAL RD
CARMELITA AVE
CAMBRIDGE ST
CORDILLERAS AVE
CLUB DR
WOODLAND AVE
ALLEY
GERANIUM LN OAKLEY AVE
WINDSOR DR
BIRCH AVE ALLEY
BELMONT AVE
TULIP LNMELENDY DR
RICHLAND CT WINGATE AVE
WHITE OAK WY
AZALEA LN
PINE AVE
LAUREL ST
SCHOOL ST
CHESTNUT ST
PHILIP LN
MOLTON AVE
BRITTAN AVE OLD COUNTY RD BAYVIEW AVE
WALNUT ST
HIDDEN VALLEY DR AMERICAN ST
ALLEY
WINDSOR CT ORANGE AVE LAUREL ST
INDUSTRIAL RD
ELM ST
CEDAR ST BING ST
OLD COUNTY RD KINGS CT
GREENWOOD AVE
ALAMEDA DE LAS PULGAS
DALE AVE MORSE BLVD
WALNUT ST
ARROYO AVE
STATE HIGHWAY 82
ALMA ST
AMERICAN ST
POPPY LN
CRESTVIEW DR
CORONADO AVE VISTA DEL GRANDE
BRITTAN AVE
TAMARACK AVE
CHESHAM AVE
ALLEY
HEATHER DR
ALLEY
EL SERENO DR
MANOR DR ALLEY
CLUB DR
ELM ST ROSEWOOD AVE
HONEYSUCKLE LN
OLD COUNTY RD COLEMAN CT
ELSTON CT
ELM ST
ROSEWOOD AVE
CORDILLERAS AVE EUCALYPTUS AVE
BELVEDERE AVE ELM ST
WINDING WY
CHICORY LN
ABERDEEN DR
CENTRAL AVE
LAUREL ST
TRAMANTO DR
CABOT CT
MELENDY DR ST FRANCIS WY CRESTVIEW DR
HUDSON CT
DEBBIE CT
KRISTA LN
TIMOTHY DR
PORTO MARINO DR
ESTATES CT
EDGEHILL DR
PORTO MARINO DR CEDAR ST
QUAIL LN SAN REMO WY WHITE OAK WY
REGENT CT APPIAN WY
HILL WY
FRANCES LN
BRITTAN AVE
CLIFFORD AVE
TIMOTHY DR
QUARRY RD
BRAGATO RD
ENSENADA RD
MONTGOMERY ST
DARTMOUTH AVE
F ST RIVERTON DR
FAIRFIELD DR
INVERNESS DR
DARTMOUTH AVE
INDUSTRIAL RD
BUCKLAND AVE
NORTHAM AVE VINE ST
TAYLOR WY
SPRING ST
STATE HIGHWAY 82
PRIMROSE LN SHELFORD AVE LYNDHURST AVE
MC CUE AVE
CHESTNUT ST
LAUREL ST
CHERRY ST
BAYPORT AVE
LAUREL ST
FAIRFIELD DR
SYLVAN DR
MANZANITA AVE
FIR ST E SAN CARLOS AVE
OLD COUNTY RD
GARDEN LN
ERLIN DR
BARFORD AVE
OAK ST
LAUREL ST
HILLCREST RD
VALLEY RD
BRANSTEN RD
HALL ST
SHELFORD AVE HULL DR
CLIFTON AVE
DARTMOUTH AVE
SPRING ST ELM ST
INDUSTRIAL RD
WYCOMBE AVE
NORTHAM AVE
ACACIA CT MONTGOMERY LN BUCKLAND AVE OLD COUNTY RD EXBOURNE AVE OAK ST
NORTHWOOD DR OLD COUNTY RD
ELM ST
CEDAR ST
ARCH LN
NORTHAM AVE CHERRY LN
HULL DR
LAUREL ST
ANCHOR LN
DARTMOUTH AVE
DARTMOUTH AVE
MC CUE AVE BAYPORT CT
HARTFORD AVE
STATE HIGHWAY 82
DARTMOUTH AVE
SHELFORD AVE
RIVERTON DR
HOLLY ST
E SAN CARLOS AVE BAYPORT CT
MIRAMONTE CT PEPPER LN
BUCKLAND AVE
LAUREL ST
LAUREL ST
WELLINGTON DR
HOLLY ST
HULL DR
ELM ST
BUSH ST
COTTAGE LN
LOMA RD
US HIGHWAY 101
US HIGHWAY 101
SHOREWAY RD
US HIGHWAY 101
HOLLY ST
US HIGHWAY 101
HOLLY ST
SKYWAY RD
MONTE VISTA RD SKYWAY RD
US HIGHWAY 101 US HIGHWAY 101
ALLEY
WALNUT ST
ALTA LN
WELLINGTON DR MANZANITA AVE
SYCAMORE ST
HALL ST INDUSTRIAL RD
CURRY CT
CLIFTON AVE
TERMINAL WY WESSEX WY
OLD COUNTY RD MAGNOLIA AVE
CHESTNUT ST
SYCAMORE ST
SAN CARLOS AVE
SEQUOIA CT CURTIS CT
LAUREL ST ELM ST
MADRONA ST
HIGHLAND AVE
HIGHLAND AVE
WILLIAMS LN
ADAM CT
CLIFTON AVE CLIFTON AVE
CHERRY ST
WALNUT ST
SAN CARLOS AVE
BRANSTEN RD
ALLEY ALLEY ARUNDEL RD
SPRING VALLEY WY
PHELPS RD
ALLEY
CEDAR ST
OLIVE ST
ALLEY
SEQUOIA CT
ARUNDEL RD
ELM ST
CEDAR ST
ALLEY
ALLEY
HOLLY ST
WALNUT ST MONTGOMERY ST
LAUREL ST
SAN CARLOS AVE
ALAMEDA DE LAS PULGAS VINE ST TERMINAL WY
ALLEY
NORTHAM AVE CHESTNUT ST
GLENWOOD ST KENTON AVE
SAN CARLOS AVE
HIGHLAND AVE SHELFORD AVE
WELLINGTON DR
NORTHAM AVE
CHERRY ST
OLD COUNTY RD
MAGNOLIA AVE
SAN CARLOS AVE HIGHLAND CT
TANKLAGE RD HOLLY ST
ELM ST
BARBARA LN
CLUB DR
LYNTON AVE
ELIZABETH ST
WALNUT ST VISTA AVE
ARROYO AVE
INDUSTRIAL RD
KNOLL DR
PLYMOUTH AVE
TRILLIUM LN
BELMONT AVE
ALLEY
LYNTON AVE
WASHINGTON ST
ALLEY
BLUEBELL LN GASLIGHT LN HOWARD AVE BELLFLOWER LN
GREENWOOD AVE
ALLEY
GENEVA AVE
MARIGOLD LN HOWARD AVE GREENWOOD AVE ABERDEEN DR
EUCALYPTUS AVE
ALLEY
SAN CARLOS AVE
SYCAMORE ST
BEVERLY DR
EXETER AVE
HEMLOCK ST
ORANGE AVE
ALLEY
ARROYO AVE
WILLOW GLEN WY
AMERICAN ST
BAYPORT AVE
WOODLAND AVE
CHESTNUT ST
KNOLL DR BING ST
BAYPORT AVE
LAUREL ST
ALLEY
BELMONT AVE
CHESTNUT ST
WINDING WY
BAUER DR
LAUREL ST
SAN CARLOS AVE
PHELPS RD
SAN CARLOS AVE
CHERRY ST WELLINGTON DR
OLIVE ST
ROSEWOOD AVE
WASHINGTON ST WITHERIDGE RD
MALABAR CT
CLUB DR
CORONADO AVE
EL CAMINO REAL
CORDILLERAS AVE
TORINO DR
ALLEY
CENTRAL AVE ELM ST
VISTA AVE
SAN CARLOS AVE
BEVERLY DR ELM ST
CLUB DR
OLD COUNTY RD
ALLEY
CHESTNUT STBAYTREE RD
BRITTAN AVE
CEDAR ST
DEVONSHIRE BLVD VIOLET LN
WALNUT ST
PYXIE LN
TORINO DR
IRIS LN CRESTVIEW DR
CHARLTON ST
MOLTON AVE
PROSPECT ST
CHILTON AVE
CLUB DR
CARMELITA AVE
PLYMOUTH AVE
ALAMEDA DE LAS PULGAS
MADERA AVE WOODLAND AVE GREENWOOD AVE
LAUREL ST
EL CAMINO REAL CENTER ST
BAYPORT AVE
VARIAN ST
ROSLYN AVE ALLEY
ASHFORD AVE
HOWARD AVE WHITE OAK WY
MELENDY DR
QUEENS CT TORINO KNOLLS
ROCKRIDGE RD
OLD COUNTY RD
ALLEY
ARROYO AVE
ALLEY
CORDILLERAS AVE
CARMELITA AVE
BUTTERCUP LN BUTTERCUP LN
INDUSTRIAL RD CORONADO AVE
KNOLL DR
EL CAMINO REAL
EL CAMINO REAL
GLASGOW LN GENEVA AVE
BRAGATO RDGLENN WY
SPRINGFIELD DR SYLVAN DR
INVERNESS DR BAYPORT CT
AIRPORT WY
HOLLY ST
HOLLY ST
CHERRY ST
CHESTNUT ST CEDAR ST
ELM ST
CLUB DR
BAUER DR
LUPIN AVE
BIRCH AVE
ARROYO AVE
ROSEWOOD AVE WALNUT ST
ELM ST
BRITTAN AVE
CHESTNUT ST
MELENDY DR
PORTOFINO DR SUNSET DR BROOK ST
HOWARD AVE
OAKVIEW DR
OAKVIEW DR
RUBY AVE
OAKHURST AVE
BELMONT AVE
CHESTNUT ST
CEDAR ST
ORANGE AVE
OAKHURST AVE LAUREL ST
KELTON AVE
GARNET AVE
HOWARD AVE
LAUREL ST
LEMOORE DR
PORTOFINO DR
HILLTOP DR
LUPIN AVE
DUNDEE LN
CALYPSO LN
CLUB DR
WILSHIRE CT
FAIRMONT AVE
PARK AVE
GAYLORD ST BRITTAN AVE GRACELAND AVE LOS VIENTOS WY
GRACELAND AVE
ALDERLEE WY
DE ANZA AVE DE ANZA AVE
LA MESA DR CRESTVIEW DR ESTRADA PL
PALOMAR DR
CRESTVIEW DR
VINE ST
CHESTNUT ST
EATON AVE
CHESTNUT ST FOREST LN
KELTON AVE
PEARL AVE
CRESTVIEW DR
BRITTAN AVE
DE ANZA AVE LA BARTHE LN
ALAMEDA DE LAS PULGAS
ST FRANCIS WY
MESA LN
MESA VERDE WY
LA MESA DR
SCENIC DR
CARMEL LN
WALTON ST
CEDAR ST
TANKLAGE RD
SPRINGFIELD DR
OLD COUNTY RD
MELENDY DR
BURNHAM CT EMERALD AVE
TERRACE RD
SHERWOOD DR PEARL AVE
GARNET AVE
LOMA CT
BRECON CT LA MESA DR
CLIFFORD AVE
ALBERTA AVE
BEST CT CRESTVIEW DR
FRANCISCAN CT ST FRANCIS WY
LESLIE CT
LESLIE DR
PALOMAR DR PALOMAR DR
ENCINA RD
BAYVIEW AVE
BLOSSOM LN
GRACELAND AVE
GRACELAND LN
WILDWOOD AVE
EDGEHILL DR
HOWARD AVE CEDAR ST
COVENTRY CT
EATON AVE
RUBY AVE
AMBER CT
EATON AVE
HUBBARD AVE
PALOMAR DR
CRESTVIEW CT STEVENS CT
KENT AVE
OAKVIEW DR
TRAMANTO DR
LOCARNO WY
SUDAN LN
PEARL AVE FAIRMONT AVE
CRESTVIEW DR
DEBBIE PL
EATON AVE
ROBIN WY
PALOMAR DR
SCENIC DR
EDMOND DR
VAL MAR PL
BRITTAN AVE
EATON AVE
EMERALD AVE
LA MESA DR
FLEETWOOD DR
PALOMAR DR PALOMAR DR PEBBLE DR
HOSMER CT
CORDILLERAS AVE BRITTAN AVE
MILANO WY
KELTON AVE
PARK AVE
LESLIE DR
GARNET AVE
OAK CREEK LN
NORBURT LN
BANBURY LN
SUSIE LN
CYPRESS CT
PALOMAR DR
CORTEZ RD PALOMAR DR
TRAMANTO DR
NEAL AVE
RIDGE RD
HEWITT DR
BRITTAN AVE
EMERALD AVE
SARA LN
FRANCES LN
BRITTAN AVE
MICHAEL CT
PALOMAR DR
S PALOMAR DR
CRESTVIEW DR
BOW DR
MONTALVO RD CRESTVIEW DR
HILL AVE
TASKER LN
EATON AVE
LOMA RD
CLIFFORD AVE
VICTORIA MANOR
ELVANADA RD
DE ANZA AVE
MAPLE WY
EATON AVE
LAUREL ST
WINDING WY
HILLTOP DR COLTON AVE
HOWARD AVE
MAJORCA WY
ROLAND AVE
DICKENS CT
LOMA LN
LOMA RD
WHITMAN CT
GREENBRIAR RD
WINDING WY
BRITTAN AVE
TORINO DR
ALAMEDA DE LAS PULGAS
EATON AVE
BROMLEY DR
LOMA RD
INDUSTRIAL RD
EATON VILLA PL
ALAMEDA DE LAS PULGAS
CAMBORNE AVE
FAY AVE
CRANFIELD AVE
FIRE ACCESS ROAD
FIRE ACCESS ROAD
BAYVIEW AVE
BAYVIEW AVE HYDE PARK AVE DOLTON AVE
DOLTON AVE
DEVONSHIRE BLVD FAY AVE
WINDSOR DR
BROMLEY DR HULL DR
INDUSTRIAL RD
SHELFORD AVE
DEL REY CT
BAYVIEW AVE
CRESTVIEW DR
RAYMOND CT ROLAND AVE
BRITTAN AVE
LAMSHIN LN
CEDAR ST
HILLCREST RD
MAGNOLIA AVE
CHESHAM AVE
HEATHER DR
LOS CERROS RD
ROYAL LN
EXETER AVE
BAUER DR
ALAMEDA DE LAS PULGAS
CHESTNUT ST
HOWARD AVE
PYROLA LN
EXETER AVE
PORTOFINO DR
WESSEX WY
WHITE OAK WY
PICADILLY CT
CORDILLERAS AVE
HOWARD AVE
HILLCREST RD
HILLCREST RD
UPLAND AVE
SAN CARLOS AVE
SAN MIGUEL WY SOMERSET CT
MELENDY DR
ARUNDEL RD
ST FRANCIS WY
OAKVIEW DR ALBERTA AVE
MADERA AVE
EATON AVE
CLUB DR
LYNTON AVE
COBBLESTONE LN
THORNHILL DR
ELIZABETH ST ASTER RD
DRAKE CT
EATON AVE
GRANITE CT
CHESHAM AVE
BRITTAN AVE
DOVER CT
BRITTAN AVE
EATON AVE CAMELOT CT
GREENBRIAR RD
HIGHLAND AVE ELM ST
INDUSTRIAL RD
DARTMOUTH AVE
CEDAR ST
LA MESA DR
RUBY AVE
TERRACE RD
BRITTAN AVE
CRESTVIEW DR
CHESHAM AVE
MELENDY DR
SUNSET DR
CEDAR ST
WALNUT ST
BEVERLY DR
DEVONSHIRE BLVD
HOWARD AVE
MORSE BLVD
WASHINGTON ST
SORRELL LN
EXETER AVE
EXETER WY
SUNSET DR
FAIRBANKS AVE
CANYON VISTA WY ELIZABETH ST
SHRATTON AVE
TRILLIUM LN
OAK CREEK LN
ROSLYN AVE
EXBOURNE AVE
HILLTOP DR
HERMOSA RD
MONTALVO RD
BELLE ROCHE AVE MONTALVO RD
MONTALVO RD
CORDILLERAS AVE
HIGHLAND AVE
NORTHAM AVE
VISTA DEL GRANDE
CORONADO AVE
WINDSOR DR
SUNNYDALE AVE
EL CAMINO REAL
EL CAMINO REAL
EL CAMINO REAL
EL CAMINO REAL
FIRE ACCESS ROAD
CANYON VISTA WAY
PARK ACCESS
PARK ACCESS
ARUNDEL RD
GATEWAY CT
CIRCLE STAR WY
MIRABEL PL
DEER LN
CERVANTES RD
CERVANTES RD
DUGGAN RD
DUGGAN RD
DUGGAN CT
S PALOMAR DR
BELLE ROCHE CT
BELLE ROCHE CT
PALOMAR OAKS LN
RATHGAR CT
Airport
General Commercial - Industrial
Mixed Use, 30-40 DUs/Ac
Mixed Use, 38-50 DUs/Ac
Mixed Use, 90-120 DUs/Ac
Multi-Family, 15-20 DUs/Ac
Multi-Family, 75-100 DUs/Ac
Neighborhood Retail
Neighborhood Retail/Mixed Use, 75-120 DUs/Ac
Park
Planned Industrial
Public
Single Family, 6 DUs/Ac
Single Family, 3 DUs/Ac
City Boundary
APRIL 2026 0 1000 2000 4000
FEET Source: City of San Carlos, 2026; CALCAD, 2026
Open Space - Schools
Open Space
Multi-Family, 45-59 DUs/Ac
Mixed Use, 75-100 DUs/Ac
CITY OF SAN CARLOS GENERAL PLAN MAP
Mixed Use, 57-75 DUs/Ac
Mixed Use, 68-90 DUs/Ac
10.b
June 08, 2026 Packet Pg. 2472
Brittan Creek Cordilleras Creek
Pulgas Creek
Quarry Road Bragato Rd Taylor Wy
Sylvan Dr Holly St
Bransten Rd Tanklage Rd Hall St
American St Washington St Bing St
Old County Rd
Shoreway Rd
El Camino Real
Hull Dr
Vine St
Laurel St Walnut St Elm St San Carlos Ave Olive St Arroyo Ave Morse Blvd Brittan Ave Howard Ave Belmont Ave
St Francis Wy
Eaton Ave
Park Ave
De Anza Ave
Ridge Rd
Bromley Dr
Edgewood Rd
Graceland Ave
Greenbrier Rd
Drake Ct Cabot Ct
Crestview Dr
Devonshire Blvd Alameda De Las Pulgas Cordilleras Ave Knoll Dr Cedar St Edgehill Dr Orange Ave
Madera Ave
Arundel Ave
Chestnut Ave
Shelford Ave
Dartmouth Ave
Club Dr
Exeter Ave
Highland Ave
Melendy Dr
Hewitt Dr
Coronado Ave
Skyway Dr Industrial Rd
Belmont Creek
Belmont
Devonshire
Pulgas Ridge
San Mateo County
Palomar Park
Redwood City
Bair Island
0 0.25 0.5 Miles NORTH
City Limit
Sphere of Influence Areas Downtown
Laurel Street (South of Arroyo Street)
East Side Area
Northeast Area Specific Plan Area
Residential Neighborhoods West of El Camino Real
FIGURE 3-3
Major Developed Areas
in San Carlos
El Camino Real
10.b
June 08, 2026 Packet Pg. 2473
ORDINANCE NO. ____
AN ORDINANCE OF THE CITY OF SAN CARLOS
AMENDING THE SAN CARLOS ZONING MAP AND MUNICIPAL CODE TITLE 18 - ZONING, REPEALING CHAPTER 18.14A, REMOVING REFERENCES TO CHAPTER 18.14A WITHIN CHAPTER 18.07 AND CHAPTER 18.30, ADDING CHAPTER 18.14.2 TO CODIFY THE NORTHEAST AREA SPECIFIC PLAN, AND AMENDING CHAPTER 18.19.
SECTION 1: Findings. The City Council of the City of San Carlos does hereby finds and declares as follows:
WHEREAS, the City Council adopted the 2022 Strategic Work Plan that included a Strategic Objective for preparation of the Northeast Area Specific Plan and reaffirmed this Strategic Objective in subsequent Strategic Work Plans including the 2026 Strategic Work Plan; and
WHEREAS, in April 2022 the City Council authorized a development moratorium for the northeast area that was in effect until April 2024; and WHEREAS, in March 2024, the City Council adopted amendments to Title 18 of the San Carlos Municipal Code Chapters 18.07 Industrial Districts and 18.30 Use Permits and added Chapter 18.14A Northeast Area Overlay District for the establishment of the Northeast Area Overlay District; and
WHEREAS, in September 2022 the City Council approved a professional services agreement with Perkins&Will for consulting services to prepare a Northeast Area Specific Plan (“Specific Plan”) and Environmental Impact Report (“EIR”), in response to the City Council’s Strategic Objective to develop a plan that includes policies and strategies for development and housing in the northeast area; and
WHEREAS, between February 2023 through July 2025, 30 different civic engagement opportunities inclusive of focus group meetings, pop-up events, open-houses, community workshops, and study sessions with the City Council and Planning and Transportation Commission were held to receive input on the Specific Plan; and WHEREAS, on February 12, 2024, the City Council endorsed the preferred land use scenario for the Northeast Area Specific Plan that determines the anticipated buildout of land uses in the Northeast Area Specific Plan boundary through the year 2045 that introduces housing to advance a vision for a new mixed use district; and
WHEREAS, a Public Draft of the Northeast Area Specific Plan was available for public review in April 2025 and was presented to the Planning and Transportation Commission in April 2025 and to the City Council in May 2025 and September 2025 who directed modifications to the Specific Plan; and
WHEREAS, in April 2026 following input from the Planning and Transportation Commission and the City Council, the Final Draft Northeast Area Specific Plan was available for public review outlining a complete vision and guiding principles for the northeast area with refined land uses and development standards; and
10.b
June 08, 2026 Packet Pg. 2474
WHEREAS, amendments to the Zoning Map and Zoning Ordinance are necessary to ensure consistency with the Northeast Area Specific Plan and to implement its overall vision; and WHEREAS, amendments to the Zoning Map include rezoning sites to Production and Innovation, Mixed-Use Northeast - 75 dwelling units per acre (MU-NE-75), and Mixed-Use Northeast - 90 dwelling units per acre (MU-NE-90) are necessary to ensure consistency with the zoning designations identified in the Northeast Area Specific Plan and the preferred land use scenario; and
WHEREAS, amendments to the Zoning Ordinance include repealing Chapter 18.14A Northeast Area Overlay District, the Northeast Area Overlay District, and removing references to Chapter 18.14A in Chapter 18.07 Industrial Districts and Chapter 18.30 Use Permits because the purpose of the Northeast Area Overlay District and associated references were to manage development while the Northeast Area Specific Plan was being prepared; and WHEREAS, amendments to the Zoning Ordinance include establishing Chapter 18.14.2 Northeast Area Specific Plan to codify and provide reference to the Northeast Area Specific Plan; and
WHEREAS, amendments to the Zoning Ordinance include revisions to Chapter 18.19 Nonconforming Uses, Structures, and Lots to provide more permissive regulations for nonconforming uses and structures for parcels subject to the Northeast Area Specific Plan; and WHEREAS, pursuant to Government Code Sections 65853 and 65850 and San Carlos Municipal Code Chapter 18.35.050, when a change in the Zoning Ordinance (Title 18 of the San Carlos Municipal Code) is found necessary, the Planning and Transportation Commission shall hold a public hearing to consider such change and render its decision to the City Council; and WHEREAS, on May 18, 2026, the Planning and Transportation Commission held a duly noticed public hearing and adopted Resolution No. PTC2026-06 recommending that the City Council introduce an Ordinance to amend the San Carlos Zoning Map, and the San Carlos Municipal Code, Title 18, Zoning repealing Chapter 18.14A, removing references to Chapter
18.14A within Chapter 18.07 and Chapter 18.30, adding Chapter 18.14.2 to codify the Northeast Area Specific Plan, and amending Chapter 18.19; and
WHEREAS, on May 28, 2026, the City mailed a public notice to all property owners and occupants/tenants within the Specific Plan boundary and within 300 feet of the Specific Plan boundary informing stakeholders of the proposed adoption of the Northeast Area Specific Plan project; and
WHEREAS, on May 29, 2026, a legal notice was published in the local newspaper informing stakeholders of the proposed adoption of the Northeast Area Specific Plan project; and
WHEREAS, on June 8, 2026, the City Council adopted a Resolution certifying the Environmental Impact Report for the Northeast Area Specific Plan; and WHEREAS, on June 8, 2026, the City Council adopted a Resolution amending the General Plan Land Use Map, Land Use Element, Circulation and Scenic Highways Element,
10.b
June 08, 2026 Packet Pg. 2475
Environmental Management Element, and Environmental Safety and Public Services Element; and
WHEREAS, on June 8, 2026, the City Council held a duly noticed public hearing to consider the Planning and Transportation Commission’s recommendation to introduce an Ordinance to amend the San Carlos Zoning Map, and the San Carlos Municipal Code, Title 18, Zoning repealing Chapter 18.14A, removing references to Chapter 18.14A within Chapter 18.07 and Chapter 18.30, adding Chapter 18.14.2 to codify the Northeast Area Specific Plan, and amending Chapter 18.19.
SECTION 2: Pursuant to SCMC Section 18.35.080 Criteria for Zoning Amendments, the City Council finds that the proposed zoning amendment included in this Ordinance meets the following criteria:
A. Zoning Ordinance Text Amendment Findings:
1. The proposed Ordinance amendments are consistent with the General Plan.
Basis for Finding: The General Plan, as amended on November 24, 2025, recognizes that the Northeast Area Specific Plan was underway. The 2045 General Plan Reset project (adopted on May 27, 2025) also accounted for the Northeast Area Specific Plan buildout. The associated General Plan amendments also ensure consistency with the Northeast Area Specific Plan’s vision and guiding principles. Through these concurrent amendments, policy consistency among the Northeast Area Specific Plan, Zoning Ordinance, and General Plan are upheld.
2. The ordinance amendment is consistent with the purpose of San Carlos Municipal Code, Title 18, to promote the growth of the City in an orderly manner and to promote and protect the public health, safety, peace, comfort and general welfare.
Basis for Finding: The purpose of the proposed amendments to the Zoning Ordinance is to guide growth in the Northeast Area in a deliberate and coordinated manner.
Alignment of the land use regulations, policies, and development standards of the Northeast Area Specific Plan with the Zoning Ordinance ensure that this overall purpose is met.
B. Zoning District Boundary Amendment Findings:
1. The change in district boundaries is consistent with the General Plan.
Basis for Finding: The proposed Zoning designations identified in the Northeast Area Specific Plan are consistent with the concurrent amendments to the General Plan Land Use designations. More specifically, properties rezoned to MU-NE-75 would align with the proposed Mixed Use 57-75 du/ac designation; and properties rezoned to MU-NE90 would align with the proposed Mixed Use 68-90 du/ac designation. Properties rezoned to Production and Innovation would continue to align with their existing Planned Industrial General Plan land use designation.
2. The change in district boundaries is consistent with the purpose of this title to promote the growth of the City in an orderly manner and to promote and protect the public health, safety, peace, comfort and general welfare.
10.b
June 08, 2026 Packet Pg. 2476
Basis for Finding: The proposed Zoning designations identified in the Northeast Area Specific Plan are necessary to uphold consistency with the Northeast Area Specific Plan’s vision and guiding principles, which include the incorporation of new land uses including housing. The Northeast Area Specific Plan and corresponding Zoning designations have been designed to promote a safe, comfortable, and vibrant mixed use district.
3. The change in district boundaries is necessary to achieve the balance of land use desired by the City, consistent with the General Plan, and to increase the inventory of land within a given zoning district.
Basis for Finding: The proposed Zoning designations identified in the Northeast Area Specific Plan are consistent with the preferred land use scenario endorsed by the City Council. This includes intensified commercial uses and the allowance for housing that would allow development potential of approximately 4.5 million square feet of commercial uses and 1,890 housing units where no housing exists currently.
Properties rezoned to MU-NE-75 and MU-NE-90 specifically have been identified as optimal sites for housing in the Northeast Area given their proximity to residential uses to the south. These amendments would expand the City’s opportunity to provide more housing where no housing currently exists in favor of a new, vibrant mixed use district.
SECTION 3: Addition of Code. San Carlos Municipal Code, Title 18, Chapter 18.14.2 (Northeast Area Specific Plan) is hereby added with the language in Exhibit B.
SECTION 4: Removal of Code. San Carlos Municipal Code, Title 18, Chapter 18.14A (Northeast Area Overlay District) and references to Chapter 18.14A in Chapter 18.07 (Industrial Districts) and Chapter 18.30 (Use Permits) are hereby removed.
NOW, THEREFORE BE IT RESOLVED by the City Council of the City of San Carlos as follows:
SECTION 5: The City Council hereby approves the Zoning Map Amendments attached as Exhibit A and the Municipal Code Ordinance amendments attached as Exhibit B and Exhibit C.
SECTION 6: CEQA. An Environmental Impact Report (EIR) for the Northeast Area Specific Plan was prepared in accordance with California Environmental Quality Act (“CEQA”) Guidelines Section 15060(d). The EIR identified potentially significant and unavoidable environmental effects that could result from implementation of the Northeast Area Specific Plan related to air quality and greenhouse gas emissions. Having received, reviewed, and considered the information in the EIR, as well as the supporting administrative record, the City Council adopted and made Statement of Overriding Considerations regarding the significant, unavoidable impacts of the Northeast Rea Specific Plan and the anticipated benefits of the project and adopted a Resolution certifying the EIR for the Northeast Area Specific Plan on June 8, 2026.
SECTION 7: Severability. The City Council hereby declares that it would have passed this Ordinance sentence by sentence, paragraph by paragraph, and section by section, and does hereby declare that any provisions of this Ordinance are severable and if for any reason any sentence, paragraph or section of this Ordinance shall be held invalid, such decision shall not affect the validity of the remaining parts of this Ordinance.
10.b
June 08, 2026 Packet Pg. 2477
SECTION 8: Publication and Effective Date. This Ordinance shall be published and posted according to law and shall take effect and be in force from and after 30 days after its passage and adoption.
* * * *
I, City Clerk Crystal Mui, hereby certify that the foregoing Ordinance was introduced on the 8th day of June 2026 and passed and adopted as an Ordinance of the City Council of the City of San Carlos at a regular meeting thereof held on the ____ day of ____, 2026 by the following vote:
________________________________
CITY CLERK of the City of San Carlos
APPROVED:
____________________________
MAYOR of the City of San Carlos
Exhibits:
A. Zoning Map Amendments
B. Chapter 18.14.2 Northeast Area Specific Plan
C. Amendments to Chapter 18.19 Nonconforming Uses, Structures, and Lots (track changes) AYES, COUNCILMEMBERS:
NOES, COUNCILMEMBERS:
ABSENT, COUNCILMEMBERS:
10.b
June 08, 2026 Packet Pg. 2478
BRAGATO RD
OLD COUNTY RD TAYLOR WY
GLENN WY
QUARRY RD
BRAGATO RD
F ST RIVERTON DR
FAIRFIELD DR
INVERNESS DR
TAYLOR WY
SPRING ST
STATE HIGHWAY 82
LAUREL ST
FAIRFIELD DR
SYLVAN DR
LAUREL ST
SPRING ST ELM ST
INDUSTRIAL RD
NORTHWOOD DR OLD COUNTY RD
HULL DR
LAUREL ST RIVERTON DR
HOLLY ST
ELM ST
US HIGHWAY 101
US HIGHWAY 101
SHOREWAY RD
US HIGHWAY 101 US HIGHWAY 101
EL CAMINO REAL
BRAGATO RDGLENN WY
SPRINGFIELD DR SYLVAN DR
INVERNESS DR BAYPORT CT
HOLLY ST CHESTNUT ST CEDAR ST
CHESTNUT ST
CEDAR ST
SPRINGFIELD DR
OLD COUNTY RD
INDUSTRIAL RD
INDUSTRIAL RD
US HIGHWAY 101
BRAGATO RD
TAYLOR WY
GLENN WY
QUARRY RD
BRAGATO RD
F ST RIVERTON DR
FAIRFIELD DR
INVERNESS DR
TAYLOR WY
SPRING ST
STATE HIGHWAY 82
LAUREL ST
FAIRFIELD DR
SYLVAN DR
LAUREL ST
SPRING ST ELM ST
INDUSTRIAL RD
NORTHWOOD DR OLD COUNTY RD
HULL DR
LAUREL ST RIVERTON DR
HOLLY ST
ELM ST
US HIGHWAY 101
US HIGHWAY 101
SHOREWAY RD
US HIGHWAY 101 US HIGHWAY 101
CHESTNUT ST
CEDAR ST
SPRINGFIELD DR
OLD COUNTY RD
INDUSTRIAL RD
INDUSTRIAL RD
EL CAMINO REAL
BRAGATO RDGLENN WY
SPRINGFIELD DR SYLVAN DR
INVERNESS DR BAYPORT CT
HOLLY ST CHESTNUT ST CEDAR ST
1031
135
26 590
964
301
1000
1003
992
1051
42-44
551
965
221
1056
90 351
159
279
259
551
970
1036
1007
1008
975
1200
33 266
151
1028
21 551
120
210
1011
1060
999
66 7
83 327
54 1027
335 1023
96 1020
331
686
17 355
989
476
1040
81 240
147
307
917
58 81
1015
1032
50 1039
1250
1210
935
5 633
301
1 90
100
1043
946
315
995
12 161
349
354
1011
58 57
1048
195
73 40
291
1011
317
90 1003
1036
1003
620
1004
1015
1016
641
287-A
1501
595
243
57 1039
100
1008
285
1040
991
996
217
1201
1016
1052
1000
188
41 219
1043
370
1048
75 145
34 41
992
84 991
41 1055
64 1048
50 71
987
1047
1 201
1016
923
958
1027
235
11 363
500-550
80 1007
280
1044
1011
1019
73 26
1052
111
9 1027
952
1020
1015
251
1040
49 300
555
1020
405
1028
57 156
1032
1012
1211
1011
995
1015
303
601
1004
58 150
1020
1036 112
66 60
1035
34 585
1051
585
370
239
80 270
100
1024
18-20
247
979
1028
1027
1035
72 1007
151
611
580
610
89 1056
370
50 151
1047
999
988
311
195
1023
74 1032
983
1044
934
1035
1003
359
181
81 1321
1016
360
1019
255
129 17
1031
995
1008
988
1000
1008
907
65 180
70 1330
309 8
74 1007
996
319
999
1 49
128
24 1340
380
1012
49 1048
101
2 928
11 987
999
323
100
1023 96
979
1004
360
1047
380
191
295
1052 976
1056
50 947
63 18
82 25
1036
251
339
1012
1035
1310
367
1055
941
991
1039
988
996
1015
371
1004
343
1044
1024
1019
980
1044
1023
1055
906
41 1024
66 26
611
299
1020
58 71
1320
1350
390
65 307
161
23 78
333
1043
1031
201
1007
1016
75-125
565
171
315
987
1031
541
95 305
1012
333
984
990
983
1056
400
311
320
1019
4 1024
1032
1051
10 209
67 295
34 66
131
79 959
1040
984
1023
940
1024
445
87 1052
205
42 347
1028
929
982
1360
360
171
283
591
1019
1043
1028
90 171
1032
1039
535
550
1036
953
33 268
501
PD-17
MU-NB-120
MU-N-120 PD-23
PD-18
PD-2
IP
PD-21
IH
RS-6
LC
NR RM-100
PD-7
PD-27
PD-28
P-I
RS-6
PD-30
P-I
MU-NE-90
MU-NE-75
P-I
Proposed Zoning Amendment
From: IL , Light Industrial
To: MU-NE-75 , Mixed Use Northeast
MU-NE-90 , Mixed Use Northeast
P-I , Production and Innovation
Northeast Area Specific Plan Boundary
APRIL 2026
Source: City of San Carlos, 2026; CALCAD, 2026
Belmont
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June 08, 2026 Packet Pg. 2479
Chapter 18.14.2
NORTHEAST AREA SPECIFIC PLAN
Sections:
18.14.2.010 Purpose.
18.14.2.020 Applicability.
18.14.2.030 Procedures.
18.14.2.040 Consistency with Northeast Area Specific Plan.
18.14.2.050 Northeast Area Specific Plan contents and chapters.
18.14.2.010 Purpose.
The Northeast Area Specific Plan establishes a comprehensive framework to guide the long-term development in the Northeast Area envisioning a mixed-use district merging traditional industry, innovation, environmental resiliency, and inclusive community life. The purpose of this chapter is to provide regulations and reference to the Northeast Area Specific Plan governing land use and urban form, mobility and parking, and environmental resilience within the Northeast Area.
18.14.2.020 Applicability.
The Northeast Area Specific Plan applies to all areas as delineated in the map below.
Figure 1. Northeast Area Specific Plan Boundary
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June 08, 2026 Packet Pg. 2480
18.14.2.030 Procedures.
A. Administrative Regulations. All applications and permits subject to the Northeast Area Specific Plan shall be subject to the administrative regulations including discretionary entitlement applications and other permits in Article IV of the Municipal Code.
B. Planning Authorities. All applications and permits subject to the Northeast Area Specific Plan shall be subject to approval by the bodies, oƯicials, and administrators set forth in Chapter 18.26.
C. Common Procedures. Approval of all applications and permits subject to the Northeast Area Specific Plan shall be subject to procedures that are common to the application and processing of all permits and approvals set forth in Chapter 18.27.
18.14.2.040 Consistency with Northeast Area Specific Plan.
A. Findings. In addition to required findings pursuant to applicable entitlement applications, no application or permit may be approved, no local public works project may be approved, no tentative map or parcel map for which a tentative map was not required may be approved, no zoning ordinance may be adopted or amended within in area covered by the Northeast Area Specific Plan unless they are consistent with the adopted Northeast Area Specific Plan.
B. Conflict. All provisions of the Municipal Code that are not expressly modified or superseded by the Northeast Area Specific Plan shall continue to apply within the Northeast Area. In the event of a conflict between provisions of the Northeast Area Specific Plan and Title 18 of the Municipal Code, the Northeast Area Specific Plan shall prevail.
C. Amendments. The Northeast Area Specific Plan may be amended as often as deemed necessary by the City Council.
18.14.2.050 Northeast Area Specific Plan contents and chapters.
A. The Northeast Area Specific Plan (available online and at City Hall upon request) is organized into the following sections and chapters:
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June 08, 2026 Packet Pg. 2481
1. Introduction;
2. Vision;
3. Existing Conditions;
4. Land Use and Urban Form;
5. Mobility and Parking;
6. Environmental Resilience;
7. Implementation.
10.b
June 08, 2026 Packet Pg. 2482
Chapter 18.19
NONCONFORMING USES, STRUCTURES, AND LOTS
Sections:
18.19.010 Purpose.
18.19.020 Applicability.
18.19.030 Establishment of lawful nonconforming uses, structures and lots.
18.19.040 Continuation and maintenance of nonconforming structures.
18.19.050 Additions and enlargements to nonconforming structures.
18.19.060 Expansion of nonconforming uses.
18.19.070 Changes and substitutions of nonconforming uses.
18.19.080 Repair and replacement of damaged or destroyed nonconforming buildings.
18.19.090 Abandonment of nonconforming uses.
18.19.100 Abatement.
18.19.010 Purpose.
This chapter is intended to permit continuation of uses and continued occupancy and maintenance of structures that were legally established but do not comply with all of the standards and requirements of this title in a manner that does not conflict with the General Plan. To that end, the chapter establishes the circumstances under which a nonconforming use or structure may be continued or changed and provides for the removal of nonconforming uses and structures when their continuation conflicts with the General Plan and public health, safety, and general welfare. (Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.020 Applicability.
The provisions of this chapter apply to structures, land, and uses that have become nonconforming by adoption of the ordinance codified in this title as well as structures, land, and uses that become nonconforming due to subsequent amendments to its text or to the Zoning Map.
A. Nonconforming structures and uses include:
1. Those made nonconforming by the addition of a standard or requirement previously not required for such use or structure; and
2. Uses and structures reclassified from permitted to being subject to a discretionary permit.
B. Nothing contained in this chapter shall be deemed to require any change in the plans, construction, or designated use of any building or structure for which a building permit has
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June 08, 2026 Packet Pg. 2483
properly been issued, in accordance with the provision of ordinances then in eƯect and upon which actual construction has been started prior to the eƯective date of the ordinance codified in this title; provided, that in all such cases, actual construction shall be diligently carried on until completion of the building or structure. (Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.030 Establishment of lawful nonconforming uses, structures and lots.
Any lawfully established use, structure, or lot that is in existence on the eƯective date of the ordinance codified in this title or any subsequent amendment but does not comply with all of the standards and requirements of this title shall be considered nonconforming.
Nonconforming uses and structures may only be continued subject to the requirements of this chapter.
A. Nonconformities, Generally. A nonconformity may result from any inconsistency with the requirements of this title including, but not limited to, location, density, floor area, height, yard, usable open space, buƯering, performance standards, or the lack of an approved use permit or other required authorization. A use or structure shall not be deemed nonconforming solely because it does not conform with the parking and loading space dimension standards, landscape planting area, or screening regulations of the district in which it is located or does not conform to the standards for the following building features: garage door location; garage door width; cornices, eaves, and other ornamental features that exceed maximum projections into required yards; or bay windows, balconies, and terraces above the second floor that exceed maximum projections into required yards.
Also see Section 18.20.030(B), Nonconforming Parking or Loading.
B. Nonconforming Lots. Any lot that is smaller than the minimum lot size required by this title or does not meet any of the applicable dimensional requirements shall be considered a lawful nonconforming lot if it is described in the oƯicial records on file in the oƯice of the San Mateo County Recorder as a lot of record under one ownership. A nonconforming lot may be used as a building site subject to compliance with all applicable requirements, unless a variance or other modification or exception is approved as provided for in this title.
C. Airport Hazards. No permit shall be granted that would allow the establishment or creation of an airport hazard or permit a nonconforming structure or nonconforming use to be made or become higher or become a greater hazard to air navigation than it was when the applicable regulation was adopted or than it is when the application for a permit is made. (Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.040 Continuation and maintenance of nonconforming structures.
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Lawful nonconforming structures may be continued and maintained in compliance with the requirements of this section unless deemed by the Building OƯicial to be a public nuisance because of health or safety conditions.
A. Right to Continue. Any use or structure that was lawfully established prior to the eƯective date of the ordinance codified in this title or of any subsequent amendments to its text or to the Zoning Map may only be continued and maintained provided there is no alteration, enlargement, or addition to any building or structure; no increase in occupant load; nor any enlargement of the area, space, or volume occupied by or devoted to such use, except as otherwise provided in this chapter. The right to continue a nonconforming use or structure shall attach to the land and shall not be aƯected by a change in ownership.
No substitution, expansion, or other change in use and no alteration or other change in structures is permitted, except as otherwise provided in this chapter.
B. Maintenance and Nonstructural Repairs. Maintenance, nonstructural repairs and nonstructural interior alterations to a nonconforming structure are permitted if the changes and improvements do not enlarge or extend the structure.
C. Structural Repairs. Structural repairs that do not enlarge or extend the structure, including modification or repair of building walls, columns, beams, or girders, may be permitted only when the Building Division determines that such modification or repair is immediately necessary to protect public health and safety, occupants of the nonconforming structure, or occupants of adjacent property, and when the cost of such work does not exceed fifty percent of the appraised value of the nonconforming structure.
D. Metal Structures. Metal structures that do not conform to the Building and Fire Code shall be improved so as to comply with the Building and Fire Code standards or removed.
Prior to the issuance of a building permit or zoning clearance for an alteration, change in occupancy, change in ownership or repair of damage by fire or disaster to a nonconforming metal structure, the property owner shall enter into an agreement with the City providing that the structure shall be improved or altered to comply with the City Building and Fire Codes, or shall be removed within fifteen years of the agreement date. This provision shall be imposed:
1. When a change in occupancy (as defined by the Uniform Building Code) is proposed for more than fifty percent of the gross floor area of the building;
2. When the building or property ownership changes; or
3. When the building is damaged by fire or other disaster to an extent of more than fifty percent of its appraised value. (Ord. 1438 § 4 (Exh. A (part)), 2011)
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June 08, 2026 Packet Pg. 2485
18.19.050 Additions and enlargements to nonconforming structures.
Nonconforming structures may be enlarged or extended in compliance with all applicable laws subject to the following provisions:
A. Additions Generally. Additions to and/or enlargements of nonconforming structures are allowed, and no use permit is required, if the addition or enlargement complies with all applicable laws and requirements of this Code and if the existing use of the property is conforming.
B. Residential Additions. Additions or enlargements may be made to a building that is designed for and used as a residence without requiring any additional parking space or changes to an existing driveway; provided, that such alterations or enlargements neither trigger the need for additional parking pursuant to Chapter 18.20, Parking and Loading, nor occupy the only portion of a lot that can be used for required parking or access to parking.
C. Accessory Dwelling Units. Notwithstanding the requirements of subsection B of this section, an accessory dwelling unit in compliance with Section 18.23.210, Accessory dwelling units/junior accessory dwelling units, may be developed on a lot that contains a single-unit dwelling that is nonconforming with respect to development standards.
D. EƯect of Nonconforming Setbacks. For the purpose of additions in any residential district, maintaining an existing nonconforming setback shall not be considered an increase in the discrepancy; provided, that:
1. Such maintenance is consistent with the provisions under Sections 18.19.040(B) and (C);
2. In no case shall any existing setback of less than three (3) feet be considered legal for the purposes of this chapter; and
3. Any residential additions shall conform to the setbacks in eƯect at the time the application for the addition is submitted.
E. EƯect of Excessive Lot Coverage. Additions to or enlargements of nonconforming structures that exceed the maximum allowable lot coverage require approval of a variance pursuant to the provisions of Chapter 18.32, Variances, if the addition or enlargement would increase the lot coverage. (Ord. 1566 (Exh. B (part)), 2020: Ord. 1480 (Exh. C (part)), 2015: Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.060 Expansion of nonconforming uses.
No lawful nonconforming use may be expanded without the approval of a use permit, subject to the following requirements:
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June 08, 2026 Packet Pg. 2486
A. Within a Conforming Structure. A nonconforming use occupying a portion of a structure that conforms to this title may expand the portion that it occupies with Zoning Administrator approval of a minor use permit in accord with Chapter 18.30, Use Permits.
B. Expansion within a Structure That Does Not Conform to This Title. A nonconforming use in a structure that does not conform to the requirements of this title but does conform to the requirements of the Building Code may expand its occupancy and building floor area subject to Zoning Administrator approval of a minor use permit in accord with Chapter 18.30, Use Permits; provided, however, that the expansion meets the requirements of this title.
C. Expansion within a Structure That Does Not Conform to the Building Code. Any nonconforming use in a structure that does not conform to the Building Code may not expand the area it occupies until and unless the structure is brought into conformance with all applicable Building Code requirements. (Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.070 Changes and substitutions of nonconforming uses.
No lawful nonconforming use shall be changed to a diƯerent use type or subclassification without the approval of a use permit unless the new use is permitted by right in the zoning district. This requirement does not apply to a change of ownership, tenancy, or management where the new use is of the same use type and use classification, if applicable, as the previous use, as defined in Chapter 18.40, Use Classifications, and the use is not expanded or intensified.
A. Change from Nonconforming to Permitted Use. Any nonconforming use may be changed to a use that is allowed by right in the district in which it is located and complies with all applicable standards for such use.
B. Absence of Permit. Any use that is nonconforming solely by reason of the absence of a use permit may be changed to a conforming use by obtaining a minor use permit pursuant to the requirements in Chapter 18.30, Use Permits.
C. Substitutions. The Zoning Administrator may allow substitution of a nonconforming use with another nonconforming use, subject to approval of a minor use permit. In addition to any other findings required by this title, the Administrator must finding that:
1. The existing nonconforming use was legally established;
2. The proposed new use would not preclude or interfere with implementation of the General Plan or any applicable adopted specific, area, or community plan;
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June 08, 2026 Packet Pg. 2487
3. The proposed new use will be no less compatible with the purposes of the district and surrounding uses that comply with the requirements of this title than the nonconforming use it replaces;
4. The proposed new use will not be detrimental to the health, safety, peace, comfort, or general welfare of persons residing or working in the surrounding area or be detrimental or injurious to property and improvements of adjacent lots, the surrounding area, or the neighborhood because of noise, odors, dust, glare, vibrations, or other eƯects; and
5. The proposed new use will comply with all applicable standards of the district and City-wide standards, there are special circumstances peculiar to the property and its relation to surrounding uses or to the district itself that would justify modification to applicable standards, or the impacts of the new use will be mitigated. (Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.080 Repair and replacement of damaged or destroyed nonconforming buildings.
A lawful nonconforming building or structure that is damaged or partially destroyed by fire, explosion, earthquake, or natural disaster which is not caused by an act or deliberate omission of a property owner, their agent, or person acting on their behalf or in concert with, may be restored or rebuilt subject to the following provisions.
A. Restoration When Damage Is Fifty Percent or Less of Value. If the cost of repair or reconstruction does not exceed fifty percent of the appraised value of the building or structure replacement of the damaged portions of the building is allowed by right; provided, that the replaced portions are the same size, extent, and configuration as previously existed. The determination of the appraised value shall be made by a professional appraiser selected by the City, whose fee shall be paid by the building owner.
B. Restoration When Damage Exceeds Fifty Percent of Value. If the cost of repair or reconstruction exceeds fifty percent of the appraised value of the building or structure, as determined pursuant to subsection A of this section, the land and building shall be subject to all of the requirements of this title, except as provided below:
1. Nonresidential Structures. The Planning and Transportation Commission may approve a conditional use permit for the structure to be rebuilt to the same size, extent, and configuration as previously existed. In such cases any expansion or change to the previous use must conform to the requirements of this chapter.
2. Residential Structures. Any nonconforming residential use may be reconstructed, restored, or rebuilt up to the size and number of dwelling units prior to the damage and
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June 08, 2026 Packet Pg. 2488
the nonconforming use, if any, may be resumed subject to a zoning clearance in the case of single-unit dwellings or a conditional use permit approval in the case of other residential uses, unless the Zoning Administrator finds that:
a. The reconstruction, restoration, or rebuilding will be detrimental or injurious to the health, safety, or general welfare of persons residing or working in the neighborhood, or will be detrimental or injurious to property and improvements in the neighborhood; or
b. The existing nonconforming use of the building or structure can be more appropriately moved to a zoning district in which the use is permitted, or that there no longer exists a district in which the existing nonconforming use is permitted.
3. Any reconstruction, restoration, or rebuilding undertaken pursuant to this section shall conform to all applicable Building Code requirements, and a building permit must be obtained within two years after the date of the damage or destruction. (Ord. 1612 § 1 (Exh. A), 2024; Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.090 Abandonment of nonconforming uses.
No nonconforming use may be resumed, reestablished, reopened or replaced by any other nonconforming use after it has been abandoned or vacated for a period of six months, except as provided for in this section.
A. Abandonment. The six-month period shall commence when the use ceases and any one of the following occurs:
1. The site is vacated;
2. The business license lapses;
3. Utilities are terminated; or
4. The lease is terminated.
B. Reestablishment. The nonconforming use of a legally established structure may be reestablished if the Planning and Transportation Commission approves a conditional use permit after making all the following findings in addition to any other required findings. As a condition of approving the resumption of such nonconforming use, the Commission may impose a time limit on its duration if necessary in order to make the required findings.
1. The structure cannot be used for any conforming use because of its original design or because of lawful structural changes made for a previous nonconforming use;
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June 08, 2026 Packet Pg. 2489
2. The structure can be reasonably expected to remain in active use for a period of twenty years without requiring repairs or maintenance in excess of fifty percent of the replacement cost of the structure, as determined by the Building OƯicial, within any five-year period; and
3. The continuation of the use or structure will not be incompatible with or detrimental to surrounding conforming uses.
C. Abandonment in the Northeast Area Specific Plan Area. No nonconforming use subject to Chapter 18.14.2, Northeast Area Specific Plan, may be resumed, reestablished, reopened or replaced by another nonconforming use after it has been abandoned or vacated for a period of twelve (12) months, except as provided for in this subsection. The twelve (12) month period shall commence when the use ceases and any one of the following occurs:
1. The site is vacated;
2. The business license lapses;
3. Utilities are terminated; or
4. The lease is terminated.
D. Reestablishment in the Northeast Area Specific Plan Area. The nonconforming use of a legally established structure for sites subject to Chapter 18.14.2, Northeast Area Specific Plan, may be reestablished, or a similar use as determined by the Director may be established, if the Zoning Administrator approves a minor use permit after making all of the following findings in addition to any other required findings. As a condition of approving the resumption of such nonconforming use, the Zoning Administrator may impose a time limit on its duration if necessary in order to make the required findings.
1. The structure cannot be used for any conforming use because of its original design or because of lawful structural changes made for a previous nonconforming use;
2. The structure can be reasonably expected to remain in active use for a period of twenty years without requiring repairs or maintenance in excess of fifty percent of the replacement cost of the structure, as determined by the Building OƯicial, within any five-year period;
3. The continuation of the use or structure will not be incompatible with or detrimental to existing surrounding uses and planned uses envisioned in the Northeast Area Specific Plan; and
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June 08, 2026 Packet Pg. 2490
4. The continuation of the use or structure does not preclude the long-term implementation of the Northeast Area Specific Plan.
(Ord. 1612 § 1 (Exh. A), 2024; Ord. 1438 § 4 (Exh. A (part)), 2011)
18.19.100 Abatement.
The provisions of this chapter shall not apply to a use or structure that is or becomes a public nuisance. In the event that a legal nonconforming structure or use is found to constitute a public nuisance, appropriate action may be taken by the City pursuant to the municipal code and Section 18.39.020, Enforcement. (Ord. 1438 § 4 (Exh. A (part)), 2011)
10.b
June 08, 2026 Packet Pg. 2491
ORDINANCE NO. ____
AN ORDINANCE OF THE CITY OF SAN CARLOS
ADOPTING THE NORTHEAST AREA SPECIFIC PLAN.
SECTION 1: Findings. The City Council of the City of San Carlos does hereby find and declares as follows:
WHEREAS, the City Council adopted the 2022 Strategic Work Plan that included a Strategic Objective for preparation of the Northeast Area Specific Plan and reaffirmed this Strategic Objective in subsequent Strategic Work Plans including the 2026 Strategic Work Plan; and
WHEREAS, in September 2022 the City Council approved a professional services agreement with Perkins&Will for consulting services to prepare a Northeast Area Specific Plan (“Specific Plan”) and Environmental Impact Report (“EIR”), in response to the City Council’s Strategic Objective to develop a plan that includes policies and strategies for development and housing in the northeast area; and
WHEREAS, between February 2023 through July 2025, 30 different civic engagement opportunities inclusive of focus group meetings, pop-up events, open-houses, community workshops, and study sessions with the City Council and Planning and Transportation Commission were held to receive input on the Specific Plan; and WHEREAS, on February 12, 2024, the City Council endorsed the preferred land use scenario for the Northeast Area Specific Plan that determines the anticipated buildout of land uses in the Northeast Area Specific Plan boundary through the year 2045 that introduces housing to advance a vision for a new mixed use district; and
WHEREAS, a Public Draft of the Northeast Area Specific Plan was available for public review in April 2025 and was presented to the Planning and Transportation Commission in April 2025 and to the City Council in May 2025 and September 2025 who directed modifications to the Specific Plan; and
WHEREAS, in April 2026 following input from the Planning and Transportation Commission and the City Council, the Final Draft Northeast Area Specific Plan was available for public review outlining a complete vision and guiding principles for the northeast area with refined land uses and development standards; and
WHEREAS, the Northeast Area Specific Plan project includes interrelated amendments to the General Plan Land Use Map, Land Use Element, Circulation and Scenic Highways Element, Environmental Management Element, and Environmental Safety and Public Services Element (herein referred to as “General Plan Amendments”) and amendments to the Zoning Map and Ordinance; and
WHEREAS, the Northeast Area Specific Plan project necessitates amendments the San Carlos Zoning Map, and the San Carlos Municipal Code, Title 18, Zoning to repeal Chapter
18.14A, remove references to Chapter 18.14A within Chapter 18.07 and Chapter 18.30, add Chapter 18.14.2 to codify the Northeast Area Specific Plan, and amend Chapter 18.19 (herein referred to as “Zoning Amendments”); and
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WHEREAS, in July 2024, the City provided written notification of the proposed Northeast Area Specific Plan, EIR, and General Plan Amendments to the list of tribes provided by the Native American Heritage Commission and to other entities listed pursuant to Assembly Bill 52 and Senate Bill 18, and no tribes requested consultation; and WHEREAS, on May 18, 2026, the Planning and Transportation Commission held a duly noticed public hearing and adopted Resolution No. PTC2026-05 recommending that the City Council introduce an Ordinance to adopt the Northeast Area Specific Plan; and WHEREAS, on May 28, 2026, the City mailed a public notice to all property owners and occupants/tenants within the Specific Plan boundary and within 300 feet of the Specific Plan boundary informing stakeholders of the proposed adoption of the Northeast Area Specific Plan project; and
WHEREAS, on May 29, 2026, a legal notice was published in the local newspaper informing stakeholders of the proposed adoption of the Northeast Area Specific Plan project; and
WHEREAS, on June 8, 2026, the City Council adopted a Resolution certifying the Environmental Impact Report for the Northeast Area Specific Plan; and WHEREAS, on June 8, 2026, the City Council adopted a Resolution amending the General Plan Land Use Map, Land Use Element, Circulation and Scenic Highways Element, Environmental Management Element, and Environmental Safety and Public Services Element; and
WHEREAS, on June 8, 2026, the City Council introduced an Ordinance the Zoning Map and Municipal Code, Title 18 Zoning, repealing Chapter 18.14A, removing references to Chapter
18.14 A within Chapter 18.07 and Chapter 18.30, adding Chapter 18.14.2 to codify the Northeast Area Specific Plan, and amending Chapter 18.19; and
WHEREAS, on June 8, 2026, the City Council held a duly noticed public hearing to consider the Planning and Transportation Commission’s recommendation to introduce an Ordinance to adopt the Northeast Area Specific Plan.
NOW, THEREFORE BE IT RESOLVED by the City Council of the City of San Carlos as follows:
SECTION 2: The City Council, having independently heard, considered, and weighed all the evidence in the record present on behalf of interested parties and being fully informed of the Northeast Area Specific Plan project, finds that Northeast Area Specific Plan’s vision, guiding principles, policies, and standards represent a shared vision for the northeast area and are based on foundational principles embodying equity and resilience, placemaking and identity, vibrancy, and mobility and connectivity, hereby approves the Northeast Area Specific Plan as set forth in Exhibit A.
SECTION 3: CEQA. An Environmental Impact Report (EIR) for the Northeast Area Specific Plan was prepared in accordance with California Environmental Quality Act (“CEQA”) Guidelines Section 15060(d). The EIR identified potentially significant and unavoidable environmental effects that could result from implementation of the Northeast Area Specific Plan
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related to air quality and greenhouse gas emissions. Having received, reviewed, and considered the information in the EIR, as well as the supporting administrative record, the City Council adopted and made Statement of Overriding Considerations regarding the significant, unavoidable impacts of the Northeast Rea Specific Plan and the anticipated benefits of the project and adopted a Resolution certifying the EIR for the Northeast Area Specific Plan on June 8, 2026.
SECTION 4: Severability. The City Council hereby declares that it would have passed this Ordinance sentence by sentence, paragraph by paragraph, and section by section, and does hereby declare that any provisions of this Ordinance are severable and if for any reason any sentence, paragraph or section of this Ordinance shall be held invalid, such decision shall not affect the validity of the remaining parts of this Ordinance.
SECTION 5: Publication and Effective Date. This Ordinance shall be published and posted according to law and shall take effect and be in force from and after 30 days after its passage and adoption.
* * * *
I, City Clerk Crystal Mui, hereby certify that the foregoing Ordinance was introduced on the 8th day of June 2026 and passed and adopted as an Ordinance of the City Council of the City of San Carlos at a regular meeting thereof held on the ____ day of ____, 2026 by the following vote:
________________________________
CITY CLERK of the City of San Carlos
APPROVED:
____________________________
MAYOR of the City of San Carlos
Exhibit A: Northeast Area Specific Plan
AYES, COUNCILMEMBERS:
NOES, COUNCILMEMBERS:
ABSENT, COUNCILMEMBERS:
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PUBLIC DRAFT
April 2026
SHARED
NORTHEAST AREA
SPECIFIC PLAN
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Northeast Area Specific Plan 2
Figure 1 Plan Area in relation to the City of San Carlos and the larger region.
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Northeast Area Specific Plan 4
Acknowledgments
City Council
Pranita Venkatesh
Mayor of City of San Carlos
Adam Rak,
Vice Mayor of City of San Carlos
Sara McDowell
John Dugan
Neil Layton
Ron Collins (Former)
Planning and Transportation
Commission
Frank Kenniasty
Jorge Tapias
Twisha Anand
Summer Bundy
Kristen Clements
Ellen Garvey (Former)
Janet Castaneda (Former)
Jim Iacoponi (Former)
David Roof (Former)
Economic Development
Advisory Commission
Kelly Hickey
Anthony Kamm
Rajesh Krishnan
Madhura Kumar
Heather Liu
Sailesh Mehra
Karen Molinari
City Staff
Nil Blackburn
Interim City Manager
Jeff Maltbie
Former City Manager
Al Savay, AICP
Community & Economic Development Director
Lisa Porras, AICP
Planning Manager
Sajuti Haque, AICP
Economic Development & Housing Manager
Rendell Bustos
Project Manager
Kristie Woo
Associate Planner
Consultants
Perkins&Will
Prime Consultant, Urban Design
Nelson\Nygaard
Mobility
Strategic Economics
Economics
BKF
Civil Engineering
David J. Powers & Associates
Environmental Planning
Plan to Place
Public Engagement
Good City Company
Strategic Advisor
Adopted______
Ordinance No.______
Prepared by
Prepared for
This Specific Plan was the culmination of collaboration and civic discourse from 2022 to 2026 and would not have been possible without the time, knowledge, and energy of the property owners, business owners, and residents of San Carlos who attended public workshops, Planning and Transportation Commission and City Council meetings, and generously provided their invaluable input.
Northeast Area
Specific Plan
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Chapter 1
Introduction
1.1 At 2026, Why Now? 13
1.2 Where Is The Northeast Area? 15
1.3 What Is A Specific Plan? 17
1.4 How To Use This Document 19
1.5 Who Shaped This Plan? 21
Chapter 3
Existing Conditions
3.1 Northeast Area Background 51
3.2 Flooding and Resilience 55
3.3 Natural Environment 57
3.4 Urban Heat 59
3.5 Zoning 61
3.6 Land Use 63
3.7 Business Snapshot 65
3.8 Transportation 69
Chapter 4
Land Use and Urban Form
Chapter 2
The Vision
2.1 Vision For 2045 27
2.2 Guiding Principles 29
2.3 Land Use and Urban Form 31
2.4 Mobility and Parking 37
2.5 Flooding and Resilience 43
Contents
4.1 Land Use Designations 73
4.2 Zoning Districts 75
4.3 Ground Floor Active Uses 77
4.4 Administration and Permits 79
4.5 Land Use RegulationsMixed-Use Districts 81
4.6 Land Use Regulations- Industrial District 95
4.7 Floor Area Ratio (FAR) and Density
Standards 109
4.8 Height Standards 111
4.9 Bonus FAR and Building Height
Provisions 113
4.10 Publicly Accessible Open Spaces 117
4.11 District Wide Development Standards 117
4.12 Non-Residential Development
Standards 119
4.13 Residential Development Standards 129
Chapter 5
Mobility and Parking
Standards
5.1 Street Network 155
5.2 Active Mobility 157
5.3 Mobility Hub 161
5.4 Vehicle Parking Standards 163
5.5 Shared Parking 165
5.6 Unbundled Parking 167
5.7 Bicycle Parking 169
5.8 Transportation Demand Management 171
5.9 On-Site Loading 177
5.10 On-Street Loading 179
5.11 Street Design 181
5.12 Quarry Road 185
5.13 Taylor Way 187
5.14 Industrial Road 189
5.15 Old County Road 191
5.16 Bragato Road 193
5.17 Glenn Way 194
5.18 New Street 195
5.19 Paseo 196
CHAPTER 6
Environmental Resilience
Standards
6.1 District-Wide Development Standards 199
6.2 Sea Level Rise Priority Zone 201
6.3 Creek Front Zone 203
6.4 Green Streets 206
CHAPTER 7
Implementation
Glossary
Appendix
7.1 Implementation Overview 209
7.2 Storm Drain Infrastructure 211
7.3 Flooding and Sea Level Rise 213
7.4 Stormwater Treatment 215
7.5 Sanitary Sewer Infrastructure 217
7.6 Domestic Water Infrastructure 219
7.7 Dry Utility Infrastructure 221
7.8 Rehabilitation or Reconstruction of
Frontage Pavement 222
7.9 Parking and Curb Management
District 223
7.10 Community Benefits 225
7.11 Funding and Financing 228
7.12 Implementation Actions 235
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List of Figures & Tables
Figure 1 Plan Area in relation to the City of San Carlos and the larger region. 2 Figure 10 Historical Mapping of Bay Shore, Pre 1950 51
Figure 11 Historical Mapping Overlay, circa 1940 52
Figure 12 An aerial illustration of the District’s built form today 53 Figure 13 Existing Conditions Flooding and Resilience Map 56 Cover, Table of Contents
Chapter 1
Introduction
Figure 2 Illustrative Drawing of North East Area Today 16 Figure 3 Context Key Map 16
Figure 4 The Layers of the Specific Plan 18
Figure 5 Example of Document Structure 20
CHAPTER 2
Vision
Figure 6 San Carlos Specific Plan Vision Diagram 28
Table 1 20-Year Development Projection 32
Figure 7 Land Use and Urban Form Vision Diagram 34
Figure 8 Mobility and Parking Vision Diagram 40
Figure 9 Flooding and Resilience Vision Diagram 46
CHAPTER 3
Existing Conditions
Figure 14 Existing Conditions Vegetation Map 58
Figure 15 Existing Conditions Heat Map 60
Table 2 Existing Zoning Regulations 61
Figure 16 Existing Zoning District Map 62
Figure 17 Pie Chart of Existing Land Uses 63
Figure 18 Existing Land Uses Map 64
Figure 19 Pie Chart of Existing Businesses 65
Figure 20 Existing Businesses Map 66
Figure 21 Existing Transportation Infrastructure Map 70 CHAPTER 4
Land Use and Urban Form
Figure 22 Land Use Designation Map 74
Figure 23 Zoning Districts Map 76
Figure 24 Ground Floor Active Use Map 78
Table 3 Land Use Regulations - Mixed-Use Districts 81
Table 4 Land Use Regulations - Industrial Districts 95
Figure 25 FAR and Density Map 110
Figure 26 Easement Setback and Height Diagram 111
Figure 27 Maximum Building Heights Map 112
Figure 28 Bonus Density and Height Map 114
Figure 29 Site of Future Public Park 116
Table 5 District Wide Development Standards 117 Table 6 Non-Residential Development Standards 119
Figure 30 Ground Floor Retail Corners Diagram 124
Figure 31 Ground Floor Industrial, Artisan, Manufacturing Section 126 Table 7 Lot, Density and FAR Standards 127
Figure 32Building Placement 129
Table 8 Building Placement Standards 129
Table 9 Building Heights and Height Limitations 130
Figure 33Building Projections and Blank Wall 131
Table 10 Blank Wall and Building Projections Standards 132 Figure 34Building Projections and Blank Wall 132
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List of Figures & Tables
Table 11 Parking and Parking Location 133
Figure 35Parking and Loading Locations 134
Table 12 Landscaping and Residential Open Space Standards 135 Figure 36 Street Frontage Improvements 137
Figure 37 Building Entrances 138
Figure 38Massing Breaks 140
Figure 39Corners 141
Figure 40Base, Middle and Top Treatments 144
Figure 41Fenestration Variety 145
Figure 42Material Variety 145
Figure 43Roof Variety 146
Figure 44 Projecting and Recessed Elements 147
Figure 45Window Standards 148
Figure 46 Windows Standards for Storefronts and Ground Floor Transparency 149 CHAPTER 5
Mobility and Parking
Table 13 On-Street Curb Uses 155
Figure 47 Roadway Network Map 156
Table 14 Paseo Type 157
Table 15 Bicycle Network Facilities 157
Figure 48 Active Mobility Map 158
Table 16 On-Site Maximum Vehicle Parking Standards 163
Table 17 Bicycle Parking Standards 170
Table 18 Minimum Bicycle Showers and Lockers Standards 170 Table 19 TDM Applicability 171
Table 20 Baseline Required TDM Strategies for Residential Projects 174 Table 21 Baseline Required TDM Strategies for Non-Residential Projects 174 Table 22 TDM Points Target 174
Table 23 TDM Points Menu 175
Table 24 Required On-Site Loading Spaces 178
Figure 49 Street Design Illustrative Section 182
Table 25 Furnishing and Curbside Table 183
Figure 50 Quarry Road Section 186
Figure 51 Taylor Way Section 188
Figure 52 Industrial Road Section 190
Figure 53 Old County Road Section 192
Figure 54 Bragato Road Section 193
Figure 55 Glenn Way Section 194
Figure 56 New Street Section 195
Figure 57 Paseo Section 196
CHAPTER 6
Environmental Resilience
Figure 58 Sea Level Rise Priority Zone Map 202
Figure 59 Creek Frontage Zone Map 204
Figure 60 Creek Front Zone Section 205
Figure 61 Illustrative of a typical green street 206
CHAPTER 7
Implementation
Figure 62 Storm Drain Infrastructure 212
Figure 63 Sanitary Sewer Infrastructure 218
Figure 64 Domestic Water Infrastructure 220
Figure 65 Dry Utility Infrastructure 221
Figure 66 Rehabilitation or Reconstruction of Frontage Pavement 222 Figure 67 Illustration of Community Benefits Programs, Base Height and Bonus Height 225 Figure 68 Allowed Community Benefits Menu 227
Table 26 Funding Sources for Capital Improvements 231
Table 27 Funding Sources for Operation and Maintenance 233 Table 28 List of Implementation Actions 235
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CHAPTER 1
Introduction
THIS SECTION WILL COVER:
1.1 AT 2026, WHY NOW?
1.2 WHERE IS THE NORTHEAST AREA?
1.3 WHAT IS A SPECIFIC PLAN?
1.4 HOW TO USE THIS DOCUMENT?
1.5 WHO SHAPED THIS PLAN?
← Aerial Image of Industrial Road from Bragato Street
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Northeast Area Specific Plan 14
INTRODUCTION
Since partially being annexed into the City of
San Carlos in 1997, the Northeast Area (the
area) has remained largely unchanged. For
decades, many businesses have offered a wide
mix of services. These businesses serve the San
Carlos community and customers throughout the Peninsula and greater Bay Area.
Over the last few years, numerous properties
have changed to new owners, and the area is
experiencing renewed development interest,
especially in the life science and biotechnology
sectors. As a part of the City of San Carlos 2022
Strategic Plan, the City Council directed staff to
prepare a Specific Plan to manage and direct
changes in the area. This includes examining
what regulations can be implemented to support
the existing businesses and industrial fabric, while
encouraging new development, businesses, and
jobs into the City. This presented an opportunity
for the City of Good Living to ensure sustained
economic prosperity through a diverse mix of
different types of businesses, redefining what it
means to be a maker in the 21st century. At the onset of the project, the question of whether housing is appropriate in this area arose. All California cities and counties must provide a framework for the community’s long term
approach to housing. Housing affordability in San
Mateo County and in the Bay Area as a whole is a
critical issue. Council directed staff to examine if
the Northeast Area would be viable for residential
mixed-use development in the future and if so,
where. With its proximity to Caltrain, El Camino
Real, and Downtown as well as the Greater
East San Carlos Neighborhood, the area is well
situated to become a transit-oriented community.
San Carlos, like most communities in California, is
directly experiencing multiple impacts of climate
change. The Northeast Area, being close to
the Bay and on low-lying terrain, is particularly
vulnerable to bayshore flooding and sea level
rise. The historic topographic map circa 1850
indicates that a large segment of the district was
originally a part of the historic San Francisco
bayshore. In recent years, strong storms and
king tides have swept the Bay Area causing
major flooding and damage to Northeast Area
properties, disrupting transportation routes, and
harming important economic assets. Along the
San Carlos bay shoreline, sea levels are projected
to rise approximately 24 inches by 2050 and 84
inches by 2100. If left unaddressed, sea level may
rise to permanently flood low-lying areas in the
Northeast Area.
These considerations, among many others, have
informed the Northeast Area Specific Plan, a
shared City-Community vision for a resilient 21st
century district. The Specific Plan responds to
the increasing hazards posed by climate change,
while envisioning a future built environment that
serves all San Carlos employees and residents
for generations to come. Grounded in community
input, the Specific Plan reflects an ambitious yet
pragmatic vision that will be realized incrementally
over time.
Historic Topographic Map circa 1850
Credit - EDR
1.1 The East Side is transforming.
At 2026, Why now?
←
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Northeast Area Specific Plan 16
INTRODUCTION
Life Science
Trampoline Park
Vitalis
Maxx Metals
Badminton
Advanced Sports
Delta Star
GW Williams Business Park
Enel X Way
PG&E
Natera
Where Is The
Northeast Area?
The boundary consists of U.S. Highway 101 to
the east, Belmont Creek and the Harbor Industrial
Area to the north, Caltrain rail tracks to the west,
and the Greater East San Carlos neighborhood to
the south. The district is located within a 10-minute
walk of both the San Carlos and Belmont Caltrain
Stations.
The Northeast Area is home to over 175 diverse
businesses. Some of San Carlos’ largest employers
are located in the district, including Sutter Health
Palo Alto Medical Foundation, Natera, Inc. (a clinical
genetic testing company), PG&E, and Delta Star
(a transformer manufacturing company). Smaller
businesses also call the Northeast Area home
and offer services including recreation, gardening
supplies, food service equipment, plumbing
services, office supplies, and photography.
The Northeast Area offers a variety of smallscale industrial spaces. These spaces provide entrepreneurs and small businesses with
relatively lower-cost rents and the opportunity
to start and grow. The spaces are adaptable and
flexible to changing economic conditions, allowing
businesses to pivot and adjust to new market
conditions as needed.
Figure 2 Illustrative Drawing of North East Area Today
Figure 3 Context Key Map
1.2 The Northeast Area is comprised of 145
acres located on the eastside of San Carlos.
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Northeast Area Specific Plan 18
INTRODUCTION
What Is A Specific Plan?
The purpose of this Specific Plan is to serve as
a detailed framework for guiding development
within the Northeast Area in San Carlos, ensuring
it aligns with the community’s goals and with
the City’s General Plan. It outlines infrastructure
improvements, protects resources, attracts
investment, and enhances quality of life by laying
out guidelines for land use, transportation, and
environmental resilience. Consistent with the
State law, the Northeast Area Specific Plan covers
the following:
nj Collaborated closely with the community and
key stakeholders to forge a cohesive and
forward-looking vision for the area, ensuring it
meets the aspirations and needs of those it will
affect.
nj Conducted a careful evaluation of the existing
infrastructure and formulated strategic
recommendations to address the anticipated
future needs of the neighborhood to ensure the
area’s infrastructure can support its growth and
evolution.
nj Established a robust framework for land use
that directs development towards creating
a transit-oriented, mixed-use neighborhood.
This framework aims to facilitate a blend
of residential spaces and job opportunities,
fostering a community where living and working
are closely integrated.
nj Enhanced the mobility infrastructure to support
a diverse mix of industrial and residential traffic.
This includes accommodating trucks and
personal vehicles while promoting bicycle and
pedestrian connectivity, ensuring seamless and
safe movement throughout the area.
nj Developed urban design standards that
emphasize the creation of walkable, livable
environments. These standards apply to streets,
streetscapes, buildings, and open spaces within
the project area, prioritizing public well-being
and aesthetic harmony to enhance the quality
of life for all residents.
Of critical importance is ensuring that the
Specific Plan supports and reinforces the plans
already adopted, as well as the separate but
complementary planning efforts being conducted
in parallel. This includes the following:
2045 General Plan Reset is the City’s official
policy document that guides new development
and capital projects as San Carlos evolves and
changes over the course of a 20-year time
horizon. In May 2025, the City adopted an update
to the 2030 General Plan to reset the horizon year
from 2030 to 2045 to accommodate continued
interest in the development of new offices,
restaurants, commercial uses and services, retail,
industrial, and housing in the City. The 2045
General Plan Reset was much more focused than
a complete General Plan Update. It did not include
any changes to the 2030 General Plan land use
designations or development standards; instead
the focus was to adjust development projections
A Specific Plan is a planning and policy document that establishes a vision for a defined area or district within a city.
1.3 Community and
Key Stakeholder
Engagement
Infrastructure for
a Resilient Future
Calibrated Land
Use Framework
Enhanced Mobility
Network
Context-Sensitive
Figure 4 The Layers of the Specific Plan
to the year 2045. The update also accounted for
other long range planning initiatives, specifically
the Downtown and Northeast Area Specific Plans.
Downtown Specific Plan (adopted in January
2026) creates a new vision for Downtown San
Carlos based upon what the community most
loves and celebrates about Downtown, and what
needs updating.
Objective Design and Development Standards
creates clear and measurable design standards
for mixed-use and multi-family residential projects,
as well as single-family units.
East Side Innovation District Vision Plan
(adopted in 2021) guides new development in
the 150-acre commercially zoned area. This area
is envisioned to be a well-connected, multi-modal
neighborhood with a mix of uses that integrates
existing businesses with new science and
technology uses.
Climate Mitigation and Adaptation Plan
(adopted in 2021) is San Carlos’ strategic plan to
reduce greenhouse gas emissions and adapt to
changing climate conditions.
Bicycle and Pedestrian Master Plan (adopted
in 2020) identifies specific projects and policies
to enhance the walkability and bikeability of San
Carlos.
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INTRODUCTION
How To Use This Document
This plan document is structured into seven comprehensive sections, each designed to provide a holistic understanding and actionable framework for the transformative development of the Northeast Area.
Chapter 1 - Introduction: This chapter provides
the fundamental information of the Specific Plan
including why the City took this effort on, what
area is impacted by this plan, and who shaped the
plan.
Chapter 2 - The Vision: This chapter articulates
the overarching vision, outlines key planning
principles, and describes the planning process
undertaken. It sets the stage for the Specific
Plan’s development, establishing a context that
highlights community aspirations with practical
objectives.
Chapter 3 - Existing Conditions: This chapter
outlines the current state of the area, and delves
into its existing conditions through historical
maps, topographical studies, and an analysis of its
socio-economic fabric. This baseline assessment
is crucial for understanding the area’s challenges,
needs and future potential.
Chapter 4, 5, 6 - Design Standards: This
chapter specifies the standards and guidelines
essential for enhancing the aesthetic and
functional quality of streets, open spaces, and
buildings. It distinguishes between mandatory
standards (“shall” or “must” statements) that will be
regulated, and recommended practices (“should”
statements) that articulate the aspirational vision
for the site’s development. All standards and
guidelines are subject to staff interpretation to
ensure proposed projects align with the Specific
Plan’s intent.
The design standards are broken out into three
chapters - Chapter 4: Land Use and Urban Form;
Chapter 5: Mobility and Parking; and Chapter 6:
Environmental Resilience.
Chapter 7 - Implementation: The document
concludes with an Implementation chapter, which
lays out the infrastructure improvements, capital
investments, monitoring mechanisms, community
benefits menu, and funding and financing required
to realize the plan’s vision.
Glossary: The glossary provides definitions for
terminology used throughout the document.
Appendix: The appendix provides a treasure trove
of reference materials, including market studies
and analyses on infrastructure and sustainability,
that have informed the creation of the Northeast
Area Specific Plan.
1.4 CHAPTER NUMBER AND TITLE
SUB SECTION NUMBER AND TITLE
FIGURE
LEGEND
STANDARDS
Figure 5 Example of Document Structure
INDEX OF SUB-SECTIONS
REGULATING
FIGURE
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INTRODUCTION
22 Who Shaped This Plan?
Community engagement and comprehensive stakeholder involvement have been central to shaping the Specific Plan, finding consensus between a diverse cross section of the San Carlos population.
The process began with a stakeholder focus
group workshop conducted by the City and
Consultant team in February 2023, marking
the commencement of a series of community
workshops. These workshops, designed to mirror
the Plan’s key decision milestones, included an
initial visioning session, a feedback gathering
stage on the developing preferred option, and
a final meeting in November 2024 for final
comments before finalization of the Specific Plan.
This approach ensured that the Plan accurately
reflected the community and city’s aspirations
and requirements. To complement these inperson engagements, the City and Consultant Team also implemented online surveys. This was
supplemented by three pop-up events, hosted
at the San Carlos Public Library and Auto Vino,
aimed at both gathering additional feedback
and raising public awareness about the ongoing
Specific Plan.
Engagement with the Planning and Transportation
Commission and the City Council occurred at
significant points during the process, inviting
their insights and opinions on the Specific Plan’s
direction and the future of Northeast San Carlos.
This comprehensive engagement strategy has
ensured a Plan that is both reflective of and
responsive to the community’s and stakeholders’
visions for the area.
NEASP ENGAGEMENT BY THE NUMBERS
3 online surveys
distributed after each
public workshop.
3 virtual focus groups
with property owners,
business owners, and
developers.
3 pop-ups at the San
Carlos Public Library
and AutoVino.
3 project updates with
property owners and the
Greater East San Carlos
neighbors.
3 virtual community
workshops which
included interactive
sessions on plan
development and
refinement.
3 Planning and
Transportation
Commission
worksessions with
public comment.
2 City Council
workesssions with
public comment.
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Northeast Area Specific Plan 24
INTRODUCTION
1.5 VIRTUAL COMMUNITY WORKSHOP
City staff and the consultant team presented in progress design options and facilitated community discourse at the 2nd virtual workshop in August 2023.
LIBRARY INFORMATIONAL POP-UP
City staff answering community questions about the Specific Plan process at the San Carlos Library.
City staff hosted an outdoor pop up event at Auto Vino inviting community members to share their thoughts on the draft land use and urban design concepts.
CITY STAFF VISIONING SESSION AND SITE TOUR AUTOVINO POP-UP EVENT At the onset of the planning process, city department representatives came together to walk the area and discuss opportunities and challenges.
Community Engagement Meetings Photos
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2.1 VISION FOR 2045
2.2 GUIDING PRINCIPLES
2.3 LAND USE AND URBAN FORM
2.4 MOBILITY AND PARKING
2.5 FLOODING AND RESILIENCE
THIS SECTION WILL COVER:
An aerial photograph of Old County Road and the Caltrain berm.
Vision
CHAPTER 2
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Northeast Area Specific Plan 28
VISION
0 400 800 Feet
Figure 6
San Carlos Specific Plan Vision Diagram
A Vision For 2045
The Northeast Area Specific Plan envisions a
mixed-use district that lies at the nexus of traditional industry, innovation, and resilient, inclusive
community life.
Streets and public spaces are multi-functional,
serving as effective means for modes of lowcarbon transport to efficiently navigate the district, supporting vibrancy and economic development,
and acting as an absorbent landscape defending
the district from flooding and sea level rise
2.1 Retail Gateway
Industrial, Artisan,
Manufacturing
Ground Floor
Active Uses
Industrial Priority
Street
Local Streets
Multi-Modal Street
Neighborhood
Greenway
Pedestrian/Bike
Paseo
F Street Underpass
Belmont Creek Trail
Industrial
Professional
Production and
Innovation
Mixed-Use
Northeast 90
Mixed-Use
Northeast 75
Planned
Development
El Camino Real
Mobility Hub
ECR Stops
Major Stormwater
Infrastructure
Existing Water Channel
Water Retention in Private
Open Space
Stormwater Flow
Zoning
Legend
Mobility
Active Uses
Resilience
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Northeast Area Specific Plan 30
VISION
Celebrate the
Industrial Legacy
This Plan should foster a unique identity
for Northeast San Carlos that honors the
industrious and innovative spirit of the
region.
Calibrate the Right
Mix-of-Uses
The land use should be diverse,
stimulating economic activity while
balancing industrial and residential
needs to create a dynamic and adaptable
urban fabric.
Champion District
Resiliency
The Northeast Area should promote and
incentivize sustainable and innovative
design practices on the district scale.
Address Flooding and
Environmental Issues
The Specific Plan should propose and
incentivize proactive measures aimed at
mitigating flooding risks and addressing
environmental contamination challenges.
The following guiding principles reflect the community’s aspirations for the Northeast Area as it grows incrementally and intentionally over the next 20 years.
Guiding
Principles
2.2 Improve Access for All
Modes of Transportation
The transportation network should be
inclusive and multi modal, prioritizing
seamless connectivity for all user
groups in the area.
Develop District Parking
Strategies
The parking strategy should focus
on optimizing parking availability
and management to create shared
parking systems.
Promote Equity and
Access in Public Spaces
This Plan envisions a network of
inclusive, accessible public and
private open spaces that connect
people and enhance community life
in Northeast San Carlos.
SHARED
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Northeast Area Specific Plan 32
VISION
Land Use and
Urban Form
Community stakeholders spoke about a need for balanced economic growth, sensitive integration of residential uses, and provision of community amenities to support change.
Focus On Economic Growth, But Preserve
Existing Businesses
• Protect the unique, diverse mix of local-serving
businesses and ensure they have the space to
operate and adapt by supporting flexible use
and improvements.
2.3 Table 1 20-Year Development Projection
LAND USE ALLOWABLE SQUARE FOOTAGE NET INCREASE
General Light Industrial 700,000
Manufacturing 492,000
Warehouse 40,000
Research and Development 2,964,000
General Office 180,000
Retail 80,000
Utilities 52,000
Residential 1,890,000 (1,890 units)
HOW THE SPECIFIC PLAN RESPONDS
Preservation of existing permitted land uses in the Light Industrial (IL) and Industrial Professional (IP) zoning districts.
Ground floor requirements for small scale manufacturing spaces on select roads to support current and future generations of San Carlos makers.
Ground floor retail at the district’s major gateways and allowable ground floor active uses along major corridors.
Residential mixed-use zoning in the southwestern portion of the Plan Area to balance employment with the City and region’s need for housing.
Ensuring that critical services for the region including PG&E and Palo Alto Medical Foundation (PAMF) are able to remain in the district.
Calibrated height and density envelopes that enables a dense, compact urban district with stepdown requirements to the surrounding neighborhood.
The updates to land use classifications, density, and height allowances could allow for a Integrate Residential Uses 20-year development projection of the following:
• Support thoughtfully located housing,
especially affordable housing.
• Prioritize multi-family housing, concentrating
along the south side of the Plan Area to take
advantage of transit proximity.
• Consider the transition to Greater East San
Carlos neighborhood. Implement height
transitions and buffers between non-residential
and residential areas to ensure harmonious
coexistence within the community.
Provide Open Space or Community
Amenity for Employees and Residents
• Improve amenities and open space for
employees and residents.
• Enhance the community by adding daytime
amenities and restaurants for employees,
improving family recreational options, and
creating a trail along Belmont Creek for better
connectivity.
WHAT WE HEARD
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Northeast Area Specific Plan 34
VISION
0 400 800 Feet
Figure 7
Land Use and Urban Form
Vision Diagram
Continuation
of residential
zoning
Land Use and
Urban Form
The Specific Plan outlines a long term
land use and urban form framework
to guide intentional growth and
investment, centered on leveraging
future market demand to deliver
tangible community benefit.
Legend
Existing Conditions
Active Uses
Retail Gateway
Industrial, Artisan,
Manufacturing
Existing Water Channel
Study Area Boundary
Ground Floor Active Uses
2.3 Industrial
Professional
Production and
Innovation
Mixed-Use
Northeast 90
Mixed-Use
Northeast 75
Planned
Development
Zoning
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June 08, 2026 Packet Pg. 2512
Northeast Area Specific Plan 36
VISION
Aerial of Existing Industrial,
San Carlos, CA
University of Cincinnati Gardner
Neuroscience Institute
Cincinnati, OH
Barangaroo South Public Domain,
Sydney, Australia
1 De Haro,
San Francisco, CA
Ninot Market Refurbishment
Barcelona, Spain
R&D and life science uses serve as major
economic engines, where an influx of
employees into the district can catalyze
retail and community uses.
Creating active ground floor uses can compliment the neighborhood and promote a lively neighborhood.
Allowing uses that compliment
the district’s industrial uses and
allow for additional job sectors to
thrive.
Land Use and
Urban Form
Weaving together a dynamic mixeduse district where existing and future employees and residents can thrive.
2.3 TRADITIONAL LIGHT
INDUSTRIAL
Traditional light industrial uses
can thrive in a mixed-use district,
preserving space for operations,
freight, and storage.
RESEARCH AND DEVELOPMENT (R&D)
RESIDENTIAL MIXED-USE
SMALL SCALE
MANUFACTURING
RETAIL AND COMMUNITY USES
Creating opportunities for community and retail to
make use of building frontages along appropriately
chosen streets.
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Northeast Area Specific Plan 38
VISION
Prioritize Safety For All Modes
• Address safety concerns on all streets to create
a safer and more accessible environment for
pedestrians, bicyclists, freight, and private
vehicles.
• Address safety concerns at existing pedestrian
paseos to El Camino Real and proposed
paseos into the surrounding community.
Enact Effective Parking Solutions
• Develop a parking strategy that enables
existing businesses to continue to operate while
ensuring new development can accommodate
parking demand.
• Ensure new development have enough parking
and works with the City to prevent streets from
being used for vehicle storage.
Provide First and Last Mile Transit
Solutions
• In order to fully take advantage of nearby transit
and reduce vehicle activity, invest in first mile
/ last-mile mobility options for easy access to
the Caltrain Stations and SamTrans bus transit
on El Camino Real.
Focus On Improved Street Connectivity
• Plan for a connected, functional street grid
that looks beyond the Plan Area to reduce
congestion, while supporting future urban
development in both the Northeast Area and
Belmont’s Harbor Industrial Area.
• Enhance bike and pedestrian connectivity,
including extending Eastside Connect along
Old County Road and adding a trail along
Belmont Creek.
Mobility and Parking
Community stakeholders spoke about a need for improved
connectivity, effective parking solutions, and first and last mile connections to Caltrain and SamTrans.
HOW THE SPECIFIC PLAN RESPONDS
A new public street segment between Quarry Road and Bragato Road which creates an additional internal north-south connection through the district.
Roadway safety measures like a new signalized intersection on Industrial Road, midblock crossings with traffic calming measures.
Intentional on-street curb flexible space to serve the larger district including designated spaces for permitted on-street parking, commercial loading, and mobility hubs.
Class I protected bikeways on select streets to ensure a safe, low-stress biking experience that connects to the larger city network.
Publicly accessible paseos and a Belmont Creek multi-use trail which serves as both active transportation corridor as well as usable community open space.
The proposed siting of a district mobility hub enables access to multiple transportation options.
Updated parking requirements for new development and shared parking policy to ensure supply can be used as efficiently as possible.
2.4 WHAT WE HEARD
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Northeast Area Specific Plan 40
VISION
0 400 800 Feet
Legend
Industrial Priority - Quarry
Road
Local Streets - Taylor Way,
Bragato Road, Glenn Way
Multi-Modal Boulevard -
Industrial Road
Neighborhood Greenway -
Old County Road
Ped/Bike Paseo
F Street Underpass
Belmont Creek Trail
Mobility Hub
Existing Conditions
Transit Corridor - El
Camino Real
Existing Water Channel
Study Area Boundary
ECR Stops
Mobility
2.4 Mobility and Parking
Figure 8
Mobility and Parking Vision Diagram
The Specific Plan outlines a multimodal, low-carbon transportation network that balance the needs
of current and future users. This
includes safe, low-stress facilities
for pedestrians and cyclists, while
ensuring economic prosperity with
proper freight service and vehicle
travel lanes.
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Northeast Area Specific Plan 42
VISION
MOBILITY HUB
Creating a hub for residents
and workers to park and
charge electric vehicles,
bikes, and scooters.
INDUSTRIAL PRIORITY STREETS
Streets that can effectively accommodate
freight movement and access are needed
in this district to ensure operations of
traditional and emerging industrial uses.
MULTI-MODAL BOULEVARD
Creating streets that have multi-modal functions for
pedestrians, cyclists, vehicles, and transit options ensures for a dynamic boulevard.
NEIGHBORHOOD GREENWAY
Using planting, material changes, and
street furniture to clearly delineate
paths of travel, creates for a beautiful
pedestrian experience.
SHARED PARKING
Prioritizing well-designed shared
parking garages.
Mobility and Parking
The quality of a district’s public life is
largely defined by what happens in its
streets.
2.4 Curtin University Bicycle Hub,
Bentley, Australia
100 Hooper Street,
San Francisco, CA
Brighton Boulevard,
Denver, CO
Quay Street,
Auckland, New Zealand
Santa Monica Municipal Garage,
Santa Monica, CA
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Northeast Area Specific Plan 44
VISION
Flooding and
Resilience
Belmont Creek Needs Improvement
• During extreme weather events, which are
becoming more frequent, Belmont Creek will
flood its banks. The existing culverts at Old
County Road, Industrial Road, and Highway
101 are undersized.
• Belmont Creek and the Harbor Industrial Canal
is filled with sediment, vegetation, and other
debris, which causes flows to be “choked”
when flowing through the channel.
• Belmont Creek and the Harbor Industrial Canal
are subject to downstream backwater effects
due to high tides in the San Francisco Bay.
2.5 Community stakeholders acknowledge the district’s vulnerabilities to flooding and other environmental stressors amplified by climate change. Stakeholders spoke about investing in new stormwater and sewer infrastructure, more soft scape and park areas, and standards to protect existing and future development from flooding and sea level rise.
Underground Utilities are Undersized
• The existing utility infrastructure that handles
rainfall runoff is undersized and requires
improvements in order to prevent localized
flooding.
• Property owners want to see capital
investments implemented in the near term to
effectively manage flooding vulnerability to
protect properties.
The District Needs Green Space
• The District is almost completely urbanized.
As such, new development should include
extensive Low Impact Development (LID)
techniques to increase the amount of
disconnected stormwater runoff, capture, and
reuse runoff, and well as maximize infiltration
and landscape features.
• New development should incorporate design
elements such as publicly accessible green
spaces as well as green roofs, bio filtration
planters that can be used not only as detention
and treatment strategies, but they can also
reduce the amount of localized flooding
through the District.
Identifies priority underground sewer and stormwater updates within the District for long term stormwater management.
Design typologies for all streets integrate green stormwater infrastructure such as enhanced bioswales.
New development on large sites is required to integrate green spaces that can mitigate flooding.
The ground floor of all new development must be raised in preparation for future sea level rise.
Two resilience zones are established in the District’s low-lying terrain and subsequently most vulnerable areas: the Sea Level Rise Priority Zone and Creek Front Zone.
The Sea Level Priority Zone applies to land within the FEMA 100-year flood plain and requires context specific strategies for new development.
The Creek Front Zone applies to sites adjacent to the Belmont Creek and requires context specific strategies for new development.
HOW THE SPECIFIC PLAN RESPONDS
WHAT WE HEARD
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Northeast Area Specific Plan 46
VISION
Legend
Resilient Features
Channel Easement
Major Stormwater
Infrastructure
Green Infrastructure
Water Retention in Private
Open Space
Stormwater flow
Critical Infrastructure
Low Carbon Mobility Network
Existing Water Channel
Study Area Boundary
Existing Conditions
0 400 800 Feet
Figure 9
Flooding and Resilience Vision Diagram
Flooding and
Resilience
The Specific Plan puts forward a
coordinated resilience strategy to
ensure proper defense from extreme
weather events and sea level rise,
while leveraging this new investment
to foster an enhanced quality of life for
all employees, residents, and visitors
of the District.
2.5 10.b
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Northeast Area Specific Plan 48
VISION
CREEK SETBACK
Create opportunities to bring residents
and workers to resilient landscapes that
double up as floodable infrastructure.
ENHANCED BIOSWALES
Green streets can utilize
frontages to provide space for
enhanced bioswale facilities, and
add to overall street aesthetics.
STORMWATER PARKS & PLAZAS
Larger areas in private spaces can utilize water retention methods in a thoughtful, enjoyable, and functional landscape.
BIORETENTION ALLEYS
Where space is limited, bioretention
can still be prioritized along
alleyways and paseos to create
critical stormwater infrastructure in
an industrial context.
RAISED GROUND FLOORS
Building 12 in San Francisco raised its ground
floor as a mitigation measure for sea level rise.
Nottingham Science Park
Nottingham, England
855 Brannan Street,
San Francisco, CA
Mission Creek Stormwater Park
San Francisco, CA
100 Hooper Street
San Francisco, CA
Building 12,
San Francisco, CA
Robust ecosystem infrastructure network
enables a myriad of public benefits.
2.5 Flooding and
Resilience
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CHAPTER 3
Aerial photograph of Quarry Road
Existing
Conditions 3.1 NORTHEAST AREA
BACKGROUND
3.2 FLOODING AND RESILIENCE
3.3 NATURAL ENVIRONMENT
3.4 URBAN HEAT
3.5 ZONING
3.6 LAND USE
3.7 BUSINESS SNAPSHOT
3.8 TRANSPORTATION
THIS SECTION WILL COVER:
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Northeast Area Specific Plan 52
EXISTING CONDITIONS
3.1 The wetlands were critical ecosystems and
foundational elements of the region’s natural
resilience. They served a multitude of ecological
functions, including water filtration, flood
protection, carbon sequestration, and providing
habitat for diverse species. As the demand for
industrial and commercial space grew over time,
the wetlands were filled to pave the way for urban
development. This development first extended to
the north of Old County Road and eventually to
the entire Northeast Area.
Figure 10 Historical Mapping of Bay Shore, Pre 1950
Northeast Area Background
The District’s original landscape was characterized by marshy wetlands and meandering creeks, draining into the sloughs of San Francisco Bay.
Figure 11 Historical Mapping Overlay, circa 1940.
Satellite Image of the Northeast Area circa 1943 Historical Image of the San Francisco Speedway in San Carlos, California
The filling of marshland in 1953 catalyzed a wave
of commercial and light industrial expansion,
including the site of the San Francisco Speedway
on the parcel currently home to PG&E. By the
1980s, the area was fully developed, marking a
significant economic upswing for the city. This
period set the stage for the area’s evolution into a
diverse industrial hub.
The Northeast Area of San Carlos began transforming in 1940 with commercial development along Quarry and Industrial Roads.
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Northeast Area Specific Plan 54
EXISTING CONDITIONS
The Northeast Area has evolved into a more diverse employment hub, fueled by the opening of the Palo Alto Medical Foundation’s campus in 2014.
The Northeast Area has a 50 foot easement that borders the Greater East San Carlos Neighborhood. This existing easement provides a natural buffer between the industrial and the single family residential properties.
Leveraging the region’s strategic location to
innovation hubs like the Redwood Shores,
convenient highway access, and access to skilled
workforce, the district has seen an influx in
startups, and biotech companies.
Figure 12 An aerial illustration of the District’s built form today
View of Palo Alto Medical Foundation
3.1 Spotlight on the 50 foot easement
Subdivision maps from 1948 show the 50 foot
easement area along the southern boundary of
the plan area was originally owned by the City and
County of San Francisco. However, parcel maps
from 1974 and 1975 for properties along Taylor
Way and Industrial Road show the 50 foot area
divided into multiple parcels, owned by private
entities, not the City and County of San Francisco.
The easement includes a 15 foot storm drain
easement and 10 foot storm drain access
easement on the side closest to the single family
residential neighborhood. A subdivision map from
1997 for the portion of the 50 foot closest to
Old County Road indicates a 10 foot storm drain
easement as well and the adjacent 50 foot wide
parcel under private ownership. There are also
residential condominiums built within this 50’
parcel, adjacent to the storm drain.
This easement contains pipelines for the Hetch
Hetchy Regional Water System, which according
to the Bay Area Water Supply and Conservation
Agency (BAWSCA) supplies water for 1.8
million residents, businesses, and community
organizations. Due to the importance of this
infrastructure, the easement will not be subject to
development standards or guidelines featured in
the following chapters.
A 1975 parcel map showing the 50 foot easement on properties fronting Industrial Road.
Northeast Area Background
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Northeast Area Specific Plan 56
EXISTING CONDITIONS
Flooding and Resilience
Due to its location within the historic shoreline, the Northeast Area is susceptible to both flooding and sea level rise.
Originally, the wetlands in San Carlos served as
natural defenses against flooding, absorbing
and storing water during heavy rains and acting
as a vital buffer. However, development has
significantly diminished these natural protections,
making the area more vulnerable to extreme
weather events. In recent years, San Carlos has
experienced significant flooding challenges, with
intense rainfall overwhelming the city’s drainage
systems and causing widespread water intrusion
in residential and commercial districts. Looking
ahead, the northeast area faces mounting
climate-induced challenges. Today, the Northeast
Area has about a third of its area within the 100-
year FEMA floodplain.
According to the City’s Climate Mitigation and
Adaptation plan, the San Carlos bay shoreline,
sea levels are projected to rise approximately 24
inches (2 feet) by 2050 and 84 inches (7 feet) by
2100.1
The 2017 City of San Carlos Storm Drain Master
Plan highlights undersized storm drain pipes in
Quarry Road, Industrial Road, Bragato Road, north
of Holly Street on Industrial Road, and within
Shoreway Road across Highway 101.
1 The 2050 and 2100 projections are based on the
March 2020 Adapting to Rising Tides report for the San
Francisco Bay Area. This is consistent with the scenarios presented in the San Mateo County Sea Level Rise Assessment.
3.2 Photograph of flash flood in San Carlos in 2023. Photograph of a flooded Belmont Creek east of Industrial Road in 2023.
Figure 13 Existing Conditions Flooding and Resilience Map Undersized Storm Drain Pipes
Existing Stormwater Infrastructure
100 Year FEMA Floodplain
500 Year FEMA Floodplain
Sea Level Rise - 2 Foot Projection
Sea Level Rise - 4 Foot Projection
Sea Level Rise - 7 Foot Projection
Legend
0 400 800 Feet
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Northeast Area Specific Plan 58
EXISTING CONDITIONS
Natural Environment
The Northeast Area’s wetlands have been significantly compromised by development, leaving the district susceptible to weather-induced flooding, a challenge set to intensify with climate change.
Belmont Creek, although its course has been
altered, is the sole lasting natural feature in an
area predominantly marked by hardscape and
scant green spaces or habitats. Surrounding
Belmont Creek is an established twenty-five (25)
feet buffer.
Complementing the creek’s natural flood control
role, several man-made open channels have been
constructed throughout the district to enhance
drainage and mitigate flooding. There is a fifty
(50) foot easement on the open water channel
closest to the Palo Alto Medical Foundation. The
open water channel between PG&E and 201
Industrial Road does not have an easement. As
stated in Section 3.1, there is a fifty (50) foot
easement that serves as a natural buffer between
the Taylor Way and Industrial Road properties and
the residential properties in the Greater East San
Carlos neighborhood.
3.3 Photograph of Belmont Creek, east of Industrial
Road.
Photograph of one of the existing open water channels.
Figure 14 Existing Conditions Vegetation Map
Easements
Belmont Creek
Existing Water Channel
Tree Cover
Project Boundary
Legend
0 400 800 Feet
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Northeast Area Specific Plan 60
EXISTING CONDITIONS
Urban Heat
Temperatures are expected to warm by 3 - 4.5°
Fahrenheit by 2050 and 5.5 - 8° Fahrenheit by
2100.
Analysis shows the highest degree of urban heat
intensity is in the southern portion of the district,
located around traditional industrial businesses
and surface parking lots.
The Northeast Area is primarily composed of paved and impervious areas, which contributes to worsening heat waves and diminished quality of life.
Figure 15 Existing Conditions Heat Map
0 400 800 Feet
3.4 Aerial photograph of the AutoVino pop up space located in a surface parking lot.
Aerial photograph of industrial fabric within the district, illustrating a primarily hardscaped built environment.
5 (Highest Intensity)
4 3
2 1 (Lowest Intensity)
Project Boundary
Legend
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Northeast Area Specific Plan 62
EXISTING CONDITIONS
3.5 Zoning
The predominant zoning districts are Light Industrial and Industrial Professional, which dictate the built environment’s characteristics.
The maximum Floor Area Ratio (FAR) and building
heights for these zones are detailed in the table
below. The built environment predominantly
features one-story structures under 20 ft in
height, centrally positioned and often encircled
by extensive paving and scant landscaping. This
architectural homogeneity, coupled with varied
front setbacks, results in an irregular street
frontage that lacks uniformity across different
parcels. There are also several properties that
have a unique development regulations under
individual planned developments in and around the
district including 642 Quarry Road, PG&E, PAMF,
and 405 Industrial Road. For more information
on planned developments, go to the San Carlos
Municipal Code (SCMC), Chapter 18.10
Planned Development District, as well as
associated Ordinances adopting these planned
developlements.
ZONING DISTRICT MAXIMUM FLOOR
AREA RATIO (FAR)
MAXIMUM ALLOWABLE
HEIGHT
Light Industrial (IL) 0.5 (1.0 for project sites greater than 1 acre)
75 Feet
Industrial Professional (IP) 2.0 100 Feet
Planned Development N/A N/A
Figure 16 Existing Zoning District Map
0 400 800 Feet
Light Industrial (IL)
Industrial Professional (IP)
Planned Development
Project Boundary
Table 2 Existing Zoning Regulations
Legend
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Northeast Area Specific Plan 64
EXISTING CONDITIONS
3.6 Land Use
The current land use composition is predominantly shaped by industrial activities, accounting for 47% of the Plan Area’s utilization.
This is complemented by office/commercial
spaces making up 28%, transportation/utilities at
14%, warehousing operations at 9%, and a small
retail presence at 2%. With minimal vacancies, this
distribution highlights the Plan Area’s economic
vitality. The Northeast Area’s demographics shift
between active and semi-active periods.
During the day, it’s populated by office workers,
industrial employees, business owners, patients,
and recreational visitors. At night and on weekends,
the crowd changes to visitors frequenting places
like the trampoline park, badminton academy, and
sports facilities, indicating a versatile usage of the
area.
Figure 18 Existing Land Use Map
0 400 800 Feet
Industrial
Office / Commercial
Retail
Transportation / Utilities
Warehouse
Figure 17 Pie Chart of Existing Land Uses
Total
(blank)WarehouseTransportation/UtilitiesRetailOffice/CommercialIndustrial Industrial, 47%
Office/Commercial,
28%
Warehouse, 9%
Retail, 2%
Transportation/
Utilities, 14%
Project Boundary
Legend
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Northeast Area Specific Plan 66
EXISTING CONDITIONS
Business Snapshot
The Northeast Area is made up of a wide range of businesses.
A more granular study of existing businesses can
be seen in Figure 19. A focal point of business
density is the southwestern corner of the area in
Williams Business Park. This business park has an
aggregation of smaller-scale businesses, leading
to a high density of approximately 3 businesses
per 10,000 sq. ft.
The map also highlights significant adaptive
reuse projects such as Viatris, Trampoline Park,
Badminton Academy, Advanced Sports, and Enel
X Way that have transformed the district in the
past decade by introducing recreational uses.
WALNUT ST
General Sales
Level of Concentration of Business
Food
Civic and Social
Recreational
Service
Business Service
Life Science
Construction, Material & Services
Industrial
Auto
Utility
Transportation
Other
Study Area Boundary
Utility, 1%
Transportation, 2%
Service, 7%
Other, 1%
Life Science, 3%
Industrial, 18%
Food, 6%
Construction and
Material, 23%
General Sales, 15% Auto, 16%
Business Service, 5%
Civic and Social, 1%
Recreational, 2%
Figure 19 Pie Chart of Existing Businesses
3.7 Figure 20 Existing Businesses Map
Auto
Business Service
Civic and Social
Construction, Material, Services
Food
General Sales
Industrial
Life Science
Recreational
Service
Transportation
Utility
Other
Concentration of
Business
Project Boundary
Legend
0 400 800 Feet
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Northeast Area Specific Plan 68
EXISTING CONDITIONS
Light Industrial-Maxx Metals Notable Adaptive Reuse-Badminton Academy Light Industrial-Multiple Tenant Space Retail-Duet Pharmacy Manufacturing-Delta Star Commercial-Life Sciences Palo Alto Medical Foundation (PAMF) Surrounding Residential Neighborhood A
C
B
D
A
C B
D
E F
G H
E
F
G
H
Business Snapshot
3.7 10.b
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Northeast Area Specific Plan 70
EXISTING CONDITIONS
Transportation
Access to the Northeast Area is limited by major barriers and few gateways.
Internal circulation is challenging, especially for non-drivers.
Connectivity is facilitated by two arterials:
Industrial Road and Old County Road, linking the
study area with the broader Harbor Industrial Area
to the north and Greater East San Carlos and East
Side Innovation District to the south. Industrial
Road transitions to a local/collector street north
of Quarry Road, culminating at Harbor Boulevard.
The San Carlos Caltrain Station, located just south
of the site, offers direct access to downtown San
Francisco and other Bay Area locations. Nearby,
on El Camino Real to the west of the site, several
bus stops provide convenient local transportation
options.
However, the Caltrain tracks are currently a major
barrier to connect to El Camino with poor access
for pedestrian and bicycles.
3.8 Figure 21 Existing Transportation Infrastructure Map Numerous driveways with vehicles blocking
the sidewalk.
Wide streets with high vehicle speeds
offer limited protection for pedestrians
and bicyclists.
Narrow sidewalks with obstructions impede
users with mobility assistive devices. Large trucks
can conflict with bicyclists and block bike lanes.
The F Street underpass
provides a pedestrian
and bike connection, but
its lack of wayfinding
and 24-hr lighting makes
this a low visibility and
uncomfortable pathway.
Northeast Area Specific Plan | Nelson\Nygaard 6
Photograph of parked vehicles blocking the sidewalk on
Quarry Road.
Photograph of a parked truck blocking the bike lane on
Industrial Road.
Photograph of Industrial Road’s current street configuration near Delta Star.
Photograph of the F Street underpass which connects Old County Road to El Camino Real.
Numerous driveways with vehicles blocking
the sidewalk.
Wide streets with high vehicle speeds
offer limited protection for pedestrians
and bicyclists.
Narrow sidewalks with obstructions impede
users with mobility assistive devices. Large trucks
can conflict with bicyclists and block bike lanes.
The F Street underpass
provides a pedestrian
and bike connection, but
its lack of wayfinding
and 24-hr lighting makes
this a low visibility and
uncomfortable pathway.
Northeast Area Specific Plan | Nelson\Nygaard 6
h vehicles blocking
Wide streets with high vehicle speeds
offer limited protection for pedestrians
and bicyclists.
Narrow sidewalks with obstructions impede
users with mobility assistive devices. Large trucks
can conflict with bicyclists and block bike lanes.
The F Street underpass
provides a pedestrian
and bike connection, but
its lack of wayfinding
and 24-hr lighting makes
this a low visibility and
uncomfortable pathway.
Northeast Area Specific Plan | Nelson\Nygaard 6
Traffic Signal
Stop Signs
F Street Underpass
SamTrans Bus Routes
Bus Stops
Pedestrian Route
II Class II Bike lane
Project Boundary
Legend
0 400 800 Feet
10.b
June 08, 2026 Packet Pg. 2530
CHAPTER 4 THIS SECTION WILL COVER:
Aerial photograph of the AutoVino parking lot.
Land Use and
Urban Form
4.1 LAND USE DESIGNATION
4.2 ZONING DISTRICTS
4.3 ADMINISTRATION AND
PERMITS
4.4 PERMITTED USES FOR
MIXED-USE DISTRICTS
4.5 PERMITTED USES
FOR PRODUCTION AND
INNOVATION, INDUSTRIAL
PROFESSIONAL USES
4.6 FLOOR AREA RATIO (FAR)
AND DENSITY STANDARDS
4.7 HEIGHT STANDARDS
4.8 BONUS FAR AND BUILDING
HEIGHT PROVISIONS
4.9 PUBLICLY ACCESSIBLE
OPEN SPACE
4.10 GROUND FLOOR ACTIVE
USES
4.11 DISTRICT WIDE
DEVELOPMENT STANDARDS
4.12 NON-RESIDENTIAL
DEVELOPMENT STANDARDS
4.13 RESIDENTIAL
DEVELOPMENT STANDARDS
←
10.b
June 08, 2026 Packet Pg. 2531
4.1.1 Land Use Designations
The District is organized into two land use
designations: Planned Industrial and Mixed-Use,
75 and Mixed-Use 90 DUs/Acre.
Planned Industrial
The Planned Industrial land use designation
includes the area in purple as illustrated in
Figure 22. Consistent with the General Plan, this
designation permits research and development,
bio-tech, light industrial, flex, warehousing, and
related uses.
Mixed-Use 75 and Mixed-Use 90 DUs/Acre
The Mixed-Use 75 Du/Acre permits densities of
57-75 Dwelling Units per Acre (DUs/Acre) and
Mixed-Use 90 Du/Acre allows densities of 68-
90 Dwelling Units per Acre (DUs/Acre). These
designations are shown as the area in light yellow
and yellow respectively, in Figure 22. Due to
its proximity to the San Carlos Caltrain Station,
Dowwntown San Carlos, and the Greater East San
Carlos Neighborhood, this designation permits
multi-family residential uses and mixed-uses at
densities of 75-90 DU/Acre.
Figure 22 Land Use Designations Map
Planned Industrial
Mixed-Use 57-75 DUs/Acre
Mixed-Use 68-90 DUs/Acre
Project Boundary
Land Use Designations
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 74
4.1 Land Use Designations
The framework provides flexibility for both existing and future land use designations to advance a 21st century model for mixed-use development focused on makers and innovators.
0 400 800 Feet
10.b
June 08, 2026 Packet Pg. 2532
4.2.1 Zoning
The Northeast Area shall be organized into
the following zoning districts: Production and
Innovation, Mixed-Use Northeast 90, Mixed-Use
Northeast 75, Industrial Professional, and Planned
Development.
Production and Innovation (P-I)
The Production and Innovation Zone is shown in
the area in purple as illustrated in Figure 23. This
District is intended to foster a mix of industrial
workshops, warehouses, commercial recreation,
research and development, office, and retail.
Mixed-Use Northeast 90 (MU-NE-90)
The Mixed-Use Northeast 90 Zone is shown in
the area in gold as illustrated in Figure 23. Due to
its proximity to both the San Carlos and Belmont
Caltrain Stations, Downtown San Carlos, and El
Camino Real, this District is intended for higher
density multi-family residential, retail, and ground
floor active uses.
Mixed-Use Northeast 75 (MU-NE-75)
The Mixed-Use Northeast 75 Zone is shown in
the area in yellow as illustrated in Figure 23..
Due to it’s adjacency to the Greater East San
Carlos Neighborhood, this District is intended to
provide medium to high density mix of multi-family
residential, retail and ground floor active uses.
Figure 23 Zoning Districts Map
Production and Innovation (P-I)
Mixed Use Northeast 90 (MU-NE-90)
Mixed-Use Northeast 75 (MU-NE-75)
Industrial Professional (IP)
Planned Development (PD)
Project Boundary
Zoning Districts
PD-18
PD-21
PD-28
P-I
P-I P-I
P-I MU-NE-90
P-I MU-NE-75
IP
0 400 800 Feet
STANDARDS
Industrial Professional (IP)
As illustrated in Figure 23. the Industrial
Professional District is intended for large or
campus-like office and technology development
that includes office, research, and development,
manufacturing, and other large-scale professional
uses.
Planned Development (PD)
The Northeast Area contains three Planned
Development sites as shown in the blue hatching
as illustrated in Figure 23.. These PDs were
established to provide site specific coordination
and development standards. This includes PD 18,
PD 21, and PD 28.
4.2.2 Legal Non-Conforming Uses
Applicants shall refer to San Carlos Municipal
Code (SCMC) 18.19 Nonconforming uses,
Structures, and Lots.
LAND USE AND URBAN FORM
Northeast Area Specific Plan 76
The Northeast Area’s land use designations are codified into distinct Zoning Districts.
4.2 Zoning Districts
10.b
June 08, 2026 Packet Pg. 2533
Figure 24 Ground Floor Active Use Map
Required Retail Corners
Required Industrial, Artisan, Manufacturing Frontages
Allowed Active Use Corridors
Project Boundary
4.3.1 Allowed Active Ground Floor Use
Corridors
To create pedestrian and visual activity at the
ground floor of new developments, Active Use
Corridors are allowed on street segments lined
with pink identified in Figure 24. The list of
allowed active uses can be found in Table 3.
Ground floor active uses shall provide usable
spaces with a depth of at least twelve (12)
feet without interior obstructions such as walls
or partitions. Ground floor active uses shall
extend to at least sixty-five percent (65%)
of the length of the public street frontage.
Note: Ground floor active uses may extend
beyond the minimum depth of 12 feet.
4.3.2 Required Industrial, Artisan,
Manufacturing Uses
To support new small-scale industrial uses in the
Northeast Area, new development on Quarry
Road shall have Industrial, Artisan, Manufacturing
Uses (IAM) as the primary ground floor use.
IAM shall mean spaces where goods are produced
or fabricated. The list of uses can be found in
Table 4.
IAM can also include uses that are accessory to
production such as retail, restaurant, office, and
educational uses to create an environment where
production uses can be public facing.
This zone strategically clusters similar types of
businesses to optimize infrastructure and minimize
conflicts with residential uses.
4.3.3 Required Retail Corners
The required retail corners at the key intersections
illustrated in Figure 24. shall be limited to the
uses listed in Table 3.
A corners shall be defined for at least twenty (20)
feet along each of the two street-facing building
facades.
Required retail corners shall provide usable spaces
with a depth of at least twelve (12) feet without
interior obstructions such as walls or partitions.
and shall occupy at least sixty-five percent (65%)
of the twenty (20) feet.
Applicants shall only be subject to this requirements
with new construction or a significant remodel at
the discretion of the Community and Economic
Development Director.
Ground Floor Active Uses
PD-18
PD-21
PD-28
P-I
P-I P-I
P-I MU-NE-90
P-I MU-NE-75
IP
0 400 800 Feet
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 78
Ground Floor Active Uses
A diverse range of active uses on the ground floors of buildings will encourage activation in the Northeast Area at different times of the day and week and support the needs of the employees, residents, and visitors. Applicants are subject to these requirements with new construction or a significant remodel.
4.3 10.b
June 08, 2026 Packet Pg. 2534
4.4.1 Planning Authorities
Applicants shall refer to San Carlos Municipal
Code (SCMC) 18.26 Planning Authorities to
identify responsibilities for specific bodies, officials and administrators as it pertains to development
in the Northeast Area.
Table 18.26.070: Review Authority provides a
summary of review authorities for decisions and
appeals.
4.4.2 Common Procedures
Applicants shall refer to San Carlos Municipal
Code (SCMC) 18.27 Common Procedures
to identify proceduces that are common to the
application and processing of all permits and
approvals.
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 80
Administration and Permits
The Specific Plan directs applicants to Article IV of the Zoning Ordinance which will inform the appropriate pathway for approval.
4.4 This page is intentionally blank.
10.b
June 08, 2026 Packet Pg. 2535
Use classifications are defined in San Carlos
Municipal Code (SCMC) Chapter 18.40, Use
Classifications. In cases where a specific land
use or activity is not defined, the Director shall
assign the land use or activity to a classification
that is substantially similar in character. Use
classifications and subclassifications not listed in
the table or not found to be substantially similar
to the uses below are prohibited. The table also
notes additional use regulations that apply to
various uses. Section numbers in the right-hand
column refer to other sections of this title.
4.5.1 Permitted Uses for Mixed-Use Districts
The regulations for each are established by letter designation as follows:
“ P ” designates permitted uses.
“ C ” designates use classifications that are permitted after review and approval of a conditional use permit by the Planning and Transportation Commission. “ - ” designates uses that are not permitted.
“ M ” designates use classifications that are permitted after review and approval of a minor use permit by the Zoning Administrator.
Use classifications describe one (1) or more uses
of land having similar characteristics but do not
list every use or activity that may appropriately
be within the classification. The Planning and
Transportation Commission, upon request from
the Director, shall determine whether a specific
use shall be deemed to be within one (1) or more
use classifications or not within any classification
in this chapter. The Commission may determine
that a specific use shall not be deemed to be
within a classification, whether or not named
within the classification, if its characteristics are
substantially incompatible with those typical of
uses named within the classification.
LAND USE AND URBAN FORM
Northeast Area Specific Plan 82
4.5 Land Use Regulations -
Mixed-Use Districts
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
RESIDENTIAL USES
Residential Housing Types See subclassifications below
Multi-Unit Residential P P P -
Accessory Dwelling Unit P P P - Only if the site includes a proposed or existing dwelling. See Section 18.23.210,
Accessory dwelling units
Junior Accessory Dwelling Unit - - - -
Elderly and Long-Term Care C C P -
Family Child Care See subclassifications below
Table 3 Land Use Regulations - Mixed-Use Districts
10.b
June 08, 2026 Packet Pg. 2536
LAND USE AND URBAN FORM
Northeast Area Specific Plan 84
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
Small P P P -
Large P P P - See Section 18.23.090, Day care centers
and large family child care homes
Residential Care Facilities See subclassifications below General - - - - See Section 18.23.200, Residential care facilities
Limited P P P -
Senior P P P - See Section 18.23.200, Residential care
facilities
Single Room Occupancy C C C - See Section 18.23.220, Single room occupancy hotels
Transitional Housing P P P - See Section 18.23.250, Transitional and supportive housing
Supportive Housing P P P - See Section 18.23.250, Transitional and supportive housing
PUBLIC AND SEMI-PUBLIC USES
Colleges and Trade Schools, Public or Private - - C -
Community Assembly, Less Than 3,500 Square Feet - - P - See Section 18.23.080, Community assembly facilities
Community Assembly, 3,500 Square Feet or More - - C - See Section 18.23.080, Community assembly facilities
Community Garden P P P C
Cultural Institutions - - P M
Day Care Centers - - P(4) - See Section 18.23.090, Day care Emergency Shelters C C - -
10.b
June 08, 2026 Packet Pg. 2537
LAND USE AND URBAN FORM
Northeast Area Specific Plan 86
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
Government Offices - - M -
Hospitals - - - -
Clinics - - P -
Instructional Services - - P(4) M
Park and Recreation Facilities, Public P P P -
Public Safety Facilities - - M -
Schools, Public or Private - - C -
Social Service Facilities - - C -
COMMERCIAL USES
Animal Care, Sales and Services See subclassifications below Grooming and Pet Stores - - P P
Veterinary Services - - C C
Artist’s Studio - - P M
Automobile/Vehicle Sales and Services See subclassifications below Automobile Rentals - - C - See Section 18.23.050, Automobile/ vehicle sales and services
Automobile/Vehicle Repair, Major - - - -
Automobile/Vehicle Service and Repair, Minor - - - -
Automobile/Vehicle Sales and Leasing - - - -
Automobile/Vehicle Washing - - - -
Large Vehicle and Equipment Sales, Service and Rental - - - -
10.b
June 08, 2026 Packet Pg. 2538
LAND USE AND URBAN FORM
Northeast Area Specific Plan 88
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
Service Station - - - - See Section 18.23.050, Automobile/ vehicle sales and services
Towing and Impound - - - -
Vehicle Storage - - - -
Banks and Financial Institutions - - P -
Business Services - - P -
Commercial Entertainment and Recreation See subclassifications below Cinema/Theaters - - C C
Large-Scale - - C C
Small-Scale - - C C
Eating and Drinking Establishments See subclassifications below Bars/Night Clubs/Lounges - - C C See Section 18.23.060 Bars/nightclubs/ lounges and commercial entertainment
and recreation
Full Service - - P P See Section 18.23.140, Outdoor dining Convenience - - P P
Food Preparation - - P(4) -
Lodging - - - -
Offices See subclassifications below
Business and Professional - - P -
Medical and Dental - - P -
Walk-In Clientele - - P -
10.b
June 08, 2026 Packet Pg. 2539
LAND USE AND URBAN FORM
Northeast Area Specific Plan 90
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
Funeral Parlors and Interment Services - - - -
Personal Services See subclassifications below
General Personal Services - - P C
Tattoo or Body Modification Parlor - - P C See Section 18.23.170, Personal service Retail Sales See subclassifications below
Building Materials and Services - - - -
Cannabis Dispensary - - - -
Convenience Markets - - P P
Food and Beverage Sales - - P(3) P(3)
General Retail - - P(3) P(3)
Price Point Retail - - - -
Second Hand Store - - P P
Retail Establishments Selling Ammunition or Firearms - - - - See Section 18.23.290, Retail establishments selling ammunition or
firearms
Construction and Material Yards - - - - See Section 18.23.160, Outdoor storage Custom Manufacturing - - P C
Industry, General - - - - See Section 18.23.270, Commercial cannabis businesses
Industry, Limited - - - -
Recycling Facility See subclassifications below
10.b
June 08, 2026 Packet Pg. 2540
LAND USE AND URBAN FORM
Northeast Area Specific Plan 92
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
Reverse Vending Machine - - - - See Section 18.23.190, Recycling facilities
Recycling Collection Facility - - - -
Recycling Processing Facility - - - -
Research and Development - - - - See Section 18.23.270, Commercial cannabis businesses
Salvage and Wrecking - - - -
Warehousing and Storage See subclassifications below
Chemical, Mineral, and Explosives Storage - - - -
Indoor Warehousing and Storage - - - -
Outdoor Storage - - - -
Wholesaling and Distribution - - - -
Cannabis Microbusiness - - - - See Section 18.23.270, Commercial cannabis businesses
Communication Facilities See subclassifications below
Antenna and Transmission Towers See Chapter 18.24, Wireless Telecommunications Facilities Facilities within Buildings - - - -
Freight/Truck Terminals and Warehouses - - - -
Light Fleet-Based Services - - - -
Parking, Public or Private - - - -
Utilities, Major - - - -
Utilities, Minor P P P P
10.b
June 08, 2026 Packet Pg. 2541
LAND USE AND URBAN FORM
Northeast Area Specific Plan 94
USE CLASSIFICATIONS MU-NE-75 MU-NE-90 ALLOWED GROUND FLOOR
ACTIVE USE CORRIDORS
REQUIRED RETAIL
CORNERS ADDITIONAL REGULATIONS
Waste Transfer Facility - - - -
OTHER APPLICABLE TYPES
Accessory Uses and Structures See Section 18.23.030, Accessory uses, and Section 18.15.020, Accessory buildings and structures Home Occupations P P P - See Section 18.23.120 Home occupations Drive-In and Drive-Through Facilities Prohibited in MU districts; see Section 18.23.100, Drive-in and drive-through facilities Nonconforming Use Chapter 18.19, Nonconforming Uses, Structures, and Lots Temporary Use Chapter 18.31, Temporary Use Permits
Specific Limitations:
1. Shall be conducted entirely within an enclosed building.
2. Limited to establishments with a gross floor area of five thousand (5,000) square feet.
3. Minor use permit required for uses adjacent to R districts.
4. Shall be required to submit a Pick-Up and Drop-Off Plan, subject to review and approval by the Planning Director. The Planning Director may refer items directly to the Zoning Administrator when in his/her/their opinion the public interest would be better served by having the Zoning Administrator conduct review and approval of Instructional Services.
10.b
June 08, 2026 Packet Pg. 2542
4.6.1 Permitted Uses for Production and Innovation, and Industrial Professional Uses The regulations for each are established by letter designation as follows:
“ P ” designates permitted uses.
“ C ” designates use classifications that are permitted after review and approval of a conditional use permit by the Planning and Transportation Commission. “ - ” designates uses that are not permitted.
“ M ” designates ministerial approval
LAND USE AND URBAN FORM
Northeast Area Specific Plan 96
4.6 Land Use Regulations -
Industrial District
USE CLASSIFICATIONS P-I IP
ALLOWED GROUND
FLOOR ACTIVE USE
CORRIDORS
INDUSTRIAL, ARTISAN,
MANUFACTURING USES
(IAM) FRONTAGES
REQUIRED RETAIL
CORNERS
ADDITIONAL
REGULATIONS
PUBLIC AND SEMI-PUBLIC USES
Colleges and Trade Schools, Public or Private C - C C - Government Offices C C M - -
Hospitals - C - - -
Clinics - - P - -
Public Safety Facilities M - M - -
COMMERCIAL USES
Animal Care, Sales and Services See subclassifications below Grooming and Pet Stores M - P - P
Kennels M - M - -
Table 4 Land Use Regulations - Industrial Districts
10.b
June 08, 2026 Packet Pg. 2543
LAND USE AND URBAN FORM
Northeast Area Specific Plan 98
USE CLASSIFICATIONS P-I IP
ALLOWED GROUND
FLOOR ACTIVE USE
CORRIDORS
INDUSTRIAL, ARTISAN,
MANUFACTURING USES
(IAM) FRONTAGES
REQUIRED RETAIL
CORNERS
ADDITIONAL
REGULATIONS
Veterinary Services M - M - C
Artist's Studio P - P P M
Automobile/Vehicle See subclassifications below
Automobile Rentals C(1) C(4) C(1) - - See Section 18.23.050, Automobile/vehicle sales
and services
Automobile/Vehicle Repair, Major P C P - - See Section 18.23.050, Automobile/vehicle sales
and services
Automobile/Vehicle Service and Repair, Minor P - P - - See Section 18.23.050, Automobile/vehicle sales
and services
Automobile/Vehicle Sales and Leasing C(1) C(4) C(1) - - See Section 18.23.050, Automobile/vehicle sales
and services
Automobile/Vehicle Washing P - P - - See Section 18.23.050, Automobile/vehicle sales
and services
Large Vehicle and Equipment Sales, Service and Rental P - M - - See Section 18.23.050, Automobile/vehicle sales
and services
Service Station P(3) - P(3) - - See Section 18.23.050,
Automobile/vehicle sales
and services
Towing and Impound M - M - - See Section 18.23.050,
Automobile/vehicle sales
and services
Vehicle Storage M - M - - See Section 18.23.050,
Automobile/vehicle sales
and services
10.b
June 08, 2026 Packet Pg. 2544
LAND USE AND URBAN FORM
Northeast Area Specific Plan 100
USE CLASSIFICATIONS P-I IP
ALLOWED GROUND
FLOOR ACTIVE USE
CORRIDORS
INDUSTRIAL, ARTISAN,
MANUFACTURING USES
(IAM) FRONTAGES
REQUIRED RETAIL
CORNERS
ADDITIONAL
REGULATIONS
Banks and Financial Institutions - - P - -
Business Services P P P P -
Commercial Entertainment and Recreation See subclassifications below Cinema/Theaters C - C - C See Section 18.23.060
Bars/nightclubs/
lounges and commercial
entertainment and
recreation
Large-Scale C - C - C See Section 18.23.060
Bars/nightclubs/
lounges and commercial
entertainment and
recreation
Small-Scale C - C - C See Section 18.23.060
Bars/nightclubs/
lounges and commercial
entertainment and
recreation
Eating and Drinking Establishments See subclassifications below Bars/Night Clubs/Lounges C - C C C See Section 18.23.140, Outdoor dining
See Section 18.23.060
Bars/nightclubs/
lounges and commercial
entertainment and
recreation
Full Service P(5) P(5) P(5) P(5) P(5) See Section 18.23.140, Outdoor dining
Convenience M(5) M(5) P(5) P(5) P(5)
10.b
June 08, 2026 Packet Pg. 2545
LAND USE AND URBAN FORM
Northeast Area Specific Plan 102
USE CLASSIFICATIONS P-I IP
ALLOWED GROUND
FLOOR ACTIVE USE
CORRIDORS
INDUSTRIAL, ARTISAN,
MANUFACTURING USES
(IAM) FRONTAGES
REQUIRED RETAIL
CORNERS
ADDITIONAL
REGULATIONS
Food Preparation P - M P -
Nurseries and Garden Centers M - M M -
Lodging - - - - -
Bed and Breakfast - - - - -
Hotels and Motels C - C - -
Offices See subclassifications below
Business and Professional P M P M -
Medical and Dental P M P - -
Walk-In Clientele P P P M -
Funeral Parlors and Interment Services - - - - -
Personal Services See subclassifications below
General Personal Services C C P P C See Section 18.23.170 Personal services
Tattoo or Body Modification Parlor C C M P C See Section 18.23.170 Personal services
Retail Sales See subclassifications below
Building Materials and Services M - - - -
Cannabis Dispensary - - - - -
Convenience Markets M(5) M(5) P(5) - P(5)
Food and Beverage Sales M(5) M(5) P(5) P(5) P(5)
General Retail M(5) - P(5) - P(5)
10.b
June 08, 2026 Packet Pg. 2546
LAND USE AND URBAN FORM
Northeast Area Specific Plan 104
USE CLASSIFICATIONS P-I IP
ALLOWED GROUND
FLOOR ACTIVE USE
CORRIDORS
INDUSTRIAL, ARTISAN,
MANUFACTURING USES
(IAM) FRONTAGES
REQUIRED RETAIL
CORNERS
ADDITIONAL
REGULATIONS
Price Point Retail - - - - -
Second Hand Store P(5) P(5) P(5) P(5) P(5)
Retail Establishments Selling Ammunition or Firearms - - - - - See Section 18.23.290, Retail establishments
selling ammunition or
firearms
INDUSTRIAL USES
Construction and Material Yards P - M M -
Custom Manufacturing P - P P M
Industry, General P - P P -
Industry, Limited P P P P -
Reverse Vending Machine P - P - -
Recycling Collection Facility C - C - - See Section 18.23.190 Recycling facilities.
Recycling Processing Facility C - C - -
Salvage and Wrecking M - - - -
Research and Development P P P M -
Research and Development Activities Requiring BSL-1 and BSL-2 Containment
P P P M -
Research and Development Activities Requiring BSL-3
Containment
- - - - -
Research and Development Activities Requiring BSL-4
Containment
- - - - -
Warehousing and Storage See subclassifications below
10.b
June 08, 2026 Packet Pg. 2547
LAND USE AND URBAN FORM
Northeast Area Specific Plan 106
USE CLASSIFICATIONS P-I IP
ALLOWED GROUND
FLOOR ACTIVE USE
CORRIDORS
INDUSTRIAL, ARTISAN,
MANUFACTURING USES
(IAM) FRONTAGES
REQUIRED RETAIL
CORNERS
ADDITIONAL
REGULATIONS
Chemical, Mineral, and Explosives Storage C(6) - C(6) - - Indoor Warehousing and Storage P - P - - See Section 18.15.090, Screening
Outdoor Storage P - - - - See Section 18.15.090,
Screening
See Section 18.23.160
Outdoor storage
Wholesaling and Distribution P - P - -
Cannabis Microbusiness - - - - - See Section 18.23.270, Commercial cannabis
businesses
Communication Facilities See subclassifications below
Antenna and Transmission Towers See Chapter 18.24, Wireless Telecommunications Facilities Facilities within Buildings M M M - -
Freight/Truck Terminals and Warehouses C - C - -
Light Fleet-Based Services P - P - -
Parking, Public or Private P - P - -
Utilities, Major C C C - -
Utilities, Minor P P P P P
Waste Transfer Facility P - P - -
OTHER APPLICABLE TYPES
Accessory Uses and Structures See Section 18.23.030, Accessory uses, and Section 18.15.020, Accessory buildings and structures Nonconforming Use Chapter 18.19, Nonconforming Uses, Structures, and Lots Temporary Use Chapter 18.31, Temporary Use Permits
10.b
June 08, 2026 Packet Pg. 2548
LAND USE AND URBAN FORM
Northeast Area Specific Plan 108
Specific Limitations:
1. Shall be conducted entirely within an enclosed building.
2. Limited to establishments with a gross floor area of five thousand (5,000) square feet or less.
3. Limited to alternative fueling stations such as for electric or hybrid vehicles, hydrogen-powered vehicles, and similar vehicles using alternative fuels.
4. Limited to properties between Industrial Road and Highway 101 and adjacent to Shoreway Road.
5. Permitted only as an accessory use.
6. Prohibited within five hundred (500) feet of a residential district.
This page is intentionally blank.
10.b
June 08, 2026 Packet Pg. 2549
Figure 25 FAR and Density Map
2.0 FAR
1.5 FAR
1.0 FAR
68-90 DUs/ACRE
57-75 DUs/ACRE
Project Boundary
4.7.1 Floor Area Ratio (FAR)
The permissible floor area ratio for non-residential
development in the Production and Innovation
district and IP district is shown in Figure 25.
Bonus FAR for non-residential properties can be
earned in exchange for community benefits as
allowed in Section 7.10.
For existing Planned Developments, refer to the
associated Ordinance adopting the Planned
Development for FAR limits.
4.7.2 Measuring Floor Area Ratio (FAR)
Floor area shall be measured pursuant to San
Carlos Municipal Code (SCMC) 18.03 Rules
of Measurement.
FAR and Density Standards
P-I PD-18 IP
PD-21
PD-28
P-I P-I
P-I P-I
P-I
MU-NE-90
MU-NE-75
4.7.3 Residential Density
Residential development in the Mixed-Use
Northeast 90 (MU-NE-90) Zone and the MixedUse Northeast 75 (MU-NE-75) Zone shall be allowed by right to utilize the Dwelling Unit per
Acre (DU/Acre) densities shown in Figure 25.
The minimum density requirements for each of
these zones are 75% of the maximum allowable
density, which is 57 DU/Acre for MU-NE-75 zone
and 68 DU/Acre for MU-NE-90 zone.
0 400 800 Feet
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 110
Floor Area Ratio (FAR) and
Density Standards
The Northeast Area promotes a dense urban area with a broad mix of commercial, residential, industrial, and institutional uses, fosters transit-oriented development, and a vibrant public realm.
4.7 10.b
June 08, 2026 Packet Pg. 2550
Figure 27 Maximum Building Heights Map
Figure 26 Easement, Setback and Height Diagram
100 Feet (P-I, IP)
90 Feet (MU-NE-90)
75 Feet (P-I, MU-NE-75)
Planned Development
Project Boundary
Maximum Building Heights
P-I PD-18 IP PD-21
PD-28
P-I P-I
P-I P-I
P-I
MU-NE-90
MU-NE-75
0 400 800 Feet
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 112
Height Standards
4.8.1 Maximum Building Heights
Maximum building heights shall adhere to Figure
27, with heights ranging from 75 feet to 100
feet. Bonus heights for select properties shall be
allowed as set forth under Section 4.8. Properties
zoned MU-NE-75 and MU-NE-90 do not qualify
for additional heights unless otherwise allowed
under State Law for housing development.
4.8.2 Measuring Building Height
Building height shall be measured pursuant to
San Carlos Municipal Code (SCMC) 18.03
Rules of Measurement.
4.8.3 San Carlos Airport FAA Compliance
Applicants shall measure mean sea level (MSL) of
development site to determine allowable maximum
height envelop. All development shall comply with
Federal Aviation Administration (FAA) regulations
and subject to review by C/CAG Airport Land Use
Commission (ALUC), as necessary.
4.8.4 Height Stepdowns
New development in the MU-NE-75 Zoning
District shall step down to 35 feet when a building
is within 130 feet of the rear lot line abutting
the 50 foot easement. The minimum 30 foot
landscape buffer shall occur within the 130 feet .
For more information on Landscape Buffers go to
Section 4.13.2. An example of the stepdown is
illustrated in Figure 26.
4.8 The Northeast Area uses a calibrated height framework designed to accommodate future growth and redevelopment, while
preserving an appropriate scale and transition to surrounding residential neighborhoods.
10.b
June 08, 2026 Packet Pg. 2551
Figure 28 Bonus Density and Height Map
To provide an incentive for development, and in partnership with the City to provide community benefits that would not otherwise be created, a nonresidential project may have increased FAR, and/or height in return for provision of specific community benefits. Bonus FAR and height regulations provide opportunity to deliver tangible community benefits within the district.
These standards apply to new development within sites zoned P-I.
No FAR Cap, Maximum Height - 155 Feet above MSL
Project Boundary
Bonus FAR and Building Height Provisions
0 400 800 Feet
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 114
Bonus FAR and Building
Height Provisions
4.9.1 Bonus FAR and Building Height
Applicants shall adhere to Figure 28 to determine
if property is qualified to earn an FAR or Building
Height bonus. There is no cap on bonus FAR.
4.9.2 Community Benefits Menu
Applicants shall refer to Section 7.10 to review
the Community Benefits menu and calculation
method.
4.9.3 San Carlos Airport FAA Compliance
Applicants shall measure mean sea level (MSL)
of development site to determine allowable
maximum height envelop. All development shall
comply with Federal Aviation Administration (FAA)
regulations and maintain compliance with C/CAG
Airport Land Use Compatibility Plan (ALUCP).
4.9 10.b
June 08, 2026 Packet Pg. 2552
Figure 29 Site of Future Public Park
Potential Site of Future Public Park
Existing Open Channels and Easements
Project Boundary
Publicly Accessible Open Spaces
4.10.1 Minimum Publicly Accessible Open
Space
For lots greater than 15,000 sq. ft. (0.3 acres)
but less than or equal to 1 acre, a minimum of
10% shall be required to be publicly accessible
open or park space. For lots greater than 1 acre,
a minimum of 15% shall be required to be publicly
accessible.
A community park/open space shall be provided
that meets the following design criteria:
• Is a minimum of 15% or 10% percent of site
area depending on the total lot size;
• Is located at ground level with direct pedestrian
and ADA access to the adjacent public street;
• Is unenclosed by any wall, fence, gate, or other
obstruction across the subject property;
• Is open to the public, without charge, each day
of the year, except for temporary closures for
necessary maintenance or public safety;
Water quality facilities that do not provide any type
of recreational benefit (e.g., retention basins, bioswales, etc.) shall not be included in the minimum park space.
Water quality facilities that include recreational
facilities, (e.g., underground detention basins with
recreational facilities above) may count towards
the minimum park space requirement;
4.10.2 Minimum Usable Area for Publicly
Accessible Open Spaces
In the MU-NE-90 Zone, the minimum usable area
shall be 20,000 sq.ft. and a minimum 100 foot
width.
In the MU-NE-75 Zone, the minimum usable area
shall be 5,000 sq.ft. and a minimum 20 foot width.
4.10.3 Future Public Park Siting
To ensure public access to open space, a public
park shall be located in the Mixed-Use Northeast
90 (MU-NE-90) Zoning District.
The primary entry to the open space shall be
located immediately from the public right of way
to maximum visibility and accessibility from the
surrounding neighborhood.
The exact design of the park shall be determined
at a later date in partnership with any future
applicant.
Built examples of publicly accessible open spaces.
STANDARDS
New publicly accessible open spaces in the Northeast Area is essential to a coordinated resilience strategy and fostering an enhanced quality of life for all employees, residents, and visitors.
LAND USE AND URBAN FORM
Northeast Area Specific Plan 116
Publicly Accessible Open Spaces
4.10 10.b
June 08, 2026 Packet Pg. 2553
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 118
DEVELOPMENT STANDARDS SAN CARLOS MUNICIPAL CODE
(SCMC) CHAPTERS
GENERAL SITE REGULATIONS
Accessory Buildings and Structures Refer to SCMC 18.15
Fences and Walls
Height and Height Exceptions
Lighting and Illumination
Projections into Yards
Screening
Swimming Pools and Spas
Trash and Recycling Collection Areas
Underground Utilities
Visibility at Intersections and Driveways
AFFORDABLE HOUSING (MIXED-USE RESIDENTIAL NORTHEAST ZONES ONLY) Affordable Housing Programs Refer to SCMC 18.16
Affordable Housing Incentives Refer to SCMC 18.17
LANDSCAPING
Landscaping Refer to SCMC 18.18
DISTRICT WIDE DEVELOPMENT STANDARDS SAN CARLOS MUNICIPAL CODE (SCMC) CHAPTERS
PERFORMANCE STANDARDS
Noise Refer to SCMC 18.21
Vibration
Odors
Heat and Humidity
Air Contaminants
Liquid or Solid Waste
Fire and Explosive Hazards
Hazardous and Extremely Hazardous Materials
Electromagnetic Interference
Radioactivity
Airport Land Use Compatibility Plan Consistency
SIGNS
Signs Refer to SCMC 18.22
SPECIFIC USES AND ACTIVITIES
Standards for Specific Uses and Activities Refer to SCMC 18.23
WIRELESS TELECOMMUNICATIONS
Wireless Telecommunication Facilities Refer to SCMC 18.24 District Wide
Development Standards
Northeast Area development projects, regardless of Zoning, shall adhere to development standards listed below:
In the event of conflicts between multiple standards, the more restrictive shall apply .
4.11.1 District Wide Development Standards
4.11.2 Multiple Standards Resolution
Table 5 District Wide Development Standards
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June 08, 2026 Packet Pg. 2554
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 120
Non-Residential
Development Standards
The Northeast Area’s non-residential zoning designations shall adhere to the following standards:
DEVELOPMENT STANDARDS PRODUCTION & INNOVATION INDUSTRIAL PROFESSIONAL LAND USE REGULATIONS Refer to SCMC 18.07.020 Refer to SCMC 18.07.020
DEVELOPMENT STANDARDS
Lot, Density, FAR Standards
Minimum Lot Size 40,000 sq. ft. 1 Acre
Minimum Lot Size - Corner Lots 40,000 sq. ft. 1 Acre
Maximum Lot Size n/a n/a
Minimum Lot Width 50’ 75’
Minimum Lot Width Corner Lots 60’ 75’
Height
Maximum Height Varies (Refer to Section 4.10: Height Standards) 100’ Building Placement Standards
Minimum Front Setback Varies (Refer to Sections 5.15 through 5.22 for Street Sections)
20’
Minimum Interior Side Setback 0’ 0’
Minimum Street Side Setback 5’ 5’
Minimum Rear Setback 0’ 0’
Minimum Creek Setback 35’ from creek top of bank
(Refer to Section 6.3: Creek Front Zone)
N/A
Floor Area Ratio
Maximum FAR Varies (Refer to Section 4.9) 2.0
4.12.1 Non-Residential Development Standards
Table 6 Non-Residential Development Standards
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June 08, 2026 Packet Pg. 2555
LAND USE AND URBAN FORM
Northeast Area Specific Plan 122
DEVELOPMENT STANDARDS PRODUCTION & INNOVATION PLANNED INDUSTRIAL SUPPLEMENTAL REGULATIONS Refer to SCMC 18.07.040
Landscaping A minimum of ten percent (10%) of the site must be landscaped.
Building Design Near HWY 101 For any site that is fully or partially located within two hundred (200) feet of the right-of-way line of Highway 101, all sides of the building shall be architecturally compatible where each wall is designed consistently with the primary facade in the extent of building articulation and quality of exterior materials, and consistent with the color scheme of the primary facade.
Sidewalks New sidewalks shall be provided as part of new development. Refer to Chapter 5: Mobility and Parking for sidewalk width specifications for relevant streets. No new sidewalks as part of development may be considered at the discretion of the Public Works Director.
Public Open Space ` For properties greater than 1 acre (gross), new development shall dedicate a minimum of 15% of total site area toward publicly accessible open space and for properties greater than 15,000 sq.ft. (0.3 acres) development shall dedicate a minimum of 10% of total site area toward publicly accessible open space.
Parking Location Surface parking lots shall be located at the side or rear of buildings.
Entries to parking structures, underground parking decks or partially undergound parking decks shall be located at the side or rear of buildings, wherever possible. If this is not possible, the approval will be at the discretion of the Community Development Director.
Every new development, and every building enlarged by more than five thousand (5,000) square feet, shall provide on-site loading and unloading areas per Table 24 in Section 5.9.
Limitation on Curb Cuts Wherever possible, parking and loading entrances shall share curb cuts in order to minimize the overall number of curb cuts. On corner lots, curb cuts shall be located on the street frontage with the least pedestrian activity wherever feasible.
Access shall be provided from a side street or alley wherever possible. If this is not possible, the approval will be at the discretion of the Community Development Director.
Access Location Access shall be provided from a side street or alley wherever possible. If this is not possible, the approval will be at the discretion of the Community Development Director.
Truck Docks Truck Docks shall be provided from a side street or alley wherever possible. If this is not possible, the approval will be at the discretion of the Community Development Director.
Retail Corners on the Ground Floor Retail corners shall setback at a minimum of 10 feet deep and a maximum of 30 feet deep from the property line.
10.b
June 08, 2026 Packet Pg. 2556
Buildings and the public realm together create a
dynamic urban experience that is informed by and
integrates with the surrounding context. Retail
and active-use ground floors offer flexibility and
variety, featuring a high level of transparency that
enhances the vibrancy of the streets they face.
1 2
3 4
Figure 30 Ground Floor Retail Corners Diagram
4.12.2 Ground Floor Required Retail Corners
Floor to Floor Height
Legend
1 2 Transparent Frontage
3 4
Corner Treatments and
Entrances
Active Setbacks
300 Ivy Street in San Francisco shows how corner retail can anchor the street life.
Tartine Bakery in San Francisco Dogpatch neighborhood
is an example of manufacturing areas that can also house their brick and mortar shops to invite people to see the space product being made while enjoying it.
SF Jazz Center show a successful distinct corner with
visual transparency.
ASU Beus Center for Law & Society Building has a
recessed corner that allows for shelter and spill out space for corner retail.
LAND USE AND URBAN FORM
Northeast Area Specific Plan 124
Floor to Floor Height
All new development with required Required
Retail Corners shall have a minimum of 14 feet to
a maximum of 16 feet, floor to floor height from
sidewalk grade.
Transparency
Retail facades shall be at least 55 percent
transparent across the entire length of the retail
space, measured 12 feet vertically from the
finished grade.
Corner Entrances
Retail corners entries shall have architectural
detailing that emphasizes the importance of the
corner such as minor inset at the ground floor and
large-scale awnings and canopies.
Active Setbacks
Retail corners on the ground floor shall setback at
a minimum of 10 feet deep and a maximum of 30
feet deep from the property line.
Credit - Bruce Damonte
Credit - Commune Design
Credit - Tim Griffith
Credit - Perkins&Will
10.b
June 08, 2026 Packet Pg. 2557
Small scale Industrial, Artisan, and Manufacturing
spaces at the ground floor of new development
celebrates the industrial legacy of the Northeast
Area, allowing people to see and experience
where goods are made firsthand.
Figure 31 Ground Floor Industrial, Artisan,
Manufacturing Section
1 2
3 4
5 STANDARDS
GUIDELINES
Floor to Floor Height
Legend
1 2 Minimum Length and
Depth
3 4
Permeability to Street
Individualized Facades
Aarhus School of Architecture maker spaces is open to the street for both active and passive participation.
Industrial streets will be strategically designed to optimize loading and unloading operations, ensuring efficient and smooth functionality for industrial activities.
FLOOR TO FLOOR
HEIGHT
LAND USE AND URBAN FORM
Northeast Area Specific Plan 126
4.12.3 Ground Floor Industrial,
Artisan, Manufacturing
Floor to Floor Height
All new development with required ground floor
Industrial, Artisan, and Manufacturing spaces shall
have a minimum clear ceiling height of 20 feet,
measured from sidewalk grade.
Dimensions
Light industrial ground floor spaces shall be a minimum of 20 feet in depth and at least 30 feet in length.
Permeability to Street
Small scale industrial frontages should open
directly onto the street to enhance the interaction
between ground-floor spaces and the public realm
and ensure eyes on the street. Options such as
concertina doors, large pivot doors, roll-up doors,
and expansive operable windows are ideal for
facilitating this connection. These options should
incorporate glazing to adhere to transparency
requirements.
Individualized Facades
The street-facing facades of individual shops or
light industrial facilities should be designed to allow for customization by each tenant, thereby creating
a diverse and visually engaging streetscape. By
varying facade materials, awning heights, signage
styles, and types of doorways and windows, each
unit can express its unique identity and contribute
to the dynamic character of the street.
Outdoor Spillover
Outdoor spillover spaces should be setback to a
maximum of 20 feet from the back of sidewalk.
This will enable space for social interaction and
flexible space for parking, loading, and service.
Credit - Rasmus Hjortshøj Credit - Janna Cordeiro
10.b
June 08, 2026 Packet Pg. 2558
STANDARDS
LAND USE AND URBAN FORM
Northeast Area Specific Plan 128
Residential Development
Standards
The Northeast Area’s Residential Zoning is broken into two separate Zones:
Mixed-Use Northeast 75 (MU-NE-75) and Mixed-Use Northeast 90 (MUNE-90), each with objective design and development standards.
4.13.1 Lot, Density and FAR Standards
New Residential developments shall adhere to the
standards prescribed in Table 7.
DEVELOPMENT STANDARDS MIXED USE NORTHEAST
75 (MU-NE-75)
MIXED USE NORTHEAST
90 (MU-NE-90)
Lot, Density and FAR Standards
Maximum Density 75 du/ac 90 du/ac
Minimum Density 57du/ac
(75% of 75 du/ac)
68 du/ac
(75% of 90 du/ac)
Minimum Lot Size 5,000 sq. ft. 5,000 sq. ft.
Minimum Lot Width 50’ 50’
Maximum Floor Area Ratio N/A N/A
4.13.2 Building Placement
Where an MU district is adjacent to an RS district,
the following standards apply:
Rear transitions - For the MU zoning district,
the maximum height at the rear setback line
shall be thirty-five (35) feet maximum to match
the RS district height maximum. Above thirty-five
(35) feet, a stepback of at least six (6) feet shall
be provided from the story below. If the building
is five (5) stories or more, the upper stories
shall step back from the fourth story by at least
another six (6) feet. When abutting an easement,
the development shall step down to thirty-five
(35) feet when a building is within one hundred
and thirty (130) feet of the rear lot line. New
development in this zoning district shall step down
to 35 feet when a building is within 130 feet of the
rear lot line abutting the 50 foot easement.
Side transitions - The maximum height at the
side setback line adjacent to a RS district shall
be twenty-eight (28) feet maximum to match the
RS district height maximum. Above twenty-eight
(28) feet, a stepback of at least six (6) feet shall
be provided from the story below. If the building
is five (5) stories or more, the upper stories shall
step back from the fourth story by at least another
six (6) feet.
Landscape Buffer- When abutting an easement,
a minimum thirty (30) feet landscape buffer shall
occur within the 130 feet between the easement
and the development. A minimum ten (10) foot
wide landscape buffer area shall be provided
along all rear boundaries adjacent to a RS district
(Type 2 - Refer to Section 18.18.050 Landscaping
Tables 18.18.050-B(1) and Table 18.18.050-
B(2) for buffer types). Trees and shrubs shall
be planted continuously in the landscape buffer
along the site’s rear property line to create privacy
screening between properties. Selected species
shall be of a fast-growing, evergreen variety and
capable of attaining a minimum height of twentyfive (25) feet at maturity. Trees shall be planted at a minimum interval of twenty to thirty (20-30) feet
on center depending on the species and mature
canopy width or growth habitat. Continuous
shrubbery planting is required between the trees
and shall be a minimum six (6) feet in height within
three (3) years of planting. Species selection and
placement must be approved by the City Arborist.
A minimum of fifteen (15) gallon planting stock
shall be utilized, unless otherwise approved by the
City Arborist.
a. Type 2 Buffers: Landscape buffers shall be
ten (10) feet wide. For every one hundred
(100) feet in rear property line length a minimum of three (3) trees and six (6) shrubs shall be planted.
b. For other landscaping buffer requirements,
refer to Section 18.18.050 Areas to be landscaped.
c. All new proposed tree species shall adhere to
the City’s most recent preferred tree list or as
specified by the City Arborist.
Where conflict between this section and
landscaping requirements of SCMC Section
18.18.050 occurs, the provisions of NEASP shall
apply.
Table 7 Lot, Density and FAR Standards
4.13 10.b
June 08, 2026 Packet Pg. 2559
Figure 32 Building Placement
LAND USE AND URBAN FORM
Northeast Area Specific Plan 130
DEVELOPMENT
STANDARDS
MIXED USE
NORTHEAST 75
(MU-NE-75)
MIXED USE
NORTHEAST 90
(MU-NE-90)
ADDITIONAL
REGULATIONS #
Building Placement Standards
Front Setback 5’ min; 15’ max 10’ min; 15’ max 1
Interior Side Setback 0’ min; 10 min if
adjacent to RS
0’ min; 15’ max (B) 2
Rear Setback 30’ min if adjacent
to RS
0’ min; 15’ max (B) 3
Corner Build Area 20’; Ground floor building facades shall be located in accordance with the required
setbacks within 20 ft. of every corner.
Ground floor public plazas may be at the
street corner instead, provided buildings are
built to the edge of the public plaza.
- 4
4.13.3 Build-To-Line
Buildings shall be constructed at the required
setback for at least eighty percent (80%) of
their linear street frontage. The remaining twenty
percent (20%) of linear street frontage shall be
further set back by at least two (2) feet, including
building massing breaks, recessed entrances,
service or utility areas, and/or vehicle access
4.13.4 Building Heights and
Height Limitations
The building height standards for MU- NE-75 and
MU-NE 90 are as shown in the Table 9.
Vertical Projections. - A parapet wall, cornice or
sloping roof may project up to five (5) feet above
the height limit (see SCMC Section 18.15.060 for
vertical projection allowances).
Towers - If the project site is greater than fifteen
thousand (15,000) square feet, a tower or other
projecting architectural elements may extend up
to ten (10) feet above the top of the roof; provided,
that the square footage of the element(s) does
not total more than ten percent (10%) of the
building footprint. The area above the uppermost
permitted floor of the element(s) shall not be
habitable space.
DEVELOPMENT STANDARDS MIXED USE NORTHEAST 75
(MU-NE-75)
MIXED USE NORTHEAST 90
(MU-NE-90)
Building Heights and Height Limitations
Heights 75’ 90’
Maximum Height Adjacent to RS
District
35’ within 130’ of the
rear lot line. This applies
to the entire length of the
building. Refer to Figure
25. N/A
Maximum Stories 6 8
Ground Floor - Minimum 14’ 14’
Table 8 Building Placement Standards
Table 9 Building Heights and Height Limitations
areas. The area between the building and property
line shall be paved where possible so that it
functions as a wider public sidewalk. For further
requirements refer to 18.05.040-A-1.
Street Frontage Improvements - This area
is allowed to have landscaping and/or planters
along ground-floor residential unit frontages and
along non-active frontages (i.e. frontages with
no windows, openings, or fenestrations etc.) to
reduce the visual impact of blank walls, provided
the landscaping and/or planters do not reduce
the sidewalk pedestrian clearance width below
the pedestrian clear zone requirement. Features
including entry courtyards, plazas, building entries,
and outdoor eating and display areas located
between the build-to line and the building count
towards the eighty percent (80%) build-to line
requirement provided the buildings are built to the
edge of these features.
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June 08, 2026 Packet Pg. 2560
LAND USE AND URBAN FORM
Northeast Area Specific Plan 132
4.13.5 Upper Story Setbacks
Upper story stepbacks help mitigate building
height by providing visual and spatial relief more
consistent with the context of San Carlos. All
required upper story stepbacks shall occur for at
least seventy percent (70%) of the facade length.
1. In the MU-NE-75 district, any new building
located within 130 feet of the rear lot line of RS
district shall step down in height to 35 feet.
2. In the MU-NE-90 district, street-facing façades
above the fourth floor shall be stepped back a
minimum of 6 feet from the building face of the
fifth story below, along Old County Road and
Taylor Way.
4.13.7 Building Projections and
Maximum Length of Blank Wall
Building projections, awnings, overhangs,
and canopies shall project no more than three
(3) feet into the public right-of-way. Building
projections shall maintain a minimum twelve
(12) foot clearance above sidewalk grade, and
awnings, overhangs, and canopies shall maintain
a minimum eight (8) foot clearance above the
sidewalk. The total width of all projections into
the public right-of-way along a building face shall
not be more than twenty-five percent (25%) of
the building frontage. Projecting balconies may
account for up to an additional twenty-five percent
(25%) of the building frontage. Refer to Table 10
for building projection allowable dimensions.
Blank walls along the building’s street-facing
facades shall not exceed ten (10) feet in length
along the ground floor and twenty-five (25) feet
in length along upper floors. If a blank wall area
includes vertical interior spaces such as elevator
towers or trash chutes, a change in building
material, color, or texture, or a change in facade
plane depth shall be provided if those vertical
interior spaces would otherwise cause the blank
wall to exceed the length limits.
4.13.6 Ground floor Activation
Ground floor active uses in a mixed-use building
shall occupy at least sixty-five (65%) of the public
street frontage including any side street frontage.
Commercial ground floor active uses shall have
a depth of at least twelve (12) feet without walls
or partitions, providing unobstructed views into
the space. Distinct awning, canopy, or entry
treatments shall be provided for commercial uses
to distinguish from residential uses. Different
treatments shall include, but are not limited to,
doorway materials and recesses, signage, and
paving in front of commercial entries.
New development in mixed-use districts shall
comply with the window and transparency
requirements of Section 4.12.23 and shall
incorporate at least one (1) of the following
active uses within the ground floor along public
street frontages as permitted pursuant to Section
4.4: Residential units with individual entrances
oriented towards the street, retail, restaurant,
office, business services, personal services,
childcare center, theater, entertainment, indoor
recreational uses, art gallery, maker space, livework units, work-from-home shared work space, social gathering space, common residential
lobbies, individual residential entrances, and
residential common space such as fitness rooms,
conference rooms, leasing and/or management
offices.
DEVELOPMENT STANDARDS MIXED USE NORTHEAST
75 (MU-NE-75)
MIXED USE NORTHEAST
90 (MU-NE-90) #
Blank Wall
Maximum Length of Blank Wall Ground Floor - 10 feet
Upper Floor - 25 feet
1 Building Projections
Maximum Building Projections into
the Public Right of Way
3 Feet; 12 Feet minimum above sidewalk
grade. 2
Awnings and Overhands into the
Public Right of Way 3 Feet; 8 Feet minimum above sidewalk grade. 3 Table 10 Blank Wall and Building Projections Standards
Figure 34 Building Projections and Blank wall
Figure 33 Building Projections and Blank wall
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June 08, 2026 Packet Pg. 2561
LAND USE AND URBAN FORM
Northeast Area Specific Plan 134
4.13.8 Parking and Loading Location
Parking shall be allowed within forty (40) feet
of the street-facing property line, subject to the
following standards:
1. Fully Undergrounded Parking - Fully
undergrounded parking may be located
anywhere on a subject property. If tiebacks or
similar structures extend beyond the property
lines, a tieback agreement with the affected
property owner(s) shall be included upon initial
planning application submittal.
2. Partially Submerged Parking - Parking
located partially underground shall match the
setbacks of the main structure. The maximum
height of a parking podium visible from a street
is five (5) feet above finished grade.
3. Surface Parking - Above-ground surface
parking is allowed within forty (40) feet from
4.13.9 Pedestrian Walkway Design
1. Walkways shall have a minimum clear
unobstructed width of five (5) feet, shall be
hard-surfaced, and paved with concrete, stone,
tile, brick, or comparable material.
2. Where a required walkway or sidewalks crosses
driveways, parking areas, or loading areas, it
shall be clearly identifiable through the use of
a raised crosswalk, a different paving material,
or similar method to prevent conflict between
pedestrians and vehicles. Where a required
walkway is parallel and adjacent to an auto
travel lane, it must be raised or separated from
the auto travel lane by a raised curb at least
four (4) inches high, bollards, or other physical
barrier.
4.13.10 Commercial Loading and/or
Service Areas
Commercial loading or service spaces shall not
be located along the primary street frontage and
shall be located either along the sides or rear of
the structure. Loading and/or service areas shall
only be allowed along the primary street frontage
when the subject property fronts only one street
and where there is no internal onsite vehicle
circulation and/or access points.
DEVELOPMENT
STANDARDS
MIXED USE
NORTHEAST 75
(MU-NE-75)
MIXED USE
NORTHEAST 90
(MU-NE-90)
ADDITIONAL
REGULATIONS #
Surface Parking Setback
from Street Property Line
40 feet; Parking shall be placed behind a building
or on the interior side or rear of the site.
(H) 1
Surface Parking Setback
from Buildings and Public
Plazas
8 feet: 5 feet walkway plus 3 feet landscaping; applicable only to above-ground parking.
2 Parking Access Location Side street or alley wherever possible. 3 Curb Cuts Refer SCMC Chapter 12.04 for dimensional
requirements.
Curb cuts shall be minimized and shall be placed in
areas least likely to impede pedestrian circulation.
Loading/Service Area Side or rear of lot; must be screened from public ROW
4 Parking Podium Maximum height of a parking podium visible from the street is 5 feet above finished grade.
5 a street-facing property line when all of the
following occur:
a. Buildings are built to setback standards and
as close to the public sidewalk as feasible;
The parking area is at least eight (8) feet from
the public right-of-way, screened from adjacent
properties with a minimum four (4) foot tall wall,
hedges or landscaping, or a trellis along publicrights-of-way, and six (6) foot tall wall, hedges or landscaping, or a trellis along side and rear
property lines; and the site is constrained such
that underground, partially submerged, or surface
parking located more than forty (40) feet from
the street frontage is not feasible due to sitespecific conditions. Fences, hedges, and similar structures shall meet sight distance triangle
regulations and the requirements pursuant to San
Carlos Municipal Code SCMC 18.15.040.
Table 11 Parking and Parking Location
Figure 35 Parking and Loading Locations
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flagstone, wood planking, concrete, or other
serviceable, dust-free surfacing. The maximum
slope shall not exceed ten percent (10%).
2. Accessibility
a. Private Open Space - The space shall be
accessible to only one (1) living unit by a
doorway to a habitable room or hallway.
a. Common Open Space - The space shall
be accessible to the living units on the lot. It
shall be served by any stairway or other accessway qualifying as an egress facility from a habitable room or hallway.
3. Exemption - If a new development has met
the requirements of the public open space, they
shall be exempt from this standard.
4.13.11 Landscaping and Residential
Open Space
4.13.12 Street Preservation
4.13.13 Street Frontage Improvements
DEVELOPMENT STANDARDS MIXED USE NORTHEAST
75 (MU-NE-75)
MIXED USE NORTHEAST
90 (MU-NE-90)
Minimum Common and/or Private
Open Space (% of site)
10% if lots are equal to or under 1 acre,15% if
lots are over 1 acre;
Applicable to mixed-use and nonresidential
development on lots greater than 15,000 square-feet;
Minimum Usable Area for Common
Open Space (sq. ft.)
200 square feet minimum, with a minimum
width of 10 feet
Minimum Usable Area for Private
Open Space (sq.ft.)
36 square feet minimum, with minimum 6 foot
depth
Landscaping and residential open space shall be
provided as required by Table 13. Residential open
space shall be usable space and may be common,
private, or a combination thereof. Common open
space areas consist of courtyards, plazas, terraces,
lawns, patios, swimming pools, barbecue areas,
playgrounds, or other usable outdoor areas. Private
open areas consist of balconies, decks, patios,
porches, or fenced yards. Private open areas when
provided shall provide a minimum six (6) foot by
six (6) foot clear area and be directly accessed
from a residential unit. Landscaping consists of
planting areas, stormwater management features,
treed areas, gardens, and other vegetation areas
not otherwise considered common or private open
space.
1. Usability - A surface shall be provided that
allows convenient use for outdoor living and/
or recreation. Such a surface may be any
practicable combination of lawn, garden,
Existing public right-of-way(s) shall be preserved.
Public right-of-way shall not be eliminated or
abandoned unless substantial public benefits are
provided, such as a new park, as determined by
the review authority.
New development shall provide street frontage
improvements in accordance with the following:
1. Between the Property Line and Curb
(Sidewalk Zone).
a. Sidewalks - Sidewalks shall be provided if
none already exist or if the existing sidewalks
are in poor condition as determined by the
Public Works Director. Sidewalks shall be designed to be composed of two (2) zones, the pedestrian clear zone and the landscape and
furniture zone. The pedestrian clear zone shall
have a minimum width that varies based on
the street within which no landscape, furniture,
or any other obstructions may be located. The
width of the landscape and furniture zone may
vary, and shall include a combination of street
trees, landscaping, planter boxes, benches,
street lights, bike racks, trash receptacles, bus
shelters, outdoor dining, utilities such as fire
hydrants, and sidewalk paving. Sidewalk width
and design within any adopted Specific Plan
area shall meet the objective requirements of
the Specific Plan. If minimum sidewalk dimensions cannot be accommodated in the public right-of-way, a sidewalk easement shall be
required.
b. Street Furniture - Trash receptacles, benches, bike racks, and other street furniture from a list maintained by the Director shall be provided. These elements shall be located outside of the required pedestrian clear path and within the landscape and furniture zone.
c. Street Lights - Pedestrian-scaled street
lights, including attachments from which banners may be hung, shall be located in the landscape and furniture zone and shall be provided from a list maintained by the Director d. Street Trees - Sidewalks shall include at least
one (1) street tree from the City’s most recent
Preferred Tree List for every thirty (30) feet of
sidewalk length. Tree guards shall be provided. Street trees and other trees on site counted towards the minimum tree requirement shall be a minimum of twenty-four (24) inch
box size. All new trees shall be a minimum of
fifteen (15) gallons in size. When trees cannot
be accommodated due to site constraints a
minor deviation may be requested subject to
the discretion of the City Arborist and Director.
2. Interior from Property Line - (Frontage/
Setback Zone)
Except where occupied by a building, residential
ground floor entrances, or areas necessary for
parking access, the street frontage, for a depth
of ten (10) feet from the property line, shall be
utilized for active outdoor uses for at least sixtyfive percent (65%) of the available frontage length, including but not limited to outdoor dining,
paved for public uses so that it functions as part of
a wider public sidewalk, stormwater management
planters, or improved with landscaping, public
art, and/or pedestrian amenities such as outdoor
seating.
Table 12 Landscaping and Residential Open Space Standards
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4.13.14 Building Entrances
1. Orientation - All ground-floor commercial
and residential active uses located along
public rights-of-way shall have their primary
entrance(s) facing this right-of-way. If groundfloor residential active uses are located on four (4) lane streets carrying high traffic volumes
and/or streets that do not allow on-street
parking, unit entrances may be oriented around
courtyards.
2. Main Building Entrances - if a building
has a main entrance to a commercial space
or shared residential lobby, the main entrance
shall incorporate either a canopy, recess,
or combination thereof. A covered area at
minimum of four (4) feet deep shall be provided.
Refer to Table 18.05.030-3 for canopy
projection standards. Entry canopies, stoops,
patios, and balconies shall be constructed of
all-weather, durable materials. If an entrance
requires an accessible ramp, the ramp shall not
encroach into the right of way or pedestrian
clear zone and will be integrated into the
building and landscape design to minimize the
visual impact of the ramp. Clear access to the
ramp shall be maintained.
3. Ground Floor Dwelling Units - Exterior
entrances to ground floor units shall be
connected to the public sidewalk by a paved
walkway with a minimum width of five (5) feet.
An at-grade patio, a raised stoop, or a raised
porch may serve as a ground floor unit entrance.
Raised stoops or porches shall not exceed
five (5) feet above grade. Patios, stoops, and
porches shall provide a minimum six (6) foot
by six (6) foot clear area. Ground floor patios
shall be surrounded by a low wall, fence, railing,
and/or landscaping no higher than 42 inches
to distinguish private outdoor space from the
public sidewalk area. Ground floor exterior unit
entrances may be recessed or project no more
than eight (8) feet from the building facade.
Fences shall meet the requirements pursuant
to SCMC 18.15.040.
4. Corner Entrances - Corner building
entrances shall have a distinct architectural
treatment to animate the intersection and
facilitate pedestrian flow around the corner.