A - Ex A Draft EIR — San Leandro City Council, May 5, 2025 (part 1 of 12)

Exhibit A
Draft Environmental Impact Report
880 Doolittle Drive Industrial Project
Draft Environmental Impact Report
PLN22-0039
prepared by
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Contact: Cindy Lemaire, AICP, CNU-A, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
June 2024
880 Doolittle Drive Industrial Project
Draft Environmental Impact Report
PLN22-0039
prepared by
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Contact: Cindy Lemaire, AICP, CNU-A, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
June 2024
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Table of Contents
Environmental Impact Report i
Table of Contents
Executive Summary ...........................................................................................................................ES-1 Project Synopsis.........................................................................................................................ES-1 Project Objectives......................................................................................................................ES-3 Alternatives................................................................................................................................ES-3 Areas of Known Controversy .....................................................................................................ES-5 Issues to be Resolved.................................................................................................................ES-5 Issues Not Studied in Detail in the EIR.......................................................................................ES-5 Summary of Impacts and Mitigation Measures ........................................................................ES-6 1 Introduction................................................................................................................................ 1-1

1.1 Environmental Impact Report Background..................................................................... 1-1

1.2 Purpose and Legal Authority........................................................................................... 1-1

1.3 Scope and Content.......................................................................................................... 1-8

1.4 Issues Not Studied in Detail in the EIR............................................................................ 1-8

1.5 Environmental Review Process..................................................................................... 1-11 2 Project Description ..................................................................................................................... 2-1

2.1 Project Applicant............................................................................................................. 2-1

2.2 Lead Agency Contact Person........................................................................................... 2-1

2.3 Project Location .............................................................................................................. 2-1

2.4 Existing Site Characteristics ............................................................................................ 2-4

2.4.1 Site History and Existing Conditions............................................................... 2-4

2.4.2 General Plan Designation ............................................................................... 2-4

2.4.3 Zoning ............................................................................................................. 2-4

2.4.4 Surrounding Land Uses................................................................................... 2-8

2.5 Project Description.......................................................................................................... 2-8

2.5.1 Property Consolidation and Demolition......................................................... 2-8

2.5.2 Industrial Development.................................................................................. 2-8

2.5.3 Circulation/Access and Parking ...................................................................... 2-9

2.5.4 Landscaping .................................................................................................. 2-13

2.5.5 Utilities.......................................................................................................... 2-13

2.5.6 Construction and Grading............................................................................. 2-14

2.6 Project Objectives......................................................................................................... 2-17

2.7 Lead, Responsible, and Trustee Agencies..................................................................... 2-17

2.8 Required Approvals....................................................................................................... 2-18 3 Environmental Setting ................................................................................................................ 3-1

3.1 Regional Setting .............................................................................................................. 3-1

3.2 Project Site Setting.......................................................................................................... 3-1

3.3 Cumulative Development ............................................................................................... 3-2 4 Environmental Impact Analysis .................................................................................................. 4-1

4.1 Greenhouse Gas Emissions.......................................................................................... 4.1-1

4.1.1 Setting.......................................................................................................... 4.1-1

4.1.2 Regulatory Setting ....................................................................................... 4.1-3

4.1.3 Impacts Analysis .......................................................................................... 4.1-6

4.1.4 Cumulative Impacts................................................................................... 4.1-13 City of San Leandro
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4.2 Hazards and Hazardous Materials............................................................................... 4.2-1

4.2.1 Setting.......................................................................................................... 4.2-1

4.2.2 Regulatory Setting ....................................................................................... 4.2-6

4.2.3 Impacts Analysis ........................................................................................ 4.2-11

4.2.4 Cumulative Impacts................................................................................... 4.2-19

4.3 Noise and Vibration ..................................................................................................... 4.3-1

4.3.1 Setting.......................................................................................................... 4.3-1

4.3.2 Regulatory Setting ....................................................................................... 4.3-4

4.3.3 Impacts Analysis .......................................................................................... 4.3-7

4.3.4 Cumulative Impacts................................................................................... 4.3-20

4.4 Transportation ............................................................................................................. 4.4-1

4.4.1 Setting.......................................................................................................... 4.4-1

4.4.2 Regulatory Setting ....................................................................................... 4.4-3

4.4.3 Impacts Analysis .......................................................................................... 4.4-5

4.4.4 Cumulative Impacts..................................................................................... 4.4-7 5 Other CEQA Required Discussions.............................................................................................. 5-1

5.1 Growth Inducement........................................................................................................ 5-1

5.1.1 Population Growth ......................................................................................... 5-1

5.1.2 Economic Growth ........................................................................................... 5-1

5.1.3 Removal of Obstacles to Growth.................................................................... 5-2

5.2 Irreversible Environmental Effects.................................................................................. 5-2

5.3 Significant and Unavoidable Impacts.............................................................................. 5-3 6 Alternatives................................................................................................................................. 6-1

6.1 Potentially Significant Impacts........................................................................................ 6-1

6.2 Alternative 1: No Project Alternative.............................................................................. 6-2

6.2.1 Impact Analysis............................................................................................... 6-2

6.3 Alternative 2: No Natural Gas Alternative ...................................................................... 6-5

6.3.1 Impact Analysis............................................................................................... 6-5

6.4 Alternative 3: Airport Parking Land Use Alternative....................................................... 6-9

6.4.1 Impact Analysis............................................................................................... 6-9

6.5 Alternatives Considered but Eliminated....................................................................... 6-13

6.6 Environmentally Superior Alternative .......................................................................... 6-14 7 References.................................................................................................................................. 7-1

7.1 Bibliography .................................................................................................................... 7-1

7.2 List of Preparers.............................................................................................................. 7-4 Tables
Table ES 1- Summary of Potentially Significant Environmental Impacts, Mitigation Measures, and Residual Impacts............................................................................................................ES-7 Table 1-1 NOP Comments Summary .............................................................................................. 1-2 Table 1-2 Issues Not Studied in the EIR .......................................................................................... 1-9 Table 3-1 Cumulative Projects List.................................................................................................. 3-3 Table 4.1-1 San Leandro Annual GHG Emissions, Metric Tons....................................................... 4.1-2 Table 4.1-2 Project Consistency Analysis with the BAAQMD 2017 Clean Air Plan....................... 4.1-10 Table of Contents
Environmental Impact Report iii
Table 4.1-3 Project Consistency with the San Leandro Climate Action Plan................................ 4.1-11 Table 4.3-1 Groundborne Vibration Architectural Damage Thresholds....................................... 4.3-11 Table 4.3-2 Estimated Noise Levels by Project Construction Phase............................................. 4.3-12 Table 4.3-3 Estimated Construction Vibration Levels (in/sec PPV) .............................................. 4.3-19 Table 6-1 Impact Comparison of Alternatives.............................................................................. 6-15 Figures
Figure 1-1 Environmental Review Process.................................................................................. 1-13 Figure 2-1 Regional Location......................................................................................................... 2-2 Figure 2-2 Project Site Location.................................................................................................... 2-3 Figure 2-3 Existing Site Conditions: Representative Photographs................................................ 2-5 Figure 2-4 Conceptual Site Plan.................................................................................................. 2-10 Figure 2-5 Conceptual Building Elevations ................................................................................. 2-11 Figure 2-6 Conceptual Rendering of Project............................................................................... 2-12 Figure 2-7 Preliminary Utility Plan .............................................................................................. 2-15 Figure 2-8 Conceptual Grading Plan ........................................................................................... 2-16 Figure 4.2-1 On-Site Groundwater Well Network ........................................................................ 4.2-3 Figure 4.2-2 Soil Management Areas............................................................................................ 4.2-5 Figure 4.3-1 City of San Leandro Land Use Compatibility Noise Guidelines................................. 4.3-8 Figure 4.3-2 Estimated Rooftop HVAC Noise Levels near Project Site ....................................... 4.3-14 Figure 4.3-3 Estimated Truck Operations and HVAC Noise Levels near Project Site: North Side of Building ................................................................................................................... 4.3-15 Figure 4.3-4 Estimated Truck Operations and HVAC Noise Levels near Project Site: East Side of Building ................................................................................................................... 4.3-16 Figure 4.3-5 Estimated Truck Operations and HVAC Noise Levels near Project Site: South Side of Building ................................................................................................................... 4.3-17 Appendices
Appendix A Initial Study
Appendix B Notice of Preparation (NOP) and NOP Comment Letters Appendix C Transportation Impact Analysis
Appendix D Revised Soil and Groundwater Management Plan Appendix E Evaluation of Site Sound Emissions
Appendix F Noise Letter Report
City of San Leandro
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Executive Summary
Environmental Impact Report ES-1
Executive Summary
This document is an Environmental Impact Report (EIR) analyzing the environmental effects of the proposed 880 Doolittle Drive Industrial Project (proposed project). This section summarizes the characteristics of the proposed project, alternatives to the proposed project, and the environmental impacts and mitigation measures associated with the proposed project.

Project Synopsis
Project Applicant
Prologis
510-656-1900
Lead Agency Contact Person
Cindy Lemaire, AICP, CNU-A, Senior Planner
City of San Leandro
835 East 14th Street
San Leandro, California 94577
510-577-3348
Project Description
This EIR has been prepared to examine the potential environmental effects of the 880 Doolittle Drive Industrial Project. The following is a summary of the full project description, which can be found in Section 2.0, Project Description.

The project site is located at 880 Doolittle Drive, which is on the east side of Doolittle Drive just east of adjacent properties with frontage on Doolittle Drive, approximately 0.2 mile north of its intersection with Davis Street, in San Leandro. The project site measures approximately 14.14 acres and consists of two Assessor’s parcels: APN 77A-0741-004-02 and 77A-0741-005-00. Existing access to the project site is from a driveway on Doolittle Drive. Access to the site is also provided from a driveway at the southern terminus of Hester Street, which is a public street north of the project site.

The regional location of the site is shown in Figure 2-1, and the vicinity of the site and its boundaries are shown in Figure 2-2.

Project Characteristics
The proposed project consists of consolidating the two parcels comprising the project site into a single parcel, demolishing existing vacant structures, and developing a new industrial shell building on the site. The proposed project also includes a new surface parking lot, internal circulation roadways, new utility connections, and landscaping. Site preparation activities would commence with demolition of the two existing vacant structures on site, as well as all associated surface parking, landscaping, and internal circulation and driveways on the site. Existing utility connections would be completely removed or abandoned in place in accordance with local and state regulations, in coordination with utility providers. After approximately 6 months following demolition of existing structures, the proposed project would include construction of a new warehouse with supporting City of San Leandro
880 Doolittle Drive Industrial Project
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office space. The proposed warehouse is approximately 244,573 square feet, comprised of a 229,573 square-foot of warehouse and 15,000 square feet of associated office space. Approximately 10,000 square feet of office space would be provided on the ground floor alongside the warehouse use. The remaining 5,000 square feet of office space would be on a mezzanine level of the warehouse. The footprint of the warehouse and office use would be 239,753 square feet. The proposed floor area ratio (FAR) is 0.40 and the maximum building height would be 50 feet with an interior clear height of 40 feet. Sixty-four loading docks are proposed, 27 on the north side and 37 on the south side of the building. In addition to dock doors, traditional doors for egress and ingress to the building would be provided for each of the two office spaces within the proposed warehouse.

Traditional doors would be provided on the north side of the building and south side of the building, next to dock doors. A conceptual site plan is provided as Figure 2-4.

The building would be constructed for a speculative tenant or tenants; the project is intended for occupancy by uses consistent with the site’s General Industrial designation, as well as those uses permitted under the site’s Industrial General zoning classification. The proposed shell building would be designed to accommodate a future industrial tenant who may perform interior improvements to accommodate their specific needs.

Parking and Site Access
Access to the project site would be from the driveway on Doolittle Drive in the southwest area of the site, and from the end of Hester Street in the northern area of the site. Although these are both existing driveways, the proposed project would include reconstruction of the driveways to meet City standards and current ADA requirements. This would involve repairs as needed of the driveway from Doolittle Drive. New curb cut would be provided at the cul-de-sac on Hester Street, which would also include reconstructing (i.e., replacement of) portions of the sidewalk along the project site frontage on Hester Street. Additionally, a new, second, driveway to the site would be constructed at the end of Hester Street, providing a total of three driveways.

A total of 204 parking spaces would be provided on-site for passenger vehicles, which would be located primarily in a new surface parking lot on the west side of the proposed building. The other main surface parking area would be on the north side of the warehouse. This parking area would consist of 59 spaces sized for tractor trailers. A total of 24 bicycle parking spaces would be provided in the vicinity of the office main entrance, including 12 short-term spaces and 12 long-term spaces.

Utilities
The proposed industrial building would require utility and drainage improvements including new sanitary sewer, storm drain, and domestic water lines. These new utilities would connect to existing utilities within the right-of-way of Doolittle Drive. Bioretention areas would be constructed on-site to collect and treat stormwater runoff prior to discharge into the City’s storm drain system.

Electricity at the project site would be provided by Pacific Gas & Electric, which provides services to the project area. The proposed project would also include natural gas energy, also provided by Pacific Gas & Electric.

Executive Summary
Environmental Impact Report ES-3
Construction and Grading
The timing of project construction would be determined by market forces and other considerations, such as weather or availability of workforce. However, for purposes of this analysis it is anticipated that construction would begin in 2024 with demolition of existing vacant structures and related infrastructure, such as utilities and surface parking. Site grading would occur following demolition of the existing development on the project site, which totals approximately 212,000 square feet of structures. Elevations on the project site following grading would vary between approximately 10 feet and 17 feet above mean sea level. Preliminary grading design shows a balanced site. Project construction would commence following grading. Construction would include excavation and trenching to install buried utility connections, such as new water, sanitary sewer, and storm drain laterals. The foundation of the warehouse would be poured followed by framing and construction of the walls, interior spaces, and exterior. Paving of surface parking areas, driveways, and internal access roads would also occur during project construction, as well as construction of new sidewalk on site frontage along Hester Street. Construction staging would occur on-site. A variety of typical construction equipment would be used, such as backhoes, dump trucks, excavators, pavers, and dozers. A crawler crane with a boom height of up to approximately 161 feet would also be required.

During construction, up to five existing trees just off the project site at the terminus of Hester Street would be removed.

Project Objectives
The underlying purpose of the proposed project is to provide a modern industrial warehouse with ancillary office using sustainable and environmentally superior practices within the existing industrialized portion of the City. The proposed project would accommodate the need for additional large warehouse uses in the City and in Alameda County, while enhancing the economic vitality of the City.

The City and the applicant have the following objectives for the project:
 Increase the economic base of the City's industrial corridor by maximizing the productive use of the City’s industrial land, which is currently underutilized;  Create a modern warehouse that contributes to the aesthetics of the surrounding area through the redevelopment of an obsolete and underutilized property;  Create a new, efficient and updated warehouse that is attractive to future tenants, by incorporating the state's green building design and building health and safety standards;  Maintain and protect the City’s inventory of larger-scale industrial sites with easy access to freeways, rails, airports, and seaports; and
 Support and retain existing industrial uses and employment in the City of San Leandro’s industrial sector.

Alternatives
As required by Section 15126.6 of the CEQA Guidelines, this EIR examines a range of reasonable alternatives to the proposed project that would attain most of the basic project objectives (stated in Section 2, Project Description, of this EIR) but would avoid or substantially lessen the significant adverse impacts.

City of San Leandro
880 Doolittle Drive Industrial Project
ES-4
Included in this analysis are three alternatives, including the CEQA-required “no project” alternative, that involve changes to the project that would reduce the project-related potentially significant environmental impacts as identified in this EIR. Alternatives have been developed to provide a reasonable range of options to consider that would help decision makers and the public understand the general implications of revising or eliminating certain components of the proposed project.

The following alternatives are evaluated in this EIR:
 Alternative 1: No Project
 Alternative 2: No Natural Gas
 Alternative 3: Airport Parking Land Use
Detailed descriptions of the alternatives are included in the impact analysis for each alternative. The potential environmental impacts of each alternative are analyzed in Sections 6.2 through 6.4.

Alternative 1 (No Project). The No Project Alternative assumes that the two existing industrial masonry buildings would remain on the project site. These buildings are currently vacant. The City has no applications on file for occupancy of the buildings; therefore, this analysis assumes the buildings would remain vacant under this alternative. The project applicant or another person or organization could submit an application for occupancy of one or both buildings in the future.

Granting an occupancy permit for a business or activity allowed by-right within the existing Industrial General zoning district of the site would be a ministerial permit, and CEQA may not be applicable.

The No Project Alternative would not fulfill any of the project objectives.

Alternative 2 (No Natural Gas). Under the No Natural Gas Alternative, the proposed industrial building would be constructed on the project site, nearly consistent with the proposed project.

Alternative 2 assumes that the industrial building and associated surface parking lot would be approximately the same size and design as the proposed project, which would require the same demolition and construction activities as the proposed project. Once construction is complete, Alternative 2 assumes the same on-site operations would occur as with the proposed project, with the exception of natural gas consumption. Under this alternative, natural gas connections would not be provided on the project site. Therefore, potential future occupants and uses in the new industrial building would not consume natural gas, as natural gas would be unavailable on the project site.

Alternative 2 would instead require on-site building operations to rely entirely on electricity for energy.

The No Natural Gas Alternative would fulfill most project objectives but not all objectives. For example, this alternative would develop an industrial building with easy access to freeways and airports, while also supporting industrial employment opportunities within the city’s industrial sector. Alternative 2 would also contribute to the aesthetics of the surrounding area because the vacant and aging existing buildings on-site would be demolished and replaced with a new building.

However, Alternative 2 may not fulfill the objective of creating a warehouse that is attractive to future tenants to the same extent as the proposed project. While it is reasonable to assume a new warehouse proximate to freeways, rail, and the Oakland International Airport would be attractive to many tenants, the elimination of natural gas utility may deter some tenants from leasing or purchasing the warehouse, as natural gas could be critical to their business or operations. For example, businesses that manufacture products such as paper, glass, and steel typically use natural gas.

Executive Summary
Environmental Impact Report ES-5
Alternative 3 (Airport Parking Land Use). Under the Airport Parking Land Use Alternative, the proposed industrial building would be constructed on the project site, nearly consistent with the proposed project. Alternative 3 assumes that the industrial building and associated surface parking lot would be approximately the same size and design as the proposed project, which would require the same demolition and construction activities as the proposed project. Once construction is complete, Alternative 3 assumes the proposed building would not operate as a warehouse. Instead, the building would operate as covered vehicle parking serving the Oakland International Airport.

The new surface parking areas would also be for airport parking. Because the building would not operate as a warehouse, more surface parking would be provided on-site compared to the proposed project because larger parking spaces and areas for tractor trailer maneuvers would be eliminated from the project design. Alternative 3 assumes that the new building would not include natural gas connections, as there would not be demand to heat internal spaces used solely for vehicle parking and storage that could not generally be met with electric heat.

The Airport Parking Land Use Alternative would fulfill the project objective to create a modern warehouse structure that contributes to the aesthetics of the surrounding area through the redevelopment of an obsolete and underutilized property, although the building would not operate as a warehouse. Alternative 3 would not fulfill the other objectives of the project, which are generally centered on creating industrial employment and industrial productivity, which would not be accomplished from airport parking.

Refer to Section 6.0, Alternatives, for the complete alternatives analysis.

Areas of Known Controversy
The EIR scoping process did not identify any areas of known controversy for the proposed project.

Responses to the Notice of Preparation of a Draft EIR are summarized in Section 1, Introduction.

Comments pertained to a range of issues, but most notably air quality, airport hazards, greenhouse gas emissions, hazardous materials and soil and groundwater contamination, noise, transportation, and tribal cultural resources.

Issues to be Resolved
The proposed project would require site plan review and grading and building permits, as well as a tree removal permit, use permit, and height exception. In addition, given the proximity of the Oakland Internation Airport to the project site, a No Hazard Determination for the warehouse was issued from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77.

Further, several mitigation measures discussed in Section 4.2, Hazards and Hazardous Materials, of this EIR would require either approval or oversight from the California Department of Toxic Substances Control (DTSC). Issues to be resolved also include the choice among alternatives and whether or how to mitigate potentially significant effects of the project.

Issues Not Studied in Detail in the EIR
Section 1.4, Issues Not Studied in Detail in the EIR, summarizes issues from the environmental checklist that were addressed in the Initial Study (Appendix A). As indicated in the Initial Study, there is no substantial evidence that significant impacts would occur to the following issue areas:

Aesthetics, Agricultural Resources, Air Quality, Biological Resources, Cultural Resources, Energy, Geology and Soils, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, City of San Leandro
880 Doolittle Drive Industrial Project
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Population and Housing, Public Services, Recreation, Tribal Cultural Resources, Utilities and Service Systems, and Wildfire. Impacts to Greenhouse Gas Emissions, Hazards and Hazardous Materials, Noise, and Transportation were found to be potentially significant and are addressed in this EIR.

Summary of Impacts and Mitigation Measures
Table ES-1 includes a brief description of the environmental issues relative to the proposed project, the identified environmental impacts, proposed mitigation measures, and residual impacts. Impacts are categorized by significance. Per Section 15123(b) of the State CEQA Guidelines, Table ES-1 addresses only those impacts determined to be potentially significant in either the Initial Study (Appendix A) or the EIR, or both. Significant and unavoidable adverse impacts require a statement of overriding considerations to be issued per Section 15093 of the State CEQA Guidelines if the project is approved. Significant but mitigable impacts are adverse impacts that can be feasibly mitigated to less than significant levels and which require findings to be made under Section 15091 of the State CEQA Guidelines. Less than significant impacts would not exceed significance thresholds and therefore would not require mitigation.

The Initial Study found that the proposed project would have significant but mitigable impacts on air quality, biological resources, cultural resources, and tribal cultural resources. The Initial Study addresses these issues and provides mitigation measures, which are summarized in Table ES-1 below. These issues, as well as those issues found to have less than significant impacts in the Initial Study, are not analyzed further in this EIR. Discussion of these impacts may be found in the Initial Study (Appendix A). Issues that were found to have potentially significant impacts in the Initial Study and therefore required additional analysis in the EIR include greenhouse gas emissions, hazards and hazardous materials, noise, and transportation. Table ES-1 summarizes the impacts related to these issues as well as applicable mitigation measures to reduce impacts, as identified in this EIR.

Impacts are categorized as follows:
 Significant and Unavoidable. An impact that cannot be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires a Statement of Overriding Considerations to be issued if the project is approved per §15093 of the CEQA Guidelines.
 Less than Significant with Mitigation Incorporated. An impact that can be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires findings under §15091 of the CEQA Guidelines.
 Less than Significant. An impact that may be adverse but does not exceed the threshold levels and does not require mitigation measures. However, mitigation measures that could further lessen the environmental effect may be suggested if readily available and easily achievable.  No Impact: The proposed project would have no effect on environmental conditions or would reduce existing environmental problems or hazards.

Executive Summary
Environmental Impact Report ES-7
Table ES-1 Summary of Potentially Significant Environmental Impacts, Mitigation Measures, and Residual Impacts
Impact Mitigation Measure (s) Residual Impact
Air Quality
Construction of the proposed project
would generate wind-blown dust that
could contribute particulate matter
into the local atmosphere. With
implementation of Mitigation
Measure AQ-1, this impact would be
less than significant.

AQ-1 BAAQMD Best Management Practices for
Construction-Related Fugitive Dust Emissions. The
project applicant shall require all construction contractors to implement the basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust
emissions. Emission reduction measures will include, at a minimum, the following measures:

1. All exposed surfaces (e.g., parking areas, staging
areas, soil piles, graded areas, and unpaved access
roads) shall be watered two times per day.

2. All haul trucks transporting soil, sand, or other loose material off-site shall be covered.

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum
street sweepers at least once per day. The use of dry
power sweeping is prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 mph.

5. All roadways, driveways, and sidewalks to be paved
shall be completed as soon as possible. Building pads
shall be laid as soon as possible after grading unless
seeding or soil binders are used.

6. All excavation, grading, and/or demolition activities shall be suspended when average wind speeds
exceed 20 mph.

7. All trucks and equipment, including their tires, shall be washed off prior to leaving the site.

8. Unpaved roads providing access to sites located 100
feet or further from a paved road shall be treated
with a 6- to 12-inch compacted layer of wood chips,
mulch, or gravel.

9. Publicly visible signs shall be posted with the
telephone number and name of the person to
contact at the lead agency regarding dust
complaints. This person shall respond and take
corrective action within 48 hours. The Air District’s
General Air Pollution Complaints number shall also
be visible to ensure compliance with applicable
regulations.

Less than
significant.

Biological Resources
The proposed project would involve
construction work near street trees
just off the project site near the
driveway that connects to Hester
Street which may affect protected
nesting birds in existing trees.

Impacts to nesting birds would be
reduced to less than significant with
implementation of Mitigation
Measure BIO-1.

BIO-1 Nesting Bird Avoidance and Minimization
Measures. The following avoidance and minimization
measures shall be implemented during project
construction activities:
 Initial site disturbance shall occur outside the
general avian nesting season (February 1 through
September 15), if feasible.
 If initial site disturbance occurs in a work area within the general avian nesting season indicated above, a
qualified biologist shall conduct a pre-construction
Less than
significant.

City of San Leandro
880 Doolittle Drive Industrial Project
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Impact Mitigation Measure (s) Residual Impact
nesting bird survey no more than 14 days prior to
initial disturbances in the work area. The survey shall include the entire area of disturbance area plus a 50-
foot buffer (relevant to non-raptor species) and 300-
foot buffer (relevant to raptors) around the site. If
active nests are located, all construction work shall
be conducted outside a buffer zone from the nest to
be determined by the qualified biologist. The buffer
should be a minimum of 50 feet for non-raptor bird
species and at least 300 feet for raptor species.

Larger buffers may be required and/or smaller
buffers may be established depending upon the
species, status of the nest, and construction
activities occurring in the vicinity of the nest. The
buffer area(s) shall be closed to all construction
personnel and equipment until the adults and young
are no longer reliant on the nest site. A qualified
biologist shall confirm that breeding/nesting is
completed and young have fledged the nest prior to
removal of the buffer.
 If construction activities in a given work area cease for more than 14 days, additional surveys shall be
conducted for the work area. If active nests are
located, the aforementioned buffer zone measures
shall be implemented.

Cultural Resources
Unanticipated archaeological
deposits could be encountered and
damaged during ground-disturbing
activities required for project
construction. Impacts to
archeological resources would be
reduced to less than significant with
implementation of Mitigation
Measure CR-1.

CR-1 Unanticipated Discovery of Cultural Resources. In
the event that archaeological resources are unexpectedly encountered during ground-disturbing activities, work
within 50 feet of the find shall halt and an archaeologist meeting the Secretary of the Interior’s Professional
Qualifications Standards for archaeology (National Park Service 1983) shall be contacted immediately to evaluate the find. If the resource is determined by the qualified archaeologist to be prehistoric, then a Native American representative shall also be contacted to participate in the evaluation of the resource. If the qualified archaeologist and/or Native American representative determines it to
be appropriate, archaeological testing for CRHR eligibility shall be completed. If the resource proves to be eligible for the CRHR and impacts to the resource cannot be
avoided via project redesign, a qualified archaeologist shall prepare a data recovery plan tailored to the physical nature and characteristics of the resource, per the
requirements of CCR Guidelines Section 15126.4(b)(3)(C).

The data recovery plan shall identify data recovery
excavation methods, measurable objectives, and data
thresholds to reduce any significant impacts to cultural resources related to the resource. Pursuant to the data recovery plan, the qualified archaeologist and Native
American representative, as appropriate, shall recover
and document the scientifically consequential information that justifies the resource’s significance. The City shall review and approve the treatment plan and
archaeological testing as appropriate, and the resulting documentation shall be submitted to the regional
Less than
significant.

Executive Summary
Environmental Impact Report ES-9
Impact Mitigation Measure (s) Residual Impact
repository of the CHRIS, per CCR Guidelines Section
15126.4(b)(3)(C).

Greenhouse Gas Emissions
Impact GHG-1. The proposed project
would include new natural gas
connections, which would have the
potential to contribute to the longterm generation of GHG emissions affecting the environment. This
impact would be significant and
unavoidable.

No feasible mitigation measures are available. Significant and unavoidable.

Impact GHG-1. The proposed project
would include new natural gas
connections, which would have the
potential to contribute to the longterm generation of GHG emissions affecting the environment. This
impact would be significant and
unavoidable.

No feasible mitigation measures are available. Significant and unavoidable.

The cumulative GHG impacts of the
proposed project would be
significant.

No feasible mitigation measures are available. Significant and unavoidable.

Hazards and Hazardous Materials
Impact HAZ-1. The project has the
potential to 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 due to potential
hazardous materials that may be
present in the existing on-site
structures and soils and groundwater.

In addition, because of existing soil
and groundwater contamination, the
site is on a list compiled pursuant to
Government Code Section 65962.5.

This impact would be potentially
significant but mitigable.

HAZ-1 Project Demolition Activities. In conformance with State and local laws, a visual inspection/pre-demolition survey, and possible sampling, shall be conducted prior to the demolition of on-site building(s) to determine the
presence of asbestos-containing materials (ACMs) and/or lead-based paint. Documentation of the survey shall be
provided to the City of San Leandro prior to
commencement of demolition activities.

During demolition activities, all building materials
containing lead-based paint shall be removed in
accordance with Cal/OSHA Lead in Title 8, California Code of Regulations (CCR), Section 1532.1, including employee training, employee air monitoring, and dust control. Any debris or soil containing lead-based paint or coatings shall be disposed of at landfills that meet acceptance criteria for the type of lead being disposed.

All potentially friable asbestos containing materials
(ACMs) shall be removed in accordance with National
Emission Standards for Air Pollution (NESHAP) guidelines prior to demolition or renovation activities that may
disturb ACMs. All demolition activities shall be undertaken in accordance with Cal/OSHA standards contained in Title 8, CCR, Section 1529, to protect workers from asbestos
exposure.

Materials containing more than one-percent asbestos are also subject to Bay Area Air Quality Management District regulations. Removal of materials containing more than
Less than
significant.

City of San Leandro
880 Doolittle Drive Industrial Project
ES-10
Impact Mitigation Measure (s) Residual Impact
one-percent asbestos shall be completed in accordance
with Bay Area Air Quality Management District
requirements and notifications.

Based on Cal/OSHA rules and regulations, the following
conditions shall be implemented to limit impacts to
construction workers:
 Prior to commencement of demolition activities, a
building survey, including sampling and testing, shall
be completed to identify and quantify building
materials containing lead-based paint.
 During demolition activities, all building materials
containing lead-based paint shall be removed in
accordance with Cal/OSHA Lead in Construction
Standard, Title 8, CCR, Section 1532.1, including
employee training, employee air monitoring and
dust control.
 Any debris or soil containing lead-based paint or
coatings shall be disposed of at landfills that meet
acceptance criteria for the type of waste being
disposed.

HAZ-2 Implementation of the Revised Soil and
Groundwater Management Plan and DTSC Regulatory
Oversight. The project shall implement the appropriate
handling procedures and worker health and safety
measures during excavating or dewatering activities as
described in the site-specific Revised Soil and
Groundwater Management Plan developed by RMD
Environmental Solutions for the project in June 2021
(included as Appendix D to this EIR). Measures included in the Revised Soil and Groundwater Management Plan to
control potential hazardous contamination and exposure
include, but are not limited to the following:
 Construction contractors shall implement dust
control mitigation measures during construction
activities at the project site to minimize the
generation of dust. Examples of dust control
measures that shall be implemented include
routinely applying water or non-toxic soil stabilizers
to exposed soils while performing grading and
excavation activities; sweeping (with wet power
sweepers) paved access roads, parking areas, and
staging areas; covering or otherwise stabilizing soil
stockpiles at the end of each workday; And
suspending construction activities that cause visible
dust plumes and odors to extend beyond project site
boundaries. Some additional dust control mitigation
measures listed in the Soil and Groundwater
Management Plan include limiting construction
vehicle and equipment speeds to 15 miles per hours
when operated on exposed soils and removing
visible loose soils from vehicles before leaving the
project site.
 To prevent or minimize construction equipment
from tracking polluted spoils off the site onto
roadways, trucks used to transport soil will be
Executive Summary
Environmental Impact Report ES-11
Impact Mitigation Measure (s) Residual Impact
loaded in a manner to minimize soil spillage and
fugitive dust. Examples of ways to load trucks to
minimize spillage and dust include loading the truck
bed to less than full capacity and covering the bed of
truck after it has been loaded.
 Construction equipment shall be cleaned prior to
movement out of active work zones in impacted
areas. The equipment wheels/tires shall be cleaned
by means of shovels and stiff-bristled brooms or
brushes until they are fully cleaned. Upon
completion of cleaning, debris shall be placed in the
appropriate transportation vessel and the plastic
sheeting shall be disposed. If washing water is
required, decontamination wash water shall be
profiled and transported to an appropriate disposal
or recycling facility. Equipment exiting the project
site shall be inspected and logged for compliance
with the site decontamination requirements.
 A construction Health and Safety Plan shall be
prepared by the project applicant or its general
contractor for the proposed project in accordance
with Federal and State Occupational Safety and
Health Administration (OSHA) standards for
hazardous waste operations (29 Code of Federal
Regulations [CFR] 1910.1208 and 8 California Code of
Regulations [CCR] 5192, respectively).

Subcontractors shall either adopt the General
Contractor’s Health and Safety Plan or prepare their
own Health and Safety Plan satisfying the same
regulatory requirements. The General Contractor
shall be responsible for verifying that onsite
construction workers and visitors have read and
adhere to the procedures established in the Health
and Safety Plan. A copy of the Health and Safety Plan
shall be kept onsite during redevelopment activities.

In the event that unanticipated conditions occur at
the site, the General Contractor shall be responsible
for modifying the Health and Safety Plan accordingly.
 Field screening of soil shall be conducted
continuously during ground disturbing activities
using a calibrated handheld photoionization detector
or other organic vapor meter. Field screening using a
photoionization detector shall be conducted by
properly trained General Contractor and/or
Environmental Consultant personnel. Based on the
field screening, excavated soil shall be separated into stockpiles in three categories: 1) Background Soil: No
visual and odor indicators, and photoionization
detector measurements that are consistent with
background levels. Photoionization detector readings
of up to 5 parts per million by volume (ppmv) shall
be considered background levels. These soils can be
characterized for onsite reuse, if applicable; 2)
Interim Soil: No visual and odor indicators, and
photoionization detector measurements between 5
ppmv and 50 ppmv. These soils can be characterized
City of San Leandro
880 Doolittle Drive Industrial Project
ES-12
Impact Mitigation Measure (s) Residual Impact
for onsite reuse, if applicable; and 3) Contaminated
Soil: Staining and odor indicators present, and/or
photoionization detector measurements of more
than 50 ppmv. These soils shall be further evaluated
and are likely to be characterized for offsite disposal.  If soil exhibiting evidence of contamination (e.g.,
visual and odor indicators, and photoionization
detector measurements of more than 50 ppmv), is
encountered during ground disturbing activities, the
project applicant and/or General Contractor shall
cease ground disturbing activities in the area and
delineate the area with barricades or fencing, stakes
and plastic sheeting as appropriate, and signage to
notify onsite workers and visitors of access
restrictions. The General Contractor shall notify the
Property Owner and Environmental Consultant.

Upon notification, the Environmental Consultant
shall implement and/or provide oversight.
 Stormwater pollution controls shall be implemented
by the project applicant and/or General Contractor
to minimize sediment runoff in stormwater. Best
Management Practices including grading the site and
installing stormwater control measures such as
temporary earth berms or erecting silt fences around
the perimeter of exposed soil at the site, shall be
implemented to prevent erosion and sediment
runoff from the site. Straw bale barriers or sediment
traps shall be required to protect any existing catch
basins or drainage channels.
 During project construction activities, soil and/or
groundwater sampling, removal and management of
discovered underground structures (e.g., storage
tanks), chemical analysis and proper disposal of
contaminated materials, and soil import activities
shall be documented in a daily field log by the
project applicant and/or General Contractor and/or
Environmental Consultant. At the completion of the
construction activities, a Construction Completion
Report shall be prepared by the Environmental
Consultant for submittal to DTSC that summarizes
the soil and groundwater handling activities.

The DTSC shall continue to be utilized for agency oversight of assessment and remediation of the project site through completion of construction activities. In addition to
implementing the Revised Soil and Groundwater
Management Plan, prior to commencement of
construction and grading activities at the project site, the project applicant shall implement and/or complete the
following tasks, and other tasks if requested by DTSC,
regarding the open Site Cleanup Program Case:
 Implement the November 19, 2020 RedevelopmentRelated Groundwater Monitoring Well Network Modification Work Plan, as approved by DTSC on
May 26, 2021
Executive Summary
Environmental Impact Report ES-13
Impact Mitigation Measure (s) Residual Impact
 Implement the October 5, 2021 Revised Vapor
Intrusion Mitigation System Implementation Work
Plan, as approved by DTSC on December 1, 2021
 Implement the October 21, 2021 Revised Community
Air Monitoring Plan (CAMP), as approved by DTSC on
December 1, 2021
 Prepare a Five Year Remedial Action Review Report
for the years 2019-2023 as specified in a DTSC letter
dated May 3, 2022
 Implement the August 30, 2022 Soil Vapor Probe
Destruction Workplan, as approved by DTSC on
September 29, 2022
Upon submittal or completion of the information above,
and in accordance with the 2012 Land Use Covenant,
DTSC may require actions such as: development of
subsurface investigation workplans; completion of soil, soil vapor, and/or groundwater subsurface investigations; installation of soil vapor or groundwater monitoring wells; soil excavation and offsite disposal; completion of human health risk assessments; and/or completion of
remediation reports or case closure documents.

Subsurface soil, soil vapor, and groundwater
investigations, if required, shall be conducted in
accordance with a sampling plan that shall be reviewed
and approved by the DTSC.

The DTSC approval documents shall be submitted to and
reviewed by the City prior to issuing grading permits.

HAZ-3 Construction Dewatering Requirements.

Construction dewatering effluent, if produced, shall be pumped into holding tanks or United Nations (UN)-rated
55-gallon drums with appropriate labeling and secondary containment. If dewatering effluent would be discharged to an existing storm drain or drains, a National Pollutant Discharge Elimination System (NPDES) permit shall be
obtained from the Regional Water Quality Control Board.

If dewatering effluent would be discharged to the San
Leandro Water Pollution Control Plant, an industrial pretreatment permit shall be obtained from the San Leandro Environmental Services Section.

Chemical analysis shall be performed in accordance with the receiving facility’s requirements prior to discharge. If concentrations exceed the limits established for the
discharge point, the dewatering effluent shall either be (1) transferred into a vacuum truck or properly labeled UNrated 55-gallon drums and transported offsite for disposal at an appropriately licensed disposal facility; or (2) treated and discharged following sampling and analysis to confirm compliance with permit requirements.

HAZ-4 Groundwater Monitoring Well Protection. A
November 19, 2020 Redevelopment-Related
Groundwater Monitoring Well Network Modification
Work Plan (RMD Environmental Solutions 2020c), which
was approved in 2021 DTSC letter, was prepared to
reduce the potential for damaged or lost wells during
development of the project site. Based on available
City of San Leandro
880 Doolittle Drive Industrial Project
ES-14
Impact Mitigation Measure (s) Residual Impact
development plans at that time, the monitoring wells
were designated for either:

1. Protection in areas where minimal grade changes are
anticipated. These monitoring wells shall be marked
with paint and/or installation of delineators/snow
fencing/bollards. The project applicant and/or
General Contractor shall protect these groundwater
monitoring wells and maintain access to the wells for
routine monitoring to the extent practicable; or

2. Destruction in areas within the building footprint and areas with substantial grade changes.

The DTSC shall be notified of changes to these
designations based on modifications to the development
plans and/or input from the project applicant and/or
General Contractor with rationale for wells that do not warrant replacement. Prior to removal or installation of any wells, permits shall be acquired from the Alameda
County Public Works Agency.

HAZ-5 Engineered Vapor Barrier Requirement. An
engineered vapor barrier shall be employed to further
protect against possible vapor intrusion of chemicals of potential concern into the proposed building. The vapor barrier shall be designed to meet the needs of the
building. Vapor barriers are generally constructed using membranes constructed with high-density polyethylene
or other polyolefin-based resins. The vapor barrier shall be resistant to volatile organic compounds. The vapor
barrier shall meet the American Society for Testing and Materials guideline for a vapor barrier and have a
permeance rating of 0.1 perms or less. The thickness and strength of the vapor barrier shall be based on the needs for the building, but the architect and contractor shall use a material strong enough to easily withstand the building construction and other building considerations. The
selected vapor barrier shall be approved by the DTSC or Regional Water Quality Control Board prior to installation.

Written approval from either the DTSC or Regional Water Quality Control Board shall be provided to the City of San Leandro before building permits are issued.

HAZ-6 Bioretention Design Coordination. The project
applicant shall consult with the City of San Leandro on location and/or design of the on-site bioretention basins to ensure protection of the groundwater basin, which may include, but is not limited to, locating the basins outside of the restricted areas or use of a liner in the detention basin. The final design and location of the on-site
bioretention basins shall demonstrate that groundwater
would be protected from contamination. If bioretention
basins are proposed in the restricted areas, DTSC and/or the San Francisco Bay RWQCB shall also approve the
design of the bioretention basins.

Noise and Vibration
Impact NOI-1. Construction and
operation of the proposed project
would generate noise, increasing
NOI-1 On-Site Noise Barrier. The applicant shall install a permanent noise barrier along the property boundary
that is oriented in a northwest-southeast direction and Less than
significant.

Executive Summary
Environmental Impact Report ES-15
Impact Mitigation Measure (s) Residual Impact
ambient noise levels near the project
site. Construction noise would be
temporary and below thresholds of
significance. Traffic noise during
operation would also be below
significance thresholds; however, onsite operational noise would exceed thresholds established for the nearest
sensitive receptor. Impacts would be
potentially significant but mitigable.
separates the project site from APN 77A-742-3-2. The
noise barrier shall be a solid fence or wall design and no less than 8 feet tall. The noise barrier shall be no less that 140 feet in length, beginning at the southernmost end of this property boundary.

Impact NOI-2. Operation of the
project would not generate
substantial groundborne vibration,
but project construction would
generate groundborne vibration.

Construction vibration levels would
exceed thresholds of structural
damage at nearby existing buildings.

Impacts would be potential
significant but mitigable.

NOI-2 Static Roller Requirement. The project applicant
and/or its construction contractors shall use of a static roller in lieu of a vibratory roller for paving activities within 15 feet of the existing off-site buildings to the north and west of the project site. City staff shall verify that this requirement is incorporated into construction plans prior to issuance of a building permit and verified in the field.

Less than
significant.

Impact NOI-3. The project would
result in employment opportunities
within areas that occur inside of noise
contours of the Oakland International
Airport. However, the project site
would be within the 60 dBA noise
contour, and 60 dBA is not an
excessive noise level. Therefore,
people working in the project site
would not be exposed to excessive
airport noise, and impacts would be
less than significant.

No mitigation measures are required. Less than
significant.

Transportation
Impact TRA-1. The project would
generate VMT that is more than 15
percent below the average VMT per
employee in the project area
Therefore, the proposed project
would not conflict with CEQA
Guidelines Section 15064.3,
subdivision (b), and impacts would be
less than significant.

No mitigation measures are required. Less than
significant.

Impact TRA-2. The project would
introduce tractor trailers entering
into roadway traffic via driveways.

However, sufficient sight distance
exists to prevent tractor trailers
existing the project site from creating
hazards related to dangerous
intersections. Impacts would be less
than significant.

No mitigation measures are required. Less than
significant.

Tribal Cultural Resources
Unanticipated tribal cultural
resources could be encountered and
TCR-1 Unanticipated Discovery of Tribal Cultural
Resources. In the event that cultural resources of Native Less than
significant.

City of San Leandro
880 Doolittle Drive Industrial Project
ES-16
Impact Mitigation Measure (s) Residual Impact
damaged during ground-disturbing
activities required for project
construction. Impacts to tribal
cultural resources would be reduced
to less than significant with
implementation of Mitigation
Measure TCR-1.

American origin are identified during project construction, all earth-disturbing work within 50 feet of the find shall be temporarily suspended or redirected until an
archaeologist has evaluated the nature and significance of the find as a cultural resource and an appropriate local Native American representative is consulted. If the City, in consultation with local Native American tribes,
determines that the resource is a tribal cultural resource and thus significant under CEQA, a mitigation plan shall be prepared and implemented in accordance with state
guidelines and in consultation with local Native American group(s). The plan shall include avoidance of the resource or, if avoidance of the resource is infeasible, the plan shall outline the appropriate treatment of the resource in
coordination with the appropriate local Native American tribal representative and, if applicable, a qualified
archaeologist. The plan shall include measures to ensure the find is treated in a manner that respectfully retains, to the degree feasible, the qualities that render the resource of significance to the local Native American group(s).

Examples of appropriate mitigation for tribal cultural
resources include, but are not limited to, protecting the cultural character and integrity of the resource, protecting traditional use of the resource, protecting the
confidentiality of the resource, or heritage recovery.

Introduction
Environmental Impact Report 1-1
Introduction
This document is an Environmental Impact Report (EIR) for a proposed industrial development located at 880 Doolittle Drive, San Leandro, California. The proposed 880 Doolittle Drive Industrial Project (hereafter referred to as the “proposed project” or “project”) would be constructed on a site currently developed with vacant warehouses and surface parking.

This section discusses (1) the project and EIR background; (2) the legal basis for preparing an EIR; (3) the scope and content of the EIR; (4) issue areas found not to be significant by the Initial Study; (5) the lead, responsible, and trustee agencies; and (6) the environmental review process required under the California Environmental Quality Act (CEQA). The proposed project is described in detail in Section 2, Project Description. The Initial Study is provided as Appendix A to this EIR.

1.1 Environmental Impact Report Background
The City of San Leandro distributed a Notice of Preparation (NOP) of the EIR for a 30-day agency and public review period starting on November 22, 2023 and ending on December 22, 2023. The City received letters from eight public agencies in response to the NOP during the public review period.

The NOP is presented in Appendix B of this EIR, along with the responses received. Table 1-1 on the following page summarizes the content of the letters and where the issues raised are discussed in the EIR.

1.2 Purpose and Legal Authority
The proposed project requires the discretionary approval of the City of San Leandro; therefore, the project is subject to the environmental review requirements of the California Environmental Quality Act (CEQA). In accordance with Section 15121 of the CEQA Guidelines (California Code of Regulations, Title 14), the purpose of this EIR is to serve as an informational document that:
“will inform public agency decisionmakers and the public generally of the significant environmental effect of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project.”
This EIR has been prepared as a project EIR pursuant to Section 15161 of the CEQA Guidelines. A Project EIR is appropriate for a specific development project. As stated in the CEQA Guidelines:
“This type of EIR should focus primarily on the changes in the environment that would result from the development project. The EIR shall examine all phases of the project, including planning, construction, and operation.”
This EIR is to serve as an informational document for the public and City of San Leandro decision makers. The process will include a public hearing before the City Council of San Leandro to consider certification of a Final EIR and approval of the proposed project.

City of San Leandro
880 Doolittle Drive Industrial Project
1-2
Table 1-1 NOP Comments Summary
Commenter Comment/Request Summary
Where the Topic is Discussed in
the EIR
Alameda County,
Community
Development Agency,
Planning Department
The Airport Land Use Commission has no comments on
the scope of the environmental analysis in the EIR.

However, regarding the Oakland Airport Land Use
Compatibility Plan:

The project site is located primarily in the Outer
Approach Zone (Zone 4), where warehouses and
distribution facilities are a compatible use. This assumes that there will be at most 100 employees per acre and
that at least 20 percent of the parcel will be vacant land (this includes parking areas).

Commercial and industrial uses are compatible with the
60 dB CNEL contour, in which 880 Doolittle is located.

With the stated height of 50 feet, the new warehouse
should be under the Part 77 surface maximum for the
area.

The site is located in the plan’s avigation easement
zone.

Potential noise impacts of the
project are evaluated in Section

4.3, Noise.

Section 9, Hazards and Hazardous
Materials, of the Initial Study,
which is provided as Appendix to
this EIR, discusses Part 77 surface
maximum and proposed building
height.

Bay Area Air Quality
Management District
It is recommended that the project incorporate all
feasible measures to reduce air quality and greenhouse
gas impacts, including the installation of on-site solar arrays, procurement of 100 percent renewable energy,
electrification of all operations to the extent feasible including ‘make-ready’ electrification infrastructure,
and consideration of truck route management to
reduce community impacts.

Additionally, the Initial Study
contains a detailed health risk
assessment prepared for the
project.

The potential impacts of the
project related to greenhouse gas
emissions are evaluated in Section

4.1, Greenhouse Gas Emissions, of
this EIR.

Bay Area Air Quality
Management District
The project should incorporate construction mitigation
measures, especially for demolition and site preparation that may elevate fugitive dust.

The potential air quality impacts of
the project, including potential
health risk impacts from air
pollution, are evaluated in the
Initial Study for the project. The
Initial Study is provided as
Appendix A to this EIR. Best
management practices for
controlling fugitive dust during
project construction have been
incorporated as mitigation.

Bay Area Air Quality
Management District
Certain aspects of the project may require a permit
from the Bay Air Quality Management District (for
example, backup diesel generators and asbestos
demolition). Please ensure the Bay Air Quality
Management District is adequately recognized as a
permitting agency in future environmental documents.

The project applicant will be
responsible for obtaining
applicable permits for the project.

Introduction
Environmental Impact Report 1-3
Commenter Comment/Request Summary
Where the Topic is Discussed in
the EIR
California Department
of Justice
Diesel trucks visiting warehouses emit nitrogen oxide
(NOx)—a primary precursor to smog formation and a
significant factor in the development of respiratory
problems like asthma, bronchitis, and lung irritation—
and diesel particulate matter (a subset of fine particular matter that is smaller than 2.5 micrometers)—a
contributor to cancer, heart disease, respiratory
illnesses, and premature death.

Additionally, the Initial Study
contains a detailed health risk
assessment prepared for the
project.

California Department
of Justice
Trucks and on-site loading activities can also be loud, bringing disruptive noise levels during 24/7 operation
that can cause hearing damage after prolonged
exposure.

Potential noise impacts of the
project are evaluated in Section

4.3, Noise.

California Department
of Justice
The hundreds, and sometimes thousands, of daily truck
and passenger car trips that warehouses generate can
contribute to traffic jams, deterioration of road
surfaces, traffic accidents, and unsafe conditions for
pedestrians and bicyclists.

Traffic jams are a type of traffic
delay. Traffic delay at key
intersection near the project site is
discussed in the Initial Study. The
Initial Study is provided as
Appendix A to this EIR.

Potential conflicts of the project
with pedestrian and bicycle modes
of transportation are evaluated in
the Initial Study.

Potential transportation hazards
such as unsafe intersections or
incompatible vehicle types are
evaluated in Section 4.4,
Transportation, of this EIR.

California Department
of Justice
Warehouses may also have other environmental
impacts.

The potential environmental
impacts of the project are
evaluated in this EIR and in the
Initial Study, which is provided as
Appendix A to this EIR.

California Department
of Justice
In preparing the EIR, the Department of Justice
encourages the City to consult its publication titled
Warehouse Projects: Best Practices and Mitigation
Measures to Comply with the California Environmental
Quality Act.

The City reviewed the publication
referenced in this comment and
relevant components have been
incorporated into the preparation
of this EIR. For example, the
publication recommends
preparation of a noise impact
analysis. As described in EIR
Section 4.3, Noise, a noise impact
analysis has been prepared for the
project.

City of San Leandro
880 Doolittle Drive Industrial Project
1-4
Commenter Comment/Request Summary
Where the Topic is Discussed in
the EIR
California Department
of Justice
Priority should be placed on avoiding land use conflicts between warehouses and sensitive receptors and on
mitigating the impacts of any unavoidable land use
conflicts. However, even projects located far from
sensitive receptors may contribute to harmful regional
air pollution, so you should consider measures to
reduce emissions associated with the project to help
the State meet its air quality goals. A distant warehouse may also impact sensitive receptors if trucks must pass near sensitive receptors to visit the warehouse.

The potential air quality impacts of
the project are evaluated in the
Initial Study. The Initial Study is
provided as Appendix A to this EIR.

California Department
of Toxic Substances
Control
Surveys should be conducted for lead-based paint and
products, mercury, asbestos containing materials, and
polychlorinated biphenyl caulk prior to demolition of
buildings and structures. Removal, demolition, and
disposal of the above-mentioned chemicals should be
conducted in compliance with California environmental
regulations and policies.

Potential impacts of the project
associated with hazardous
materials, including chemicals
mentioned in this comment, are
evaluated in Section 4.2, Hazards
and Hazardous Materials.

California Department
of Toxic Substances
Control
Imported soil and fill material should be tested to
ensure any contaminants of concern are within
approved screening levels for the intended land use. To minimize the possibility of introducing contaminated
soil and fill material there should be documentation of the origins of the soil or fill material and, if applicable, sampling be conducted to ensure that the imported soil
and fill material meets screening levels for the intended land use. The soil sampling should include analysis
based on the source of the fill and knowledge of the
prior land use.

The proposed project does not
include importing fill material.

California Department
of Toxic Substances
Control
Prior to new buildings being constructed on site, a
Remedial Action Plan amendment will be required to
evaluate the soil vapor impacts and vapor intrusion risk.

While a vapor mitigation system has been discussed for
the site, the system cannot be installed before the
completion of the Remedial Action Plan amendment.

The potential impacts related to
soil vapor intrusion are evaluated
in Section 4.2, Hazards and
Hazardous Materials. Section 4.2,
Hazards and Hazardous Materials,
also identifies mitigation measures
for impacts related to soil vapor
intrusion.

California Department
of Transportation –
Aeronautics Program
The project site is primarily in Safety Zone 4 (Outer
Approach/Departure Zone), with a portion in Zone 6
(Traffic Pattern Zone) of the Oakland International
Airport and therefore must adhere to the safety criteria and restrictions defined in the Airport Land Use
Compatibility Plan (ALUCP) formed by the ALUC
pursuant to the PUC, Section 21674. Warehouse and
office space square footage per person should be
further reviewed to adhere to consistency with the
ALUCP and Table 3-2 of the ALUCP. Section 3.3.2.7.
should also be reviewed to ensure compatibility with
development criteria.

This comment does not directly
pertain to environmental impacts
evaluated under CEQA. However,
the City recognizes the importance
of adhering to the Airport Land Use
Compatibility Plan. The Alameda
County Community Development
Agency, Planning Department
(ALUC) also provided a written
comment in response to the NOP.

In that letter the ALUC indicates
that warehouses are a compatible
use within Safety Zone 4 assuming
certain restrictions on the number
of employees on-site.

Introduction
Environmental Impact Report 1-5
Commenter Comment/Request Summary
Where the Topic is Discussed in
the EIR
California Department
of Transportation –
Aeronautics Program
The project site is included on a list of hazardous
material sites compiled pursuant to Government Code
Section 65962.5, compatibility restrictions should be
reviewed per the ALUCPs Table 3-2 and Section

3.3.2.8(e).

Potential impacts of the project
associated with hazardous
materials are evaluated in Section

4.2, Hazards and Hazardous
Materials.

California Department
of Transportation –
Aeronautics Program
The proposed project may also be subject to 14 CFR
Part 77 Conical Surface standards and CNEL Contours
noise compatibility in applicable areas.

The Alameda County, Community
Development Agency, Planning
Department (ALUC) also provided a
written comment in response to
the NOP. In that letter the ALUC
indicates that the proposed height
of the warehouse should be under
the Part 77 surface maximum for
the area. The ALUC also indicated
that commercial and industrial
uses are compatible with the 60 dB
CNEL contour, in which 880
Doolittle is located.

California Department
of Transportation –
Aeronautics Program
Caltrans advises the City of San Leandro to submit its
plans to the ALUC to determine if the plans or projects are consistent or not with the ALUCP according to the
State Aeronautics Act’s statutory procedure.

This comment does not directly
pertain to environmental impacts
evaluated under CEQA. However,
the project plans will be submitted
to the ALUC for review.

California Department
of Transportation
Please consider the following freight issues when
drafting the DEIR: the number of parking spaces should
be based on peak operating time of the activity
generator; site entrance and exit points should
accommodate the design of vehicle movements; the
DEIR should identify pedestrian and bicycle conflict
points to and from the proposed facility as well as bus stops that may conflict with truck parking zones; and
the project should consider the number of legal truck
parking spots available in the area and the potential
areas that may be utilized as unauthorized parking.

Parking requirements are not a
CEQA topic or issue area. However,
the project will be evaluated by the
City for conformance to the San
Leandro Municipal Code, including
the provision of adequate parking.

Potential conflicts of the project
with transit, pedestrian, and
bicycle modes of transportation
are evaluated in the Initial Study.

The Initial Study is provided as
Appendix A to this EIR.

Potential transportation hazards
such as unsafe intersections or
incompatible vehicle types are
evaluated in Section 4.4,
Transportation, of this EIR.

California Department
of Transportation
Potential impacts to the state right-of-way from projectrelated temporary access points should be analyzed.

Mitigation for significant impacts due to construction
and noise should be identified. 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. Prior to construction, coordination may be required with Caltrans to develop
a Transportation Management Plan to reduce
construction traffic impacts to the State Transportation Network.

Impacts to state right-of-way are
not environmental impacts
pursuant to CEQA. Regardless, the
proposed project does not include
temporary access points from or
within state right-of-way.

The project applicant must obtain
all required permits and comply
with regulatory requirements.

Construction and operational noise
impacts are evaluated in Section

4.3, Noise, of this EIR.

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Commenter Comment/Request Summary
Where the Topic is Discussed in
the EIR
California Department
of Transportation
As the Lead Agency, the City of San Leandro is
responsible for all project mitigation, including any
needed improvements to the State Transportation
Network. The project’s fair share contribution,
financing, scheduling, implementation responsibilities
and lead agency monitoring should be fully discussed
for all proposed mitigation measures.

Mitigation measures required for
the project are identified in the
Initial Study (see Appendix A) and
throughout this EIR. The Executive
Summary of this EIR also lists all
required mitigation measures for
the project. The identified
mitigation measures do not require
improvements or modifications to
the State Transportation Network.

As part of the CEQA process, the
City will prepare a Mitigation
Monitoring and Reporting Program
(MMRP). The MMRP will identify
the timing and monitoring
frequency of mitigation measures,
as well as the agency or
organization responsible for
ensuring the measure is
implemented and monitored
accordingly.

East Bay Municipal
Utility District
When the development plans are finalized, the project
sponsor should contact EBMUD's New Business Office
and request a water service estimate to determine
costs and conditions for providing water service to the project. Engineering and installation of water services require substantial lead time, which should be provided for in the project sponsor's development schedule.

The project applicant would
request water service for the
project site once the development
plans are finalized and would
consider the lead time in their
project development schedule.

East Bay Municipal
Utility District
The District’s Standard Site Assessment Report indicates the potential for contaminated soils or groundwater to
be within the project’s boundaries. The project sponsor should be aware that East Bay Municipal Utility District will not install pipeline or services in contaminated soil or groundwater, nor in areas where groundwater
contaminant concentrations exceed specified limits. The project sponsor must submit copies to East Bay
Municipal Utility District of all known information
regarding soil and groundwater quality within or
adjacent to the project boundary and a legally
sufficient, complete, and specific written remediation
plan establishing the methodology, planning and design
of all necessary systems for the removal, treatment, and disposal of contaminated soil and groundwater.

Potential impacts of the project
associated with hazardous
materials, including contaminated
soil and groundwater, are
evaluated in Section 4.2, Hazards
and Hazardous Materials.

Introduction
Environmental Impact Report 1-7
Commenter Comment/Request Summary
Where the Topic is Discussed in
the EIR
East Bay Municipal
Utility District
The East Bay Municipal Utility District will not design piping or services until soil and groundwater quality
data and remediation plans have been received and
reviewed and will not start underground work until
remediation has been carried out and documentation of
the effectiveness of the remediation has been received
and reviewed. If no soil or groundwater quality data
exists, or the information supplied by the project
sponsor is insufficient, East Bay Municipal Utility District may require the project sponsor to perform sampling
and analysis to characterize the soil and groundwater
that may be encountered during excavation, or East Bay
Municipal Utility District may perform such sampling
and analysis at the project sponsor's expense. If
evidence of contamination is discovered during East Bay Municipal Utility District work on the project site, work may be suspended until such contamination is
adequately characterized and remediated to East Bay
Municipal Utility District standards.

Potential impacts of the project
associated with hazardous
materials, including contaminated
soil and groundwater, are
evaluated in Section 4.2, Hazards
and Hazardous Materials.

East Bay Municipal
Utility District
East Bay Municipal Utility District requests that the City include in its conditions of approval a requirement that the project sponsor comply with Assembly Bill 325,
"Model Water Efficient Landscape Ordinance," (Division
2, Title 23, California Code of Regulations, Chapter 2.7, Sections 490 through 495). The project sponsor should
be aware that Section 31 of East Bay Municipal Utility
District’s Water Service Regulations requires that water service shall not be furnished for new or expanded
service unless all the applicable water-efficiency
measures described in the regulation are installed at
the project sponsor's expense.

This comment cites regulatory
requirements. The proposed
project must comply with
regulatory requirements regardless
of CEQA analysis and mitigation
measures.

Native American
Heritage Commission
The Native American Heritage Commission
recommends consultation with California Native
American tribes that are traditionally and culturally
affiliated with the geographic area of the proposed
project as early as possible in order to avoid inadvertent discoveries of Native American human remains and best
protect tribal cultural resources.

No California Native American
Tribes have submitted requests to
the City of San Leandro for
consultation on CEQA projects
pursuant to Public Resources Code
Section 21080.3.1. The proposed
project does not involve an
amendment to the City’s General
Plan; therefore, consultation
pursuant to SB 18 is not required.

Potential project impacts related to
tribal cultural resources are
evaluated in the Initial Study,
which is provided as Appendix A to
the EIR. The Initial Study also
provides mitigation measures to
reduce potential impacts to tribal
cultural resources. These
mitigation measures also appear in
the Executive Summary of this EIR.

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1.3 Scope and Content
This EIR addresses impacts identified by the Initial Study to be potentially significant. The following issues were found to include potentially significant impacts and have been studied in the EIR:
 Greenhouse Gas Emissions
 Hazards and Hazardous Materials
 Noise
 Transportation
In preparing the EIR, use was made of pertinent City policies and guidelines, certified EIRs and adopted CEQA documents, and other background documents. A full reference list is contained in Section 7, References and Preparers.

The alternatives section of the EIR (Section 5) was prepared in accordance with Section 15126.6 of the CEQA Guidelines and focuses on a range of reasonable alternatives that are capable of eliminating or reducing significant adverse effects associated with the project while feasibly attaining most of the basic project objectives. In addition, the alternatives section identifies the “environmentally superior” alternative among the alternatives assessed. The alternatives evaluated include the CEQA-required “No Project” alternative and two alternative development scenarios for the project site.

The level of detail contained throughout this EIR is consistent with the requirements of CEQA and applicable court decisions. Section 15151 of the CEQA Guidelines provides the standard of adequacy on which this document is based. The CEQA Guidelines state:

An EIR should be prepared with a sufficient degree of analysis to provide decisionmakers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of the proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection, but for adequacy, completeness, and a good faith effort at full disclosure.

1.4 Issues Not Studied in Detail in the EIR
Table 1-2 lists the environmental resource areas that were addressed in the Initial Study (Appendix A). A full analysis of each resource area listed in Table 1-2 can be found in Appendix A. As indicated in the Initial Study, there is no substantial evidence that the proposed project may have a significant impact on the environment in any of these issue areas, either with or without mitigation, depending on the specific impact.

Introduction
Environmental Impact Report 1-9
Table 1-2 Issues Not Studied in the EIR
 Aesthetics  Agriculture and Forestry Resources
 Air Quality  Biological Resources
 Cultural Resources  Energy
 Geology and Soils  Hydrology and Water Quality
 Hydrology and Water Quality  Land Use and Planning
 Mineral Resources  Population and Housing
 Public Services  Recreation
 Tribal Cultural Resources  Utilities and Service Systems  Wildfire
Impacts included in the Initial Study that would be less than significant with implementation of mitigation include:
 Air Quality: Construction of the proposed project would generate wind-blown dust that could contribute particulate matter into the local atmosphere. With implementation of Mitigation Measure AQ-1, this impact would be less than significant.

AQ-1 BAAQMD Best Management Practices for Construction-Related Fugitive Dust Emissions
The project applicant shall require all construction contractors to implement the basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust emissions.

Emission reduction measures will include, at a minimum, the following measures:

1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two Ɵmes per day.

2. All haul trucks transporƟng soil, sand, or other loose material off-site shall be covered.

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 mph.

5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.

Building pads shall be laid as soon as possible aŌer grading unless seeding or soil binders are used.

6. All excavaƟon, grading, and/or demoliƟon acƟviƟes shall be suspended when average wind speeds exceed 20 mph.

7. All trucks and equipment, including their Ɵres, shall be washed off prior to leaving the site.

8. Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch compacted layer of wood chips, mulch, or gravel.

9. Publicly visible signs shall be posted with the telephone number and name of the person to contact at the lead agency regarding dust complaints. This person shall respond and take correcƟve acƟon within 48 hours. The Air District’s General Air PolluƟon Complaints number shall also be visible to ensure compliance with applicable regulaƟons.

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 Biological Resources: The proposed project would involve construction work near street trees just off the project site near the driveway that connects to Hester Street which may affect protected nesting birds in existing trees. Impacts to nesting birds would be reduced to less than significant with implementation of Mitigation Measure BIO-1.

BIO-1 Nesting Bird Avoidance and Minimization Measures
The following avoidance and minimization measures shall be implemented during project construction activities:
 Initial site disturbance shall occur outside the general avian nesting season (February 1 through September 15), if feasible.
 If initial site disturbance occurs in a work area within the general avian nesting season indicated above, a qualified biologist shall conduct a pre-construction nesting bird survey no more than 14 days prior to initial disturbances in the work area. The survey shall include the entire area of disturbance area plus a 50-foot buffer (relevant to non-raptor species) and 300-foot buffer (relevant to raptors) around the site. If active nests are located, all construction work shall be conducted outside a buffer zone from the nest to be determined by the qualified biologist. The buffer should be a minimum of 50 feet for non-raptor bird species and at least 300 feet for raptor species. Larger buffers may be required and/or smaller buffers may be established depending upon the species, status of the nest, and construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and young have fledged the nest prior to removal of the buffer.  If construction activities in a given work area cease for more than 14 days, additional surveys shall be conducted for the work area. If active nests are located, the aforementioned buffer zone measures shall be implemented.  Cultural Resources: Unanticipated archaeological deposits could be encountered and damaged during ground-disturbing activities required for project construction. Impacts to archeological resources would be reduced to less than significant with implementation of Mitigation Measure CR-1.

CR-1 Unanticipated Discovery of Cultural Resources
In the event that archaeological resources are unexpectedly encountered during grounddisturbing activities, work within 50 feet of the find shall halt and an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for archaeology (National Park Service 1983) shall be contacted immediately to evaluate the find. If the resource is determined by the qualified archaeologist to be prehistoric, then a Native American representative shall also be contacted to participate in the evaluation of the resource. If the qualified archaeologist and/or Native American representative determines it to be appropriate, archaeological testing for CRHR eligibility shall be completed. If the resource proves to be eligible for the CRHR and impacts to the resource cannot be avoided via project redesign, a qualified archaeologist shall prepare a data recovery plan tailored to the physical nature and characteristics of the resource, per the requirements of CCR Guidelines Section 15126.4(b)(3)(C). The data recovery plan shall identify data recovery excavation methods, measurable objectives, and data thresholds to reduce any significant impacts to cultural resources related to the resource. Pursuant to the data recovery plan, the qualified archaeologist and Native American representative, as Introduction
Environmental Impact Report 1-11
appropriate, shall recover and document the scientifically consequential information that justifies the resource’s significance. The City shall review and approve the treatment plan and archaeological testing as appropriate, and the resulting documentation shall be submitted to the regional repository of the CHRIS, per CCR Guidelines Section 15126.4(b)(3)(C).  Tribal Cultural Resources: Unanticipated tribal cultural resources could be encountered and damaged during ground-disturbing activities required for project construction. Impacts to tribal cultural resources would be reduced to less than significant with implementation of Mitigation Measure TCR-1.

TCR-1 Unanticipated Discovery of Tribal Cultural Resources In the event that cultural resources of Native American origin are identified during project construction, all earth-disturbing work within 50 feet of the find shall be temporarily suspended or redirected until an archaeologist has evaluated the nature and significance of the find as a cultural resource and an appropriate local Native American representative is consulted. If the City, in consultation with local Native American tribes, determines that the resource is a tribal cultural resource and thus significant under CEQA, a mitigation plan shall be prepared and implemented in accordance with state guidelines and in consultation with local Native American group(s). The plan shall include avoidance of the resource or, if avoidance of the resource is infeasible, the plan shall outline the appropriate treatment of the resource in coordination with the appropriate local Native American tribal representative and, if applicable, a qualified archaeologist. The plan shall include measures to ensure the find is treated in a manner that respectfully retains, to the degree feasible, the qualities that render the resource of significance to the local Native American group(s). Examples of appropriate mitigation for tribal cultural resources include, but are not limited to, protecting the cultural character and integrity of the resource, protecting traditional use of the resource, protecting the confidentiality of the resource, or heritage recovery.

1.5 Environmental Review Process
The environmental impact review process, as required under CEQA, is summarized below and illustrated in Figure 1-1. The steps are presented in sequential order.

Notice of Preparation (NOP) and Initial Study. After deciding that an EIR is required, the lead agency (City of San Leandro) must file a NOP soliciting input on the EIR scope to the State Clearinghouse, other concerned agencies, and parties previously requesting notice in writing (CEQA Guidelines Section 15082; Public Resources Code Sections 21080.4 and 21092.2). Aside from temporary exceptions in place prior to September 30, 2021, due to the COVID-19 pandemic, the NOP must be posted at the County Clerk's office for 30 days. The NOP may be accompanied by an Initial Study that identifies the issue areas for which the project could create significant environmental impacts (CEQA Guidelines Section 15082(a)(2).

Draft EIR Prepared. The Draft EIR must contain a) table of contents or index; b) summary; c) project description; d) environmental setting; e) discussion of significant impacts (direct, indirect, cumulative, growth-inducing and unavoidable impacts); f) a discussion of alternatives; g) mitigation measures; and h) discussion of irreversible changes.

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Notice of Completion (NOC). The lead agency must file a NOC with the State Clearinghouse when it completes a Draft EIR and prepare a Public Notice of Availability of a Draft EIR. The lead agency must post the NOC in the County Clerk’s office for at least 30 days and send a copy of the NOC to anyone requesting it (Public Resources Code Sections 21092, 21092.3, and CEQA Guidelines Section 15087). Additionally, public notice of Draft EIR availability must be given through at least one of the following procedures: a) publication in a newspaper of general circulation; b) posting on and off the project site; and c) direct mailing to owners and occupants of contiguous properties. The lead agency must solicit input from other agencies and the public and respond in writing to all comments received (Public Resources Code Sections 21104 and 21153). The minimum public review period for a Draft EIR is 30 days (Public Resources Code 21091).

Final EIR. A Final EIR must include a) the Draft EIR; b) copies of comments received during public review; c) a list of persons and entities commenting on the Draft EIR; and d) the Lead Agency’s responses to comments.

Certification of Final EIR. Prior to making a decision on a proposed project, the lead agency must certify that: a) the Final EIR has been completed in compliance with CEQA; b) the Final EIR was presented to the decision-making body of the lead agency; c) the decision-making body reviewed and considered the information in the Final EIR prior to approving a project; and d) the Final EIR reflects the lead agency’s independent judgment and analysis (CEQA Guidelines Section 15090).

Lead Agency Project Decision. The lead agency may a) disapprove the project because of its significant environmental effects; b) require changes to the project to reduce or avoid significant environmental effects; or c) approve the project despite its significant environmental effects, if the proper findings and statement of overriding considerations are adopted (CEQA Guidelines Sections 15042 and 15043).

Findings/Statement of Overriding Considerations. For each significant impact of the project identified in the EIR, the lead agency must find, based on substantial evidence in the record, that either: a) the project has been changed to avoid or substantially reduce the magnitude of the significant impact; b) changes to the project are within another agency’s responsibility and jurisdiction and such changes have or should be adopted by the other agency; or c) specific economic, social, legal, technological, or other considerations make the mitigation measures or project alternatives infeasible (CEQA Guidelines Section 15091). If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency’s decision (CEQA Guidelines Section 15091).

Mitigation Monitoring Reporting Program. When the lead agency makes findings on significant effects identified in the EIR, it must adopt a reporting or monitoring program for mitigation measures that were adopted or made conditions of project approval to mitigate significant effects (CEQA Guidelines Sections 15091 and 15097).

Notice of Determination (NOD). The lead agency must file a NOD after deciding to approve a project for which an EIR is prepared (CEQA Guidelines Section 15094). A local agency must file the NOD with the County Clerk. The NOD must be posted for 30 days and sent to anyone previously requesting notice. Posting of the NOD starts a 30-day statute of limitations on CEQA legal challenges (Public Resources Code Section 21167[c]).

Introduction
Environmental Impact Report 1-13
Figure 1-1 Environmental Review Process
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Project Description
Environmental Impact Report 2-1
2 Project Description
This section describes all components and characteristics of the proposed project, including the project applicant, the project site and surrounding land uses, major project characteristics, project objectives, and discretionary actions needed for approval, and serves as a basis for the analysis that follows in subsequent chapters of this Draft Environmental Impact Report (EIR). This section also provides an overview of existing conditions on and around the project site, including current jurisdictional designations; however, existing conditions are described in greater detail in the Environmental Setting portion of each environmental analysis section in Chapter 3, Environmental Setting.

2.1 Project Applicant
Prologis
Claudia Tarpin, Director, Development
(510)-656-1900

2.2 Lead Agency Contact Person
Cindy Lemaire, AICP, CNU-A, Senior Planner
City of San Leandro
835 East 14th Street
San Leandro, California 94577
(510) 577-3348

2.3 Project Location
The project site is located at 880 Doolittle Drive, which is on the east side of Doolittle Drive just east of adjacent properties with frontage on Doolittle Drive, approximately 0.2 mile north of its intersection with Davis Street, in San Leandro. The project site measures approximately 14.14 acres and consists of two Assessor’s parcels: APN 77A-0741-004-02 and 77A-0741-005-00. Existing access to the project site is from a driveway on Doolittle Drive. Access to the site is also provided from a driveway at the southern terminus of Hester Street, which is a public street north of the project site.

Figure 2-1 shows the site location in a regional context. Figure 2-2 shows an aerial view of the location of the site relative to the surrounding area. The aerial photograph shown in Figure 2-2 is outdated in that is shows vehicles on-site indicating an occupied building. The buildings on site are currently vacant with no active operations.

The project site is also in the planning area of the Airport Land Use Compatibility Plan for the Oakland International Airport (Alameda County Community Development Department 2010).

City of San Leandro
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Figure 2-1 Regional Location
Project Description
Environmental Impact Report 2-3
Figure 2-2 Project Site Location
City of San Leandro
880 Doolittle Drive Industrial Project
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2.4 Existing Site Characteristics

2.4.1 Site History and Existing Conditions
The project site is entirely developed. Existing on-site development consists of an approximately 207,000 square-foot industrial masonry building, an approximately 4,700 square-foot industrial masonry building, and paved surface parking lots, including a large surface parking lot covering approximately the northern half of the site. These existing buildings are vacant, and the unoccupied condition is the circumstance used for the environmental baseline in this document. Unpaved portions of the site are limited to small islands of landscaping, such as a strip of landscaping around the cul-de-sac at the end of Hester Street and landscaping along the easternmost project site boundary. Existing landscaping is a mix of non-native and weedy ground cover consisting of ruderal grass. There are inactive railroad tracks adjacent to the south and west of the site, and there is an active railroad corridor approximately 400 feet east of the project site.

In addition to the on-site warehouses, the project site has also been used as vehicle parking for people departing from the Oakland International Airport. However, operation of airport parking on the site ended during the COVID-19 pandemic and never resumed. The project site is currently vacant with no active operations.

Representative photographs of existing site conditions are shown on Figure 2-3.

2.4.2 General Plan Designation
The project site is designated as General Industrial (IG) in the San Leandro 2035 General Plan (City of San Leandro 2016). According to the Land Use Element of the 2035 General Plan, areas designated as General Industrial may contain a wide range of manufacturing, transportation, food and beverage processing, technology, warehousing, vehicle storage, office-flex, and distribution uses. A limited range of commercial uses are also permitted in these areas.

2.4.3 Zoning
The site is zoned as an Industrial General (IG) District. According to the San Leandro Zoning Code, areas zoned as Industrial General Districts are allowed to contain the following uses: accessory uses, other than entertainment events, when in conjunction with a permitted use; adult-oriented business; emergency and non-emergency ambulance services; artists’ studios; automobile parts sales; building materials and services; business services; business and trade schools; catering services; communications facilities; emergency health care; equipment sales; retail financial institutions; general and limited food processing; government offices; health and fitness centers; home improvement and interior decoration; custom, general, limited, and research and development industry; laboratories; maintenance and repair services; marine sales and services; medical supply stores; nurseries; offices, business and professional; parcel processing and shipping centers; pre-existing residential uses; big box retail sales; telecommunications, architecturallyintegrated antennas and/or co-locations on existing tower structures; minor utilities; new vehicle/heavy equipment dealers; and storage and wholesale/retail distribution warehouse that utilizes the existing building that would not be expanded 10,000 square feet or more.

Project Description
Environmental Impact Report 2-5
Figure 2-3 Existing Site Conditions: Representative Photographs Existing driveway connection between Doolittle Drive and the project site. The view in this photograph is northeast, toward the project site with Doolittle Drive behind the camera.

Typical existing development on the project site, incuding existing vacant structures, fencing, ashpalt parking and driving surfaces, and signage. The view in this photograph is east toward where the driveway from Doolittle Drive crosses into the project site.

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Figure 2-3 Existing Site Conditions: Representative Photographs (Continued) Typical existing development on the project site, incuding existing vacant structures, ashpalt parking and driving surfaces, and ruderal vegetation. The view in this photograph is southwest facing existing buildings with the camera positioned in the northern area of ths site.

Typical existing development on the project site, incuding existing vacant structures, overhead utilities, ashpalt parking and driving surfaces, and tractor trailers. The view in this photograph is south facing existing buildings with the camera positioned in the northern area of ths site.

Project Description
Environmental Impact Report 2-7
Figure 2-3 Existing Site Conditions: Representative Photographs (Continued) Typical existing developmen ton the project site, incuding an existing vacant structure, fencing, ashpalt parking and driving surfaces, as well as off-site railroad tracks along the southern site boundary. The view in this photograph is east.

The terminus of Hester Street and the existing driveway connection between Hester Street and the project site. Existing development on the project site is visible in the background. The view in this photograph is southeast toward the project site.

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2.4.4 Surrounding Land Uses
The project is located on an infill site that is largely surrounded by industrial and commercial uses.

Land adjacent to the northern boundary of the project site is developed with a mix of commercial and industrial land uses, including but not limited to, tool vendors, screen printing shops, machine shops, and sign shops. Carden Street separates the project site from land uses to the east, which are comprised of trucking businesses, a landscape company, metal supplier, and other commercial/industrial businesses.

The site is approximately 2.5 miles east of the San Francisco Bay, 5.8 miles northwest of San Lorenzo Creek, and 2.5 miles west of San Leandro Creek. The San Francisco Bay shoreline is approximately 3,000 feet southwest of the project site. The freight and corporate aircraft runways at Oakland International Airport are approximately 4,050 feet northwest of the project site.

2.5 Project Description
The proposed project consists of consolidating the two parcels comprising the project site into a single parcel, demolishing existing vacant structures, and developing a new industrial shell building on the site. There is no specific known land use and/or tenant proposed at this time, and the shell building would be designed to accommodate a future industrial tenant who may perform interior improvements to accommodate their specific needs. The proposed project also includes a new surface parking lot, internal circulation roadways, new utility connections, and landscaping, including landscaped areas that would serve as stormwater management. The major components of the proposed project are described in subsections below.

2.5.1 Property Consolidation and Demolition
The project site comprises two separate parcels, identified as APNs 77A-0741-004-02 and 77A-0741- 005-00. The proposed project includes merging these two parcels into a single parcel. The new parcel would measure approximately 14.14 acres.

Site preparation activities would commence with demolition of the two existing vacant structures on site, as well as all associated surface parking, landscaping, and internal circulation and driveways on the site. Existing utility connections would be completely removed or abandoned in place in accordance with local and state regulations, in coordination with utility providers. Demolition materials, such as solid waste from the existing structures and asphalt pavement, would be disposed of at permitted or licensed facilities in accordance with local and state regulations. Demolition would last approximately 2 months.

2.5.2 Industrial Development
After approximately 6 months following demolition of existing structures, the proposed project would include construction of a new warehouse with supporting office space. The proposed building is approximately 244,573 square feet, comprised of a 229,573 square-foot of warehouse and 15,000 square feet of associated office space. Approximately 10,000 square feet of office space would be provided on the ground floor alongside the warehouse use. The remaining 5,000 square feet of office space would be on a mezzanine level of the warehouse. The footprint of the warehouse and office use would be 239,753 square feet. The proposed warehouse would be positioned within the project site to comply with the City’s minimum frontage setback requirement of 10 feet. The proposed floor area ratio (FAR) is 0.40 and the maximum building height would be 50 feet with an Project Description
Environmental Impact Report 2-9
interior clear height of 40 feet. Figure 2-4, which is a conceptual site plan, shows the location of the proposed warehouse on the project site.

As shown on Figure 2-4, sixty-four loading docks are proposed, 27 on the north side and 37 on the south side of the building. In addition to dock doors, traditional doors for egress and ingress to the building would be provided for each of the two office spaces within the proposed warehouse.

Traditional doors would be provided on the north side of the building and south side of the building, next to dock doors.

The exterior of the proposed warehouse would be constructed of a mix of materials, including concrete panels, corrugated and noncorrugated metal panels, wood finish/trim, and glazing. Glazing refers to the glass installed in the building such as windows. Glazing would be a mix of insulated glass installed over concrete and other materials, and glass installed over openings to serve as traditional windows. Generally, given the proposed warehouse use, exterior windows would be limited to the office use areas of the buildings. Figure 2-5 shows conceptual elevations of the proposed building, including identifying the various exterior finishes and glazing that would be used.

Conceptual renderings of the project are shown on Figure 2-6.

At the time of publishing of this EIR, a tenant has not been identified for the proposed building.

However, operational hours and activities would be typical of a warehouse land use. The building would be constructed for a speculative tenant or tenants; the project is intended for occupancy by uses consistent with the site’s General Industrial General Plan land use designation, as well as those uses permitted under the site’s Industrial General zoning classification. Based on employee generation rates published by the U.S. Green Building Council (2023), the proposed project would employ approximately 152 full-time employees.1

2.5.3 Circulation/Access and Parking
Access to the project site would be from the driveway on Doolittle Drive in the southwest area of the site, and from the end of Hester Street in the northern area of the site, as shown on Figure 2-4.

Although these are both existing driveways, the proposed project would include reconstruction of the driveways to meet City standards and current ADA requirements. This would involve repairs as needed of the driveway from Doolittle Drive. New curb cut would be provided at the cul-de-sac on Hester Street, which would also include reconstructing (i.e., replacement of) portions of the sidewalk along the project site frontage on Hester Street. Additionally, a new, second, driveway to the site would be constructed at the end of Hester Street, providing a total of three driveways.

The proposed driveways would lead to internal access and circulation roads that encircle the proposed warehouse as well as surface parking areas that would be provided on the west and north sides of the warehouse. The internal circulation roads are designed to comply with standards for passenger vehicles, tractor-trailers, and emergency equipment like fire engines and ambulances.

The internal circulation road would be wide enough to allow tractor trailers to maneuver in reverse into loading docks on the north and south side of the warehouse, as shown on Figure 2-4. 1 (229,573 square foot warehouse distribution use/2,500 square foot per employee) + (15,000 square foot office use/250 square foot per employee) = 152 employees (US Green Building Council 2023). Numbers may not add up due to rounding.

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Figure 2-4 Conceptual Site Plan
Project Description
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Figure 2-5 Conceptual Building Elevations
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Figure 2-6 Conceptual Rendering of Project
Project Description
Environmental Impact Report 2-13
The proposed project would include two main surface parking areas. The lot on the west side of the building would consist primarily of parking spaces for passenger vehicles. A total of 204 parking spaces would be provided for passenger vehicles, consisting of the following:
 116 standard parking spaces (9 feet by 18.5 feet)
 57 spaces for compact cars (8 feet by 16 feet)
 3 standard accessible spaces
 3 standard accessible van space
 4 clean air spaces
 21 electric vehicle spaces
The other main surface parking area would be on the north side of the warehouse, as shown on Figure 2-4. This parking area would consist of 59 spaces sized for tractor trailers. Tractor trailer parking spaces would be 10 feet by 53 feet each.

In addition to vehicle parking, the proposed project would also provide on-site bicycle parking. A total of 24 bicycle parking spaces would be provided in the vicinity of the office main entrance, including 12 short-term spaces and 12 long-term spaces.

2.5.4 Landscaping
Approximately 41,592 square feet of landscaping would be provided throughout the site including along the perimeter of the site to provide screening and a buffer between adjoining properties and land uses as well as in parking islands. No landscaping is proposed on the east side of the warehouse, which faces Carden Street and other commercial and industrial land uses. Instead, the project would include rock mulch at the eastern project site boundary. Where landscaping is installed, it would consist mostly of shrubs, providing either visual accents or screening, depending on planting density. Landscaping would also include new trees. New trees would be planted amongst shrubs along much of the site boundary, but also in landscaped parking islands within the surface parking area designed for passenger vehicles. Trees would also be planted around the proposed driveways on Hester Street, near the surface parking area designed for trailers. Trees would be a mix of conifers and deciduous species. Landscaping shrubs and trees would consist of species native to California. The proposed project would comply with water efficient landscape and would include the planting of species that would be appropriate for the local climate and contribute to conserving outdoor water use.

The project would also include bioswale areas to treat stormwater runoff. The bioswales would be planted with a mix of native grasses, low shrubs, and sod. These bioswale areas are described in more detail below in the Utilities section of this project description.

2.5.5 Utilities
Potable water service for the project would be provided by the East Bay Municipal Utility District (EBMUD), the City of San Leandro potable water service provider. A new water connection would be constructed on site and connect to an existing water main that is beneath the surface of the existing driveway at Doolittle Drive. Generally, the new water connection would be located beneath the new surface parking area on the west side of the proposed warehouse, as shown on Figure 2-7. A new fire hydrant pipeline would also connect to the existing water main in the project area in accordance with City code and requirements.

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Sanitary sewer service for the project would be provided by the City’s Sewer Department. Similar to the water line, a new sanitary sewer line would connect the proposed warehouse and an existing sanitary sewer main through the driveway on Doolittle Drive, as shown on Figure 2-7.

Stormwater runoff would be treated on site to meet the current Alameda County C.3 stormwater regulations before being discharged to the existing storm drain system. On-site treatment would occur with a series of bioswales, as shown on Figure 2-7. The bioswales are designed to capture and slow/pool runoff from impervious surfaces, functioning as bioretention areas. The bioswales would include approximately 18 inches of biotreatment soils and an underlying approximately 12 inches of permeable gravels. The bioswales will be vegetated with a native bioretention grass. Runoff collects and infiltrates the biotreatment soil, reducing the volume of runoff discharged into the storm drain system. Slowing the velocity of runoff by directing it into bioswales also allows solids to settle out before the runoff is discharged into the storm drain system. After entering on-site bioswales, treated runoff that infiltrates the soil would enter storm drain inlets installed in each bioswale. As shown on Figure 2-7, the inlets would connect to a storm drain pipeline installed beneath new surface parking areas and connect to an existing storm drain through the Doolittle Drive driveway.

Electricity and natural gas service at the project site would be provided by Pacific Gas & Electric, which provides services to the project area.

2.5.6 Construction and Grading
The timing of project construction would be determined by market forces and other considerations, such as weather or availability of workforce. However, for purposes of this analysis it is anticipated that construction would begin in 2024 with demolition of existing vacant structures and related infrastructure, such as utilities and surface parking.

Site grading would occur following demolition of the existing development on the project site, which totals approximately 212,000 square feet of structures. The site is relatively level, which minimizes the amount of grading included in the proposed project. Generally, grading would be designed to slope in a west-southwest direction across the site, which would allow stormwater runoff to flow into bioswale areas and then continue into the City’s storm drain system using gravity rather than mechanical forces. Elevations on the project site following grading would vary between approximately 10 feet and 17 feet above mean sea level. Preliminary grading design shows a balanced site The conceptual grading plan for the proposed project is shown on Figure 2-8.

Project construction would commence following grading. Construction would include excavation and trenching to install buried utility connections, such as new water, sanitary sewer, and storm drain laterals. The foundation of the warehouse would be poured followed by framing and construction of the walls, interior spaces, and exterior. Paving of surface parking areas, driveways, and internal access roads would also occur during project construction, as well as construction of new sidewalk on site frontage along Hester Street. Additionally, repaving of a small off-site area between the existing off-site railroad tracks and the project site would be conducted. Following construction, new landscaping would be planted or installed. Assuming construction of the project is continuous, construction would occur over approximately 18 months, with 6 of those months being a period of inactivity following demolition that is associated with construction contracting.

Construction staging would occur on-site. A variety of typical construction equipment would be used, such as backhoes, dump trucks, excavators, pavers, and dozers. A crawler crane with a boom height of up to approximately 161 feet would also be required. During construction, up to five existing trees just off the project site at the terminus of Hester Street would be removed.

Project Description
Environmental Impact Report 2-15
Figure 2-7 Preliminary Utility Plan
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Figure 2-8 Conceptual Grading Plan
Project Description
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2.6 Project Objectives
CEQA Guidelines Section 15124(b) requires an EIR to include a statement of objectives sought by the project. The objectives assist the City, as the lead agency, in developing a reasonable range of alternatives to be evaluated in the EIR. The project objectives also aid decision-makers in preparing findings or, if necessary, a statement of overriding considerations. The statement of objectives also includes the underlying purpose of the Project and the Project benefits.

The underlying purpose of the proposed project is to provide a modern industrial warehouse with ancillary office using sustainable and environmentally superior practices within the existing industrialized portion of the City. The proposed project would accommodate the need for additional large warehouse uses in the City and in Alameda County, while enhancing the economic vitality of the City.

2.7 Lead, Responsible, and Trustee Agencies
The CEQA Guidelines define lead, responsible, and trustee agencies. The City of San Leandro is the lead agency for the project because it holds principal responsibility for approving the project.

A responsible agency refers to a public agency other than the lead agency that has discretionary approval over the project. The project site is approximately 4,050 feet away from the nearest runways at Oakland International Airport. Due to this proximity, pursuant to Federal Aviation Regulations Part 77, a No Hazard Determination for the warehouse was issued from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77, because the proposed warehouse would have a maximum height of 50 feet, exceeding the 43 feet maximum permitted at this distance from the airport runway. The applicant submitted the project to the FAA, who determined that a building height of 50 feet does not present a hazard to air navigation. An additional No Hazard Determination may also be needed for the use of project construction equipment exceeding 43 feet in height.

Several mitigation measures discussed in Section 4.2, Hazards and Hazardous Materials, of this EIR require either approval or oversight from the California Department of Toxic Substances Control (DTSC). For this reason, DTSC is identified as a responsible agency.

A trustee agency refers to a state agency having jurisdiction by law over natural resources affected by a project. There are no trustee agencies for the proposed project.

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2.8 Required Approvals
The following permits and approvals are required from the City of San Leandro prior to the construction of the proposed project:
 Use Permit
 Site Plan Review
 Height Exception
 Building Permit
 Grading Permit
 Tree Removal Permit
Environmental Setting
Environmental Impact Report 3-1
3 Environmental Setting
This section provides a general overview of the environmental setting for the proposed project.

More detailed descriptions of the environmental setting for each environmental issue area can be found in Section 4, Environmental Impact Analysis.

3.1 Regional Setting
The project site is in the City of San Leandro, which is part of the greater San Francisco Bay Area in northern California. The San Francisco Bay Area is an urbanized region composed of numerous cities and counties that have a combined population of approximately 7.5 million people and encompass almost 7,000 square miles (California Department of Finance 2023). The climate varies within the San Francisco Bay Area, but the region is generally known to have a coastal Mediterranean climate with cool, wet winters and mild to hot, dry summers. Although air quality in the area has steadily improved in recent years, several counties in the San Francisco Bay Area Region remain nonattainment areas for ozone (urban smog).

San Leandro is located along the eastern side of the bay and is approximately 17 miles inland of Pacific Ocean coastline. Incorporated in 1872, San Leandro was primarily an agricultural city until World War II, when the city experienced rapid population growth. The city’s population doubled between 1940 and 1950 and doubled again between 1950 and 1960. San Leandro shifted to manufacturing and commercial sectors, and by the late 1960s, the city was almost completely built out. Infill development has continued to expand San Leandro’s commercial and residential growth (City of San Leandro 2020). The city borders the San Francisco Bay to the west and extends approximately 4 miles inland. To the north of the city are the cities of Alameda and Oakland, and to the south are the cities of Hayward and Fremont. Major roadways in the city include San Leandro Boulevard, Marina Boulevard, and Washington Avenue. Freeways that pass through the City include Interstate 880 (I-880), Interstate 580 (I-580), and State Route 185 (SR 185). I-880 is approximately

0.3 mile east of the project site, and I-580 is approximately 2.7 miles east. Figure 2-1 in Section 2, Project Description, shows the location of the project site in the region.

3.2 Project Site Setting
As shown in Figure 2-2 in Section 2, Project Description, the project site is bordered by industrial and commercial development to the north, including but not limited to, tool vendors, screen printing shops, machine shops, and sign shops. Carden Street separates the project site from land uses to the east, which are comprised of trucking businesses, a landscape company, metal supplier, and other commercial/industrial businesses. Industrial and commercial development also occurs to the south of the project site, as well as to the west. The freight and corporate aircraft runways at Oakland International Airport are approximately 4,050 feet northwest of the project site. There are inactive railroad tracks adjacent to the south and west of the site, and there is an active railroad corridor approximately 400 feet east of the project site. The San Francisco Bay shoreline is approximately 3,000 feet southwest of the project site. The site is approximately 2.5 miles east of the San Francisco Bay, 5.8 miles northwest of San Lorenzo Creek, and 2.5 miles west of San Leandro Creek.

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The project site is nearly flat and currently occupied by two vacant industrial masonry buildings and has a General Plan land use designation of General Industrial. The site is zoned Industrial General District, as defined by the City’s Zoning Ordinance. Uses permitted in the Industrial General designation include a wide range of manufacturing, transportation, food and beverage processing, technology, warehousing, vehicle storage, office-flex, and distribution uses. A limited range of commercial uses are also permitted in areas designated Industrial General.

3.3 Cumulative Development
In addition to the specific impacts of individual projects, the California Environmental Quality Act (CEQA) requires Environmental Impact Reports (EIRs) to consider potential cumulative impacts of the proposed project. The CEQA Guidelines define “cumulative impacts” as two or more individual impacts that, when considered together, are substantial or will compound other environmental impacts (CEQA Guidelines Sections 15065 and 15355). Cumulative impacts are the combined changes in the environment that result from the incremental impact of development of the proposed project and other nearby past, pending, and planned projects. For example, noise impacts of two nearby projects may be less than significant when analyzed separately but could have a significant impact when analyzed together. Cumulative impact analysis allows the EIR to provide a reasonable forecast of future environmental conditions and can more accurately gauge the effects of a series of projects. Consistent with CEQA Guidelines Section 15130, the discussion in this EIR focuses on the identification of any significant cumulative impacts and, where present, the extent to which the proposed project would constitute a considerable contribution to the cumulative impact.

CEQA requires cumulative impact analysis in EIRs to consider either a list of past, planned and pending projects that may contribute to cumulative effects or a forecast of future development potential. Past projects include those land uses that have been previously developed and comprise the existing environment. Pending projects include those projects recently approved or under construction. Planned projects are those that are reasonably foreseeable, such as those for which an application is on file and in process with a local planning department. Past, currently planned and pending projects in San Leandro are listed in Table 3-1. In particular, the projects are either located in proximity or along the same major arterial and collector roads as the project site and construction schedules may overlap. These projects are considered in the cumulative analyses in Section 4.0, Environmental Impact Analysis.

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Table 3-1 Cumulative Projects List
Project No. Project Location1 Land Use
1 1345 Doolittle Drive Industrial- 264,000 square-foot industrial spec. building 2 1091 Doolittle Drive Light Industrial – expansion of a heavy processing facility 3 100 & 200 Halcyon Drive Commercial
4 2806 Marina Boulevard Apartments – 3-story building with 6 units 5 1815 Williams Street Commercial – 2-story multi-tenant industrial building 6 1411 Bancroft Avenue Medical – reuse of a 3,457 square-foot building providing 15 medical beds
7 601 Aladdin Avenue Light Industrial – waste/bulky item hauling 8 14341 Bancroft Avenue Apartments – 20 units
9 1700 Doolittle Drive Industrial – 79,840 square-foot industrial spec. building 10 14143 Washington Avenue Industrial – 52,269 square-foot warehouse 11 Monarch Bay Shoreline Mixed-Use
12 2599 Fairway Drive Residential – 144 single-family dwellings and 62 townhomes 13 1800 Williams Street Industrial – 9,306 square-foot building 14 13489 East 14th Street Residential – 9 townhouses
15 1199 East 14th Street Apartments – 180-unit multi-family building 16 1965 Marina Boulevard Commercial – small-scale fast-food 17 1919 Williams Street Industrial – demolition of an existing warehouse and construction of a new warehouse
18 15101 Washington Avenue Apartments – 72-unit multi-family building 1 Cumulative project details were obtained from the City of San Leandro in 2024 City of San Leandro
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Environmental Impact Analysis
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4 Environmental Impact Analysis
This section discusses the possible environmental effects of the project for the specific issue areas that were identified through the scoping process as having the potential to cause significant effects on the environment. A “significant effect on the environment” as defined by the CEQA Guidelines Section 15382:
means a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. An economic or social change by itself shall not be considered a significant effect on the environment. A social or economic change related to a physical change may be considered in determining whether the physical change is significant.

This document is an EIR in that it evaluates potential impacts on a limited number of environmental issue areas that the lead agency determined to be significant (CEQA Guidelines Sections 15006(d), 15063(c)(3)). After preparation of the Initial Study Checklist (see Appendix A), the City of San Leandro determined that the EIR would focus on the potentially significant impacts of the proposed project on the following environmental topics or resources:
 Greenhouse Gas Emissions
 Hazards and Hazardous Materials
 Noise
 Transportation
The assessment of each issue area begins with a discussion of the environmental setting related to the issue, which is followed by the regulatory framework, and the impact analysis. In the impact analysis, the first subsection identifies the methodologies used and the “significance thresholds,” which are those criteria adopted by the City and other agencies, widely recognized, or developed specifically for this analysis to determine whether potential effects are significant. The next subsection describes each impact of the proposed project, mitigation measures for significant impacts, and the level of significance after mitigation measures are incorporated into or by the project. "Mitigation Measures" are measures that would be required of the project to avoid a significant adverse impact; to minimize a significant adverse impact; to rectify a significant adverse impact by restoration; to reduce or eliminate a significant adverse impact over time by preservation and maintenance operations; or to compensate for the impact by replacing or providing substitute resources or environment. Each effect under consideration for an issue area is separately listed in bold text with the discussion of the effect and its significance. Each bolded impact statement also contains a statement of the significance determination for the environmental impact as follows:
 Significant and Unavoidable. An impact that cannot be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires findings under CEQA Guidelines Section 15091 and a Statement of Overriding Considerations to be issued if the project is approved per CEQA Guidelines Section 15093.  Less than Significant with Mitigation Incorporated. An impact that can be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires findings under CEQA Guidelines Section 15091.

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 Less than Significant. An impact that may be adverse but does not exceed the threshold levels and does not require mitigation measures. However, mitigation measures that could further lessen the environmental effect may be suggested if readily available and easily achievable.  No Impact. The proposed project would have no effect on environmental conditions or would reduce existing environmental problems or hazards.

Following each environmental impact discussion is a list of mitigation measures (if required) and the residual effects or level of significance remaining after implementation of the measure(s). In cases where the mitigation measure for an impact could have a significant environmental impact in another issue area, this impact is discussed and evaluated as a secondary impact. The impact analysis concludes with a discussion of cumulative effects, which evaluates the impacts associated with the proposed project in conjunction with other planned and pending developments in the area listed in Section 3.0, Environmental Setting.

The Executive Summary of this EIR summarizes all impacts and mitigation measures that apply to the proposed project, including mitigation measures identified in the Initial Study (Appendix A).

Environmental Impact Analysis
Greenhouse Gas Emissions
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4.1 Greenhouse Gas Emissions
This section of the EIR analyzes greenhouse gas (GHG) emissions associated with the proposed project and potential impacts related to climate change. This section describes regional GHG emission sources and inventories, the regulatory framework applicable to GHG emissions, and evaluates potential project impacts related to GHG emissions as a result of project construction and operation.

4.1.1 Setting
a. Overview of Climate Change and Greenhouse Gases
Climate change is the observed increase in the average temperature of the Earth’s atmosphere and oceans along with other substantial changes in climate (such as wind patterns, precipitation, and storms) over an extended period of time. Climate change is the result of numerous, cumulative sources of GHG emissions contributing to the “greenhouse effect,” a natural occurrence which takes place in Earth’s atmosphere and helps regulate the temperature of the planet. Most of the radiation from the sun hits Earth’s surface and warms it. The surface, in turn, radiates heat back towards the atmosphere in the form of infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping into space and re-radiate it in all directions.

GHG emissions occur both naturally and from human activities, such as fossil fuel burning, decomposition of landfill wastes, raising livestock, deforestation, and some agricultural practices.

GHGs produced by human activities include carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride. Different types of GHGs have varying global warming potentials (GWP). The GWP of a GHG is the potential of a gas or aerosol to trap heat in the atmosphere over a specified timescale (generally, 100 years). Because GHGs absorb different amounts of heat, a common reference gas (CO2) is used to relate the amount of heat absorbed to the amount of the gas emitted, referred to as “carbon dioxide equivalent” (CO2e), which is the amount of GHG emitted multiplied by its GWP. Carbon dioxide has a 100-year GWP of one. By contrast, methane has a GWP of 30, meaning its global warming effect is 30 times greater than CO2 on a molecule per molecule basis (Intergovernmental Panel on Climate Change [IPCC] 2022).1
b. Greenhouse Gas Emissions Inventories
Based upon the California Air Resources Board (CARB) California Greenhouse Gas Inventory for 2000-2021, California produced 381.3 million metric tons (MMT) of CO2e in 2021 (CARB 2023).

Transportation is the major source of GHG in California, contributing 39 percent of the state’s total GHG emissions. Industrial operations are the second largest source, contributing 22 percent of the state’s GHG emissions. Specifically, emissions from the electricity sector continue to decline due to growing zero-GHG energy generation sources, dominated by solar (CARB 2023).

The City of San Leandro conducted a citywide GHG emissions inventory while preparing its current Climate Action Plan, which was approved in July 2021 (City of San Leandro 2021). Emissions 1 The Intergovernmental Panel on Climate Change’s (2022) Sixth Assessment Report determined that methane has a GWP of 30. However, the 2017 Climate Change Scoping Plan published by the California Air Resources Board uses a GWP of 25 for methane, consistent with the Intergovernmental Panel on Climate Change’s (2007) Fourth Assessment Report. Therefore, this analysis utilizes a GWP of 25.

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inventories were prepared for 2005, 2010, 2015, and 2017. Table 4.1-1 shows the change in GHG emissions from 2005 to 2017, and the activity data by subsector for the four inventory years.

Table 4.1-1 San Leandro Annual GHG Emissions, Metric Tons Sector 2005 CO2e 2010 CO2e 2015 CO2e 2017 CO2e
Transportation 363,550 372,220 353,130 344,290
Non-residential energy 182,950 146,600 96,490 88,620
Residential energy 101,760 100,650 83,830 73,320
Waste 46,910 40,080 38,880 34,860
Off-road 23,190 22,860 30,940 26,970
BART 2,920 3,030 3,720 3,710
Water and wastewater - 2,410 2,470 1,820
Total 720,990 687,860 609,460 573,580
Source: City of San Leandro 2021 Climate Action Plan (2021) In 2017, transportation remained the largest source of GHG emissions, accounting for approximately 60 percent of the city’s total. Nonresidential energy was the second-largest source of GHG emissions, equaling approximately 15 percent of the community total, followed by residential energy at 13 percent (City of San Leandro 2021).
c. Potential Effects of Climate Change
Potential impacts of climate change in California may include sea level rise, loss of water supply and snowpack, more and larger forest fires, damage to agriculture, public health impacts, and habitat destruction (Office of the Attorney General [OAG] 2018). These potential impacts are also anticipated and have been observed in the Bay Area.

The most relevant effects of climate change to the project site are those that could result in potential damage to the structure or its occupants, including severe storms or water shortages during drought conditions.

Climate change makes open space areas and the built environment at the edge of natural areas more vulnerable to fires by increasing temperatures and making forests and brush drier. Potential increases in the severity and frequency of drought would exacerbate the risk of wildfire. The fire season in California has begun to start earlier, last longer, and be more intense than in the last several decades. Wildfire occurrence statewide could increase several fold by the end of the century, increasing fire suppression and emergency response costs and damage to property (OAG 2018).

The project site is not adjacent to wildland fuels, such as forest, chaparral, or annual grasslands. The project site is developed and surrounded by urban and built-up lands and does not contain wildland fuels, such as forest or grassland. However, the smoke from wildland fires in other areas of the Bay Area, as well as other areas of the State could impact the health of potential occupants of the proposed building.

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4.1.2 Regulatory Setting
a. Federal Regulations
The federal government has taken regulatory steps toward addressing climate change. Generally, California policy and regulations and regulations implemented at the regional and local levels are as or more comprehensive and stringent than federal actions; therefore, this section focuses on state, regional, and local regulatory actions whose implementation would lessen the contribution of the proposed project to GHG emissions and associated climate change. b. State Regulations
Assembly Bill 32
Assembly Bill 32, the California Global Warming Solutions Act (Health and Safety Code Section 38500 et seq.),established a statewide GHG emissions cap for 2020, adopted mandatory reporting rules for substantial sources of GHGs, and adopted a comprehensive plan, known as the Climate Change Scoping Plan, identifying how emissions reductions would be achieved from significant GHG sources.

Effective January 1, 2017, SB 32 amended the California Global Warming Solutions Act. SB 32, and accompanying Executive Order B-30-15, requires CARB to ensure that statewide GHG emissions are reduced 40 percent below the 1990 level by 2030.

On November 30, 2017, CARB released its 2017 Climate Change Scoping Plan (2017 Scoping Plan), which lays out the framework for achieving the 2030 reductions as established in SB 32 (and other regulations). The 2017 Scoping Plan identifies the GHG reductions needed by emissions sector to achieve a Statewide emissions level that is 40 percent below 1990 levels before 2030. Many of the programs require Statewide action, promulgated through regulation, and are outside the ability of substate jurisdictions to implement on their own accord. This is important to recognize in terms of GHG emissions efficiency and attaining GHG targets. The ability to attain targets will rely not only on transportation strategies (e.g., the SCS) but also on land use strategies implemented by local cities and counties (e.g., qualified GHG reduction plans) and controls and actions tied to economy-wide changes promulgated by the State.

California Renewables Portfolio Standard
In 2015, the Legislature enacted Senate Bill 350, which embodies a policy encouraging a substantial increase in the use of electric vehicles and increased the Renewable Portfolio Standard to require 50 percent of electricity generated to be from renewables by 2030.

On September 10, 2018, former Governor Brown signed into law SB 100 and Executive Order B55-

18. SB 100 raises California’s Renewable Portfolio Standard requirement to 50 percent renewable resources target by December 31, 2026, and to achieve a 60 percent target by December 31, 2030.

SB 100 also requires that retail sellers and local publicly owned electric utilities procure a minimum quantity of electricity products from eligible renewable energy resources so that the total kilowatt hours of those products sold to their retail end-use customers achieve 44 percent of retail sales by December 31, 2024, 52 percent by December 31, 2027, and 60 percent by December 31, 2030.

Executive Order B-55-18 establishes a carbon neutrality goal for California by 2045; and sets a goal to maintain net negative emissions thereafter.

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Assembly Bill 1493, Pavley Clean Car Standards
In July 2002, the Legislature enacted AB 1493 (Pavley Bill), which requires the maximum feasible reduction of GHGs emitted by passenger vehicles and light-duty trucks beginning with model year 2009. In September 2009, CARB adopted amendments to the Pavley standards to reduce GHG emissions from new motor vehicles through the 2016 model year. These regulations created what are commonly known as the “Pavley II standards.”
Advanced Clean Cars
In January 2012, CARB adopted an Advanced Clean Cars program aimed at reducing both smogcausing pollutants and GHG emissions for vehicles model years 2017-2025. The regulations focus on substantially increasing the number of plug-in hybrid cars and zero-emission vehicles in the vehicle fleet and on making fuels such as electricity and hydrogen readily available for these vehicle technologies. It is expected that the Advanced Clean Car regulations will reduce GHG emissions from California passenger vehicles by about 34 percent below 2016 levels by 2025, all while improving fuel efficiency and reducing motorists’ costs.

Senate Bill 375, Sustainable Communities Strategy
Senate Bill 375, signed in August 2008, requires sustainable community strategies to be included in regional transportation plans to reduce emissions of GHGs. The San Francisco Bay Metropolitan Transportation Commission and the Association of Bay Area Governments jointly approve and prepare Plan Bay Area, which includes the San Francisco Bay region’s Sustainable Communities Strategy and Regional Transportation Plan. The most current version is Plan Bay Area 2050. Plan Bay Area 2050 includes a target to reduce GHG emissions by 10 percent per capita by 2020 and by 19 percent per capita by 2035.

California Energy Code
The California Energy Code (California Code of Regulations, Title 24, Part 6), which is incorporated into the California Building Standards Code, was first established in 1978 in response to a legislative mandate to reduce California's energy consumption. The California Energy Code is updated every three years by the California Energy Commission to allow consideration and possible incorporation of new energy efficiency technologies and construction methods. The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Buildings whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 Energy Code.

California Green Buildings Standards Code
The purpose of the California Green Building Standards, which became effective on January 1, 2011, is to improve building design and construction to reduce negative environmental impacts through sustainable construction practices. The 2019 California Green Building Standards instituted mandatory and voluntary environmental performance standards for all ground-up new construction of commercial, low-rise residential uses, and state-owned buildings, as well as schools and hospitals.

Jurisdictions could opt to adopt Tier 1 or Tier 2 standards, which are stricter than the mandatory standards, that would apply to new construction. The most current version, the 2022 California Green Building Standards, requires that most new homes and buildings statewide will either need to Environmental Impact Analysis
Greenhouse Gas Emissions
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be equipped with at least one highly efficient heat pump for either space heating or water heating, or face higher energy efficiency requirements. The 2022 California Green Building Standards also provides more standards for electric vehicles and infrastructure. c. Local Regulations
Bay Area Air Quality Management District 2017 Clean Air Plan The Bay Area Air Quality Management District (BAAQMD) adopted its 2017 Clean Air Plan to define a vision for achieving ambitious GHG reduction targets for 2030 and 2050, and to provide a regional climate protection strategy that will put the Bay Area on a pathway to achieve those GHG reduction targets (BAAQMD 2017). There are 85 control measures designed to decrease emissions of air pollutants and GHGs in the Clean Air Plan. The control measures that address GHG emissions and that are applicable to the project include TR1: Clean Air Teleworking Initiative; TR 2: Trip Reduction Programs; TR19: Medium and Heavy-Duty Trucks; TR 22: Construction, Freight, and Farming Equipment; BL1: Green Buildings; BL2: Decarbonize Buildings; BL4: Urban Heat Island Mitigation; and SL1: Short-Lived Climate Pollutants.

Bay Area Air Quality Management District CEQA Guidelines On April 20, 2022, the BAAQMD Board of Directors adopted CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. The purpose of the BAAQMD CEQA Guidelines is to assist lead agencies in evaluating air quality and climate impacts from proposed land use projects and plans in the San Francisco Bay Area Air Basin. The Guidelines include nonbinding recommendations for how a lead agency can evaluate, measure, and mitigate air quality and climate impacts generated from land use construction and operational activities. The Guidelines do not replace the State CEQA Statute and Guidelines; rather, they are designed to provide BAAQMD-recommended procedures for evaluating potential air quality and climate impacts during the environmental review process that are consistent with CEQA requirements.

City of San Leandro 2035 General Plan
The City of San Leandro’s 2035 General Plan, adopted in September 2016, lists several GHGreduction goals, policies, and actions as part of the Transportation Element and Open Space, Parks, and Conservation Element that support the goal of reducing GHG emissions. The following goals and policies are applicable to the proposed project (City of San Leandro 2016):

Policy T-5.2 Evaluating Development Impacts: Use vehicle miles traveled (VMT) as the primary metric for evaluating the transportation impacts of new development proposals. Traffic impact studies may also consider the total number of trips generated and the resulting impact on traffic volumes and congestion (e.g., “Level of Service”), but VMT shall provide the primary basis for determining appropriate mitigation measures.

Goal OSC-7: Promote recycling, water conservation, green building, and other programs which reduce greenhouse gas emissions and create a more sustainable environment.

Policy OSC-7.8 Green Building: Promote green building in new construction and remodels.

Goal OSC-8: Promote the efficient use of energy and the increased use of renewable energy by San Leandro residents and businesses.

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Policy OSC-8.1 Conservation and Energy Efficiency: Strongly advocate for increased energy conservation by San Leandro residents and businesses, and ensure that the City itself is a conservation role model.

Policy OSC-8.2 Planning and Building Practices: Encourage construction, landscaping, and site planning practices that minimize heating and cooling costs and ensure that energy is efficiently used. Local building codes and other City regulations and procedures should meet or exceed state and federal standards for energy conservation and efficiency, and support the City’s greenhouse gas reduction goals.

City of San Leandro Municipal Code
Section 3.24.400 of the SLMC requires commercial business organic waste generators and multifamily dwelling units to participate in organic waste collection services. These uses must subscribe to collection services for compost containers, recycling containers, and landfill containers.

Section 7.5.600 of the SLMC requires compliance with Tier 1 of the California Green Building Code, Title 24, Part 11, which details requirements for energy conservation and green design. Section

7.5.700 of the SLMC requires compliance with the California Energy Code, Title 24, Part 6, which details requirements for the use of energy-efficient design and technologies as well as provisions for incorporating renewable energy resources into building design.

San Leandro 2021 Climate Action Plan
The 2021 Climate Action Plan is San Leandro’s comprehensive strategy to reduce GHG emissions and to adapt to changing climate conditions (City of San Leandro 2021). The Climate Action Plan allows City of San Leandro (City) decision-makers, staff, and the community to understand the sources and magnitude of local GHG emissions and the impacts of climate change on the community, reduce GHG emissions, prioritize steps to achieve GHG emission-reduction targets, and increase resilience. The 2021 Climate Action Plan also presents a work plan and monitoring program for the City to track progress toward reducing GHG emissions and achieving targets. The 2021 Climate Action Plan meets the criteria under State CEQA Guidelines Section 15183.5(b), which is often referred to as “Qualified Climate Action Plan.”

4.1.3 Impact Analysis
a. Methodology and Thresholds of Significance
According to CEQA Guidelines Appendix G, impacts related to GHG emissions are considered significant if implementation of the proposed project would:

1. Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or

2. Conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases.

The 2022 BAAQMD CEQA Guidelines document contains two approaches for determining significance of GHGs (BAAQMD 2022). The two approaches are as follows:

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1. Projects must include, at a minimum, the following project design elements:

Buildings
 The project will not include natural gas appliances or natural gas plumbing (in both residential and nonresidential development).
 The project will not result in any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines.

Transportation
 Achieve a reduction in project-generated vehicle miles traveled (VMT) below the regional average consistent with the current version of the California Climate Change Scoping Plan (currently 15 percent) or meet a locally adopted Senate Bill 743 VMT target, reflecting the recommendations provided in the Governor’s Office of Planning and Research's Technical Advisory on Evaluating Transportation Impacts in CEQA:
 Residential projects: 15 percent below the existing VMT per capita  Office projects: 15 percent below the existing VMT per employee  Retail projects: no net increase in existing VMT
 Achieve compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2.

2. Projects must be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).

According to the BAAQMD CEQA Thresholds for Evaluating the Significance of Climate Impacts From Land Use Projects and Plans, a qualified GHG reduction strategy must:
 Quantify GHG emissions, both existing and projected over a specified period, resulting from activities in a defined geographic area
 Establish a level, based on substantial evidence, below which the contribution to GHG emissions from activities covered by the plan would not be cumulatively considerable  Identify and analyze the GHG emissions resulting from specific actions or categories of actions anticipated in the geographic area
 Specify measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level
 Establish a mechanism to monitor the plan's progress toward achieving the level and to require amendment if the plan is not achieving specified levels  Be adopted in a public process following environmental review While the City’s Climate Action Plan meets the requirements specified in criterion 2, the City has determined this analysis will evaluate the project in terms of consistency with the project design elements listed under criterion 1 above. Methodology for determining consistency is based on applicant-provided data, such as site plans, proposed utility plans, and a Transportation Impact Analysis (see Appendix C).

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Threshold 1: Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
IMPACT GHG-1 THE PROPOSED PROJECT WOULD INCLUDE NEW NATURAL GAS CONNECTIONS, WHICH

WOULD HAVE THE POTENTIAL TO CONTRIBUTE TO THE LONG-TERM GENERATION OF GHG EMISSIONS AFFECTING THE ENVIRONMENT. THIS IMPACT WOULD BE SIGNIFICANT AND UNAVOIDABLE.

Project Construction
Project construction would generate GHG emissions from the combustion of fuels used to power construction equipment, such as gasoline and diesel fuel. Construction workers would also use personal vehicles to commute to the project site, resulting in additional GHG emissions. The generation of GHG emissions from project construction activities would be temporary for the duration of construction, which would be approximately 18 months with some periods of inactivity.

Project construction would not conflict with the BAAQMD criterion 1 approach, above, because construction would not involve buildings or permanent substantial increases in VMT or wasteful or excessive energy consumption. Accordingly, construction of the project would not generate GHG emissions that result in significant impacts on the environment.

Project Operation
As noted in Section 2.5.5, Utilities, the proposed project would include new natural gas connections to the proposed building. According to the Bay Area Air Quality Management District, projects that include natural gas appliances or natural gas plumbing should be found to make a significant climate impact because it will hinder California’s efforts to address climate change (Bay Area Air Quality Management District 2022). Although the project would not result in wasteful or inefficient energy use (see Initial Study, Appendix A), because the proposed project would include new natural gas connections (i.e., plumbing), impacts would be significant.

The proposed project would satisfy other parameters of BAAQMD Criterion 1. For example, according to the Transportation Impact Analysis prepared for the project (see Appendix C), VMT generated by the project would be at least 15 percent below the average VMT per employee in the region. Specifically, the project would generate 15.34 VMT per employee in 2020 and 16.08 VMT per employee in 2040. The VMT per employee in the region in 2020, accounting for a 15 percent reduction, would be 16.3, and in 2040 would be 16.2. The project VMT of 15.34 and 16.08 is below the regional average for 2020 and 2040, respectively. The CalGreen Code requires at least 10 percent of the total parking spaces for a new project to be electric-vehicle ready parking spaces.

With the proposed 204 parking spaces, at least 21 electric-vehicle ready parking spaces must be provided to meet CalGeen requirements. A total of 21 electric-vehicle ready parking spaces are proposed, which therefore meets the CalGreen Code requirement. Accordingly, because the project VMT per capita would be at least 15 percent below regional VMT per capita and sufficient electricvehicle ready parking spaces would be provided, the proposed project would satisfy the transportation component of BAAQMD criterion 1.

Because the project would result in a potentially significant GHG emissions impact associated with new natural gas plumbing, implementation of mitigation is required.

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Mitigation Measures
The City is unable to implement mitigation to reduce this significant impact based on a recent court case titled California Restaurant Association v. City of Berkeley. Briefly, in this case, the California Restaurant Association sued Berkeley in the U.S. District Court for the Northern District of California, arguing among other things that the federal Energy Policy and Conservation Act (EPCA) preempted the City’s ordinance banning natural gas in new buildings. The District Court dismissed the California Restaurant Association’s challenge. However, the Ninth Circuit reversed the District Court, holding that EPCA expressly preempts state and local regulations concerning the energy use of many natural gas appliances. The Ninth Circuit concluded that EPCA preempted Berkeley’s ban of natural gas, because it prohibited the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA. Accordingly, based on the decision of the Ninth Circuit in California Restaurant Association v. City of Berkeley, the City of San Leandro cannot require the project applicant to eliminate natural gas from the proposed project. No other mitigation is available to eliminate the use of natural gas in the proposed project. See Section 6, Alternatives, which includes project alternatives that do not include natural gas connections.

Significance After Mitigation
Because there is no feasible mitigation to reduce potentially significant impacts resulting from GHG emissions of the project, impacts would remain significant and unavoidable.

Threshold 2: Would the project conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases? IMPACT GHG-2 THE PROPOSED PROJECT WOULD CONFLICT WITH AN APPLICABLE POLICY OR POLICIES ADOPTED FOR THE PURPOSES OF REDUCING THE EMISSIONS OF GREENHOUSE GASES. THIS IMPACT WOULD BE SIGNIFICANT AND UNAVOIDABLE.

The BAAQMD 2017 Clean Air Plan contains numerous control measures designed to decrease emissions of air pollutants and GHGs in the San Francisco Bay. Some of the control measures are not applicable to the proposed project and are not evaluated further in this document. For example, Control Measure TR-17 encourages increased use of cleaner burning jet fuel in commercial jets arriving and departing the Bay Area, and the proposed project does not include commercial jet operations. Control measures that are applicable to the proposed project and also address GHG emissions include: TR1: Clean Air Teleworking Initiative; TR 2: Trip Reduction Programs; TR19:

Medium and Heavy-Duty Trucks; TR 22: Construction, Freight, and Farming Equipment; BL1: Green Buildings; BL2: Decarbonize Buildings; BL4: Urban Heat Island Mitigation; and SL1: Short-Lived Climate Pollutants. Project consistency with these control measures is evaluated in Table 4.1-2, below. As shown therein, the proposed project would be consistent with most control measures of the BAAQMD 2017 Clean Air Plan. The proposed project would be inconsistent with control measure TR-1, pertaining to telecommuting policies. However, as discussed in Section 4.4, Transportation, of this EIR, the proposed project would generate VMT that is at least 15 percent below average VMT per employee in the area. Therefore, inconsistency with control measure TR-1 would not result in significant environmental impacts. As shown in Table 4.1-2, the proposed project would also be inconsistent with control measure SL-1, which pertains to reducing methane emissions from landfills. As described in Section 19, Utilities and Service Systems, of the Initial Study (Appendix A), project generated waste per day would be less than 0.02 percent of Altamont Landfill’s allowable waste limit and project generated waste annually would be less than 0.0007 percent of Altamont City of San Leandro
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Landfill’s remaining capacity. The project would be required to comply with City and State plans and policies to reduce solid waste generation, including a requirement to divert at least 50 percent of solid waste and recyclables as required by Assembly Bill 939. Therefore, inconsistency with control measure SL-1 would not result in significant environmental impacts.

Table 4.1-2 Project Consistency Analysis with the BAAQMD 2017 Clean Air Plan 2017 Clean Air Plan Control Measure Project Consistency Analysis TR-1: Develop teleworking best practices for employers
and develop additional strategies to promote
telecommuting. Promote teleworking on Spare the Air
Days.

Inconsistent. A tenant for the proposed building has not been identified at this time; therefore, it is unknown if the future tenant(s) would promote telecommuting for their
employees.

TR-2: Implement the regional Commuter Benefits
Program (Rule 14-1) that requires employers with 50 or
more Bay Area employees to provide commuter benefits.

Encourage trip reduction policies and programs in local plans, e.g., general and specific plans while providing grants to support trip reduction efforts. Encourage local governments to require mitigation of vehicle travel as part of new development approval, to adopt transit benefits
ordinances in order to reduce transit costs to employees, and to develop innovative ways to encourage rideshare,
transit, cycling, and walking for work trips. Fund various employer-based trip reduction programs.

Consistent. A tenant for the proposed building has not
been identified at this time; therefore, it is unknown how many employees may work at the site. However, the
Commuter Benefits Program is a BAAQMD rule (Rule 14-
1). Accordingly, if the future tenant is an employer with 50 or more employees, that employer must comply with Rule
14-1.

BL-1: Collaborate with partners such as KyotoUSA to
identify energy-related improvements and opportunities
for onsite renewable energy systems in school districts; investigate funding strategies to implement upgrades.

Identify barriers to effective local implementation of the CALGreen (Title 24) statewide building energy code;
develop solutions to improve
implementation/enforcement. Work with ABAG’s BayREN
program to make additional funding available for energyrelated projects in the buildings sector. Engage with additional partners to target reducing emissions from
specific types of buildings.

Consistent. The proposed project would be constructed
compliant to the version of CALGreen in effect when
construction permits are issued. Because the project
would be constructed to a newer version of CALGreen
than onsite existing buildings, the proposed project would increase the efficiency of potential future operations on the project site.

SL-1: Reduce methane from landfills and farming activities through various control measures listed under waste and agriculture sectors. Develop a rule to reduce methane
emissions from natural gas pipelines and processing
operations and amend regulations to reduce emissions of methane and other organic gases from equipment leaks at oil refineries. Enforce applicable regulations on the
servicing of existing air conditioning units in motor
vehicles, support the adoption of more stringent
regulations by CARB and/or U.S. EPA, and encourage
better HFC disposal practices.

Inconsistent. The proposed project does not include new landfill facilities and would not involve farming activities.

The proposed project would include new natural gas
plumbing, which because it would be new, would not be
corroded and less susceptible to leaks compared to older, existing natural gas infrastructure at the project site.

However, the project would not separate waste, such as
having a compost for organic waste.

Source: BAAQMD 2017 Clean Air Plan (2017)
The City of San Leandro updated and approved its Climate Action Plan in July 2021, which outlines strategies for reducing GHG emissions through various activities, including but not limited to water conservation, energy conservation, land use design and orientation, transportation-oriented development, and renewable energy source use. Table 4.1-3 below compares the project’s consistency with the City’s Climate Action Plan.

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Table 4.1-3 Project Consistency with the San Leandro Climate Action Plan San Leandro Climate Action Plan Measure Project Consistency Building Efficiency (BE)
BE-1: Electrified retrofits. Incentivize significant building retrofits with fewer or no natural gas appliances to
reduce pollution and increase cost savings.

Inconsistent. The proposed project would include the
development of a new light industrial warehouse and would not retrofit existing buildings. The proposed project would include a new natural gas connection. Although the existing on-site buildings have natural gas connections, the proposed project would not result in fewer or no natural gas
connections or appliances.

BE-2: Electrified new construction. Commit to
developing a reach code limiting natural gas use in new construction, or as directed by the State or regional
agencies.

Inconsistent. The City of San Leandro has adopted a reach code encouraging limiting natural gas use in new
construction. However, the proposed project would include natural gas infrastructure.

Renewable Energy (RE)
RE-4: Increase renewable energy generation and energy
storage capacity at nonresidential properties.Encourage the use of non-fossil fuel backup generation systems as much as possible.

Consistent. The proposed project would be required to
comply with San Leandro Municipal Code Chapter 7-5,
Article 6 Green Building Code, which would require all new development to be consistent with Title 24, including the provision for solar-ready rooftop infrastructure.

Reducing Auto Dependency (AD)
AD-1: Traffic calming. Continue to provide the
Neighborhood Traffic Calming Program and related
efforts to reduce travel speeds and cut through traffic in residential areas.

Consistent. The proposed project would not include a
roadway that could be used to cut through residential
neighborhoods and would facilitate travel to the proposed project driveways.

AD-4: Evaluate parking standards. Evaluate parking
standards and continue to support shared parking and
other efforts to ensure the availability of necessary
parking while reducing vehicle miles traveled.

Consistent. The proposed project would provide parking
consistent with development standards contained in the San Leandro Municipal Code.

Active and Alternative Transportation (AT)
AT-1: Transportation Demand Management (TDM).

Require local employers above a certain number of
employees to develop programs that promote ride
sharing, flextime, telecommuting, and other means to
reduce commute trips and congestion, and target 10
percent mode shift.

Consistent. Although the number of employees that would be employed by the proposed project is unknown at the
time of preparation of this report, the proposed project would comply with any City TDM programs should they
apply.

AT-2: Bicycle infrastructure. Expand San Leandro’s
bicycle network and supportive bicycle infrastructure,
including funding buildout of the City’s bicycle network as identified in the current Bicycle and Pedestrian
Master Plan, to meet commute trip, non-commute trip,
and recreational needs.

Consistent. The proposed project would not inhibit the
expansion of the City’s bicycle network, because it would be consistent with existing Building Codes and would not
prevent the installation of bicycle lanes or infrastructure adjacent to the project site. Additionally, the project would include 12 bicycle parking spaces.

Transportation Electrification and Low-Carbon Fuels (TE) TE-1: Electric vehicle adoption. Conduct education and
outreach to inform members of the public about the
availability of EVs, and the economic incentives
available to encourage EV adoption.

TE-2: Increase the availability of publicly accessible EV charging stations at multi-family residential buildings, retail centers, offices, and public facilities.

Consistent. The proposed project includes the development of a new warehouse that would be subject to Title 24
requirements mandating EV charging infrastructure. The
proposed project would include 21 EV charging spaces.

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San Leandro Climate Action Plan Measure Project Consistency Waste Management (WM)
WM-1: Increased curbside recycling. Increase
participation in curbside recycling programs, including efforts to reduce material contamination and
improvementsto waste educational programs.

Consistent. The proposed project would be required to
comply with the City’s construction debris and waste
recycling ordinance. The proposed project would be
provided waste removal services by Oro Loma Sanitary
District,which provides recycling services for residential uses.

WM-2: Curbside composting. Expand participation in
composting programs, including partnerships with
community organizations such as StopWaste and a
mandatory curbside composting program for all
businesses.

Consistent. The Oro Loma Sanitary District would provide Green Waste bins for the proposed project’s waste disposal and the proposed project would participate in mandatory composting practices for businesses.

Waste Reduction and Reuse (WR)
WR-1: Waste minimization. Explore emerging
opportunities for waste minimization, including maker
spaces, material reuse, and tool-lending libraries.

Inconsistent. The project has not considered maker spaces, material reuse, or tool-lending libraries.

WR-2: Construction and Demolition waste. Explore
opportunities to exceed State requirements for
construction and demolition materials by encouraging
deconstruction and material reuse.

Consistent. The construction contractor would be required to comply with San Leandro Municipal Code Section 3-7
related to constructionwaste and debris recycling. San
Leandro Municipal Code Section 3-7 exceeds State
requirements by requiring the project applicant to submit a Debris Recycling Statement to the City.

Water Efficiency (WE)
WE-4: New Greywater Installations. Continue to require
water conservation and green infrastructure strategies
as a condition of approval for major developments.

Consistent. As described in Section 2, Project Description, The proposed project would comply with water efficient
landscape and would include the planting of species that would be appropriate for the local climate and contribute to conserving outdoor water use.

Community Consumption (CC)
CC-4: Carbon Sequestration. Promote increasing soil
carbon and planting high carbon sequestering, climate
appropriate species in landscaping projects.

Consistent. The proposed project would increase the
amount of landscaping on the site compared to current
conditions, which would contribute to carbon sequestration on- site.

Source: City of San Leandro 2021
As shown above in Table 4.1-3, the proposed project would be generally consistent with the City’s Climate Action Plan. However, the proposed project would be inconsistent with policy WR-1 pertaining to waste reuse and policies BE-1 and BE-2 of the Climate Action Plan, which pertain to replacing natural gas with electricity. Inconsistency with policy WR-1 would not result in physical environmental impacts because the policy encourages maker spaces, and tool-lending libraries for example. The absence of these features from the project do not result in physical environmental effects. The proposed project would be inconsistent with policies BE-1 and BE-2 because the proposed project would include new natural gas connections. Accordingly, the proposed project would conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing GHG emissions. Impacts would be potentially significant, and mitigation is required.

Mitigation Measures
The City is unable to implement mitigation to reduce this significant impact based on a recent court case titled California Restaurant Association v. City of Berkeley. Briefly, in this case, the California Restaurant Association sued Berkeley in the U.S. District Court for the Northern District of California, Environmental Impact Analysis
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arguing among other things that the federal Energy Policy and Conservation Act (EPCA) preempted the City’s ordinance banning natural gas in new buildings. The District Court dismissed the California Restaurant Association’s challenge. However, the Ninth Circuit reversed the District Court, holding that EPCA expressly preempts state and local regulations concerning the energy use of many natural gas appliances. The Ninth Circuit concluded that EPCA preempted Berkeley’s ban of natural gas, because it prohibited the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA. Accordingly, based on the decision of the Ninth Circuit in California Restaurant Association v. City of Berkeley, the City of San Leandro cannot require the project applicant to eliminate natural gas from the proposed project. No other mitigation is available to eliminate the use of natural gas in the proposed project. See Section 6, Alternatives, which includes project alternatives that do not include natural gas connections.

4.1.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). While greenhouse gas emissions are a global occurrence and climate change affects the entire planet, it is impractical to extend the geographic scope for this cumulative impacts analysis to the entire planet. Additionally, the geographic scope for this analysis need only to include the San Franscisco Bay Area due to the abundance or GHG emission sources, including residential, commercial, industrial, and mobile sources. Combined, the GHG emissions from these sources have resulted in a significant cumulative impact related to climate change. The proposed project would result in additional GHG emissions, especially due to the combustion of natural gas that is included in the natural project. The other reasonably foreseeable future projects listed in Table 3.1 of this EIR would also generate GHG emissions. Accordingly, the cumulative GHG impacts of the proposed project would be significant. As described in Section 4.1.3, there are no feasible mitigation measures to reduce the significant GHG impacts of the proposed project. the project’s contribution to significant cumulative GHG impacts would be cumulatively considerable.

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4.2 Hazards and Hazardous Materials
This section of the EIR addresses the potential environmental impacts of the proposed project that are related to hazards and hazardous materials. Simply defined, a hazardous waste is a waste with properties that make it dangerous or capable of having a harmful effect on human health or the environment (U.S. Environmental Protection Agency 2023). This section is based largely on a Revised Soil and Groundwater Management Plan that RMD Environmental Solutions, Inc. prepared for the project site in 2021. The California Department of Toxic Substances Control (DTSC) approved the Revised Soil and Groundwater Management Plan in a letter dated August 3, 2021. The Soil and Groundwater Management Plan and the DTSC approval letter are provided as Appendix D to this EIR.

4.2.1 Setting
a. Past and Current Land Uses
As described in EIR Section 2.3, Project Location, the project site consists of two Assessor’s parcels:

APN 77A-0741-004-02 and 77A-0741-005-00. Kaiser Aerotech manufactured aerospace and/or aircraft equipment on APN 77A-0741-004-02 from approximately 1955 to 1996, when these operations ceased, and the manufacturing equipment was dismantled (RMD Environmental Solutions 2021). Kaiser Aerotech used the APN 77A-0741-005-00 for employee parking, light manufacturing, and storage between 1963 and 1976. Between 1976 and 2002, most of the APN 77A-0741-005-00 was leased to other businesses including a cargo container repair and storage company and a light manufacturing company (RMD Environmental Solutions 2021; Appendix D).

From the early 2000s to May 2020, Expresso Airport Parking operated at the Site to provide off-site airport parking and the former manufacturing buildings were repurposed as indoor parking (RMD Environmental Solutions 2021). Currently the buildings remain on site. b. Hydrogeologic Zones
Hydrogeological zones refer to the subsurface areas of rock and soil containing distinct characteristics that influence groundwater flow and storage. As it relates to prior site operations and associated use of hazardous materials, the site’s hydrogeologic zones determine how these materials may contribute to groundwater contamination. According to the Soil and Groundwater Management Plan for the project site (RMD Environmental Solutions 2021), the project site subsurface consists of the following hydrogeologic zones:
 Vadose zone: Ground surface to the top of the water table at approximately 5 feet below ground surface;
 A-zone: Approximately 5-15 feet below ground surface; thin, discontinuous sand lenses;  B-zone: Approximately 15-35 feet below ground surface; thicker sand channels enveloped by fine-grained soil;
 Fine-grained soil: Approximately 35-45 feet below ground surface; interpreted aquitard; and  C-zone: Below approximately 45 feet below ground surface; thicker, more laterally continuous sand intervals.

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In general, horizontal hydraulic gradients are toward the west in each of the three water-bearing zones. Groundwater is typically observed at approximately 5 to 7 feet below ground surface in the A-zone. Groundwater elevations in A-zone observed in existing on-site wells are typically similar to those in adjacent B-zone wells and are below those in adjacent C-zone wells (RMD Environmental Solutions 2021). On-site groundwater monitoring well locations are shown on Figure 4.2-1. c. Hazardous Constituents of Potential Concern
The project site is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5, otherwise known as the “Cortese List” (DTSC 2023; State Water Resources Control Board 2023). The project site is considered a hazardous site due to subsurface contamination with chlorinated volatile organic compounds associated with the Kaiser Aerotech operation that formerly operated on-site. Specifically, according to the Soil and Groundwater Management Plan prepared for the project site (RMD Environmental Solutions 2021; Appendix D), the primary contaminants of potential concern at the site are trichloroethene and its associated degradation products, cis-1,2-dichloroethene, trans-1,2- dichloroethene, and vinyl chloride.

Trichloroethene is considered the primary indicator contaminant of potential concern based on the past Kaiser Aerotech operations. Trichloroethene and its degradation products are distributed throughout the soil and groundwater occurring throughout the A and B hydrogeologic zones, which extend approximately 5 to 35 feet below ground surface. Tetrachloroethene is largely limited to this same zone but slightly less deep into the B hydrogeologic zone and is considered to be the result of an offsite source associated with the railroad at the western boundary of the site (RMD Environmental Solutions 2021; Appendix D).
d. Phase I Environmental Site Assessment Document
Langan Engineering and Environmental Services, Inc. prepared a Phase I Environmental Site Assessment for the project site in December 2019. The findings of the 2019 Phase I Environmental Site Assessment include a summary of the site contamination identified by DTSC (see Section c.

Hazardous Constituents of Potential Concern, above). Additionally, the Phase I Environmental Site Assessment identifies elevated concentrations of lead associated with deteriorating paint at the project site. Further, the Phase I Environmental Site Assessment identifies the presence of asbestos containing materials at the site, generally associated with the existing vacant buildings. There are also approximately 51 electrical transformers present at the site that contain polychlorinated biphenyls.
e. Remediation Actions
Environmental response activities, including remedial actions, have been implemented at the project site to address chlorinated volatile organic compounds observed in the site subsurface. As described in the Final Remedial Action Plan (The Source Group, Inc. 2008a) and Remedial Design and Implementation Plan (The Source Group, Inc. 2008b), the remediation of trichloroethene at the site was addressed using primarily bioremediation techniques. Areas containing concentrations of 1,000 micrograms per liter (µg/L) or greater were treated using enhanced reductive de-chlorination through injection of an electron-donor substrate, which is a process that modifies the groundwater conditions to enhance degradation of contaminates to their non-contaminated end products.

Routine groundwater monitoring results are used to continue to evaluate site conditions and remedial progress (RMD Environmental Solutions 2021; Appendix D).

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Figure 4.2-1 On-Site Groundwater Well Network
Source: RMD Environmental Solutions 2021
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Groundwater monitoring data indicate that remediation efforts successfully reduced trichloroethene concentrations in the onsite wells to near or below its maximum contaminant level (MCL) (5.0 µg/L) in most of the treatment areas. The MCL is the maximum level of contaminant allowed in water which is delivered to a user of a public water system. In several areas, the return toward ambient conditions and more limited enhanced reductive de-chlorination have not resulted in trichloroethene concentration rebound above 100 µg/L indicating the effectiveness of remediation efforts. In the A-zone and B-zone monitored natural attenuation wells, the generally stable-to-decreasing concentrations of trichloroethene and its degradation products (e.g., cis-1,2- dichloroethene, vinyl chloride) observed during routine groundwater monitoring are consistent with ongoing natural attenuation in lower concentration areas. The need for further electron-donor substrate injections and continued natural attenuation continue to be evaluated through routine groundwater monitoring (RMD Environmental Solutions 2021; Appendix D). f. Sub-Slab Vapor, Indoor Air, and Soil Vapor
In April 2020, 12 sub-slab vapor points were installed on-site and sampled and three ambient air samples, 13 indoor air samples, and one duplicate indoor air sample were also collected at the project site. Later, in October 2020, eight soil vapor probes were installed and sampled at approximate depths of 4.75 to 5 feet below ground surface. In January 2021, three soil vapor probes were installed and sampled at an approximate depth of 4.25 feet below ground surface (RMD Environmental Solutions 2021).

In the 2020 and 2021 vapor samples, trichloroethene, tetrachloroethene, cis-1,2- dichloroethene, vinyl chloride, benzene, and ethylbenzene were detected at concentrations exceeding the commercial/industrial screening levels in either sub-slab vapor or soil vapor sample samples, or both (using a conservative U.S. Environmental Protection Agency soil vapor to indoor air attenuation factor of 0.03).

In general, indoor air concentrations were consistent with background, ambient concentrations and benzene was the only volatile organic compound detected at concentrations exceeding the commercial/industrial screening levels. At the time of sampling, existing on-site buildings were used for off-airport parking. As such, vehicles were operating within and outside the building. Vehicular exhaust likely contributed to the benzene concentrations detected in both indoor and ambient air samples (RMD Environmental Solutions 2021; Appendix D). g. Land Use Covenant
In conjunction with environmental response activities, a Land Use Covenant (LUC) was filed with Alameda County in 2012 to ensure that the site is not used for the following land uses: residences, hospitals for humans, public or private school for persons under 21 years of age, and day care center for children. The Land Use Covenant requires DTSC approval of planned future use of groundwater at the project site and a Soil Management Plan prior to planned disturbance of subsurface soil in two limited areas of the site. These soil management areas are shown on Figure 4.2-2 as “Approximate Extent of TCE Concentration Above 910 ug/m”. Operation and maintenance activities and annual Land Use Covenant inspections are routinely conducted to evaluate groundwater conditions and remedial progress at the site (RMD Environmental Solutions 2021). The Land Use Covenant is included as an attachment to the Soil and Groundwater Management Plan, which is provided as Appendix D to this EIR.

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Figure 4.2-2 Soil Managment Areas
Source: RMD Environmental Solutions 2021
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4.2.2 Regulatory Setting
a. Federal Regulations
Toxic Substances Control Act (1976) and the Resource Conservation and Recovery Act of 1976
These acts established a program administered by the U.S. Environmental Protection Agency for the regulation of the generation, transportation, treatment, storage, and disposal of hazardous waste.

The Resource Conservation and Recovery Act was amended in 1984 by the Hazardous and Solid Waste Act, which affirmed and extended the “cradle to grave” system of regulating hazardous wastes. Among other things, the use of certain techniques for the disposal of some hazardous wastes was specifically prohibited by the Hazardous and Solid Waste Act.

Comprehensive Environmental Response, Compensation and Liability Act, amended by the Superfund Amendments and Reauthorization Act (1986) This law was enacted in 1980 and provides broad federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment.

Among other things, the Comprehensive Environmental Response, Compensation and Liability Act established requirements concerning closed and abandoned hazardous waste sites, provided for liability of persons responsible for releases of hazardous waste at these sites, and established a trust fund to provide for cleanup when no responsible party could be identified. The Comprehensive Environmental Response, Compensation and Liability Act also enabled revision of the National Contingency Plan, which provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The National Contingency Plan also established the National Priorities List.

Lead-Based Paint Regulations
Regulations for lead-based paint are contained in the Lead-Based Paint Elimination Final Rule, 24 CFR 33, governed by the U.S. Housing and Urban Development, which requires sellers and lessors to disclose known lead-based paint and lead-based paint hazards to perspective purchasers and lessees. Additionally, all lead-based paint abatement activities must be in compliance with California Occupational Safety and Health Administration (Cal/OSHA) and Federal OSHA and with the State of California Department of Health Services requirements. Only lead-based paint -trained and -certified abatement personnel are allowed to perform abatement activities. All lead-based paint removed from structures must be hauled and disposed of by a transportation company licensed to transport this type of material at a landfill or receiving facility licensed to accept the waste.

Regulations to manage and control exposure to lead-based paint are also described in CFR Title 29, Section 1926.62 and California Code of Regulations Title 8 Section 1532.1. These regulations cover the demolition, removal, cleanup, transportation, storage, and disposal of lead-containing material.

The regulations outline the permissible exposure limit, protective measures, monitoring, and compliance to ensure the safety of construction workers exposed to lead-based materials.

Cal/OSHA’s Lead in Construction Standard requires project proponents to develop and implement a lead compliance plan when lead-based paint would be disturbed during construction. The plan must describe activities that could emit lead, methods for complying with the standard, safe work Environmental Impact Analysis
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practices, and a plan to protect workers from exposure to lead during construction activities.

Cal/OSHA requires 24-hour notification if more than 100 sf of lead-based paint is disturbed.

U.S. Environmental Protection Agency
The U.S. Environmental Protection Agency is the agency primarily responsible for enforcement and implementation of Federal laws and regulations pertaining to hazardous materials. Applicable Federal regulations pertaining to hazardous materials are contained in the CFR Titles 29, 40, and 49.

Hazardous materials, as defined in the CFR, are listed in 49 CFR 172.101. The management of hazardous materials is governed by the following laws:

1. Resource Conservation and Recovery Act of 1976) (42 USC 6901 et seq.); Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (also called the Superfund Act) (42 USC 9601 et seq.)

2. Federal Insecticide, Fungicide, and Rodenticide Act (7 USC 136 et. Seq.)

3. Superfund Amendments and Reauthorization Act of 1986 (Public Law 99 499) These laws and associated regulations include specific requirements for facilities that generate, use, store, treat, and/or dispose of hazardous materials. The U.S. Environmental Protection Agency provides oversight and supervision for Federal Superfund investigation/remediation projects, evaluates remediation technologies, and develops hazardous materials disposal restrictions and treatment standards.

Asbestos Regulations
Asbestos is a naturally occurring fibrous material that was extensively used as a fireproofing and insulating agent in building construction materials before such uses were banned by the U.S.

Environmental Protection Agency in the 1970s. Asbestos-containing materials (ACMs) were commonly used for insulation of heating ducts as well as ceiling and floor tiles. Undisturbed ACMs contained within building materials present no significant health risk because there is no exposure pathway. However, once these tiny fibers are disturbed, they can become airborne and become a respiratory hazard. The fibers are very small and cannot be seen with the naked eye. Once they are inhaled, they can become lodged into the lungs, and may cause cancer, lung disease or other pulmonary complications.

The U.S. Environmental Protection Agency regulations under Title 40 CFR Part 61 regulate the removal and handling of ACMs. The federal Occupational Safety and Health Administration also has a survey requirement under Title 29 CFR that is implemented by Cal/OSHA under Title 8 California Code Regulations. These regulations require facilities to take all necessary precautions to protect employees and the public from exposure to asbestos.
b. State Regulations
Department of Toxic Substances Control
As a department of the California EPA, the Department of Toxic Substances Control (DTSC) is the primary agency in California that regulates hazardous waste, cleans up existing contamination, and looks for ways to reduce the hazardous waste produced in California. DTSC regulates hazardous waste in California primarily under the authority of the Resource Conservation and Recovery Act and the California Health and Safety Code.

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DTSC also administers the California Hazardous Waste Control Law to regulate hazardous wastes.

While the Hazardous Waste Control Law is generally more stringent than the Resource Conservation and Recovery Act, until the U.S. Environmental Protection Agency approves the California program, both state and federal laws apply in California. The Hazardous Waste Control Law lists 791 chemicals and approximately 300 common materials that may be hazardous; establishes criteria for identifying, packaging, and labeling hazardous wastes; prescribes management controls; establishes permit requirements for treatment, storage, disposal, and transportation; and identifies some wastes that cannot be disposed of in landfills.

Government Code Section 65962.5 requires the DTSC, the State Department of Health Services, the State Water Resources Control Board, and CalRecycle to compile and annually update lists of hazardous waste sites and land designated as hazardous waste sites throughout the state. The Secretary for Environmental Protection consolidates the information submitted by these agencies and distributes it to each city and county where sites on the lists are located. Before the lead agency accepts an application for any development project as complete, the applicant must consult these lists to determine if the site at issue is included.

If any soil is excavated from a site containing hazardous materials, it would be considered a hazardous waste if it exceeded specific criteria in Title 22 of the California Code of Regulations.

Remediation of hazardous wastes found at a site may be required if excavation of these materials is performed, or if certain other soil disturbing activities would occur. Even if soil or groundwater at a contaminated site does not have the characteristics required to be defined as hazardous waste, remediation of the site may be required by regulatory agencies subject to jurisdictional authority.

Cleanup requirements are determined on a case-by-case basis by the agency taking jurisdiction.

Hazardous Waste Control Act
The hazardous waste management program enforced by DTSC was created by the Hazardous Waste Control Act (California Health and Safety Code Section 25100 et seq.), which is implemented by regulations described in CCR Title 26. The State program is similar to, but more stringent than, the Federal program under the Resource Conservation and Recovery Act. The regulations list materials that may be hazardous, and establish criteria for their identification, packaging, and disposal.

Environmental health standards for management of hazardous waste are contained in California Code of Regulations (CCR) Title 22, Division 4.5. As required by California Government Code Section 65962.5, DTSC maintains a Hazardous Waste and Substances Site List for the State called the Cortese List.

California Department of Pesticide Regulation, Department of Food and Agriculture, and the Department of Public Health
The California Department of Pesticide Regulations (DPR), a division of California Environmental Protection Agency, in coordination with the California Department of Food and Agriculture, a division of Measurement Standards and the California Department of Public Health have the primary responsibility to regulate pesticide use, vector control, food, and drinking water safety. CCR Title 3 requires the coordinated response between the County Agricultural Commissioner and the Sonoma County Department of Health Services to address the use of pesticides used in vector control for animal and human health on a local level. DPR registers pesticides; the County tracks pesticide use. Title 22 is used also to regulate both small and large California Department of Public Health water systems.

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California Fire Building Code
The 2016 Fire and Building Code (2016) establishes the minimum requirements consistent with nationally recognized good practices to safeguard the public health, safety, and general welfare for the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures and premises, and to provide safety and assistance to firefighters and emergency responders during emergency operations. The provisions of this code apply to the construction, alteration, movement enlargement, replacement, repair, equipment, use and occupancy, location, maintenance, removal, and demolition of every building or structure or any appurtenances connected or attached to such building structures throughout the State of California. c. Local Regulations
Alameda County Local Hazard Mitigation Plan
The Alameda County Local Hazard Mitigation Plan assesses hazards, risks, and capabilities for hazard mitigation, and then provides a blueprint for a mitigation strategy. The hazard and risk assessment focuses on dam failure inundation, drought, earthquake, flood, landslide, liquefaction, tsunami, and wildfire. The Alameda County 2016 Local Hazard Mitigation Plan was adopted by the County Board of Supervisors in January 2016, and was approved by the Federal Emergency Management Agency in October 2016.

Alameda County Water Department
The Alameda County Water District manages the Niles Cone Groundwater Basin, which underlies the project site, through comprehensive programs that protect and improve water supplies for groundwater users. The project site is also located within the Alameda County Water District’s jurisdictional boundary. The Alameda County Water District is identified within the Sustainable Groundwater Management Act as the exclusive local agency within its statutory boundaries to comply with the Sustainable Groundwater Management Act. The Alameda County Water District is also the Groundwater Sustainability Agency for the Niles Cone Groundwater Basin and has an approved Alternative to a Groundwater Sustainability Plan.

Alameda County Department of Environmental Health
The mission of the Alameda County Department of Environmental Health is to protect the health, safety and well-being of the public through the promotion of environmental quality. The department’s Hazardous Materials Division contains the Clean Water Program, Waste Tire Program, and the Certified Unified Program Agency for much of Alameda County, but not the City of San Leandro. As discussed in the next paragraph, the City of San Leandro Environmental Services Section is designated as the City’s Certified Unified Program Agency.

San Leandro Environmental Services Section
The City of San Leandro Environmental Services Section is designated as the City’s Certified Unified Program Agency, which is overseen by the California Environmental Protection Agency and coordinates the regulation of hazardous materials and hazardous wastes in the City. The Certified Unified Program Agency ensures the consistent application of statewide standards during administrative, permitting, inspection, and enforcement activities associated with hazardous materials and hazardous wastes. If a business operated at the project site would use and store City of San Leandro
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hazardous materials and generate hazardous wastes, the Certified Unified Program Agency would require the electronic submittal of chemical and facility information, a Hazardous Materials Business Plan, and hazardous waste generator permits to the California Environmental Reporting System online database. If operations at the project site would include the treatment, storage, and/or disposal of hazardous waste, the City Environmental Services Section would regulate these activities under a tiered permitting system.

The Certified Unified Program Agency, through the Hazardous Materials Office, regulates USTs containing hazardous materials, including installation, operation and maintenance, temporary closure, and removal and disposal of USTs. Additionally, the Certified Unified Program Agency holds the responsibility and authority to implement the Aboveground Petroleum Storage Act, which regulates aboveground petroleum storage tanks through administrative requirements, permitting, inspections, and enforcement. Any aboveground or underground storage tanks present at the project site would be managed by the City Environmental Services Section.

The Hazardous Materials Office administers the California Accidental Release Prevention Program, which aims to reduce the likelihood and impact of accidental releases of regulated toxic and flammable substances through administrative and operational procedures, and facility inspections.

If the facility located on the project site would be regulated under the California Accidental Release Prevention Program, the facility would file a written Risk Management Plan with the City Environmental Services Section.

City of San Leandro General Plan
The Environmental Hazards Element of the City of San Leandro General Plan includes the following goals and policies that aim to reduce potential damage from hazardous materials:

Goal EH-5: Protect local residents and workers from the risks associated with hazardous materials.

Policy EH-5.1: Regulatory Compliance. Work with the appropriate county, regional, state, and federal agencies to develop and implement programs for hazardous waste reduction, hazardous material facility siting, hazardous waste handling and disposal, public education, and regulatory compliance.

Policy EH-5.2: Clean-Up of Contaminated Sites. Ensure that the necessary steps are taken to clean up residual hazardous wastes on any contaminated sites proposed for redevelopment or reuse. Require soil evaluations as needed to ensure that risks are assessed and appropriate remediation is provided.

Policy EH-5.3: Design of Storage and Handling Areas. Require that all hazardous material storage and handling areas are designed to minimize the possibility of environmental contamination and adverse off-site impacts. Enforce and implement relevant state and federal codes regarding spill containment facilities around storage tanks.

Policy EH-5.7: Hazardous Building Materials. Ensure the safe and proper handling of hazardous building materials, such as friable asbestos and lead based paint. If such materials are disturbed during building renovation or demolition, they should be handled and disposed of in a manner that protects human health and the environment.

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4.2.3 Impact Analysis
a. Methodology and Thresholds of Significance
According to CEQA Guidelines Appendix G, impacts related to hazards and hazardous materials are considered significant if implementation of the proposed project would:

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 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; or

7. Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

CEQA checklist items 1, 3, and 5 through 7 were found to be less than significant in the Initial Study (Appendix A). Therefore, these topics will not be discussed further in this section.

Threshold 2: Would the project 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?
Threshold 4: Would the project be located on a site that is included on a list of hazardous material 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? Impact HAZ-1 THE PROJECT HAS THE POTENTIAL TO 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 DUE TO POTENTIAL HAZARDOUS MATERIALS THAT MAY BE PRESENT IN THE EXISTING ON-SITE STRUCTURES AND SOILS AND GROUNDWATER. IN ADDITION, BECAUSE

OF EXISTING SOIL AND GROUNDWATER CONTAMINATION, THE SITE IS ON A LIST COMPILED PURSUANT TO GOVERNMENT CODE SECTION 65962.5. THIS IMPACT WOULD BE POTENTIALLY SIGNIFICANT BUT MITIGABLE.

Project Construction
Project construction would require the transport of construction equipment and fuels to the project site. This equipment and fuel, such as diesel fuel and gasoline, would be stored on-site for the duration of construction. If these fuels and other hazardous equipment fluids, such as motor oil, were to leak or be spilled they could create substantial hazards to the public or the environment.

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For example, if a diesel fuel spill were to occur during project construction, the fuel could become runoff and discharge to surface waters, which would be a substantial hazard to the environment.

Construction of the project would require ground disturbance over an area exceeding 1 acre.

Therefore, the project applicant must develop and implement a Stormwater Pollution Prevention Plan (SWPPP), pursuant to state regulations. The SWPPP must include containment and clean-up measures to implement in the event of a leak or spill of construction fluids, such as equipment diesel fuel. Mandatory implementation of the SWPPP would reduce potential impacts associated with release of substantial hazards from construction equipment and fluids to less than significant.

Asbestos is a naturally occurring fibrous material that was extensively used as a fireproofing and insulating agent in building construction materials before such uses were banned by the U.S.

Environmental Protection Agency in the 1970s. Asbestos-containing materials (ACMs) were commonly used for insulation of heating ducts as well as ceiling and floor tiles. Undisturbed ACMs contained within building materials present no significant health risk because there is no exposure pathway. However, once these tiny fibers are disturbed, they can become airborne and become a respiratory hazard. The proposed project would involve the demolition of existing vacant structures on the project site. Project demolition activities would have potential to expose construction workers to asbestos containing materials due to the age of the existing structures. Additionally, construction workers could also be exposed to lead-based paint during demolition of existing structures. Lead is hazardous to human health.

Lead-based paint and other lead-containing materials associated with the proposed project would be required to be handled in compliance with Cal/OSHA regulations regarding lead-based paints and materials. The California Code of Regulations, Section 1532.1, requires testing, monitoring, containment, and disposal of lead-based paints and materials, such that exposure levels do not exceed Cal/OSHA standards. Compliance with applicable Cal/OSHA regulations would ensure impacts related to lead-based paint would be less than significant.

Friable ACMs are regulated as a hazardous air pollutant under the Clean Air Act, and the Bay Area Air Quality Management District regulates ACM in Regulation 11, Rule 2, which governs the proper handling and disposal of ACM for demolition activities. As a worker safety hazard, ACMs are also regulated under the authority of Cal/OSHA. In structures slated for demolition, ACMs would be abated in accordance with state and federal regulations prior to the start of demolition activities and in compliance with all applicable existing rules and regulations. However, if construction workers are unaware of the potential presence of ACMs, regulations may not be properly implemented, leaving workers vulnerable to exposure to ACMs, as well as lead. Likewise, people working or living nearby could also be exposed to ACMs in dust from construction. This would be a significant impact because it could affect health. Implementation of Mitigation Measure HAZ-1 is required. Mitigation Measure HAZ-1 requires visual inspection/pre-demolition surveys to confirm the presence of ACMs and lead-based paint.

In association with existing on-site contamination, a Land Use Covenant was filed with Alameda County in 2012 to ensure that the site is not used for the following land uses: residences, hospitals for humans, public or private school for persons under 21 years of age, and day care center for children. The Land Use Covenant requires DTSC approval of planned future use of groundwater at the project site and a Soil Management Plan prior to planned disturbance of subsurface soil in two limited areas of the site. To address this, RMD Environmental Solutions prepared a Soil and Groundwater Management Plan for the site (RMD Environmental Solutions 2021; Appendix D).

The Soil and Groundwater Management Plan identifies two areas within the project site where residual contamination levels are of concern. These areas are referred to as the “land use restriction Environmental Impact Analysis
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areas” and are shown above as a small circular area on Figure 4.2-2. Soil and groundwater within the restricted areas could contain detectable concentrations of trichloroethene, a human-made chemical that is hazardous to human health. These compounds are referred to as chemicals of potential concern. According to the Land Use Covenant, elevated concentrations of the trichloroethene in soil could be encountered during construction activities at depths of less than 6 feet below ground surface within the land use restriction areas (Appendix D). Therefore, project construction activities involving excavation, such as construction of the proposed building foundation or buried utility connections, could disturb contaminated soils or groundwater and expose construction workers to trichloroethene. Because contaminated soils generally exist on-site at depths greater than 6 feet below ground surface outside of the mapped land use restriction areas, other shallow ground disturbance elsewhere on the project site during project construction would have less potential to disturb contaminated soils and expose construction workers to contamination. Nonetheless, the potential for construction workers to be exposed to contaminated soil or groundwater during project construction would be a potentially significant. Implementation of Mitigation Measure HAZ-2 is required, which requires implementation of the Revised Soil and Groundwater Management Plan during construction.

Likewise, project construction would generate dust. If soils from the contamination areas are stockpiled on site and become airborne dust, either from wind erosion or construction equipment, off-site receptors could be exposed, as well as project construction workers. Reuse of contaminated soils as fill material on site is prohibited, but if mistakenly used it could also expose workers to contamination, as well as future employees of the proposed building. Similarly, dewatering could be required if groundwater is encountered. Improper discharge of groundwater removed during dewatering would be a substantial hazard to the environment. Impacts would be potentially significant, and implementation of Mitigation Measure HAZ-2 and Mitigation Measure HAZ-3 is required. Mitigation Measure HAZ-3 requires containment of dewatering effluent and obtaining a discharge permit is released from containment.

Project construction would require the demolition of some or all existing groundwater monitoring wells that were previously installed as part of the remediation actions on-site. According to the Land Use Covenant for the project site, these wells should be maintained and monitored as an ongoing remediation activity. With the potential demolition of wells during project construction, there would be no way to monitor if prior remediation activities have continued to be effective.

Contamination levels could increase without knowledge of such increases, resulting in the migration of contaminants through the groundwater aquifer(s). This would be a potentially substantial hazard to the environment. Impacts would be potentially significant, and implementation of Mitigation Measure HAZ-4 is required. Mitigation Measure HAZ-4 requires protection of the groundwater well network.

Project Operation
As described above in Section 4.2.1, Setting, the Land Use Covenant for the project site prohibits the following land uses: residences, hospitals for humans, public or private school for persons under 21 years of age, and day care center for children. The proposed project would not be developed or used for these land uses, consistent with the Land Use Covenant restrictions. Future industrial tenants could potentially use and store hazardous materials at the project site, depending on the specific tenant or tenants. The use and storage of hazardous materials would be subject to federal and state regulations. Depending on the quantity of hazardous materials stored or used on-site, additional permits and oversight would be required, such as permits from the City. Regulatory City of San Leandro
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requirements would ensure that hazardous materials are properly handled, stored, and disposed of in such a way as not present environmental and health hazards.

During project operation, vapors from contaminated soil and groundwater underlying the site could potentially infiltrate the proposed building, including spaces within the building where employees would be routinely present. The accumulation of vapors in the breathing zone inside the building could present a potential hazard to human health. Therefore, the potential for soil vapor intrusion during operation would be a potentially significant impact. Implementation of Mitigation Measure HAZ-5 is required. Mitigation Measure HAZ-5 requires an engineered vapor barrier to be employed to further protect against possible vapor intrusion of chemicals of potential concern into the proposed building.

Stormwater runoff would be treated on site in bioretention areas to meet the current Alameda County C.3 stormwater regulations. The bioretention areas would slow runoff and aid infiltration in order to reduce the amount of runoff discharge to the City’s storm drain system. However, if improperly designed, the bioretention areas could result in contaminants leaching from soil into groundwater or result in migration of the existing contamination plume within groundwater. At least one of the proposed bioretention swales would be located partially within a land use restriction area where trichloroethene concentrations exceed MCLs. Migration or leaching of contamination would be a potentially significant environmental impact, and implementation of Mitigation Measure HAZ-6 is required. Mitigation Measure HAZ-6 requires bioretention areas to be designed and constructed in such a way as to protect groundwater aquifers from contamination.

Mitigation Measures
HAZ-1 Project Demolition Activities
In conformance with State and local laws, a visual inspection/pre-demolition survey, and possible sampling, shall be conducted prior to the demolition of on-site building(s) to determine the presence of asbestos-containing materials (ACMs) and/or lead-based paint. Documentation of the survey shall be provided to the City of San Leandro prior to commencement of demolition activities.

During demolition activities, all building materials containing lead-based paint shall be removed in accordance with Cal/OSHA Lead in Title 8, California Code of Regulations (CCR), Section 1532.1, including employee training, employee air monitoring, and dust control. Any debris or soil containing lead-based paint or coatings shall be disposed of at landfills that meet acceptance criteria for the type of lead being disposed.

All potentially friable asbestos containing materials (ACMs) shall be removed in accordance with National Emission Standards for Air Pollution (NESHAP) guidelines prior to demolition or renovation activities that may disturb ACMs. All demolition activities shall be undertaken in accordance with Cal/OSHA standards contained in Title 8, CCR, Section 1529, to protect workers from asbestos exposure.

A registered asbestos abatement contractor shall be retained to remove and dispose of ACMs identified in the asbestos survey performed for the site in accordance with the standards stated above in this mitigation measure. Materials containing more than one-percent asbestos are also subject to Bay Area Air Quality Management District regulations. Removal of materials containing more than one-percent asbestos shall be completed in accordance with Bay Area Air Quality Management District requirements and notifications.

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Based on Cal/OSHA rules and regulations, the following conditions shall be implemented to limit impacts to construction workers:
 Prior to commencement of demolition activities, a building survey, including sampling and testing, shall be completed to identify and quantify building materials containing lead-based paint.
 During demolition activities, all building materials containing lead-based paint shall be removed in accordance with Cal/OSHA Lead in Construction Standard, Title 8, CCR, Section 1532.1, including employee training, employee air monitoring and dust control.  Any debris or soil containing lead-based paint or coatings shall be disposed of at landfills that meet acceptance criteria for the type of waste being disposed.

HAZ-2 Implementation of the Revised Soil and Groundwater Management Plan and DTSC Regulatory Oversight
The project shall implement the appropriate handling procedures and worker health and safety measures during excavating or dewatering activities as described in the site-specific Revised Soil and Groundwater Management Plan developed by RMD Environmental Solutions for the project in June 2021 (included as Appendix D to this EIR). Measures included in the Revised Soil and Groundwater Management Plan to control potential hazardous contamination and exposure include, but are not limited to the following:
 Construction contractors shall implement dust control mitigation measures during construction activities at the project site to minimize the generation of dust. Examples of dust control measures that shall be implemented include routinely applying water or non-toxic soil stabilizers to exposed soils while performing grading and excavation activities; sweeping (with wet power sweepers) paved access roads, parking areas, and staging areas; covering or otherwise stabilizing soil stockpiles at the end of each workday; And suspending construction activities that cause visible dust plumes and odors to extend beyond project site boundaries.

Some additional dust control mitigation measures listed in the Soil and Groundwater Management Plan include limiting construction vehicle and equipment speeds to 15 miles per hours when operated on exposed soils and removing visible loose soils from vehicles before leaving the project site.
 To prevent or minimize construction equipment from tracking polluted spoils off the site onto roadways, trucks used to transport soil will be loaded in a manner to minimize soil spillage and fugitive dust. Examples of ways to load trucks to minimize spillage and dust include loading the truck bed to less than full capacity and covering the bed of truck after it has been loaded.  Construction equipment shall be cleaned prior to movement out of active work zones in impacted areas. The equipment wheels/tires shall be cleaned by means of shovels and stiffbristled brooms or brushes until they are fully cleaned. Upon completion of cleaning, debris shall be placed in the appropriate transportation vessel and the plastic sheeting shall be disposed. If washing water is required, decontamination wash water shall be profiled and transported to an appropriate disposal or recycling facility. Equipment exiting the project site shall be inspected and logged for compliance with the site decontamination requirements.  A construction Health and Safety Plan shall be prepared by the project applicant or its general contractor for the proposed project in accordance with Federal and State Occupational Safety and Health Administration (OSHA) standards for hazardous waste operations (29 Code of Federal Regulations [CFR] 1910.1208 and 8 California Code of Regulations [CCR] 5192, City of San Leandro
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respectively). Subcontractors shall either adopt the General Contractor’s Health and Safety Plan or prepare their own Health and Safety Plan satisfying the same regulatory requirements. The General Contractor shall be responsible for verifying that onsite construction workers and visitors have read and adhere to the procedures established in the Health and Safety Plan. A copy of the Health and Safety Plan shall be kept onsite during redevelopment activities. In the event that unanticipated conditions occur at the site, the General Contractor shall be responsible for modifying the Health and Safety Plan accordingly.  Field screening of soil shall be conducted continuously during ground disturbing activities using a calibrated handheld photoionization detector or other organic vapor meter. Field screening using a photoionization detector shall be conducted by properly trained General Contractor and/or Environmental Consultant personnel. Based on the field screening, excavated soil shall be separated into stockpiles in three categories: 1) Background Soil: No visual and odor indicators, and photoionization detector measurements that are consistent with background levels. Photoionization detector readings of up to 5 parts per million by volume (ppmv) shall be considered background levels. These soils can be characterized for onsite reuse, if applicable; 2) Interim Soil: No visual and odor indicators, and photoionization detector measurements between 5 ppmv and 50 ppmv. These soils can be characterized for onsite reuse, if applicable; and 3) Contaminated Soil: Staining and odor indicators present, and/or photoionization detector measurements of more than 50 ppmv. These soils shall be further evaluated and are likely to be characterized for offsite disposal.
 If soil exhibiting evidence of contamination (e.g., visual and odor indicators, and photoionization detector measurements of more than 50 ppmv), is encountered during ground disturbing activities, the project applicant and/or General Contractor shall cease ground disturbing activities in the area and delineate the area with barricades or fencing, stakes and plastic sheeting as appropriate, and signage to notify onsite workers and visitors of access restrictions.

The General Contractor shall notify the Property Owner and Environmental Consultant. Upon notification, the Environmental Consultant shall implement and/or provide oversight.  Stormwater pollution controls shall be implemented by the project applicant and/or General Contractor to minimize sediment runoff in stormwater. Best Management Practices including grading the site and installing stormwater control measures such as temporary earth berms or erecting silt fences around the perimeter of exposed soil at the site, shall be implemented to prevent erosion and sediment runoff from the site. Straw bale barriers or sediment traps shall be required to protect any existing catch basins or drainage channels.  During project construction activities, soil and/or groundwater sampling, removal and management of discovered underground structures (e.g., storage tanks), chemical analysis and proper disposal of contaminated materials, and soil import activities shall be documented in a daily field log by the project applicant and/or General Contractor and/or Environmental Consultant. At the completion of the construction activities, a Construction Completion Report shall be prepared by the Environmental Consultant for submittal to DTSC that summarizes the soil and groundwater handling activities.

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 Implement the November 19, 2020 Redevelopment-Related Groundwater Monitoring Well Network Modification Work Plan, as approved by DTSC on May 26, 2021  Implement the October 5, 2021 Revised Vapor Intrusion Mitigation System Implementation Work Plan, as approved by DTSC on December 1, 2021
 Implement the October 21, 2021 Revised Community Air Monitoring Plan (CAMP), as approved by DTSC on December 1, 2021
 Prepare a Five Year Remedial Action Review Report for the years 2019-2023 as specified in a DTSC letter dated May 3, 2022
 Implement the August 30, 2022 Soil Vapor Probe Destruction Workplan, as approved by DTSC on September 29, 2022
Upon submittal or completion of the information above, and in accordance with the 2012 Land Use Covenant, DTSC may require actions such as: development of subsurface investigation workplans; completion of soil, soil vapor, and/or groundwater subsurface investigations; installation of soil vapor or groundwater monitoring wells; soil excavation and offsite disposal; completion of human health risk assessments; and/or completion of remediation reports or case closure documents.

Subsurface soil, soil vapor, and groundwater investigations, if required, shall be conducted in accordance with a sampling plan that shall be reviewed and approved by the DTSC.

The DTSC approval documents shall be submitted to and reviewed by the City prior to issuing grading permits.1
HAZ-3 Construction Dewatering Requirements
Construction dewatering effluent, if produced, shall be pumped into holding tanks or United Nations (UN)-rated 55-gallon drums with appropriate labeling and secondary containment. If dewatering effluent would be discharged to an existing storm drain or drains, a National Pollutant Discharge Elimination System (NPDES) permit shall be obtained from the Regional Water Quality Control Board. If dewatering effluent would be discharged to the San Leandro Water Pollution Control Plant, an industrial pre-treatment permit shall be obtained from the San Leandro Environmental Services Section.

Chemical analysis shall be performed in accordance with the receiving facility’s requirements prior to discharge. If concentrations exceed the limits established for the discharge point, the dewatering effluent shall either be (1) transferred into a vacuum truck or properly labeled UN-rated 55-gallon drums and transported offsite for disposal at an appropriately licensed disposal facility; or (2) treated and discharged following sampling and analysis to confirm compliance with permit requirements.

HAZ-4 Groundwater Monitoring Well Protection
A November 19, 2020 Redevelopment-Related Groundwater Monitoring Well Network Modification Work Plan (RMD Environmental Solutions 2020c), which was approved in 2021 DTSC letter, was prepared to reduce the potential for damaged or lost wells during development of the project site.

Based on available development plans at that time, the monitoring wells were designated for either:
1 The DTSC may determine that the San Francisco Bay RWQCB or the City of San Leandro may be best suited to perform the cleanup oversight agency duties for the assessment and/or remediation of the project. Should the cleanup oversight agency be transferred from the DTSC to the San Francisco Bay RWQCB or the CUPA, this and other mitigation measures shall still apply.

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Protection in areas where minimal grade changes are anticipated. These monitoring wells shall be marked with paint and/or installation of delineators/snow fencing/bollards. The project applicant and/or General Contractor shall protect these groundwater monitoring wells and maintain access to the wells for routine monitoring to the extent practicable; or Destruction in areas within the building footprint and areas with substantial grade changes.

The DTSC shall be notified of changes to these designations based on modifications to the development plans and/or input from the project applicant and/or General Contractor with rationale for wells that do not warrant replacement. Prior to removal or installation of any wells, permits shall be acquired from the Alameda County Public Works Agency.

HAZ-5 Engineered Vapor Barrier Requirement
An engineered vapor barrier shall be employed to further protect against possible vapor intrusion of chemicals of potential concern into the proposed building. The vapor barrier shall be designed to meet the needs of the building. Vapor barriers are generally constructed using membranes constructed with high-density polyethylene or other polyolefin-based resins. The vapor barrier shall be resistant to volatile organic compounds. The vapor barrier shall meet the American Society for Testing and Materials guideline for a vapor barrier and have a permeance rating of 0.1 perms or less. The thickness and strength of the vapor barrier shall be based on the needs for the building, but the architect and contractor shall use a material strong enough to easily withstand the building construction and other building considerations. The selected vapor barrier shall be approved by the DTSC or Regional Water Quality Control Board prior to installation. Written approval from either the DTSC or Regional Water Quality Control Board shall be provided to the City of San Leandro before building permits are issued.

HAZ-6 Bioretention Design Coordination
The project applicant shall consult with the City of San Leandro on location and/or design of the onsite bioretention basins to ensure protection of the groundwater basin, which may include, but is not limited to, locating the basins outside of the restricted areas or use of a liner in the detention basin. The final design and location of the on-site bioretention basins shall demonstrate that groundwater would be protected from contamination. If bioretention basins are proposed in the restricted areas, DTSC and/or the San Francisco Bay RWQCB shall also approve the design of the bioretention basins.

Significance After Mitigation
Mitigation Measure HAZ-1 would reduce impacts by requiring testing to indicate whether leadbased paint or asbestos is present in the structures slated for demolition. If lead or asbestos is detected, these materials would be abated in accordance with state, federal, and local regulations to ensure they would not be released to the environment or impair human health. Therefore, the impact related to ACMs and lead would be less than significant with mitigation implemented.

With incorporation of Mitigation Measure HAZ-2, the provisions of the approved Soil and Groundwater Management Plan for the site would reduce potential hazardous materials impacts associated with the past on-site contamination during project construction. Additionally, implementation of Mitigation Measure HAZ-3 would protect the health of construction workers and the environment during construction dewatering activities. Impacts related to release and exposure Environmental Impact Analysis
Hazards and Hazardous Materials
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of hazardous materials during construction would be reduced to less than significant levels with implementation of these mitigation measures.

With incorporation of Mitigation Measure HAZ-4, the existing groundwater monitoring well network would be maintained or modified only with written approval of the DTSC. This would ensure that soil and groundwater contamination does not become more severe over the operational life of the project. Likewise, implementation of Mitigation Measure HAZ-5 would require installation of a vapor barrier approved by the DTSC or Regional Water Quality Control Board to protect the health of operational workers and occupants. Impacts related to release and exposure of hazardous materials during operation would be reduced to less than significant levels with implementation of these mitigation measures.

Mitigation Measures HAZ-6 would require coordination with local agencies to ensure that groundwater quality is protected and reduce the environmental impact associated with the existing contamination that may be affected by the bioretention basins.

Overall, with implementation of Mitigation Measure HAZ-1 through HAZ-6, impacts would be reduced to less than significant levels.

4.2.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). The geographic scope for cumulative hazardous materials impacts is limited to projects within San Leandro that are west of Interstate 880. This geographic scope is appropriate for hazardous materials because risks associated with hazards and hazardous materials occur largely in a site-specific and localized context as adverse impacts from a hazardous materials release or spill diminish in magnitude with distance. Cumulative development in the vicinity of the project site is identified in Table 3-1. Continued urban development has the potential to increase exposure to hazards. However, overall, hazards and hazardous materials impacts associated with individual developments are site specific in nature and must be addressed on a case-by-case basis. The magnitude of hazards for individual projects would depend upon the location, type, and size of development and the specific hazards associated with individual sites. Since hazards and hazardous materials are required to be examined as part of the permit application and environmental review process, it is anticipated that potential impacts associated with individual projects will be adequately addressed and mitigated prior to permit approval. Compliance with regulatory requirements would avoid potential hazard impacts associated with cumulative development. With adherence to existing policies and other local, regional, state, and federal regulations, no significant cumulative human or environmental health impacts are anticipated.

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Environmental Impact Analysis
Noise and Vibration
Environmental Impact Report 4.3-1

4.3 Noise and Vibration
This section analyzes the project’s potential noise and vibration impacts. The analysis contains a description of the existing noise setting, a discussion of both the temporary noise impacts related to construction activity and long-term impacts associated with project operations, and mitigation to reduce impacts, as applicable. Vibration impacts are analyzed related to construction activity only since project operation would not generate substantial vibration. Operational vibration is typically associated with projects involving heavy rail, blasting, pile driving, etc. These types of operational activities would not be facilitated by the project as designed.

The analysis presented in this section is based on the following technical studies, which are included as appendices to this EIR:
 Evaluation of Site Sound Emissions: Ostergaard Acoustical Associates 2024 (Appendix E)  Noise Letter Report: Rincon Consultants 2024 (Appendix F) The Evaluation of Site Sound Emissions was provided by the project applicant. Accordingly, Rincon Consultants conducted a peer review of the study at the request of the City of San Leandro to ensure its methodology and results and conclusions were appropriate and accurate.

4.3.1 Setting
a. Overview of Sound Measurement
Sound is a vibratory disturbance created by a moving or vibrating source, which is capable of being detected by the hearing organs. Noise is defined as sound that is loud, unpleasant, unexpected, or undesired and may therefore be classified as a more specific group of sounds. The effects of noise on people can include general annoyance, interference with speech communication, sleep disturbance, and, in the extreme, hearing impairment (California Department of Transportation [Caltrans] 2013).

Noise levels are commonly measured in decibels (dB) using the A-weighted sound pressure level (dBA). The A-weighting scale is an adjustment to the actual sound pressure levels so they are consistent with the human hearing response, which is most sensitive to frequencies around 4,000 Hertz and less sensitive to frequencies around and below 100 Hertz. Decibels are measured on a logarithmic scale that quantifies sound intensity in a manner similar to the Richter scale used to measure earthquake magnitudes. A doubling of the energy of a noise source, such as doubling of traffic volume, would increase the noise level by 3 dBA; reducing the energy in half would result in a 3 dBA decrease (Crocker 2007).

Human perception of noise has no simple correlation with sound energy: the perception of sound is not linear in terms of dBA or in terms of sound energy. Two sources do not “sound twice as loud” as one source. It is widely accepted the average healthy ear can barely perceive changes of 3 dBA, increase or decrease (i.e., twice or half the sound energy, respectively); a change of 5 dBA is readily perceptible (eight times the sound energy); and an increase (or decrease) of 10 dBA sounds twice (half) as loud (10.5 times the sound energy) (Crocker 2007).

Sound changes in both level and frequency spectrum as it travels from the source to the receiver.

The most obvious change is the decrease in level as the distance from the source increases. The manner by which noise reduces with distance depends on factors such as the type of sources (e.g., City of San Leandro
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point or line, the path the sound will travel, site conditions, and obstructions). Noise levels from a point source typically attenuate, or drop off, at a rate of 6 dBA per doubling of distance (e.g., construction, industrial machinery, ventilation units) (Occupational Safety and Health Administration [OSHA] 2023; Caltrans 2013). Noise from a line source (e.g., roadway, pipeline, railroad) typically attenuates at about 3 dBA per doubling of distance (Caltrans 2013). The propagation of noise is also affected by the intervening ground, known as ground absorption. A hard site, such as a parking lot or smooth body of water, receives no additional ground attenuation and the changes in noise levels with distance (drop-off rate) result from the geometric spreading of the source. An additional ground attenuation value of 1.5 dBA per doubling of distance applies to a soft site (e.g., soft dirt, grass, or scattered bushes and trees) (Caltrans 2013). Noise levels may also be reduced by intervening structures; the amount of attenuation provided by this “shielding” depends on the size of the object and the frequencies of the noise levels. Natural terrain features such as hills and dense woods, and human-made features such as buildings and walls, can substantially alter noise levels.

The impact of noise is not a function of loudness alone. The time of day when noise occurs and the duration of the noise are also important factors of a project’s noise impact. Most noise that lasts for more than a few seconds is variable in its intensity. Consequently, a variety of noise descriptors have been developed. One of the most frequently used noise metrics is the equivalent noise level (Leq); it considers both duration and sound power level. Typically, Leq is summed over a one-hour period. Lmax is the highest sound pressure level within the sampling period, and Lmin is the lowest sound pressure level within the measuring period (Crocker 2007).

Noise occurring at night tends to be more disturbing than that occurring during the day. Community noise is usually measured using Day-Night Average Level (Ldn), which is the 24-hour average noise level with a +10 dBA penalty for noise occurring during nighttime (10:00 p.m. to 7:00 a.m.) hours; it is also measured using Community Noise Equivalent Level (CNEL), which is the 24-hour average noise level with a +5 dBA penalty for noise occurring from 7:00 p.m. to 10:00 p.m. and a +10 dBA penalty for noise occurring from 10:00 p.m. to 7:00 a.m. (Caltrans 2013). Noise levels described by Ldn and CNEL usually differ by about 1 dBA. The relationship between the peak-hour Leq value and the Ldn/CNEL depends on the distribution of traffic during the day, evening, and night. Quiet suburban areas typically have CNEL noise levels in the range of 40 to 50 dBA, while areas near arterial streets are in the 50 to 60-plus CNEL range. Normal conversational levels are in the 60 to 65 dBA Leq range; ambient noise levels greater than 65 dBA Leq can interrupt conversations (Federal Transit Administration 2018).
b. Vibration
Groundborne vibration of concern in environmental analysis consists of the oscillatory waves that move from a source through the ground to adjacent structures. The number of cycles per second of oscillation makes up the vibration frequency, described in terms of Hertz. The frequency of a vibrating object describes how rapidly it oscillates. The normal frequency range of most groundborne vibration that can be felt by the human body starts from a low frequency of less than 1 Hertz and goes to a high of about 200 Hertz (Crocker 2007).

While people have varying sensitivities to vibrations at different frequencies, in general they are most sensitive to low-frequency vibration. Vibration in buildings, such as from nearby construction activities, may cause windows, items on shelves, and pictures on walls to rattle. Vibration of building components can also take the form of an audible low-frequency rumbling noise, referred to as groundborne noise. Groundborne noise is usually only a problem when the originating vibration Environmental Impact Analysis
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spectrum is dominated by frequencies in the upper end of the range (60 to 200 Hertz), or when foundations or utilities, such as sewer and water pipes, physically connect the structure and the vibration source (Federal Transit Administration 2018). Although groundborne vibration is sometimes noticeable in outdoor environments, it is almost never annoying to people who are outdoors. The primary concern associated with vibration is that it can be intrusive and annoying to building occupants and vibration-sensitive land uses.

Vibration energy spreads out as it travels through the ground, causing the vibration level to diminish with distance away from the source. High-frequency vibrations diminish more rapidly than low frequencies, so low frequencies tend to dominate the spectrum at large distances from the source.

Discontinuities in the soil strata can also cause diffractions or channeling effects that affect the propagation of vibration over long distances (Caltrans 2020). When a building is impacted by vibration, a ground-to-foundation coupling loss will usually reduce the overall vibration level.

However, under rare circumstances, the ground-to-foundation coupling may amplify the vibration level due to structural resonances of the floors and walls.

Vibration amplitudes are usually expressed in peak particle velocity (PPV) or root mean squared vibration velocity. The PPV and root mean squared velocity are normally described in inches per second (in/sec) PPV is defined as the maximum instantaneous positive or negative peak of a vibration signal. PPV is often used in monitoring of blasting vibration because it is related to the stresses that are experienced by buildings (Caltrans 2020). c. Existing Noise Setting
Sensitive Receivers
Noise exposure goals for various types of land uses reflect the varying noise sensitivities associated with those uses. The San Leandro General Plan Environmental Hazards Element identifies noisesensitive land uses as residential land uses, schools, and open space and recreation areas (City of San Leandro 2016a). The nearest sensitive receiver is a residential subdivision located approximately 510 feet northeast of the project site boundary.

The residential subdivision approximately 510 feet northeast of the project site boundary is also the nearest vibration sensitive receiver for human annoyance. The nearest structure to the project site where vibration could occur is approximately 10 feet north and south of the site boundary.

Ambient Noise Setting
The dominant sources of noise in the project site vicinity is vehicular traffic on Doolittle Drive, train operations on nearby railroad tracks, and aircraft noise from the Oakland International Airport.

The easternmost portion of the project site is within the 60 DBA CNEL contour of the Oakland International Airport (Alameda County Community Development Department 2010). According to the San Leandro General Plan Environmental Hazards Element, the eastern most of area of the project site is within the 60 dBA CNEL contour of Doolittle Drive (City of San Leandro 2016a). The easternmost area of the project site experiences noise levels of approximately 60 to 65 dBA CNEL because of traffic noise on Doolittle Drive and aircraft noise at Oakland International Airport.

The central and western areas of the project site are not within noise contours of the Oakland International Airport (Alameda County Community Development Department 2010). The central and western areas of the project site are also not near through roadways. Therefore, it is reasonable to assume noise levels in these areas of the project site are generally below or near 60 dBA CNEL.

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However, there is an active railroad corridor approximately 400 feet east of the project site. When trains pass by the site, there would be a temporary increase in ambient noise levels in the project site. According to the Federal Transit Administration, diesel locomotives traveling at speeds of 50 miles per hour generate noise levels of approximately 92 dBA when measured approximately 50 feet from the railroad track (Federal Transit Administration 2018). Based on an attenuation rate of 3 dBA per doubling of distance from the source, trains using the tracks east of the project site would generate noise levels of approximately 83 dBA at the eastern project site boundary. In the central areas of the project site (approximately 800 feet from the tracks), train noise would be approximately 80 dBA. Additionally, although the project site is not in the noise contours of the Oakland International Airport, freight aircraft do arrive and depart the airport using routes that pass over or near the project site (Alameda County Community Development Department 2010). Similar to intermittent train operations, these freight aircraft operations would cause a temporary increase in ambient noise levels in the project site.

The nearest sensitive receptors to the project site, which are the residences to the northeast, are within the 60 dBA CNEL contour of Interstate 880 (City of San Leandro 2016a). However, Interstate 880 is east of these sensitive receptors; Interstate 880 does not separate the project from these sensitive receptors. However, there are multiple other residential buildings between these receptors and Interstate 880 that would cause freeway traffic noise level to attenuate before reaching these sensitive receptors, and this attenuation is not accounted for in the noise contour mapping of the General Plan. Accordingly, ambient noise levels at the nearest sensitive receptors to the project site are likely slightly below 60 dBA.

4.3.2 Regulatory Setting
a. State Regulations
California regulates freeway noise, sets standards for sound transmission, provides occupational noise control criteria, identifies noise standards, and provides guidance for local land use compatibility. California law requires each county and city to adopt a General Plan that includes a Noise Element prepared based on guidelines adopted by the Governor’s Office of Planning and Research. The purpose of the Noise Element is to limit the exposure of the community to excessive noise levels. CEQA requires known environmental effects of a project be analyzed, including environmental noise impacts, including airport noise.

California Building Code
California Code of Regulations (CCR) Title 24, Building Standards Administrative Code, Part 2 and the California Building Code codify the State noise insulation standards. These noise standards apply to new construction in California to control interior noise levels as they are affected by exterior noise sources. The regulations specify that acoustical studies must be prepared when noise-sensitive structures, such as residential buildings, schools, or hospitals, are developed near major transportation noise sources, and where such sources create an exterior noise level of 60 dBA CNEL or higher. Acoustical studies that accompany building plans for noise-sensitive land uses must demonstrate that the structure has been designed to limit interior noise in habitable rooms to an acceptable level of 45 dBA CNEL.

The 2022 State of California’s Green Building Standards Code contains mandatory measures for nonresidential building construction in Section 5.507 on Environmental Comfort. These noise standards are applied to new construction in California for controlling interior noise levels resulting from Environmental Impact Analysis
Noise and Vibration
Environmental Impact Report 4.3-5
exterior noise sources. The regulations specify that acoustical studies must be prepared when nonresidential structures are developed in areas where the exterior noise levels exceed 65 dBA CNEL, such as within the noise contour of an airport, freeway, or railroad.

California General Plan Guidelines
The California General Plan Guidelines, published by the Governor’s Office of Planning and Research, indicate acceptable, specific land use types in areas with specific noise exposure. The guidelines also offer adjustment factors that may be used to arrive at noise acceptability standards that reflect the noise control goals of the community, the particular community’s sensitivity to noise, and the community’s assessment of the relative importance of noise pollution. These guidelines are advisory, and local jurisdictions have the responsibility to set specific noise standards based on local conditions. See the discussion below, under the “City of San Leandro General Plan,” for the compatibility guidelines adopted by the City.
b. Local Regulations
City of San Leandro General Plan
The San Leandro 2035 General Plan was adopted by the City of San Leandro on in September 2016.

Noise and vibration are addressed in the Environmental Hazards Element, which is Chapter 7 of the General Plan. The Environmental Hazards Element provides goals, objectives, policies, and actions to help protect citizens of San Leandro from excessive and incompatible noise and vibration.

General Plan goals and policies applicable to the proposed project are included below:

Goal EH-7: Ensure that noise associated with the day-to-day activities of San Leandro residents and businesses does not impede the peace and quiet of the community.

Policy EH-7.1: Noise Compatibility Table. Ensure that potential noise impacts are considered when new development is proposed. Projects that could significantly increase noise levels should incorporate mitigation measures to reduce such impacts. Apply the standards shown in Chart 7-2 when evaluating applications for future development. Chart 7-2 specifies the maximum noise levels that are normally acceptable, conditionally acceptable, and normally unacceptable for new development.

Policy EH-7.3: Residential Exterior Noise Standard. Strive to maintain an exterior noise level of no more than 60 dB Ldn in residential areas. Recognizing that some San Leandro neighborhoods already exceed this noise level, encourage a variety of noise abatement measures that benefit these areas.

Policy EH-7.4: Degradation of Ambient Noise Levels. If a neighborhood is well within acceptable noise standards, do not automatically allow noise levels to degrade to the maximum tolerable levels shown in Chart 7-2. A project’s noise impacts should be evaluated based on the potential for adverse community response, as well as its conformance to the adopted standards. For CEQA purposes, an increase of 3 dB Ldn should generally be considered a significant adverse impact.

Policy EH-7.5: Noise-Sensitive Uses. Discourage noise-sensitive uses such as hospitals, schools, and rest homes from locating in areas with very high noise levels unless sufficient noise mitigation and buffering can be provided. Conversely, discourage new uses likely to produce City of San Leandro
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high levels of noise from locating in areas where noise-sensitive uses would be adversely impacted.

Policy EH-7.9: Vibration Impacts. Limit the potential for vibration impacts from construction and ongoing operations to disturb sensitive uses such as housing and schools.

Goal EH-8: Reduce the effects of surface transportation noise, including vehicular noise and noise associated with railroad and BART traffic.

Policy EH-8.3: Site Planning and Building Design. Require new development or redevelopment near freeways, arterials, BART, and major bus routes to incorporate site planning and architectural design measures that reduce the exposure of future building occupants to traffic noise.

Chart 7-2 in Environmental Hazards Element provides noise compatibility guidelines for land uses based on State of California guidelines. The guidelines identify those areas where various uses are acceptable, conditionally acceptable, normally unacceptable, or clearly unacceptable based on ambient noise levels. Chart 7-2 of the General Plan is provided as Figure 4.3-1.

San Leandro Municipal Code
Chapter 4-1 of the San Leandro Municipal Code provides restrictions and regulations for noise within San Leandro. The noise-related code does not contain numerical noise level limits and is aimed more at prohibiting “disturbing, excessive and offensive noises” so as to abate public nuisances relative to noise. The following section forms the framework for these nuisance-related restrictions.

Section 4-1-110 of the San Leandro Municipal Code establishes a general prohibition of noise which causes discomfort or annoyance to reasonable persons of normal sensitivity. The factors which should be considered in determining whether a violation of this section exists include but are not limited to the sound level of the objectionable and ambient noise, the proximity of the noise to residential property, and the duration of the noise.

Section 4-1-115 of the San Leandro Municipal Code prohibits certain acts related to noise, such as construction-related noise near residential uses outside of the hours of 7 a.m. and 7 p.m. on weekdays and 8 a.m. and 7 p.m. on weekends. Noise within public parks and noise that conflicts with residential uses is also prohibited.

Section 4-1-505 of the San Leandro Municipal Code restricts the hours of operation of vehicles with sound amplifying equipment to 10:00 a.m. through 7:00 p.m. Pursuant to Section 4-1-505, the volume of amplified sound shall be controlled so that it will not be audible for a distance in excess of 200 feet from the vehicle and so that said volume is not unreasonably loud, raucous, jarring, disturbing, or a nuisance to persons within the area of audibility.

Neither the City of San Leandro nor the County of Alameda has specific and/or quantitative regulatory standards for construction or operational vibration sources. San Leandro Zoning Code Part IV, Article 16, Division 3, Provision 4-1670B, Vibration, requires that no use, activity, or process produce vibrations that are perceptible without instruments by a reasonable person at the property lines of a site. This performance standard applies to all land use classifications in all zoning districts.

Environmental Impact Analysis
Noise and Vibration
Environmental Impact Report 4.3-7

4.3.3 Impact Analysis
a. Methodology
The analysis of noise impacts considers the effects of both temporary construction-related noise and long-term noise associated with operation of the project. The potential for short-term construction and long-term operational noise impacts was assessed at noise-sensitive receptors closest to the project site (i.e., the residences approximately 510 feet northeast of the project site).

Construction Noise
Construction noise levels in the project vicinity would fluctuate depending on the particular type, number, and duration of usage for the various pieces of equipment. The effects of construction noise depend largely on the types of construction activities occurring on a given day, noise levels generated by those activities, distances to noise-sensitive receptors, and the existing ambient noise environment in the vicinity of the receptors. Construction generally occurs in several discrete stages, with each stage varying the equipment mix and equipment usage rates. These construction stages alter the characteristics of the noise environment generated on the project site and in the surrounding community for the duration of the construction stage. Construction stages for development of this project were assumed to include demolition, site preparation, grading, building construction, paving and painting (architectural coating).

For purposes of construction noise assessment, construction equipment can be considered to operate in two modes, stationary and mobile. As a general rule, stationary equipment operates in one location for one or more days at a time, with either a fixed-power operation, such as, pumps, generators, and compressors, or a variable noise operation, such as pile drivers, rock drills, and pavement breakers. Mobile equipment moves around the construction site with power applied in cyclic fashion, such as bulldozers, graders, and loaders (Federal Transit Administration 2018). Noise impacts from stationary equipment are assessed from the center of the equipment, while noise impacts for mobile construction equipment are assessed from the center of the equipment activity area (i.e., construction site).

Although specific construction requirements for build-out of the proposed project are currently unknown, it is anticipated that typical construction sources such as backhoes, compressors, bulldozers, excavators, loaders and other related equipment would be utilized during project construction, based on input from the project applicant. Based on the reference noise levels, usage rates, fleet mixes and operational characteristics discussed above, overall hourly average noise levels attributable to project construction activities were calculated for the project. Construction noise levels were predicted using reference noise emission data and operational parameters contained in the FHWA Roadway Construction Noise Model, Version 1.1 (Reherman, et. al. 2006), and the Federal Transit Administration guidance manual (Federal Transit Administration 2018).

Vibration
Construction activities on the project site may result in varying degrees of temporary ground vibration, depending on the specific construction equipment used and operations involved.

Groundborne vibration attenuates rapidly, even over short distances. The attenuation of groundborne vibration as it propagates from source to receptor through intervening soils and rock strata can be estimated with expressions found in Federal Transit Administration and Caltrans guidance.

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Figure 4.3-1 City of San Leandro Land Use Compatibility Noise Guidelines Source: City of San Leandro 2016
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Noise and Vibration
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Construction vibration levels were calculated at the sensitive receptor nearest to the project site, residences to the northeast, to determine whether project construction would generate vibration levels that would cause human annoyance at the receptors or physical damage to nearby structures.

Vibration levels were estimated for construction equipment expected to be used during project construction and were based on the vibration source levels for construction equipment from the Federal Transit Administration Transit Noise and Vibration Assessment (2018). Construction vibration levels were then calculated at distances of approximately 510 feet (the distance between the location of on-site vibratory equipment and the residential receptors) and at 30 feet (the distance between the location of on-site vibratory equipment, considering site constraints, and the nearest structures).

Operational Noise
Mechanical equipment associated with the operation of warehouse uses generally consists of heating, ventilation, and air-conditioning (HVAC) equipment. Mechanical equipment is often mounted on rooftops, partially enclosed at grade adjacent to buildings, or located within mechanical equipment rooms. Noise levels generated by the HVAC and other mechanical equipment vary substantially depending on unit size, efficiency, location, type of rotating or reciprocating components, and orientation of openings. For the analysis in the EIR, it was assumed up to 14 rooftop HVAC units would operate on-site. The rationale for this assumption is described in Appendix E. Each HVAC unit was assumed to be at a height of approximately 4 feet above the rooftop of the proposed building. Acoustical modelling software, specifically CadnaA, was used to model the noise associated with HVAC operation.

Additionally, CadnaA was used to model noise that would result from truck operations on the project site, given the project is a warehouse that includes docks for trucks. Trucks were modelled at various on-site locations, including along the eastern site boundary, closest to the nearest sensitive receptors. The noise reference value used to model trucks was 79 dBA at 50 feet away. As described in Appendix E, this sound level was determined by looking at a wide variety of truck activity, such as truck movement, air brakes, back-up alarms, and coupling/decoupling, and distilling it to a single conservative maximum level and spectrum. The height of a truck source for all truck activity was modelled at a conservative height of 8 feet above grade. The full range of model inputs and assumptions used for on-site truck noise is described in Appendix E.

Long-term operation of the proposed project would generate an increase in traffic volumes on the local roadway network in the project vicinity. Consequently, noise levels from this vehicular and truck traffic along affected roadway segments would have the potential to increase. To assess the effect of project-generated traffic increases, traffic noise levels were modeled for roadway segments in the project vicinity based on the FHWA Highway Traffic Noise Model prediction methodologies (Reherman, et. al. 2006).

Traffic volumes and the distribution of those volumes were obtained from the forecasted traffic volumes in the City’s General Plan EIR. Average daily trip volumes resulting from the project were calculated by summing all traffic movements for both the a.m. and p.m peak hours, existing on or turning on to a particular roadway segment during the peak-hour and multiplying the total peakhour volume by a “k-factor” of 5. Peak hours consist of 7:00 to 9:00 a.m and 4:00 to 6:00 p.m.

Average vehicle speeds on local area roadways were assumed to be consistent with posted speed limits and remain as such with or without implementation of the proposed project.

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b. Thresholds of Significance
According to CEQA Guidelines Appendix G, impacts related to noise and vibration are considered significant if implementation of the proposed project would:

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

2. Result in generation of excessive groundborne vibration or groundborne noise levels; or

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

Construction Noise
The City of San Leandro has not adopted specific quantitative standards or limits related to construction noise. However, Section 4-1-115 of the San Leandro Municipal Code prohibits certain acts related to noise, such as construction-related noise near residential uses outside of the hours of 7 a.m. and 7 p.m. on weekdays and 8 a.m. and 7 p.m. on weekends. Noise within public parks and noise that conflicts with residential uses is also prohibited. Policy EH-7.4 of the General Plan states that an increase of 3 dB Ldn at residential land uses is a significant adverse impact for purposes of CEQA. Therefore, construction noise would be considered significant if it occurs outside of the hours specified in the San Leandro Municipal Code and would also increase noise levels by 3 dBA or greater at the nearest residence to the project site.

In addition to the San Leandro Municipal Code and the City’s General Plan policies, the Federal Transit Administration has developed guidance for determining if construction of a project would expose various land uses to significant noise levels or if a project would result in a substantial temporary increase in noise levels. Based on Federal Transit Administration guidance, a significant impact would occur if project-generated construction noise exceeds the 8-hour 80 dBA Leq noise limit at residences (Federal Transit Administration 2018).

On-Site Operation Noise
As described in Appendix E, on-site HVAC noise would be considered significant if it exceeds 50 dBA.

Noise from on-site truck operations would be considered if it exceeds 55 dBA. As described in Appendix E, these thresholds are based on maintaining existing noise levels at the residences northeast of the project site. By maintaining existing noise levels at the residences northeast of the project site, this threshold would also be consistent with Policy EH-7.4 of the General Plan, which states that an increase of 3 dB Ldn at residential land uses is a significant adverse impact for purposes of CEQA.

Traffic Noise
Most people can detect changes in sound levels of approximately 3 dBA under normal, quiet conditions, and changes of 1 to 3 dBA are detectable under quiet, controlled conditions. Changes of less than 1 dBA are usually indiscernible to most people. A change of 5 dBA is readily discernible to most people in an exterior environment. Based on this, the following thresholds of significance are used to assess traffic noise impacts at the nearest sensitive receptors:
 Greater than 1.5 dBA increase for ambient noise environments of 65 dBA CNEL and higher; Environmental Impact Analysis
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 Greater that 3 dBA increase for ambient noise environments of 60–64 CNEL; and  Greater than 5 dBA increase for ambient noise environments of less than 60 dBA CNEL.

Vibration
The City of San Leandro has not adopted a significance quantitative threshold to assess vibration impacts during construction and operation. However, San Leandro Zoning Code Part IV, Article 16, Division 3, Provision 4-1670B, Vibration, requires that no use, activity, or process produce vibrations that are perceptible without instruments by a reasonable person at the property lines of a site.

Caltrans recommends a 0.2 in/sec PPV as the threshold of human annoyance for vibration (Caltrans 2020). Accordingly, vibration would be considered significant if it results in vibration levels of 0.2 in/sec or greater at the project site boundary.

In addition to human annoyance threshold, this analysis also considers the damage that groundborne vibration could do to existing structures in the project area. Based on information contained in the 2018 FTA Transit Noise and Vibration Impact Assessment Manual, groundborne vibration levels that could induce potential architectural damage to buildings are identified in Table 4.3-1. Based on FTA recommendations, limiting vibration levels to below 0.5 in/sec peak particle velocity (PPV) at reinforced concrete, steel, or timber with no plaster (which would apply to the industrial structures nearest the project site) would prevent architectural damage. If vibration levels exceed 0.5 in/sec PPV at the nearest structures, impacts would be considered potentially significant.

Table 4.3-1 Groundborne Vibration Architectural Damage Thresholds Building Category PPV (in/sec)
Reinforced concrete, steel, or timber (no plaster) 0.5
Engineered concrete and masonry (no plaster) 0.3
Non-engineered timber and masonry buildings 0.2
Buildings extremely susceptible to vibration damage 0.12 Source: FTA 2018
PPV = peak particle velocity
in/sec = inches per second
Threshold 1: Would the project result in generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
IMPACT NOI-1 CONSTRUCTION AND OPERATION OF THE PROPOSED PROJECT WOULD GENERATE NOISE, INCREASING AMBIENT NOISE LEVELS NEAR THE PROJECT SITE. CONSTRUCTION NOISE WOULD BE TEMPORARY AND BELOW THRESHOLDS OF SIGNIFICANCE. TRAFFIC NOISE DURING OPERATION WOULD ALSO BE BELOW SIGNIFICANCE THRESHOLDS; HOWEVER, ON-SITE OPERATIONAL NOISE WOULD EXCEED THRESHOLDS ESTABLISHED FOR THE NEAREST SENSITIVE RECEPTOR. IMPACTS WOULD BE POTENTIALLY SIGNIFICANT BUT MITIGABLE.

Project Construction
Project construction would consist of several different stages, including demolition, site preparation, grading, building construction, and paving. These construction activities or stages can generate City of San Leandro
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noise levels ranging from 72 dBA to 84 dBA at distances of approximately 50 feet away from the construction site (Reherman, et. al. 2006). These noise levels would attenuate before reaching the nearest sensitive receptor, approximately 510 feet northeast of the project site. As described in the analysis methodology above, project construction noise was modeled at this nearest sensitive receptor. Results of the modeling are shown in Table 4.3-2, below.

Table 4.3-2 Estimated Noise Levels by Project Construction Phase Construction Phase
Reference Noise Level at 50 Feet
(DBA Leq)
Noise Level at Nearest Sensitive Receptor
(DBA Leq)
Demolition 82 62
Site Preparation 83 63
Grading 84 64
Building Construction 78 58
Paving 78 58
Source: Federal Highway Administration Roadway Construction Noise Model (see Appendix F) As shown in Table 4.3-2, construction noise levels would be loudest during the grading stage. Noise levels during this stage would be approximately 64 DBA Leq at the nearest sensitive receptor. The estimated noise level of 64 DBA Leq is well below the Federal Transit Administration construction noise standard, which is 80 DBA Leq. In addition to being well below the Federal Transit Administration standard, project construction activities must also comply with Section 4-1-115 of the San Leandro Municipal Code, prohibiting construction activities outside of the hours of 7 a.m. and 7 p.m. on weekdays and 8 a.m. and 7 p.m. on weekends. This would prevent construction noise from reaching the nearest residence at night when most people are at home and sleeping and most sensitive to noise. Accordingly, because construction noise levels would be below thresholds of significance (i.e., 80 dBA Leq) and occur when most people are awake or away at work, school, or other daytime activities out of the residence, project construction noise impacts would be less than significant.

On-Site Project Operations
Routine or typical operations at the project site would generate noise. Examples of operational noise include rooftop HVAC equipment, trucks maneuvering or otherwise operating on-site, employees talking or shouting, garage doors rolling up or closing, among many other activities.

Generally, the highest noise levels would result from HVAC equipment and trucks operating on-site, as these things generate higher noise levels than employees having a discussion outside of the proposed building, for example.

Rooftop HVAC equipment produces noise that is nominally steady in nature, and hence will not vary substantially over time. According to the noise study prepared for project operations (Appendix E), rooftop HVAC noise levels would be up to approximately 50 dBA on the project site. However, as shown in Figure 4.3-2, below, these noise levels would quickly attenuate to below 40 dBA outside of the project site. Because project HVAC noise levels would attenuate to 40 dBA or less proximate to the project site, HVAC noise levels would attenuate even more at distances of approximately 510 feet from the project site, which is where the nearest sensitive receptor is located. Therefore, rooftop HVAC noise from project operations would attenuate below ambient noise levels at the nearest sensitive receptor, resulting in no discernible change in noise level at the receptor.

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On-site truck activity would routinely generate engine noises, as well as noise associated with air brakes, back-up alarms, and coupling/decoupling of trailers. When distilled down to a single maximum noise level, truck noise in typical dock and trailer parking areas can routinely produce maximum sound levels of approximately 79 dBA at distances of approximately 50 feet away. In the rare event that two trucks operate in the same spot and time, noise levels would increase by approximately 3 dBA (Ostergaard Acoustical Associates 2024; Appendix E).

Trucks would operate at various locations on the project site, which would affect the distance between the truck activity and nearest sensitive receptor, as well as the number and types of intervening structures between the trucks and receptor. The on-site location where trucks would have the potential to result in the highest noise levels at the nearest sensitive receptor is along the northern side of the proposed building at proposed loading docks. When trucks operate in this area of the project site, noise levels at the nearest sensitive receptor would be approximately 56 dBA.

The estimated 56 dBA noise level at the nearest sensitive receptor includes on-site truck activity noise combined with rooftop HVAC noise. Truck activities on other areas of the site would generate noise levels below 56 dBA at the nearest sensitive receptor (Ostergaard Acoustical Associates 2024; Appendix E). Figure 4.3-3, Figure 4.3-4, and Figure 4.3-5 show noise levels associated with truck activity at different areas of the project site.

Noise levels of 56 dBA at the nearest residence would exceed the significance threshold of 55 dBA.

Because on-site operational noise would exceed the threshold of 55 dBA, impacts would be potentially significant, and mitigation is required.

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Figure 4.3-2 Estimated Rooftop HVAC Noise Levels near Project Site Source: Evaluation of Site Sound Emissions: Ostergaard Acoustical Associates 2024 (Appendix E) Environmental Impact Analysis
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Figure 4.3-3 Estimated Truck Operations and HVAC Noise Levels near Project Site: North Side of Building Source: Evaluation of Site Sound Emissions: Ostergaard Acoustical Associates 2024 (Appendix E) City of San Leandro
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Figure 4.3-4 Estimated Truck Operations and HVAC Noise Levels near Project Site: East Side of Building Source: Evaluation of Site Sound Emissions: Ostergaard Acoustical Associates 2024 (Appendix E) Environmental Impact Analysis
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Figure 4.3-5 Estimated Truck Operations and HVAC Noise Levels near Project Site: South Side of Building Source: Evaluation of Site Sound Emissions: Ostergaard Acoustical Associates 2024 (Appendix E) City of San Leandro
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Traffic Noise
Based on the Transportation Impact Analysis prepared for the proposed project by Kimley-Horn and Associates in 2024 (see Appendix C), the proposed project would generate up to 1,543 additional daily vehicle trips on project area roads. These additional trips would increase traffic noise on roadways. Specifically, the existing average daily trips on Doolittle Drive, between Adams Avenue to Davis Street, is 29,400 trips. The addition of 1,543 daily vehicle trips would result in an increase in traffic noise that would be approximately 0.2 dBA CNEL. As stated in the City of San Leandro General Plan Update Draft EIR (City of San Leandro 2016b), the existing ambient noise level for Doolittle Drive, between Adams Avenue to Davis Street, is 71.8 dBA at 50 feet. The estimated 0.2 dBA CNEL increase resulting from project trips on this street would be below 1.5 dBA, which is the significance threshold for roadways with ambient noise levels of 65 dBA CNEL or higher (Appendix F).

Accordingly, traffic noise would result in less than significant noise impacts.

Mitigation Measures
NOI-1 On-Site Noise Barrier
The applicant shall install a permanent noise barrier along the property boundary that is oriented in a northwest-southeast direction and separates the project site from APN 77A-742-3-2. The noise barrier shall be a solid fence or wall design and no less than 8 feet tall. The noise barrier shall be no less that 140 feet in length, beginning at the southernmost end of this property boundary.

Significance After Mitigation
CadnaA was used to model noise that would result from truck operations on the project site with implementation of Mitigation Measure NOI-1 requiring installation of an 8-foot-tall solid sound fence along 140 feet of the northeastern property boundary. With a sound fence in this location, onsite noise levels at the nearest sensitive receptor would be reduced to 50 dBA. Noise levels of 50 dBA would be below the threshold of 55 dBA. Accordingly, with implementation of Mitigation Measure NOI-1, impacts would be less than significant.

Threshold 2: Would the project result in generation of excessive groundborne vibration or groundborne noise levels?
IMPACT NOI-2 OPERATION OF THE PROJECT WOULD NOT GENERATE SUBSTANTIAL GROUNDBORNE VIBRATION, BUT PROJECT CONSTRUCTION WOULD GENERATE GROUNDBORNE VIBRATION. CONSTRUCTION VIBRATION LEVELS WOULD EXCEED THRESHOLDS OF STRUCTURAL DAMAGE AT NEARBY EXISTING BUILDINGS.

IMPACTS WOULD BE POTENTIAL SIGNIFICANT BUT MITIGABLE.

Project Construction
Project construction activities would have the potential to generate ground-borne vibration affecting nearby receptors. Construction activities known to generate excessive groundborne vibration, such as pile driving and blasting, would not be used to construct the proposed project.

However, project construction would use heavy machinery that generates vibration, notably a vibratory roller used during on-site paving activities. The FTA has published the vibration levels for typical construction equipment at distances of 25 feet from the equipment (FTA 2018). These vibration levels include:

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 Vibratory roller: 0.21 in/sec PPV
 Large bulldozer: 0.089 in/sec PPV
 Loaded trucks: 0.076 in/sec PPV
 Small bulldozer: 0.003 in/sec PPV
 Static roller: 0.050 in/sec PPV
The vibratory roller would create the most vibration at 0.21 in/sec PPV at 25 feet away, which is

0.01 in/sec PPV above the threshold of significance for human annoyance. With Caltrans recommending a 0.2 in/sec PPV as the threshold of human annoyance for vibration (Caltrans 2020),vibration levels from project construction would be well below this threshold because the nearest residential receptors are approximately 510 feet away. As shown in Table 4.3-3, below, vibration levels are well below 0.2 at distances of only 35 feet away from the project site (Appendix F).

Although construction vibration would not exceed levels of annoyance at the nearest residences to the project site, vibration levels would increase at the nearest structures to the site, regardless of whether or not occupants would be annoyed by vibration. Based on the project site plan, it is assumed the vibratory roller would be used within 10 feet of the nearest off-site industrial structures to the north and west of the project site during paving activities. Table 4.3-3 shows the estimated vibration levels for various pieces of construction equipment, including a vibratory roller, at the industrial structure approximately 10 feet away. Table 4.3-3 also shows the estimated vibration levels at other existing nearby industrial structures.

Table 4.3-3 Estimated Construction Vibration Levels (in/sec PPV) Equipment
Reference Level
25 feet
Industrial
Buildings to the
North and West
10 feet
Industrial
Building to the
South
35 feet
Industrial
Building to the
East
95 feet
Vibratory Roller 0.210 0.830 0.127 0.028
Large Bulldozer 0.089 0.352 0.054 0.012
Loaded Trucks 0.076 0.300 0.046 0.010
Small Bulldozer 0.003 0.198 0.030 0.007
Static Roller 0.050 0.012 0.002 <0.001
Threshold for Structural Damage - 0.5 0.5 0.5
Threshold Exceeded? - Yes No No
Source: FTA 2018 (see Appendix F)
PPV = peak particle velocity
in/sec = inches per second
As shown in Table 4.3-3, vibration levels during project construction would exceed the threshold for structural damage at the existing industrial buildings approximately 10 feet away from the project site. Impacts would be potentially significant and implementation of Mitigation Measure NOI-2 is required.

Project Operation
Project operation activities would not have the potential to generate substantial groundborne vibration. Vibration levels during project operation would result in less than significant impacts.

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Mitigation Measures
NOI-2 Static Roller Requirement
The project applicant and/or its construction contractors shall use of a static roller in lieu of a vibratory roller for paving activities within 15 feet of the existing off-site buildings to the north and west of the project site. City staff shall verify that this requirement is incorporated into construction plans prior to issuance of a building permit and verified in the field.

Significance After Mitigation
Mitigation Measure NOI-2 would reduce vibration impacts by requiring use of a static roller when conducting paving activities near existing buildings. As shown in Table 4.3-3, vibration levels from a static roller at 10 feet away would be 0.012 in/sec PPV, which is below the threshold of 0.5 in/sec PPV. Therefore, the impact related vibration-induced structural damage would be less than significant with mitigation implemented.

Threshold 3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
IMPACT NOI-3 THE PROJECT WOULD RESULT IN EMPLOYMENT OPPORTUNITIES WITHIN AREAS THAT OCCUR INSIDE OF NOISE CONTOURS OF THE OAKLAND INTERNATIONAL AIRPORT. HOWEVER, THE PROJECT SITE WOULD BE WITHIN THE 60 DBA NOISE CONTOUR, AND 60 DBA IS NOT AN EXCESSIVE NOISE LEVEL. THEREFORE,

PEOPLE WORKING IN THE PROJECT SITE WOULD NOT BE EXPOSED TO EXCESSIVE AIRPORT NOISE, AND IMPACTS WOULD BE LESS THAN SIGNIFICANT.

As described above in Section 4.3.1, Setting, the easternmost portion of the project site is within the 60 DBA CNEL contour of the Oakland International Airport (Alameda County Community Development Department 2010). According to the Occupational Safety and Health Administration, 60 dBA is the noise level typical of a conversation (Occupational Safety and Health Administration 2023). Conversational noise is common and not excessive or damaging to hearing. Therefore, people working in the project area would not be exposed to excessive airport noise levels. Impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.3.4 Cumulative Impacts
A project’s environmental impacts are “cumulatively considerable” if the “incremental effects of an individual project are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects” (CEQA Guidelines Section 15065[a][3]). The geographic scope for cumulative noise impacts is limited to the area within approximately 600 feet of the project site. This geographic scope is appropriate for noise Environmental Impact Analysis
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impacts, because as discussed above in Impact NOI-1, project noise would attenuate close to existing ambient levels at sensitive receptors at distances of 510 feet from the project site. By extending the cumulative impacts assessment area to 600 feet, project noise would attenuate and not combine with other more distance noise sources.

Several of the cumulative development projects listed in Table 3-1 are within the geographic scope of the cumulative impacts analysis. For example, the project identified as 1091 Doolittle Drive is approximately 600 feet southwest of the project site. If construction of this project and the proposed project occur concurrently, construction equipment noise could be louder than if either of these projects were constructed at a separate point in time. When two identical sources of noise operate concurrently, such as two bulldozers, the increased noise from the activity is approximately 3 dBA. However, because cumulative projects are even farther from the nearest sensitive receptors to the project site than the project site is to these receptors, increase cumulative noise would attenuate before reaching these receptors. For example, the noise from equipment operated at the aforementioned cumulative project at 1091 Doolittle Drive would attenuate before reaching the project site. Therefore, noise from cumulative projects would be less than the construction noise on-site, resulting in no discernible increase in noise at the nearest sensitive receptors than would occur from the proposed project, alone. Similarly, vibration from construction equipment would also attenuate. Accordingly, cumulative noise and vibration impacts resulting from construction activities would be less than significant.

Ambient noise levels in the project area, including at the sensitive residential receptors closest to the project site are effectively the result of operation of past and current projects in the area, including businesses, other residences, aircraft operations, roadways, railroad, and other prominent noise sources in the area. Despite the abundance of noise sources in the area, noise levels at the nearest sensitive receptors to the project site are generally within the 50 to 60 dBA range, which is comparable to noise levels of a conversation. The reasonably foreseeable future projects listed in Table 3-1 of this EIR would potentially increase ambient noise levels in the cumulative assessment area, depending on whether or not the noise levels from individual projects exceed or are equal to ambient noise levels. However, the projects listed in Table 3-1 are generally further from the nearest sensitive receptors to the project site than the project site is to these receptors. Therefore, on-site operational noises generated from these projects would attenuate to below existing ambient noise levels at the sensitive residential receptors. The reasonably foreseeable future projects would generate additional vehicle trips, which could increase traffic noise. However, the future projects are scattered throughout the cumulative impacts assessment area, which means that the vehicle trips would use a variety of roadways and not entirely pass by the nearest sensitive receptors to the project site. Additionally, a doubling of traffic volumes is generally required for a discernible difference in ambient noise levels from roadways. Traffic noise at the nearest sensitive receptors to the project site is affected by Interstate 880, which has tens of thousands of vehicle trips per day. Reasonably foreseeable future projects would not double the amount of vehicle trips in the area given that Interstate 880 is in the area. Cumulative impacts from operation of cumulative projects would be less than significant.

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4.4 Transportation
This section of the EIR analyzes transportation impacts associated with the proposed project. This section describes the local transportation network, including active transportation modes (i.e., pedestrian and bicycle), and describes vehicle miles traveled (VMT). This section of the EIR is based on a Transportation Impact Analysis prepared for the project by Kimley Horn. The Transportation Impact Analysis, which is dated January 2024, is provided as Appendix C to this EIR.

4.4.1 Setting
a. Roadway Network
The major roadways in the vicinity of the project site include Interstate 880 and a network of arterial, collector, and local streets. The major roadways in the vicinity of the project site are described below.
 Interstate 880. Interstate 880 is a north-south freeway that connects Interstate 280 and State Route 17 to the south to Interstate 80 and Interstate 580 to the north. Within the project area, the roadway consists of six southbound lanes (including one HOV lane) and four northbound lanes. Interstate 880 serves as regional access to the project site. The posted speed limit on I880 within the project area is 65 miles per hour.  Doolittle Drive. Doolittle Drive is a north-south arterial road. It connects to Otis Drive and Fernside Boulevard to the north and Belvedere Avenue to the south. The roadway within the project area is two lanes in each direction and has a center two-way left-turn lane (TWLTL).

Doolittle Drive is State Route 61. It serves mainly industrial uses along the corridor. Within the project area, the speed limit on Doolittle Drive is 45 miles per hour.  Davis Street. Davis Street is a four-lane, east-west arterial which runs between Business Center Drive to the west and E 14th Street to the east. The roadway serves residential and commercial uses and is State Route 112. Within the project area, the speed limit on Davis Street is 35 miles per hour.
 Adams Avenue. Adams Avenue is a two-lane, east-west collector between Doolittle Drive to the south and Bigge Street to the north. The roadway includes Class II bike lanes and on-street parking and serves industrial uses. Within the project area, the speed limit on Adams Avenue is 35 miles per hour.
 Hester Street. Hester Street is a two-lane, north-south local road connecting the project site to Adams Avenue. The roadway includes on-street parking and serves industrial uses. Within the project area, there is no posted speed limit but given the classification of the road, it is assumed that the speed limit is 25 miles per hour.
 Airport Access Road. Airport Access Road is a five-lane, minor collector that connects to Bessie Coleman Drive to the south and Hegenberger Road to the north. The roadway provides access to the Oakland International Airport. Within the project area, there is no posted speed limit but given the classification of the road, it is assumed that the speed limit is 35 miles per hour.  98th Avenue. 98th Avenue is a minor arterial which connects to Bessie Coleman Drive to the west and Golf Links Road to the east. The roadway within the project area consists of six lanes and serves multiple uses. Within the project area, the posted speed limit is 30 miles per hour.

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b. Transit, Bicycle, and Pedestrian Facilities
The Alameda-Contra Costa Transit District (AC Transit) operates bus routes 34, 35, 73, 98, and 805 within the project area. The nearest bus stop to the project site is located at the intersection of Westgate Parkway and Davis Street, which is approximately 0.9 mile southeast of the project site.

The San Leandro Bay Area Rapid Transit (BART) station, which serves the Blue, Green, and Orange BART lines, is located approximately 2.1 miles east of the project site. The San Leandro LINKS shuttle is a free shuttle to and from the San Leandro BART station that operates a North Loop and South Loop. The North Loop runs along Davis Street from the BART station to Marina Boulevard, Merced Street, Williams Street, Doolittle Drive, and Davis Street. There is an existing stop located at Doolittle Drive and Davis Street, approximately 0.4 mile south of the project site. Pedestrians can travel between the LINKS bus stop and the project site using the existing sidewalks located along both sides of Davis Street.

Bicycle lanes in the project area include Class II bicycle lanes on both Doolittle Drive and Adams Avenue. More regionally, the bicycle lane on Doolittle Drive connects to a larger network of bicycle facilities providing bicycle access to other areas of San Leandro most distant from the project site, such as areas east of Interstate 880. Class II bicycle lanes are established lanes along streets using striping and painted patterns, such as painting a portion of the asphalt roadway a color to denote its use for bicycle travel (Caltrans 2020).

There are existing continuous sidewalks on both sides of Doolittle Drive adjacent to the project site where pedestrians can access the site, as well as existing continuous sidewalks on both sides of Adams Avenue and on the east side of Hester Street. There are also existing crosswalks along the east, south, and west legs at the signalized intersection of Doolittle Drive and Davis Street, and existing crosswalks on the east and south legs at the signalized intersection of Doolittle Drive and Adams Street.
c. Vehicle Miles Traveled
Vehicle miles traveled (VMT) measures the amount of travel for all vehicles in a geographic region over a given period of time, typically a one-year period. It is calculated as the sum of the number of miles traveled by each vehicle (Williams, et.al. 2016). VMT can be quantified in numerous ways depending on how the VMT data is to be applied, such as total annual VMT, VMT per capita, or VMT per employee. VMT per employee means the average commute trip length, in miles, made by employees over a set period, multiplied by the number of vehicle commute trips per employee.

The Alameda County Transportation Commission has developed maps displaying estimates of VMT per employee based on traffic analysis zone (TAZ) estimates from the Alameda Countywide Travel Demand Model. Based on the VMT per Employee map for the TAZs within the Central Planning Area, which is the planning area where the project site is located, the VMT per employee in 2020 provided by the Alameda County Transportation Commission is 15.34 miles. Based on the VMT per Employee table for the Central Planning Area in 2040 provided by the Alameda County Transportation Commission, the project is located in a TAZ with a VMT of 16.08 miles (Appendix C, page 15). The average VMT per employee in the overall Central Planning Area is 19.2 miles in 2020 and 19.1 miles in 2040, as shown on Page 16 of the Transportation Impact Analysis (Appendix C).

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4.4.2 Regulatory Setting
a. Federal Regulations
The federal government routinely funds roadway and other transportation projects and also recognizes VMT as a transportation planning measurement. However, there are no federal transportation regulations applicable to this analysis. b. State Regulations
Senate Bill 743
On September 27, 2013, California Governor Jerry Brown signed Senate Bill (SB) 743 into law and started a process that changes transportation impact analysis as part of CEQA compliance. SB 743 requires the Governor’s Office of Planning and Research (OPR) to identify new metrics for identifying and mitigating transportation impacts within CEQA. In January 2018, OPR transmitted its proposed CEQA Guidelines implementing SB 743 to the California Natural Resources Agency for adoption, and in January 2019 the Natural Resources Agency finalized updates to the CEQA Guidelines, which incorporated SB 743 modifications. As of July 1, 2020, localities are required to rely on vehicle miles traveled (VMT), instead of traffic delay, as the primary metric for evaluating transportation impacts in CEQA documents. Under SB 743, automobile delay, as described solely by level of service or traffic congestion, shall not be considered a significant environmental impact except for certain types of transportation projects (Public Resource Code, § 21099 (b)(2)).

State CEQA Guidelines Section 15064.3
Originating from SB 743, Section 15064.3 of the State CEQA Guidelines establishes VMT as the most appropriate measure of transportation impacts, shifting away from the level of service analysis that evaluated a project’s impacts on traffic conditions on nearby roadways and intersections. The primary components of new section 15064.3 include:
 Identifies VMT (amount and distance of automobile traffic attributable to a project) as the most appropriate measure of transportation impacts;
 Declares that a project’s effect on automobile delay shall not constitute a significant environmental impact except for projects increasing roadway capacity;  Creates a rebuttable presumption of no significant transportation impacts for (a) land use projects within one-half mile of either an existing major transit stop or a stop along an existing high quality transit corridor, (b) land use projects that reduce VMT below existing conditions, and (c) transportation projects that reduce or have no impact on VMT;  Allows a lead agency to qualitatively evaluate VMT if existing models are not available; and  Gives lead agencies discretion to select a methodology to evaluate a project’s VMT but requires lead agencies to document that methodology in the environmental document prepared for the project.

In December 2018, OPR issued a Technical Advisory on Evaluating Transportation Impacts in CEQA (OPR 2018). The technical advisory contains technical recommendations regarding assessment of VMT, thresholds of significance, and mitigation measures. The technical advisory suggests a significance threshold for VMT that is based on state mandated GHG emission reduction targets.

The technical advisory recommends a quantitative per capita or per employee VMT that is 15 City of San Leandro
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percent below that of existing development as a possible threshold of significance that would comply with the state’s long-term climate goals.

California Assembly Bill 32, Senate Bill 32, and Senate Bill 375 The “California Global Warming Solutions Act of 2006” (AB 32) outlines California’s major legislative initiative for reducing GHG emissions. AB 32 codifies the statewide goal of reducing GHG emissions to 1990 levels by 2020, a reduction of approximately 15 percent below emissions expected under a “business as usual” scenario. On September 8, 2016, the governor signed Senate Bill 32 (SB 32) into law, extending the California Global Warming Solutions Act of 2006 by requiring the state to further reduce GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged).

The Sustainable Communities and Climate Protection Act of 2008 (SB 375), signed in August 2008, enhances the state’s ability to reach AB 32 goals by directing CARB to develop regional GHG emission reduction targets to be achieved from passenger vehicles by 2020 and 2035. SB 375 aligns regional transportation planning efforts, regional GHG reduction targets, and affordable housing allocations.

Metropolitan Planning Organizations (MPOs) are required to adopt a Sustainable Communities Strategy (SCS), which allocates land uses in the MPO’s Regional Transportation Plan (RTP). Qualified projects consistent with an approved SCS or Alternative Planning Strategy (categorized as “transit priority projects”) can receive incentives to streamline CEQA processing.

On March 22, 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035. ABAG was assigned a 19 percent reduction in per capita GHG emissions from passenger vehicles by 2035. SB 375 also provides the option for the coordinated development of subregional plans by the subregional councils of governments and the county transportation commissions to meet SB 375 requirements. On October 21, 2021, ABAG formally adopted the RTP/SCS titled Plan Bay Area 2050, which meets the requirements of SB 375. c. Local Regulations
Alameda County Transportation Commission
The Alameda County Transportation Commission coordinates transportation planning efforts throughout Alameda County and programs local, regional, State and federal funding for project implementation. It prepares the CMP, a program mandated by California law to describe the strategies to address congestion problems on the CMP network, which includes state highways and principal arterials. The CMP requires analysis of Metropolitan Transportation System (MTS) roadway and transit system and uses level-of-service standards as a means to measure congestion and has established level-of-service standards to determine how local governments meet the standards of the CMP.

The Alameda County Transportation Commission also develops and manages the Countywide travel demand model, which is used for estimating future volumes and VMT based on future land uses and the future roadway network. The Alameda County Transportation Commission has developed maps displaying estimates of VMT per employee based on traffic analysis zone (TAZ) estimates from the Alameda Countywide Travel Demand Model.

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City of San Leandro 2035 General Plan
The San Leandro 2035 General Plan Transportation Element establishes the following applicable goals and policies relevant to transportation:

Policy T-1.2: Mitigation of Development Impacts. Require developers to address the impacts that their projects will have on the City’s transportation system. A variety of mitigation measures, including impact fees, street improvements, traffic signal and Intelligent Transportation Systems (ITS) improvements, transportation demand management (TDM) measures, and improvement of non-automobile transportation modes, should be considered.

Policy T-1.10: Reduced Trip Generation. Encourage local employers to develop programs that promote ridesharing, flextime and telecommuting, bicycle use, and other modes of transportation that reduce the number and distance of vehicle trips generated.

Policy T-2.6: Building Design and Site Planning. Ensure that the site planning and design of new development promotes the use of non-auto modes of transportation by including amenities such as sidewalks, bike lockers, and bus shelters.

Policy T-3.5: Accommodation of Bicycles and Pedestrians. Require new development to incorporate design features that make walking, bicycling, and other forms of nonmotorized transportation more convenient and attractive. Facilities for bicycles and pedestrians, including secured bicycle parking, clearly marked crosswalks, well-lit streets and sidewalks, landscaping, and street furniture should be provided within new employment areas, shopping destinations, multi-modal transportation facilities, and community facilities.

Policy T-6.7: Siting of Businesses with Truck Traffic. To the extent feasible, locate businesses projected to generate large amounts of truck traffic away from residential areas. Ingress and egress for such businesses should be designed to minimize the possibility of truck traffic impacting residential streets.

The Transportation Element also establishes a tiered Level of Service (LOS) system. LOS is a measure of the quality or performance of a transportation system based on factors such as travel time, traffic volume, and congestion. LOS is typically evaluated on a scale of “A,” corresponding to no congestion and free-flowing traffic, to “F,” corresponding to extreme congestion and delays. For planning purposes, LOS D is the minimum acceptable service level for intersections outside of designated Priority Development Areas and LOS E is the minimum acceptable service level for intersections within designated Priority Development Areas.

4.4.3 Impact Analysis
a. Methodology
The analysis presented herein is derived primarily from a Transportation Analysis prepared by Kimley-Horn for the proposed project, included as Appendix C to this EIR. The Transportation Impact Analysis assesses the VMT impacts of the project, as well as other transportation-related impacts.

The VMT generated by the proposed project was estimated by referring to VMT estimates produced by the Alameda County Transportation Commission for 2020 and 2040. The Alameda County Transportation Commission developed their VMT estimates on a TAZ basis using the Alameda Countywide Travel Model. The average VMT of the TAZ containing the proposed project was compared against the significance thresholds to determine the severity of VMT impacts.

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The Transportation Impact Analysis also includes a sight distance analysis for the proposed project driveways to determine if project vehicles exiting the driveways would have adequate sight distance to prevent traffic safety hazards. Intersection sight distance for the project driveways was evaluated using methodology from the American Association of State Highway and Transportation Officials, which is called A Policy on Geometric Design of Highway and Street, 7th Edition. Sight distance for each project driveway was determined based on the proposed project site plan and the following American Association of State Highway and Transportation Officials intersection sight distance criteria formula:

Intersection Sight Distance = 1.47 X Vmajor X tg
In the above formula, Vmajor is the design speed of the major road and tg is the time gap for the vehicle to exit the project driveway and enter the major road. b. Thresholds of Significance
According to CEQA Guidelines Appendix G, impacts related to transportation and circulation from the proposed project would be significant if the project would:

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

2. Conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b);

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

4. Result in inadequate emergency access.

CEQA checklist items 1 and 4 were found to be less than significant in the Initial Study (Appendix A).

Therefore, no further analysis is warranted, and these topics will not be discussed further in this section.

Threshold 2: Would the project conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b)?
IMPACT TRA-1 THE PROJECT WOULD GENERATE VMT THAT IS MORE THAN 15 PERCENT BELOW THE

AVERAGE VMT PER EMPLOYEE IN THE PROJECT AREA THEREFORE, THE PROPOSED PROJECT WOULD NOT CONFLICT WITH CEQA GUIDELINES SECTION 15064.3, SUBDIVISION (B), AND IMPACTS WOULD BE LESS THAN SIGNIFICANT.

According to the Transportation Impact Analysis (Appendix C) and the Alameda County Transportation Commission (2019), the project site is in a TAZ with a VMT of 15.34 per employee in 2020. Therefore, the Transportation Analysis determined that the proposed project would also generate 15.34 VMT per employee, consistent with the 2020 VMT of the TAZ (see Appendix C). This is a reasonable assumption because the TAZ covers a limited area surrounding the project site that is characterized by warehouses and industrial land uses, consistent with the proposed project. In other words, the proposed project would be in a TAZ that the Alameda County Transportation Commission indicates has an average VMT per employee of 15.34, and because the project would be a warehouse use similar to much of the other land uses in the TAZ, would be consistent with the average VMT per employee of 15.34. It should be noted that the Alameda County Transportation Commission VMT maps are consistent with methodology specified by the Governor’s Office of Planning and Research (Appendix C). The project VMT of 15.34 miles per employee is below the Environmental Impact Analysis
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2020 VMT threshold of 16.3 miles per employee. Therefore, the proposed project would not conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b), as it pertains to VMT.

Impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 3: Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
IMPACT TRA-2 THE PROJECT WOULD INTRODUCE TRACTOR TRAILERS ENTERING INTO ROADWAY TRAFFIC VIA DRIVEWAYS. HOWEVER, SUFFICIENT SIGHT DISTANCE EXISTS TO PREVENT TRACTOR TRAILERS EXISTING THE PROJECT SITE FROM CREATING HAZARDS RELATED TO DANGEROUS INTERSECTIONS. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Project operations would involve the use of tractor trailers, in addition to standard passenger vehicles used for worker commute trips. Tractor trailers would use both proposed driveways on Hester Street, as well as the driveway on Doolittle Drive. Because tractor trailers typically have slower acceleration speeds than standard passenger vehicles, they could create potential hazards when exiting the project driveway onto Doolittle Drive, where other vehicles are travelling at posted speed limits presumably. This hazard would not exist at driveways on Hester Street because the driveways would be at the end of Hester Street where there are no vehicles traveling through at posted speed limits.

According to the Transportation Impact Analysis (Appendix C), the sight distance criteria for trucks making a right-turn from the driveway onto Doolittle Drive is 625 feet and the sight distance criteria for trucks making a left-turn is 750 feet. The Transportation Impact Analysis determines that these sight distances should be clear of obstructions, thereby providing the necessary sight distance for tractor trailers to exit the driveway onto Doolittle Drive without increasing hazards. Impacts would be less than significant.

Mitigation Measures
No mitigation measures are required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

4.4.4 Cumulative Impacts
The geographic scope used for the assessment of cumulative impacts related to transportation consists of the Central Planning Area, which is the transportation planning area used by the Alameda County Transportation Commission. The Central Planning Area includes the City of San Leandro and other surrounding areas generally adjacent to San Leandro. The Central Planning Area is an acceptable geographic scope for this analysis because it is the average VMT per employee City of San Leandro
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within this area on which the impact significance thresholds are based (see Thresholds of Significance in Section 4.4.3, Impact Analysis, above).

The analysis of cumulative transportation impacts does not use the list of reasonably foreseeable projects presented in Table 3-1 of this EIR. Instead, the analysis is based on VMT per employee that Alameda County Transportation Commission anticipates in the Central Planning Area in 2040. This approach is used for the analysis because it is more comprehensive of the growth and associated VMT that could result in the Central Planning Area rather than from the handful of projects in Table 3-1.

According to the Transportation Impact Analysis (Appendix C), the project site is in a TAZ that will have a VMT of 16.08 miles per employee in 2040. Therefore, the Transportation Analysis determined that the proposed project would also generate 16.08 VMT per employee, consistent with the 2040 VMT of the TAZ (see Appendix C). This is a reasonable assumption because the TAZ covers a limited area surrounding the project site that is characterized by warehouses and industrial land uses, consistent with the proposed project. The project VMT of 16.08 miles per employee is below the 2040 VMT threshold of 16.2 miles per employee. Therefore, the proposed project would not result in cumulatively considerable impacts as a result of a conflict or inconsistency with CEQA Guidelines Section 15064.3, subdivision (b), as it pertains to VMT. Cumulative impacts would be less than significant.

Impacts related to traffic hazards, such as geometric design features or incompatible uses are generally site- or project-specific hazards. The traffic hazards of a particular project are unique to the circumstances of that project within its surroundings and the proposed project type, for example, if the project would require farm tractors to operate on roadways. The potential traffic hazards of the proposed project include tractor trailers that would exit the project site using the driveway on Doolittle Drive. As described above in Impact TRA-2, there would be sufficient sight distance at the intersection of this driveway and Doolittle Drive such that substantial traffic hazards would not exist. Because the traffic hazards of cumulative projects generally do not combine and become more severe, and because the project would not substantially increase hazards, cumulative impacts would be less than significant.

Other CEQA Required Discussions
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5 Other CEQA Required Discussions
This section discusses growth-inducing impacts and irreversible environmental impacts that would be caused by the proposed project.

5.1 Growth Inducement
Section 15126(d) of the CEQA Guidelines requires a discussion of a proposed project’s potential to foster economic or population growth, including ways in which a project could remove an obstacle to growth. Growth does not necessarily create significant physical changes to the environment.

However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. The proposed project’s growth inducing potential is therefore considered significant if project-induced growth could result in significant physical effects in one or more environmental issue areas.

5.1.1 Population Growth
The proposed project would generate employment opportunities during construction. However, as construction would be temporary, few people would be expected to relocate to the area permanently for project construction jobs. Instead, construction workers would be expected to be drawn from the existing regional work force, which is robust in the San Francisco Bay Area.

Therefore, construction of the project would not induce substantial population growth.

The project would involve the operation of a new warehouse which would create jobs. Job creation could indirectly cause population growth through employee relocations to the region. However, the project also includes demolishing existing industrial buildings, eliminating the potential jobs provided by business that could operate within them. Additionally, as discussed in Section 14, Population and Housing, of the Initial Study (Appendix A), the project site is located in a dense urban area and many of the warehouse employees would likely be drawn from the local population regardless of the job creation potential of existing on-site vacant buildings. Some employees may relocate to the area as a result of job opportunities resulting from operation of the proposed project; however, a substantial change in employment growth in the area would not occur.

5.1.2 Economic Growth
As described above in Section 5.1.1, Population Growth, and in Section 14, Population and Housing, of the Initial Study (Appendix A), the proposed project would not generate substantial population growth. Most employment opportunities resulting from the project would be filled by people already in the San Francisco Bay Area. As the project workforce would consist primarily of people already residing in the region, there would be no substantial economic growth associated with population growth, such as increased demand for housing, retail goods, or commercial services.

The project is located on an infill site that is largely surrounded by industrial and commercial uses.

Development of the project site with a warehouse and incidental office space would be consistent with surrounding land uses. Therefore, the proposed project would not influence development patterns in the project area, such as redevelopment of surrounding properties with new uses that could generate additional economic growth.

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Overall, the proposed project would not induce substantial economic expansion to the extent that direct physical environmental effects would result. Moreover, the environmental effects associated with future development in or around the City of San Leandro would be addressed as part of the CEQA environmental review for such development projects.

5.1.3 Removal of Obstacles to Growth
The project site is an infill property located adjacent to urbanized areas of the City of San Leandro.

As discussed in Section 19, Utilities and Service Systems, of the Initial Study (Appendix A), there are existing water, wastewater treatment, stormwater drainage, electric power, natural gas, and telecommunication facilities at the project site that are available to serve the project. The project would not require the extension of, or add substantial capacity to, roads or other infrastructure that would facilitate or accommodate development beyond the project site. Because the project does not involve or require the extension of new infrastructure through or to undeveloped areas, or increase infrastructure capacity in such a way as to facilitate or accommodate growth beyond the project site, project implementation would not remove an obstacle to growth.

5.2 Irreversible Environmental Effects
The CEQA Guidelines require that EIRs contain a discussion of significant irreversible environmental changes. This section addresses non-renewable resources, the commitment of future generations to the proposed uses, and irreversible impacts associated with the proposed project.

Construction and operation of the project would involve an irreversible commitment of construction materials and non-renewable energy resources. The project would involve the use of building materials and energy, some of which are non-renewable resources, to construct the overall building floor area. Consumption of these resources would occur with nearly all development in the region and are not unique to the proposed project.

The proposed project would also irreversibly increase local demand for non-renewable energy resources such as petroleum products and natural gas. However, increasingly efficient building design would offset this demand to some degree by reducing energy demands of the project. The project would be required to comply with standards set forth in California Building Code (CBC) Title 24, which would minimize the wasteful, inefficient, or unnecessary consumption of energy resources during operation. CALGreen (as codified in CCR Title 24, Part 11) requires implementation of energy-efficient light fixtures and building materials into the design of new construction projects.

Furthermore, the 2022 Building Energy Efficiency Standards (CBC Title 24, Part 6) requires newly constructed buildings to meet energy performance standards set by the CEC. These standards are specifically crafted for new buildings to achieve energy efficient performance. The standards are updated every three years, and each iteration increases energy efficiency standards.

The City adopted a Reach Code in January 2023 that requires efficiency beyond CalGreen, which would be applicable to the proposed project. Furthermore, the project would continue to reduce its use of nonrenewable energy resources as the percentage of electricity generated by renewable resources provided by PG&E continues to increase to comply with state requirements through Senate Bill 100, which requires electricity providers to increase procurement from eligible renewable energy resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

Other CEQA Required Discussions
Environmental Impact Report 5-3
Additional vehicle trips associated with the proposed project would incrementally increase local traffic and regional air pollutant and GHG emissions. However, as discussed in Section 3, Air Quality, and Section 7, Greenhouse Gas Emissions, of the Initial Study (Appendix A), development and vehicle trips generated from the project would not generate air quality or GHG emissions that would result in a significant impact. However, as discussed in Section 4.1, Greenhouse Gas Emissions, the project would include new natural gas connections, which would be a long-term source of GHG emissions. Impacts would be significant and unavoidable.

The project would also require a commitment of law enforcement, fire protection, water supply, wastewater treatment, and solid waste disposal services. However, as discussed in Section 15, Public Services, and Section 19, Utilities and Service Systems, of the Initial Study, impacts to these service systems would not be significant.

CEQA requires decision makers to balance the benefits of a proposed project against its unavoidable environmental risks in determining whether to approve a project. The analysis contained in this EIR concludes that the proposed project would result in impacts that are less than significant or less than significant with mitigation, except for potential impacts from GHG emissions. As described in Section 4.1, Greenhouse Gas Emissions, and below in 6.3, Significant and Unavoidable Impacts, implementation of the project would result in potentially significant unavoidable impacts, including cumulative impacts, due to GHG emissions.

5.3 Significant and Unavoidable Impacts
As described in Section 4.1, Greenhouse Gas Emissions, the proposed project would have a significant impact related to greenhouse gas emissions and resultant climate change. Specifically, the proposed project includes a natural gas connection and the potential for natural gas to be used as part of project operations, depending on the potential tenant(s). According to the Bay Area Air Quality Management District, projects that include natural gas appliances or natural gas plumbing should be found to make a significant climate impact because it will hinder California’s efforts to address climate change (Bay Area Air Quality Management District 2022).

The City is unable to implement mitigation to reduce this significant impact based on a recent court case titled California Restaurant Association v. City of Berkeley. Briefly, in this case, the California Restaurant Association sued Berkeley in the U.S. District Court for the Northern District of California, arguing among other things that the federal Energy Policy and Conservation Act (EPCA) preempted the City’s ordinance banning natural gas in new buildings. The District Court dismissed the California Restaurant Association’s challenge. However, the Ninth Circuit reversed the District Court, holding that EPCA expressly preempts state and local regulations concerning the energy use of many natural gas appliances. The Ninth Circuit concluded that EPCA preempted Berkeley’s ban of natural gas, because it prohibited the onsite installation of natural gas infrastructure necessary to support natural gas appliances covered under the EPCA. Accordingly, based on the decision of the Ninth Circuit in California Restaurant Association v. City of Berkeley, the City of San Leandro can only encourage but cannot require the project applicant to eliminate natural gas from the proposed project.

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Alternatives
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6 Alternatives
As required by Section 15126.6 of the CEQA Guidelines, this EIR examines a range of reasonable alternatives to the proposed project that would attain most of the basic project objectives but would avoid or substantially lessen the significant adverse impacts.

As discussed in Section 2, Project Description, the project applicant’s objectives for the proposed project are as follows:
 Increase the economic base of the City's industrial corridor by maximizing the productive use of the City’s industrial land, which is currently underutilized;  Create a modern warehouse that contributes to the aesthetics of the surrounding area through the redevelopment of an obsolete and underutilized property;  Create a new, efficient and updated warehouse that is attractive to future tenants, by incorporating the state's green building design and building health and safety standards;  Maintain and protect the City’s inventory of larger-scale industrial sites with easy access to freeways, rails, airports, and seaports; and
 Support and retain existing industrial uses and employment in the City of San Leandro’s industrial sector.

Included in this analysis are three alternatives, including the CEQA-required “no project” alternative, that involve changes to the project that would reduce the project-related potentially significant environmental impacts as identified in this EIR. Alternatives have been developed to provide a reasonable range of options to consider that would help decision makers and the public understand the general implications of revising or eliminating certain components of the proposed project.

6.1 Potentially Significant Impacts
According to Section 15126.6(b) of the CEQA Guidelines, the discussion of EIR alternatives shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening significant effects of the project. The City prepared an Initial Study and this EIR to analyze the project for potentially significant impacts related to each of the environmental issues or resource areas contained in Appendix G of the State CEQA Guidelines (see Appendix A to this EIR).

The results of the Initial Study and EIR analyses determined that the proposed project would have potentially significant and unavoidable impacts related to greenhouse gas (GHG) emissions (see Section 4.1, Greenhouse Gas Emissions).

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Additionally, mitigation measures are identified in this EIR (including the Initial Study provided as Appendix A) for the following topics that would reduce the respective potentially significant impacts of the project to less than significant levels:
 Air Quality, specifically effects related to fugitive dust during project construction (mitigated to less-than-significant level by Mitigation Measure AQ-1)  Biological Resources, specifically effects on migratory nesting birds, including their nests (mitigated to less-than-significant impact level by Mitigation Measure BIO-1)  Cultural Resources, specifically effects related to previously unidentified subsurface resources (mitigated to less-than-significant impact level by Mitigation Measures CR-1)  Hazards and Hazardous Materials, specifically effects related to exposure of project construction personnel to lead paint and/or asbestos containing materials during demolition of existing structures hazardous (mitigated to less-than-significant impact level by Mitigation Measure HAZ-1)
 Hazards and Hazardous Materials, specifically effects related to exposure of persons or groundwater to hazardous contamination (contaminated soil, soil vapor, etc.) during construction and operation (mitigated to less-than-significant impact level by Mitigation Measures HAZ-2 through HAZ-6)
 Noise and Vibration, specifically effects on sensitive residential noise receptors as a result of onsite HVAC and truck movements on the project site (mitigated to less-than-significant level by Mitigation Measure NOI-1)
 Noise and Vibration, specifically effects of construction vibration on structures nearest the project site (mitigated to less-than-significant level by Mitigation Measure NOI-2)  Tribal Cultural Resources, specifically effects related to the unanticipated discovery of tribal cultural resources during construction of the project (mitigated to less-than-significant level by Mitigation Measure TCR-1)

6.2 Alternative 1: No Project Alternative
The No Project Alternative assumes that the two existing industrial masonry buildings would remain on the project site. These buildings are currently vacant. The City has no applications on file for occupancy of the buildings; therefore, this analysis assumes the buildings would remain vacant under this alternative. The project applicant or another person or organization could submit an application for occupancy of one or both buildings in the future. Granting an occupancy permit for a business or activity allowed by-right within the existing Industrial General zoning district of the site would be a ministerial permit, and CEQA may not be applicable.

The No Project Alternative would not fulfill any of the project objectives.

6.2.1 Impact Analysis
a. Air Quality
The No Project Alternative would not require or involve demolition or construction activities.

Therefore, implementation of the No Project Alternative would not generate fugitive dust emissions from construction activities. Because the existing on-site buildings would remain vacant under this alternative, there would be no regular or routine operational emissions. The No Project Alternative would have no impacts on air quality.

Alternatives
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The proposed project’s impacts related to air quality would be less than significant with mitigation (see Air Quality in the Initial Study; Appendix A). Because the No Project Alternative would have no impact on air quality, the impacts of this alternative would be reduced compared to the proposed project, and no mitigation measures would be required.
b. Biological Resources
The No Project Alternative would not involve demolition of the existing on-site structures. This alternative would also not require construction activities. Therefore, implementation of the No Project Alternative would not have the potential to directly destroy or damage migratory bird nests or disrupt nesting from construction activities. The No Project Alternative would have no impact on biological resources.

The proposed project’s impacts related to biological resources would be less than significant with mitigation (see Biological Resources in the Initial Study; Appendix A). Because the No Project Alternative would have no impact on biological resources, the impacts of this alternative would be reduced compared to the proposed project, and no mitigation measures would be required. c. Cultural Resources
The No Project Alternative would not require grading, excavation, or other construction activities.

Implementation of the No Project Alternative would preserve on-site conditions, which is primarily either structures or asphalt pavement. Accordingly, the No Project Alternative would have no potential to encounter and damage or destroy previously unidentified subsurface cultural resources.

The No Project Alternative would have no impact on cultural resources.

The proposed project’s impacts related to cultural resources would be less than significant with mitigation (see Cultural Resources in the Initial Study; Appendix A). Because the No Project Alternative would have no impact on cultural resources, the impacts of this alternative would be reduced compared to the proposed project, and no mitigation measures would be required. d. Greenhouse Gas Emissions
The No Project Alternative would not require construction activities. Because no construction equipment would be operated, the potential GHG emissions resulting from equipment associated with the proposed project would be avoided. Additionally, because existing on-site buildings would remain vacant under this alternative, the No Project Alternative would not be a long-term source of GHG emissions. For example, the No Project Alternative would not generate vehicle trips or consume energy, both of which would generate GHG emissions if they were to occur. Because the No Project Alternative would not generate GHG emissions, it would not conflict with a plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases. Accordingly, the No Project Alternative would have no impacts related to GHG emissions.

The proposed project’s impacts, including the cumulative impacts, related to greenhouse GHG emissions would be potentially significant and unavoidable (see Section 4.1, Greenhouse Gas Emissions). Because the No Project Alternative would have no impacts related to greenhouse gas emissions, the impacts of this alternative would be reduced compared to the proposed project, and no mitigation measures would be required.

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e. Hazards and Hazardous Materials
Under the No Project Alternative, there would be no demolition of the existing on-site structures and no new construction. The existing buildings would remain vacant with no occupants. Therefore, there would be no impacts related to potential exposure to lead or asbestos-containing materials.

Additionally, the proposed project would not be constructed, including bioretention areas for stormwater management. Therefore, the No Project Alternative would have no potential to create new preferential pathways for existing on-site contamination to migrate into deeper groundwater aquifers or to become airborne as dust during construction activities. Because the proposed building would not be constructed, it also would not be occupied and there would be no potential for vapor intrusion risk. Existing remediation and monitoring activities, such as the existing network of monitoring wells on the site, would continue until the DTSC or other regulatory agency with oversight deems the project site a closed case in terms of remediation. Accordingly, the No Project Alternative would have no impacts related to hazards and hazardous materials.

As described in Section 4.2, Hazards and Hazardous Materials, the proposed project would have potentially significant but mitigable impacts related to hazards materials and hazardous contamination. Because the No Project Alternative would have no impact, impacts of this alternative would be reduced compared to the proposed project and no mitigation would be required.
f. Noise and Vibration
The No Project Alternative would not generate temporary increases in noise because this alternative would not involve construction activities. Because no construction would occur on-site, there would be no potential for the No Project Alternative to generate groundborne vibration. Additionally, the existing on-site buildings would remain vacant, which would generate no long-term or permanent noise or vibration. While the property owner could visit the site, the operation of a single vehicle would have no discernible effects on noise levels at the nearest sensitive receptors approximately 510 feet from the project site, as these receptors are close to streets with hundreds to thousands of vehicle trips per day (e.g., Davis Street, Interstate 880, etc.). The No Project Alternative would have no impacts on noise and vibration.

As described in Section 4.3, Noise and Vibration, the proposed project would have potentially significant but mitigable impacts related to noise and vibration. Because the No Project Alternative would have no impact, impacts of this alternative would be reduced compared to the proposed project and no mitigation would be required.
g. Tribal Cultural Resources
The No Project Alternative would not require grading, excavation, or other construction activities.

The proposed project’s impacts related to tribal cultural resources would be less than significant with mitigation (see Tribal Cultural Resources in the Initial Study; Appendix A). Because the No Project Alternative would have no impact on tribal cultural resources, the impacts of this alternative would be reduced compared to the proposed project, and no mitigation measures would be required.

Alternatives
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6.3 Alternative 2: No Natural Gas Alternative
Under the No Natural Gas Alternative, the proposed industrial building would be constructed on the project site, nearly consistent with the proposed project. Alternative 2 assumes that the industrial building and associated surface parking lot would be approximately the same size and design as the proposed project, which would require the same demolition and construction activities as the proposed project. Once construction is complete, Alternative 2 assumes the same on-site operations would occur as with the proposed project, with the exception of natural gas consumption. Under this alternative, natural gas connections would not be provided on the project site. Therefore, potential future occupants and uses in the new industrial building would not consume natural gas, as natural gas would be unavailable on the project site. Alternative 2 would instead require on-site building operations to rely entirely on electricity for energy.

6.3.1 Impact Analysis
a. Air Quality
The No Natural Gas Alternative would require virtually the same demolition and construction activities as the proposed project. These construction activities would have the potential to generate fugitive dust emissions. Fugitive dust emissions would increase the amount of particulate matter in the air, resulting in a potentially significant impact. Implementation of Mitigation Measure AQ-1 (see Air Quality in the Initial Study; Appendix A) would be required. With implementation of Mitigation Measure AQ-1, impacts from construction of Alternative 2 would be reduced to a less than significant level.

Operation of Alternative 2 would generate emissions of air pollutants. For example, Alternative 2 would involve the operation of trucks and vehicles on the project site, and operation of these trucks and vehicles would generate emissions of pollutants, such as carbon monoxide. The No Natural Gas Alternative would not generate emissions from the combustion of natural gas; however, generation of electricity used for this alternative would generate emissions. The amount of operational emissions of Alternative 2 would be similar to the proposed project given that there would be little difference in operations between this alternative and the proposed project, other than this alternative avoiding natural gas emissions. Without natural gas emissions, there would be an incremental decrease in operational emissions compared to the proposed project, which would include emissions from combustion of natural gas. The operational emissions of the proposed City of San Leandro
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project would not exceed thresholds of significance, and because operational emissions would be reduced with this alternative, significance thresholds would also not be exceeded by Alternative 2.

Therefore, operation of Alternative 2 would also have less than significant impacts related to air quality.

The proposed project’s impacts related to air quality would be less than significant with mitigation (see Air Quality in the Initial Study; Appendix A). Because the No Project Alternative would have approximately the same construction and reduced operational impacts on air quality, the impacts of this alternative would be slightly reduced compared to the proposed project. Implementation of Mitigation Measure AQ-1 would be required for Alternative 2. b. Biological Resources
The No Natural Gas Alternative would involve demolition of the existing on-site structures and require construction equipment and workers to operate across the entire project site, similar to the proposed project. These activities would have the potential to directly damage or destroy active nests of migratory bird species or cause birds to abandon nests. This impact would be potentially significant and implementation of mitigation is required.

The proposed project’s impacts related to biological resources would be potentially significant due to the possibility for demolition and construction activities to impact migratory nesting birds.

Implementation of Mitigation Measure BIO-1 in the Initial Study, which is provided as Appendix A to this EIR, would reduce biological resources impacts to less than significant levels. Implementation of this mitigation measure would also be required for Alternative 2. Within implementation of Mitigation Measure BIO-1, biological resources impacts of Alternative 2 would be reduced to less than significant levels, and impacts would be similar compared to the proposed project. c. Cultural Resources
The No Natural Gas Alternative would involve construction and ground disturbance across the entire project site, similar to the proposed project. During construction, grading of the site and excavation required for utility connections and the foundation of the new building would have the potential to uncover and disturb previously unknown or unidentified archaeological resources or human remains. Disturbance or damage to archaeological resources would be a potentially significant but mitigable impact. Implementation of the Mitigation Measure CR-1 in the Initial Study section titled Cultural Resources would be required for this alternative (see Appendix A). Implementation of mitigation measures would reduce impacts to archaeological resources to less than significant levels. Compliance with existing regulations, such as Public Resources Code Section 5097.98, would prevent significant impacts related to discovery of human remains. Compared to the proposed project the No Natural Gas Alternative would result in similar impacts to cultural resources, because the proposed project would have a similar grading and demolition program and therefore would also result in potentially significant impacts to archaeological resources that would be reduced to less than significant levels with implementation of Mitigation Measure CR-1. d. Greenhouse Gas Emissions
The No Project Alternative would generate GHG emissions during construction, similar to the proposed project. Because the No Natural Gas Alternative would involve construction of the same sized building and surface parking areas as the proposed project, and would involve the same amount of demolition, temporary construction emissions would be similar between Alternative 2 Alternatives
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and the proposed project. As described in Section 4.1, Greenhouse Gas Emissions, construction would not generate GHG emissions that result in significant impacts on the environment.

Operation of Alternative 2 would generate GHG emissions. For example, operations would routinely involve the use of tractor trailers given the warehouse design of the proposed building. However, while the new building would generate vehicle and truck trips, the VMT generated from the project would be at least 15 percent below the average existing VMT in the area. This would be below the BAAQMD’s threshold of significance for GHG impacts related to transportation emissions.

Additionally, under Alternative 2, no natural gas would be provided to the project site. By avoiding new natural gas connections to the site, Alternative 2 would avoid the long-term GHG emissions associated with natural gas combustion. With the absence of natural gas, Alternative 2 would not exceed the BAAQMD’s threshold of significance for GHG emissions from new buildings. With the new building relying on electricity without natural gas, the No Natural Gas Alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

The No Natural Gas Alternative would generate GHG emissions but would not conflict with BAAQMD thresholds of significance or an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Accordingly, the GHG impacts of Alternative 2, including cumulative impacts, would be less than significant, and mitigation would not be required. The less than significant GHG impacts of Alternative 2 would be reduced compared to the proposed project, which would result in potentially significant and unavoidable GHG impacts. e. Hazards and Hazardous Materials
Similar to the proposed project, the No Natural Gas Alternative would require demolition of the existing on-site buildings, which could contain lead paint or asbestos containing materials. There would be potential for construction workers to be exposed to these hazards accidentally during demolition. Impacts would be potentially significant, and implementation of mitigation would be required.

Construction of Alternative 2 would involve excavation, such as construction of the proposed building foundation or buried utility connections, similar to the proposed project. Excavation and grading could disturb contaminated soils or groundwater and expose construction workers to hazardous materials present as contamination. Because contaminated soils generally exist on-site at depths greater than 6 feet below ground surface outside of the mapped land use restriction areas, the risk of exposure would be low across most of the site, but construction would also occur within the land use restriction areas. Likewise, construction would generate dust. If soils from the contamination areas are stockpiled on site and become airborne dust, either from wind erosion or construction equipment, off-site receptors could be exposed, as well as construction workers.

Construction of Alternative 2 would also require the demolition of the existing groundwater monitoring wells that were previously installed as part of the remediation actions on-site. Impacts would be potentially significant, and implementation of mitigation would be required.

During operation of Alternative 2, vapors from contaminated soil and groundwater underlying the site could potentially infiltrate the proposed building, including spaces within the building where employees would be routinely present, similar to the proposed project. The accumulation of vapors in the breathing zone inside the building could present a potential hazard to human health.

Additionally, Alternative 2 would include bioretention areas where stormwater would collect during operation and be allowed to infiltrate the ground surface. This would have the potential to create a City of San Leandro
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pathway for hazardous contamination to migrate through soil layers and potentially reach other groundwater aquifers. Impacts would be potentially significant.

The potentially significant impacts of Alternative 2 related to hazards and hazardous materials would be reduced to less than significant levels with implementation of mitigation measures HAZ-1 through HAZ-6 in Section 4.2, Hazardous and Hazardous Materials. These mitigation measures are also required for the proposed project and would reduce proposed project impacts to less than significant levels. Accordingly, the potential hazards and hazardous materials impacts of the No Natural Gas Alternative would be similar to the potential impacts of the proposed project. f. Noise and Vibration
The No Natural Gas Alternative would generate temporary increases in noise during demolition and construction activities, similar to the proposed project. The types of construction activities and equipment and the construction duration of this alternative would be the same as the proposed project, as Alternative 2 would construct the same project except no natural gas would be provided to the site. As described in Section 4.3, Noise and Vibration, construction noise levels would be below thresholds of significance at the nearest sensitive receptors to the project site. Accordingly, the temporary noise impacts of the No Natural Gas Alternative would be less than significant.

However, the temporary groundborne vibration from construction activities would be potentially significant, same as the those of the proposed project.

On-site operations under this alternative would be the same as the proposed project in terms of onsite truck and vehicle operations, HVAC equipment, and trip generation on project area roads.

Accordingly, the resulting noise levels at the nearest sensitive receptors to the project site would be the same under Alternative 2 as they would be under the proposed project. As described in Section

4.3, Noise and Vibration, when trucks operate on the eastern side of the proposed building, the combined noise of these trucks and rooftop HVAC equipment would generate noise levels of approximately 56 dBA at the nearest sensitive receptors to the project site. The threshold of significance is 55 dBA, and therefore operations on the east side of the building would be potentially significant.

The potentially significant impacts of Alternative 2 related to noise and vibration would be reduced to less than significant levels with implementation of mitigation measures NOI-1 and NOI-2 in Section 4.3, Noise and Vibration. These mitigation measures would also be required for the proposed project and would reduce the proposed project’s noise impacts to less than significant levels. Accordingly, the potential noise and vibration impacts of the No Natural Gas Alternative would be similar compared to the potential impacts of the proposed project. g. Tribal Cultural Resources
The No Natural Gas Alternative would involve construction and ground disturbance across the entire project site similar to the proposed project. During construction, grading of the site and excavation required for utility connections and the foundation of the new building would have the potential to uncover and disturb previously unknown or unidentified tribal cultural resources. Disturbance or damage to tribal cultural resources would be a potentially significant but mitigable impact.

Implementation of Mitigation Measure TCR-1 in the Initial Study section titled Tribal Cultural Resources would be required for this alternative (see Appendix A). Implementation of mitigation measures would reduce impacts to tribal cultural resources to less than significant levels. Compared to the proposed project the No Natural Gas Alternative would result in similar impacts to tribal cultural resources, because the proposed project would also have potentially significant impacts to Alternatives
Environmental Impact Report 6-9
archaeological resources that would be reduced to less than significant levels with implementation of Mitigation Measure TCR-1.

6.4 Alternative 3: Airport Parking Land Use Alternative Under the Airport Parking Land Use Alternative, the proposed industrial building would be constructed on the project site, nearly consistent with the proposed project. Alternative 3 assumes that the industrial building and associated surface parking lot would be approximately the same size and design as the proposed project, which would require the same demolition and construction activities as the proposed project. Once construction is complete, Alternative 3 assumes the proposed building would not operate as a warehouse. Instead, the building would operate as covered vehicle parking serving the Oakland International Airport. The new surface parking areas would also be for airport parking. Because the building would not operate as a warehouse, more surface parking would be provided on-site compared to the proposed project because larger parking spaces and areas for tractor trailer maneuvers would be eliminated from the project design.

Because the building would be used for vehicle parking and storage, there would not be many people working inside of the building. Some workers, such as parking attendants, maintenance workers and cashiers, may be present, but generally the building would be dedicated to vehicle circulation and parking. Accordingly, Alternative 3 assumes that the new building would not include natural gas connections, as there would not be demand to heat internal spaces used solely for vehicle parking and storage that could not generally be met with electric heat.

6.4.1 Impact Analysis
a. Air Quality
The Airport Parking Land Use Alternative would require demolition and construction activities, similar to the proposed project. These construction activities would have the potential to generate fugitive dust emissions. Fugitive dust emissions would increase the amount of particulate matter in the air, resulting in a potentially significant impact. Implementation of Mitigation Measure AQ-1 (see Air Quality in the Initial Study; Appendix A) would be required. With implementation of Mitigation Measure AQ-1, impacts from construction of Alternative 3 would be reduced to a less than significant level.

Operation of Alternative 3 would generate emissions of air pollutants. For example, Alternative 3 would involve the passenger vehicles operating on the project site as they travel to and from parking spaces. While Alternative 3 would not affect the number of people arriving or departing from the Oakland International Airport, it could increase the number of vehicle trips associated with the airport. Specifically, the availability of more parking spaces proximate to the airport created by Alternative 3 could make it appealing to choose to drive to flights rather than use transit or rideshare options. However, unlike the proposed project, vehicle trips resulting from Alternative 3 would generally be traditional gasoline-powered vehicles instead of diesel. Diesel engines generally City of San Leandro
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emit emissions compared to the same number of gasoline-powered engines. Therefore, mobile source emissions would be comparable the proposed project. Additionally, the Airport Parking Land Use Alternative would not generate emissions from the combustion of natural gas; however, generation of electricity used for this alternative would generate emissions. However, airport parking would require minimal electricity, as there would be fewer on-site operational activities than warehousing or industrial uses. Electricity would be required primarily for lighting and ancillary uses such as electric vehicle charging, vehicle cleaning and administrative offices to support the parking operation. Therefore, operation of Alternative 3 would have less than significant impacts related to air quality.

Overall, the Airport Parking Land Use Alternative would have reduced air quality impacts compared with the proposed project’s impacts, and impacts would be less than significant. The reduction in the severity of impacts would be primarily due to reduced emissions from operations. The operations of an active warehouse with diesel trucks under the proposed project would generate more air quality emissions than Alternative 3, which would avoid these emissions. b. Biological Resources
The Airport Parking Land Use Alternative would involve demolition of the existing on-site structures and require construction equipment and workers to operate across the entire project site, similar to the proposed project. These activities would have the potential to directly damage or destroy active nests of migratory bird species or cause birds to abandon nests. This impact would be potentially significant and implementation of mitigation would be required.

The proposed project’s impacts related to biological resources would be potentially significant due to the possibility for demolition and construction activities to impact migratory nesting birds.

Implementation of this mitigation measure would reduce impacts to archaeological resources to less than significant. Compliance with existing regulations, such as Public Resources Code Section 5097.98, would prevent significant impacts related to discovery of human remains. Compared to the proposed project the Airport Parking Land Use Alternative would result in similar impacts to cultural resources, because the proposed project would also have potentially significant impacts to archaeological resources that would be reduced to less than significant levels with implementation of Mitigation Measure CR-1.

Alternatives
Environmental Impact Report 6-11
d. Greenhouse Gas Emissions
The Airport Parking Land Use Alternative would generate GHG emissions during construction.

Because the Airport Parking Land Use Alternative would involve construction of the same sized building and surface parking areas as the proposed project, and would involve the same amount of demolition, temporary construction emissions would be similar between Alternative 3 and the proposed project. As described in Section 4.1, Greenhouse Gas Emissions, construction would not generate GHG emissions that result in significant impacts on the environment.

Operation of Alternative 3 would generate GHG emissions. Most operational emissions would be attributed to vehicles traveling on-site while parking. However, these vehicle trips would occur elsewhere in the general project vicinity regardless of the potential implementation of this alternative, as people driving to the Oakland International Airport would need to park their vehicles near the airport. This alternative could induce trips as people choose to drive and park at the project site rather than use transit for the airport. However, the number of induced trips would be minimal given that there is already an abundance of vehicle parking opportunities proximate to the airport.

Therefore, the Airport Parking Land Use Alternative would not generate substantial new VMT, as it would not generate a substantial number of new vehicle trips that would have otherwise not occurred without the implementation of the alternative. This would be below the BAAQMD’s threshold of significance for GHG impacts related to transportation emissions. Additionally, under Alternative 3, no natural gas would be provided to the project site. By avoiding new natural gas connections to the site, Alternative 3 would avoid the long-term GHG emissions associated with natural gas combustion. With the absence of natural gas, Alternative 3 would not exceed the BAAQMD’s threshold of significance for GHG emissions from new buildings. With the new building relying on electricity without natural gas, the Airport Parking Land Use Alternative would not conflict with an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs.

The Airport Parking Land Use Alternative would generate GHG emissions but would not conflict with BAAQMD thresholds of significance or an applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs. Accordingly, the GHG impacts of Alternative 3, including cumulative impacts, would be less than significant, and mitigation would not be required. The less than significant GHG impacts of Alternative 3 would be reduced compared to the proposed project, which would have potentially significant and unavoidable GHG impacts. e. Hazards and Hazardous Materials
The Airport Parking Land Use Alternative would require demolition of the existing on-site buildings, similar to the proposed project, which could contain lead paint or asbestos containing materials.

There would be potential for construction workers to be exposed to these hazards accidentally during demolition. Impacts would be potentially significant, and implementation of mitigation would be required.

Construction of Alternative 3 would involve excavation, such as construction of the proposed building foundation or buried utility connections, similar to the proposed project. Excavation and grading could disturb contaminated soils or groundwater and expose construction workers to hazardous materials present as contamination. Likewise, construction would generate dust. If soils from the contamination areas are stockpiled on site and become airborne dust, either from wind erosion or construction equipment, off-site receptors could be exposed, as well as construction workers. Construction of Alternative 3 would also require the demolition of the existing City of San Leandro
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groundwater monitoring wells that were previously installed as part of the remediation actions onsite. Impacts would be potentially significant, and implementation of mitigation would be required.

During operation of Alternative 3, vapors from contaminated soil and groundwater underlying the site could potentially infiltrate the proposed building, similar to the proposed project. While there would not be many workers routinely present inside of the building, parking attendants may be present inside the building. Likewise, customers using the building to park their cars would also be exposed to vapors briefly. The accumulation of vapors in the breathing zone inside the building could present a potential hazard to human health. Additionally, Alternative 3 would include bioretention areas where stormwater would collect during operation and be allowed to infiltrate the ground surface. This would have the potential to create a pathway for hazardous contamination to migrate through soil layers and potentially reach other groundwater aquifers. Impacts would be potentially significant.

The potentially significant impacts of Alternative 3 related to hazards and hazardous materials would be reduced to less than significant levels with implementation of mitigation measures HAZ-1 through HAZ-6 in Section 4.2, Hazardous and Hazardous Materials. These mitigation measures would also be required for the proposed project and would reduce the proposed project’s impacts to less than significant levels. Accordingly, the potential hazards and hazardous materials impacts of the Airport Parking Land Use Alternative would be similar to the potential impacts of the proposed project.
f. Noise and Vibration
The Airport Parking Land Use Alternative would generate temporary increases in noise during demolition and construction activities, similar to the proposed project. The types of construction activities and equipment and the construction duration of this alternative would be the same as the proposed project, as Alternative 3 would involve similar construction, except no natural gas would be provided to the site. As described in Section 4.3, Noise and Vibration, construction noise levels would be below thresholds of significance at the nearest sensitive receptors to the project site.

Accordingly, the temporary noise impacts of the Airport Parking Land Use Alternative would be less than significant and similar to those of the proposed project. However, the temporary groundborne vibration from construction activities would be potentially significant.

On-site operations under this alternative would not include tractor trailers, which generate more noise than passenger vehicles due to air brakes, larger diesel engines, back-up alarms, and trailer coupling/decoupling activities. As described in Section 4.3, Noise and Vibration, when trucks operate on the eastern side of the proposed building, the combined noise of these trucks and rooftop HVAC equipment would generate noise levels of approximately 56 dBA at the nearest sensitive receptors to the project site. Therefore, it is reasonable to assume that noise levels from operation of the Airport Parking Land Use Alternative would be below 56 dBA at the nearest sensitive receptor, because this alternative would not include truck noise. The threshold of significance is 55 dBA, which would not be exceeded by Alternative 3. Accordingly, the impacts of operation noise of Alternative 3 would be less than significant and reduced compared to those of the proposed project.

The potentially significant impacts of Alternative 3 related to vibration would be reduced to less than significant levels with implementation of Mitigation Measure NOI-2 in Section 4.3, Noise and Vibration. This mitigation measure would also be required for the proposed project and would reduce proposed project impacts to less than significant levels. While both Alternative 3 and the proposed project would have less than significant noise and vibration impacts with mitigation, impacts of Alternative 3 would be reduced when compared to the potential impacts of the proposed Alternatives
Environmental Impact Report 6-13
project. Impacts would be reduced because Alternative 3 would result in reduced operational noise impacts.
g. Tribal Cultural Resources
The Airport Parking Land Use Alternative would involve construction and ground disturbance across the entire project site, similar to the proposed project. During construction, grading of the site and excavation required for utility connections and the foundation of the new building would have the potential to uncover and disturb previously unknown or unidentified tribal cultural resources.

Disturbance or damage to tribal cultural resources would be a potentially significant but mitigable impact. Implementation of the Mitigation Measure TCR-1 in the Initial Study section titled Tribal Cultural Resources would be required for this alternative (see Appendix A). Implementation of mitigation measures would reduce impacts to tribal cultural resources to less than significant levels.

Compared to the proposed project the Airport Parking Land Use Alternative would result in similar impacts to tribal cultural resources, because the proposed project would also have potentially significant impacts to archaeological resources that would be reduced to less than significant levels with implementation of mitigation.

6.5 Alternatives Considered but Eliminated
Section 15126.6 of the CEQA Guidelines states that:
“An 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 the significant effects of the project, and evaluate the comparative merits of the alternatives. An EIR need not consider every conceivable alternative to a project. Rather it must consider a reasonable range of potentially feasible alternatives that will foster informed decision making and public participation. An EIR is not required to consider alternatives which are infeasible.

The lead agency is responsible for selecting a range of project alternatives for examination and must publicly disclose its reasoning for selecting those alternatives. There is no ironclad rule governing the nature or scope of the alternatives to be discussed other than the rule of reason.” Among the factors that may be used to eliminate alternatives from detailed consideration in an EIR are: (1) failure to meet most of the basic project objectives, (2) infeasibility, or (3) inability to avoid significant environmental impacts. Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site (or the site is already owned by the proponent). An EIR need not consider an alternative whose effect cannot be reasonably ascertained and whose implementation is remote and speculative.

The California Supreme Court, in Citizens of Goleta Valley v. Board of Supervisors (1990), indicated that a discussion of alternative sites is needed if the project “may be feasibly accomplished in a successful manner considering the economic, environmental, social, and technological factors involved” at another site. Several criteria form the basis of whether alternative sites need to be considered in detail. These criteria take the form of the following questions:

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1. Could the size and other characteristics of another site physically accommodate the project?

2. Is another site reasonably available for acquisition?

3. Is the timing of carrying out development on an alternative site reasonable for the applicant?

4. Is the project economically feasible on another site?

5. What are the land use designation(s) of alternative sites?

6. Does the lead agency have jurisdiction over alternative sites? and

7. Are there any social, technological, or other factors which may make the consideration of alternative sites infeasible?
Site characteristics that could support a project that meets the project objectives include appropriate size to accommodate an economically viable industrial building; proximity to freeways, rails and airports in the San Francisco Bay Area; and proximity to other industrial, warehousing, and logistics land uses to avoid land use conflicts. In order to accommodate the needed industrial use, the building must be located on a property or contiguous properties measuring approximately 14 acres or larger. This size is needed to accommodate the building plus provide the space for tractor trailers to operate and park safely on the site alongside worker vehicles used for daily commutes.

Additionally, the property must be zoned Industrial General or for industrial uses that allow for warehouses and logistics.

Initially the City of San Leandro considered analyzing an alternative that involved locating the project on an alternate site. However, the alternate site alternative was dismissed from further consideration because there are few if any properties that are 14 acres or larger, vacant, available to the project applicant, and proximate to freeways and the Oakland International Airport. The project applicant owns other land in the region, but these holdings are generally smaller than the project site and would not facilitate the proposed project without displacing ongoing operations or for other reasons related to site characteristics as listed above. For these reasons the alternate site alternative was dismissed from further consideration.

6.6 Environmentally Superior Alternative
Table 6-1 indicates whether each alternative’s environmental impact is greater than, less than, or similar to that of the proposed project for each of the issue areas studied in this section of the EIR.

Based on the alternatives analysis provided above, Alternative 1 would be the environmentally superior alternative, though it is the No Project Alternative, and therefore would not meet the objectives of the proposed project. The environmentally superior development alternative would be Alternative 3, as it would reduce impacts in the categories of air quality, greenhouse gas emissions, hazards and hazardous materials, and noise. Alternative 3, however, would not meet all the objectives of the proposed project, such as establishing providing industrial productivity and employment in San Leandro that is near freeways and airports. Alternative 2 would meet most of the project objectives but would not reduce project impacts to the same extent as Alternative 3.

None of the alternatives analyzed above would result in significant or unavoidable impacts; thus, all alternatives would avoid the proposed project’s significant and unavoidable impacts related to GHG emissions, which are the only significant and unavoidable impacts identified for the proposed project.

Alternatives
Environmental Impact Report 6-15
Table 6-1 Impact Comparison of Alternatives
Issue
Proposed Project Impact
Classification1
Alternative 1:

No Project
Alternative
Alternative 2:

No Natural Gas
Alternative
Alternative 3:

Airport Parking Land
Use Alternative
Air Quality Less than Significant with
Mitigation
+ + +
Biological Resources Less than Significant with
Mitigation
+ = =
Cultural Resources Less than Significant with
Mitigation
+ = =
Greenhouse Gas Emissions Significant and Unavoidable + + + Hazards and Hazardous
Materials
Less than Significant with
Mitigation
+ = +
Noise and Vibration Less than Significant with
Mitigation
+ = +
Tribal Cultural Resources Less than Significant with
Mitigation
+ = =
1 Most severe level of impact determination for proposed project is presented in this table. + Superior to the proposed project (reduced level of impact) - Inferior to the proposed project (increased level of impact) = Similar level of impact to the proposed project
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References
Environmental Impact Report 7-1
7 References

7.1 Bibliography
Project Description
San Leandro, City of. 2016. 2035 General Plan. Retrieved on December 3, 2023, from https://www.sanleandro.org/civicax/filebank/blobdload.aspx?blobid=26266 U.S. Green Building Council. 2023. LEED Building Design + Construction: Appendix 2. Default Occupancy Counts. (Volume 4). Retrieved on December 3, 2023, from https://www.usgbc.org/credits/new-construction-existing-buildings-commercial-interiorscore-and-shell-schools-new-constr-3 Environmental Setting
California Department of Finance. 2023. Estimates-E1: Population and Housing Estimates for Cities, Counties, and the State - January 1, 2022 and 2023. Retrieved on December 4, 2023, from https://dof.ca.gov/forecasting/demographics/estimates-e1/ San Leandro, City of. 2020. History. Retrieved on December 4, 2023, from https://www.sanleandro.org/about/historyorig.asp
Greenhouse Gas Emissions
Bay Area Air Quality Management District (BAAQMD). 2017. Final 2017 Clean Air Plan: Spare the Air, Cool the Climate. Adopted April 19, 2017. Retrieved on February 14, 2024, from https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-airplan/attachment-a_-proposed-final-cap-vol-1-pdf.pdf Bay Area Air Quality Management District (BAAQMD). 2022. California Environmental Quality Act Air Quality Guidelines (a.k.a. 2022 CEQA Guidelines). Retrieved on January 29, 2024, from https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-actceqa/updated-ceqa-guidelines California Air Resources Board (CARB). 2017. California’s 2017 Climate Change Scoping Plan.

Retrieved on January 29, 2024, from
https://ww2.arb.ca.gov/sites/default/files/classic/cc/scopingplan/scoping_plan_2017.pdf California Air Resources Board (CARB). 2023. California Greenhouse Gas Emissions from 2000 to 2021: Trends of Emissions and Other Indicators. Retrieved on January 29, 2024, from https://ww2.arb.ca.gov/sites/default/files/2023-12/2000_2021_ghg_inventory_trends.pdf Intergovernmental Panel on Climate Change (IPCC). 2007. Fourth Assessment Report. Retrieved on January 29, 2024, from
https://www.ipcc.ch/site/assets/uploads/2018/05/ar4_wg1_full_report-1.pdf Intergovernmental Panel on Climate Change (IPCC). 2022. Sixth Assessment Report. Retrieved on January 29, 2024, from https://report.ipcc.ch/ar6/wg1/IPCC_AR6_WGI_FullReport.pdf Office of the Attorney General (OAG). 2018. “Climate Change Impacts in California.” Department of Justice. Sacramento, CA. https://oag.ca.gov/environment/impact (accessed July 2020).

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San Leandro, City of. 2016. 2035 General Plan. Retrieved on December 3, 2023, from https://www.sanleandro.org/civicax/filebank/blobdload.aspx?blobid=26266 San Leandro, City of. 2021. San Leandro 2021 Climate Action Plan. Retrieved on January 29, 2024, from https://www.sanleandro.org/DocumentCenter/View/6490/San-Leandro-CAPADOPTED-2021-08-06 Hazards and Hazardous Materials
California Department of Toxic Substances Control (DTSC). 2023. Envirostor Database. Retrieved on December 12, 2023, from
https://www.envirostor.dtsc.ca.gov/public/map/?myaddress=880+doolittle+drive Langan Engineering and Environmental Services, Inc. 2019. Phase I Environmental Site Assessment:
880 Doolittle Drive: San Leandro, California. On file with City of San Leandro.

RMD Environmental Solutions. 2021. Revised Soil and Groundwater Management Plan. June 11, 2021. Available at:
https://www.envirostor.dtsc.ca.gov/getfile?filename=/public%2Fdeliverable_documents%2 F4130524158%2FRevised%20KAF%20Doolittle%20Soil%20GW%20Management%20Plan%2 02021-06-11.pdf
State Water Resources Control Board. 2023. Geotracker Database. Retrieved on December 12, 2023, from https://geotracker.waterboards.ca.gov/
The Source Group, Inc. 2008a. Final Remediation Action Plan. February 29, 2008. Available at:
https://www.envirostor.dtsc.ca.gov/getfile?filename=/public%2Fdeliverable_documents%2 F4390348136%2FKAEC%20Final%20RAP%202008-2-29%20(Text%20and%20Figures).pdf The Source Group, Inc. 2008b. Remedial Design and Implementation Plan. April 28, 2008. Available at:
https://www.envirostor.dtsc.ca.gov/getfile?filename=/public%2Fdeliverable_documents%2 F4518338859%2Ffinal%20rdip.pdf
U.S. Environmental Protection Agency. 2023. Learn the Basics of Hazardous Waste. Retrieved on December 12, 2023, from https://www.epa.gov/hw/learn-basics-hazardous-waste Noise and Vibration
Alameda County Community Development Department. 2010. Oakland International Airport:

Airport Land Use Compatibility Plan. Retrieved on December 13, 2023, from https://www.acgov.org/cda/planning/generalplans/documents/OAK_ALUCP_122010_FULL. pdf
California Department of Transportation (Caltrans). 2013. Technical Noise Supplement to Traffic Noise Analysis Protocol. https://dot.ca.gov/-/media/dot-media/programs/environmentalanalysis/documents/env/tens-sep2013-a11y.pdf (accessed August 2022).

California Department of Transportation (Caltrans). 2020. Transportation and Construction Vibration Guidance Manual. April 2020. https://dot.ca.gov/-/media/dotmedia/programs/environmental-analysis/documents/env/tcvgm-apr2020-a11y.pdf (accessed August 2022).

References
Environmental Impact Report 7-3
Crocker, Malcolm J. (Editor). 2007. Handbook of Noise and Vibration Control Book. ISBN: 978-0-471- 39599-7, Wiley-VCH. October 2007.

Federal Highway Administration (FHWA). 2006. FHWA Roadway Construction Noise Model User’s Guide. https://www.fhwa.dot.gov/environment/noise/construction_noise/rcnm/rcnm.pdf (accessed August 2022).

Federal Transit Administration (FTA). 2018. Transit Noise and Vibration Impact Assessment.

November. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/researchinnovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report-no0123_0.pdf (accessed August 2022).

Occupational Safety and Health Administration (OSHA). 2023. Occupational Noise Exposure.

Retrieved on December 13, 2023, from https://www.osha.gov/noise/exposure-controls Reherman, Clay N., Rochat, Judith L., Thalheimer, Erich S., Lau, Michael C., Fleming, Gregg G., Ferroni, Mark, and Corbisier, Christopher. Roadway Construction Noise Model (RCNM) Users' Guide and Model. Federal Highway Administration, Washington, DC: January 2006.

San Leandro, City of. 2016a. 2035 General Plan. Retrieved on December 3, 2023, from https://www.sanleandro.org/civicax/filebank/blobdload.aspx?blobid=26266 Transportation
Alameda County Transportation Commission (ACTC). 2019. Vehicle Miles Traveled Per Employee:

Central Planning Area [map}. Retrieved on March 7, 2024, from https://www.alamedactc.org/wpcontent/uploads/2020/06/VMT_per_Employee_Central_Planning_Area.pdf California Department of Transportation (Caltrans). 2020. Highway Design Manual. Retrieved on February 29, 2024, from https://dot.ca.gov/programs/design/manual-highway-designmanual-hdm Governor’s Office of Planning and Research (OPR). 2018. Technical Advisory on Evaluating Transportation Impacts in CEQA. December 2018. Retrieved on February 29, 2024, from https://opr.ca.gov/docs/20190122-743_Technical_Advisory.pdf Williams, T.A., Chigoy, B., Borowiec, J., & Glover, B. 2016. Methodologies Used to Estimate and Forecast Vehicle Miles Traveled (VMT). Transportation Policy Research Center. Retrieved on February 29, 2024, from https://static.tti.tamu.edu/tti.tamu.edu/documents/PRC-2016-

2.pdf
Other CEQA Related Discussions
Association of Bay Area Governments (ABAG). 2017. Plan Bay Area 2040: Regional Forecast of Jobs, Population and Housing. http://2040.planbayarea.org/files/2017- 07/Regional%20Forecast%20Supplemental%20%20Report_Final_7-2017_0.pdf (accessed October 2021).

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7-4
Bay Area Air Quality Management District. 2022. California Environmental Quality Act: Air Quality Guidelines Appendix B: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. April 2022. Retrieved on December 20, 2023, from https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines2022/appendix-b-thresholds-for-evaluating-significance-of-climate-impacts_finalpdf.pdf?rev=10305f45037b41dba2cd1b45b288d54b&sc_lang=en California Energy Commission. 2019a. Electricity Consumption by County. https://ecdms.energy.ca.gov/elecbycounty.aspx (accessed October 2021) California Office of Historic Preservation Department of Parks and Recreation. 2001. California Office of Historic Preservation Technical Assistance Series #7: How to Nominate a Resource to the California Register of Historical Resources.
https://ohp.parks.ca.gov/pages/1056/files/07_TAB%207%20How%20To%20Nominate%20A %20Property%20to%20California%20Register.pdf (accessed October 2021). ______. 2019b. Gas Consumption by County. https://ecdms.energy.ca.gov/gasbycounty.aspx (accessed October 2021)
______. 2015. California Gasoline Data, Facts, and Statistics. https://www.energy.ca.gov/datareports/energy-almanac/transportation-energy/california-gasoline-data-facts-and-statistics (accessed October 2021)
Pacific Gas and Electric. 2015. PG&E’s 2015 Power Mix.
https://www.pge.com/pge_global/common/pdfs/your-account/your-bill/understand-yourbill/bill-inserts/2016/11.16_PowerContent.pdf (accessed October 2021) Papé Machinery. 2019. Fuel Efficiency Guide for Construction. https://construction.papemachinery.com/blog/how-to-improve-fuel-efficiency-on-the-jobsite (October 2021).

San Leandro, City of. 2020. 2035 General Plan.
https://www.sanleandro.org/civicax/filebank/blobdload.aspx?blobid=26266 (accessed October 2021)
U.S. Census Bureau. 2020. QuickFacts: San Leandro, California and Alameda County, California. https://www.census.gov/quickfacts/fact/table/sanleandrocitycalifornia,alamedacountycalif ornia/PST045219 (accessed October 2021).

Alternatives
Natural Gas Supply Association. 2023. Industrial Uses of Natural Gas. Retrieved on May 7, 2024, from https://www.ngsa.org/industrial-uses-of-natural-gas/

7.2 List of Preparers
This EIR was prepared by the City of San Leandro, with the assistance of Rincon Consultants, Inc.

Consultant staff involved in the preparation of the EIR are listed below.

RINCON CONSULTANTS, INC.

Abe Leider, AICP CEP, Principal
George Dix, Project Manager
References
Environmental Impact Report 7-5
Bill Vosti, Environmental Planner
Jesse McCandless, Noise Specialist
Julie Welch, REPA, Environmental Scientist
City of San Leandro
880 Doolittle Drive Industrial Project
7-6
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Appendix A
Initial Study
880 Doolittle Drive Industrial Project
Initial Study
PLN22-0039
prepared by
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Contact: Cindy Lemaire, AICP, CNU-A, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
June 2024
880 Doolittle Drive Industrial Project
Initial Study
PLN22-0039
prepared by
City of San Leandro
835 East 14th Street
San Leandro, California 94577
Contact: Cindy Lemaire, AICP, CNU-A, Senior Planner
prepared with the assistance of
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
June 2024
This page intentionally left blank.

Table of Contents
Initial Study i
Table of Contents
Initial Study.............................................................................................................................................1

1. Project Title.........................................................................................................................1

2. Lead Agency Name and Address.........................................................................................1

3. Contact Person and Phone Number ...................................................................................1

4. Project Location ..................................................................................................................1

5. Project Sponsor’s Name and Address.................................................................................1

6. General Plan Designation....................................................................................................1

7. Zoning..................................................................................................................................4

8. Description of Project .........................................................................................................4

9. Project Objectives.............................................................................................................12

10. Surrounding Land Uses and Setting..................................................................................12

11. Other Public Agencies Whose Approval is Required ........................................................16

12. Have California Native American Tribes Traditionally and Culturally Affiliated with the Project Area Requested Consultation Pursuant to Public Resources Code Section 21080.3.1? ........................................................................................................................17 Environmental Factors Potentially Affected.........................................................................................19 Determination ......................................................................................................................................19 Environmental Checklist.......................................................................................................................21 1 Aesthetics..........................................................................................................................21 2 Agriculture and Forestry Resources..................................................................................27 3 Air Quality .........................................................................................................................31 4 Biological Resources..........................................................................................................49 5 Cultural Resources............................................................................................................55 6 Energy ...............................................................................................................................59 7 Geology and Soils..............................................................................................................67 8 Greenhouse Gas Emissions...............................................................................................73 9 Hazards and Hazardous Materials....................................................................................79 10 Hydrology and Water Quality ...........................................................................................87 11 Land Use and Planning......................................................................................................95 12 Mineral Resources ............................................................................................................99 13 Noise ...............................................................................................................................101 14 Population and Housing..................................................................................................107 15 Public Services.................................................................................................................109 16 Recreation.......................................................................................................................113 17 Transportation ................................................................................................................115 18 Tribal Cultural Resources................................................................................................125 City of San Leandro
880 Doolittle Drive Industrial Project
ii
19 Utilities and Service Systems ..........................................................................................129 20 Wildfire............................................................................................................................137 21 Mandatory Findings of Significance................................................................................139 References..........................................................................................................................................143 Bibliography................................................................................................................................143 List of Preparers..........................................................................................................................146 Tables
Table 1 Industrial General Development Regulations...................................................................22 Table 2 Project Consistency with General Plan and Municipal Code............................................24 Table 3 Project Consistency with City Zoning Requirements........................................................24 Table 4 Health Effects Associated with Non-Attainment Criteria Pollutants................................32 Table 5 Criteria Air Pollutant Significance Thresholds...................................................................36 Table 6 Estimated Daily Construction Emissions of the Project....................................................41 Table 7 Estimated Operational Daily Emissions of the Project .....................................................42 Table 8 Construction Risk ..............................................................................................................44 Table 9 Operational Risk................................................................................................................45 Table 10 2020 Cumulative Health Risk ............................................................................................46 Table 11 2020 Annual Gasoline and Diesel Consumption...............................................................60 Table 12 Project Consistency with State Renewable Energy and Energy Efficiency Plans..............63 Table 13 Project Consistency with the 2035 General Plan and Climate Action Plan ......................64 Table 14 Project Consistency with San Leandro 2035 General Plan Land Use Policies...................96 Table 15 Project Consistency with the San Leandro Municipal Code .............................................97 Table 16 Federal Transit Administration Construction Vibration Impact Criteria.........................103 Table 17 City of San Leandro Noise and Land use Compatibility Guidelines ................................104 Table 18 Project Trip Generation...................................................................................................119 Table 19 Project and Cumulative Development Intersection Level of Service..............................120 Table 20 Project Consistency with General Plan Transportation Element....................................121 Table 21 EBMUD Normal and Dry Year Supply and Demand Comparison 2020-2050 .................130 Table 22 Estimated Landfill Capacities and Closure Date..............................................................132 Table 23 Generated Solid Waste and Estimated Landfill Capacity................................................136 Table of Contents
Initial Study iii
Figures
Figure 1 Regional Location................................................................................................................2 Figure 2 Project Location ..................................................................................................................3 Figure 3 Conceptual Site Plan ...........................................................................................................5 Figure 4 Conceptual Warehouse Elevations.....................................................................................7 Figure 5 Preliminary Utility Plan .......................................................................................................9 Figure 6 Conceptual Grading Plan...................................................................................................11 Figure 7 Existing Conditions: Representative Photographs............................................................13 Appendices
Appendix A Air Quality Assessment
Appendix B Health Risk Assessment
Appendix C Biological Resources Assessment
Appendix D Cultural Resources Memorandum
Appendix E Geotechnical Investigation
Appendix F Transportation Impact Analysis

Initial Study
Initial Study 1
Initial Study

1. Project Title
880 Doolittle Drive Industrial Project
PLN22-0039

2. Lead Agency Name and Address
City of San Leandro
835 E. 14th Street
San Leandro, California 94577

3. Contact Person and Phone Number
Cindy Lemaire, AICP, CNU-A
Senior Planner
(510) 577-3348

4. Project Location
The project site is located at 880 Doolittle Drive, which is on the east side of Doolittle Drive just east of adjacent properties with frontage on Doolittle Drive, approximately 0.2 mile north of its intersection with Davis Street, in San Leandro. The project site measures approximately 14.14 acres and consists of two Assessor’s parcels: APN 77A-0741-004-02 and 77A-0741-005-00. Existing access to the project site is from a driveway on Doolittle Drive. Access to the site is also provided from a driveway at the southern terminus of Hester Street, which is a public street north of the project site.

Figure 1 shows the site location in a regional context. Figure 2 shows an aerial view of the location of the site relative to the surrounding area. The aerial photograph shown in Figure 2 is outdated in that is shows vehicles on-site. The buildings on site are currently vacant with no active operations.

5. Project Sponsor’s Name and Address
Prologis
Claudia Tarpin, Director, Development
(510)-656-1900

6. General Plan Designation
The project site is designated as General Industrial in the San Leandro 2035 General Plan (City of San Leandro 2016). According to the Land Use Element of the 2035 General Plan, areas designated as General Industrial may contain a wide range of manufacturing, transportation, food and beverage processing, technology, warehousing, vehicle storage, office-flex, and distribution uses. A limited range of commercial uses are also permitted in these areas.

City of San Leandro
880 Doolittle Drive Industrial Project
2 Figure 1 Regional Location
Initial Study
Initial Study 3
Figure 2 Project Location
City of San Leandro
880 Doolittle Drive Industrial Project
4 7. Zoning
The project site is in the Industrial General (IG)zoning district. A variety of commercial and industrial land uses are permitted by right in the IG zone. Sample uses include automobile parts sales, business and trade schools, food processing, laboratories, big-box retail sales, and warehouses (San Leandro Municipal Code Section 2.12.200).

8. Description of Project
The proposed project consists of consolidating the two parcels comprising the project site into a single parcel, demolishing existing vacant structures, and developing a new industrial shell building on the site. The proposed project also includes a new surface parking lot, internal circulation roadways, new utility connections, and landscaping. The major components of the proposed project are described below.

Property Consolidation and Demolition
The project site comprises two separate parcels, identified as APNs 77A-0741-004-02 and 77A-0741- 005-00. The proposed project includes merging these two parcels into a single parcel. The new parcel would measure approximately 14.14 acres.

Industrial Development
After approximately 6 months following demolition of existing structures, the proposed project would include construction of a new warehouse with supporting office space. The proposed warehouse is approximately 244,573 square feet, comprised of a 229,573 square-foot of warehouse and 15,000 square feet of associated office space. Approximately 10,000 square feet of office space would be provided on the ground floor alongside the warehouse use. The remaining 5,000 square feet of office space would be on a mezzanine level of the warehouse. The footprint of the warehouse and office use would be 239,753 square feet. The proposed office space would be located in the building. The proposed warehouse would be positioned within the project site to comply with the City’s minimum frontage setback requirement of 10 feet. The proposed floor area ratio (FAR) is 0.40 and the maximum building height would be 50 feet with an interior clear height of 40 feet. Figure 3, which is a conceptual site plan, shows the location of the proposed warehouse on the project site.

As shown on Figure 3Figure 3, sixty-four loading docks are proposed, 27 on the north side and 37 on the south side of the building. In addition to dock doors, traditional doors for egress and ingress to the building would be provided for each of the two office spaces within the proposed warehouse.

Traditional doors would be provided on the north side of the building and south side of the building, next to dock doors.

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Initial Study 5
Figure 3 Conceptual Site Plan
City of San Leandro
880 Doolittle Drive Industrial Project
6 The exterior of the proposed warehouse would be constructed of a mix of materials, including concrete panels, corrugated and noncorrugated metal panels, wood finish/trim, and glazing. Glazing refers to the glass installed in the building such as windows. Glazing would be a mix of insulated glass installed over concrete and other materials, and glass installed over openings to serve as traditional windows. Generally, given the proposed warehouse use, exterior windows would be limited to the office use areas of the buildings. Figure 4 shows conceptual elevations of the proposed building, including identifying the various exterior finishes and glazing that would be used.

Circulation/Access and Parking
Access to the project site would be from the driveway on Doolittle Drive in the southwest area of the site, and from the end of Hester Street in the northern area of the site, as shown on Figure 3.

Although these are both existing driveways, the proposed project would include reconstruction of the driveways to meet City standards and current ADA requirements. This would involve repairs as needed of the driveway from Doolittle Drive. New curb cuts would be provided at the cul-de-sac on Hester Street, which would also include reconstructing (i.e., replacement of) portions of the sidewalk along the project site frontage on Hester Street. Additionally, a new, second, driveway to the site would be constructed at the end of Hester Street, providing a total of three driveways.

The internal circulation road would be wide enough to allow tractor trailers to maneuver in reverse into loading docks on the north and south side of the warehouse, as shown on Figure 3.

The proposed project would include two main surface parking areas. The lot on the west side of the building would consist primarily of parking spaces for passenger vehicles. A total of 204 parking spaces would be provided for passenger vehicles, consisting of the following:
 116 standard parking spaces (9 feet by 18.5 feet)
 57 spaces for compact cars (8 feet by 16 feet)
 3 standard accessible spaces
 3 standard accessible van space
 4 clean air spaces
 21 electric vehicle spaces
The other main surface parking area would be on the north side of the warehouse, as shown on Figure 3. This parking area would consist of 59 spaces sized for tractor trailers. Tractor trailer parking spaces would be 10 feet by 53 feet each.

Initial Study
Initial Study 7
Figure 4 Conceptual Warehouse Elevations
City of San Leandro
880 Doolittle Drive Industrial Project
8 Landscaping
Approximately 41,592 square feet of landscaping would be provided throughout the site including along the perimeter of the site to provide screening and a buffer between adjoining properties and land uses as well as in parking islands. No landscaping is proposed on the east side of the warehouse, which faces Carden Street and other commercial and industrial land uses. Instead, the project would include rock mulch at the eastern project site boundary. Where landscaping is installed, it would consist mostly of shrubs, providing either visual accents or screening, depending on planting density. Landscaping would also include new trees. New trees would be planted amongst shrubs along much of the site boundary, but also in landscaped parking islands within the surface parking area designed for passenger vehicles. Trees would also be planted around the proposed driveways on Hester Street, near the surface parking area designed for trailers. Trees would be a mix of conifers and deciduous species. Landscaping shrubs and trees would consist of species native to California.

The project landscaping areas would also function as bioswale areas to treat stormwater runoff. The bioswales would be planted with a mix of native grasses, low shrubs, and sod. These bioswale areas are described in more detail below in the Utilities section of this project description.

Utilities
Potable water service for the project would be provided by the East Bay Municipal Utility District (EBMUD), the City of San Leandro potable water service provider. A new water connection would be constructed on site and connect to an existing water main that is beneath the surface of the existing driveway at Doolittle Drive. Generally, the new water connection would be located beneath the new surface parking area on the west side of the proposed warehouse, as shown on Figure 5. A new fire hydrant pipeline would also connect to the existing water main in the project area in accordance with City code and requirements.

Sanitary sewer service for the project would be provided by the City’s Sewer Department. Similar to the water line, a new sanitary sewer line would connect the proposed warehouse and an existing sanitary sewer main through the driveway on Doolittle Drive, as shown on Figure 5.

Stormwater runoff would be treated on site to meet the current Alameda County C.3 stormwater regulations before being discharged to the existing storm drain system. On-site treatment would occur with a series of bioswales, as shown on Figure 5. The bioswales are designed to capture and slow/pool runoff from impervious surfaces, functioning as bioretention areas. The bioswales would include approximately 18 inches of biotreatment soils and an underlying approximately 12 inches of permeable gravels. The bioswales will be vegetated with a native bioretention grass. Runoff collects and infiltrates the biotreatment soil, reducing the volume of runoff discharged into the storm drain system. Slowing the velocity of runoff by directing it into bioswales also allows solids to settle out before the runoff is discharged into the storm drain system. After entering on-site bioswales, treated runoff that infiltrates the soil would enter storm drain inlets installed in each bioswale. As shown on Figure 5, the inlets would connect to a storm drain pipeline installed beneath new surface parking areas and connect to an existing storm drain through the Doolittle Drive driveway.

Initial Study
Initial Study 9
Figure 5 Preliminary Utility Plan
City of San Leandro
880 Doolittle Drive Industrial Project
10 Construction and Grading
The timing of project construction would be determined by market forces and other considerations, such as weather or availability of workforce. However, it is anticipated that construction would begin in 2024 with demolition of existing vacant structures and related infrastructure, such as utilities and surface parking.

Initial Study
Initial Study 11
Figure 6 Conceptual Grading Plan
City of San Leandro
880 Doolittle Drive Industrial Project
12 9. Project Objectives
CEQA Guidelines Section 15124(b) requires an EIR to include a statement of objectives sought by the project. The objectives assist the City, as the lead agency, in developing a reasonable range of alternatives to be evaluated in the EIR. The project objectives also aid decision-makers in preparing findings or, if necessary, a statement of overriding considerations. The statement of objectives also includes the underlying purpose of the Project and the Project benefits.

10. Surrounding Land Uses and Setting
The project site is nearly entirely developed. Existing on-site development consists of an approximately 207,000 square-foot industrial masonry building, an approximately 4,700 square-foot industrial masonry building, and paved surface parking lots, including a large surface parking lot covering approximately the northern half of the site. These existing buildings are vacant, which are the circumstances used for the environmental baseline in this document. Unpaved or undeveloped portions of the site are limited to small islands of landscaping, such as a strip of landscaping around the cul-de-sac at the end of Hester Street and landscaping along the easternmost project site boundary. Existing landscaping is a mix of non-native and weedy ground cover consisting of ruderal grass. Representative photographs of existing site conditions are shown on Figure 7.

The project is located on an infill site that is largely surrounded by industrial and commercial uses.

Initial Study
Initial Study 13
Figure 7 Existing Conditions: Representative Photographs Existing driveway connection between Doolittle Drive and the project site. The view in this photograph is northeast, toward the project site with Doolittle Drive behind the camera.

City of San Leandro
880 Doolittle Drive Industrial Project
14 Figure 7 Existing Conditions: Representative Photographs (Continued) Typical existing development on the project site, incuding existing vacant structures, ashpalt parking and driving surfaces, and ruderal vegetation. The view in this photograph is southwest facing existing buildings with the camera positioned in the northern area of ths site.

Initial Study
Initial Study 15
Figure 7 Existing Conditions: Representative Photographs (Continued) Typical existing developmen ton the project site, incuding an existing vacant structure, fencing, ashpalt parking and driving surfaces, as well as off-site railroad tracks along the southern site boundary. The view in this photograph is east.

City of San Leandro
880 Doolittle Drive Industrial Project
16 The southern boundary of the project site is adjacent to an existing railroad track and its associated right-of-way, as shown in Figure 7. The railroad tracks are out of service, as evidenced by the vegetation and topsoil covering the tracks in many locations near the project site. Commercial and industrial development occurs beyond the railroad track, farther south of the project site. The existing driveway access to the site from Doolittle Drive crosses the railroad track, which also adjoins most of the western boundary of the project site; a portion of the site’s western boundary includes the 60-foot-wide Southern Pacific Railroad right-of-way, as well as a 12-foot-wide storm drain easement and a 15-foot-wide sewer easement. Commercial and industrial land uses occur just west of the project site and adjoining railroad track, fronting on Doolittle Drive. A golf course and Oakland International Airport occur further to the west of the project site. The freight and corporate aircraft runways at Oakland International Airport are approximately 4,050 feet northwest of the project site.

Views into the site are largely limited to those from Doolittle Drive and the Hester Street cul-de-sac, within the industrial corridor. The nearest known residential uses to the project site are located approximately 500 feet northeast of the project site. Additional industrial development and active railroad tracks lie in between the project site and the residential areas. The site is in proximity to I880 via Davis Street, a major arterial for the City.

The San Francisco Bay shoreline is approximately 3,000 feet southwest of the project site. The area between the project site and the shoreline is dominated by warehousing and other industrial uses, along with waste management and the City's wastewater treatment facilities.

11. Other Public Agencies Whose Approval is Required
The project site is approximately 4,050 feet away from the nearest runways at Oakland International Airport. Due to this proximity, pursuant to Federal Aviation Regulations Part 77, a No Hazard Determination for the warehouse was issued from the Federal Aviation Administration pursuant to Federal Aviation Regulations Part 77, because the proposed warehouse would have a maximum height of 50 feet, exceeding the 43 feet maximum permitted at this distance from the airport runway. The applicant submitted the project to the FAA, who determined that a building height of 50 feet does not present a hazard to air navigation. An additional No Hazard Determination may also be needed for the use of project construction equipment exceeding 43 feet in height.

In addition to coordination and determinations from the FAA, the proposed project will also require multiple permits and approvals from the City of San Leandro. City permits required include:
 Use Permit
 Site Plan Review
 Height Exception
 Building Permit
 Grading Permit
 Tree Removal Permit
Initial Study
Initial Study 17

12. Have California Native American Tribes Traditionally and Culturally Affiliated with the Project Area
Requested Consultation Pursuant to Public Resources
Code Section 21080.3.1?
No California Native American Tribes have submitted requests to the City of San Leandro for consultation on CEQA projects pursuant to Public Resources Code Section 21080.3.1.

City of San Leandro
880 Doolittle Drive Industrial Project
18 This page intentionally left blank.

Environmental Factors Potentially Affected
Initial Study 19
Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry Resources
■ Air Quality
■ Biological Resources ■ Cultural Resources □ Energy
□ Geology and Soils ■ Greenhouse Gas
Emissions
■ Hazards and Hazardous
Materials
□ Hydrology and Water
Quality
□ Land Use and Planning □ Mineral Resources
■ Noise □ Population and
Housing
□ Public Services
□ Recreation ■ Transportation ■ Tribal Cultural Resources □ Utilities and Service
Systems
□ Wildfire ■ Mandatory Findings
of Significance
Determination
Based on this initial evaluation:
□ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.
□ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
■ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed project MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

City of San Leandro
880 Doolittle Drive Industrial Project
20 □ I find that although the proposed project could have a significant effect on the environment, because all potential significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Signature Date
Printed Name Title
Environmental Checklist
Aesthetics
Initial Study 21
Environmental Checklist
1 Aesthetics
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Except as provided in Public Resources Code
Section 21099, would the project:
a. Have a substantial adverse effect on a
scenic vista? □ □ □ ■
b. Substantially damage scenic resources,
including but not limited to, trees, rock
outcroppings, and historic buildings
within a state scenic highway? □ □ □ ■
c. In non-urbanized areas, substantially
degrade the existing visual character or
quality of public views of the site and its
surroundings? (Public views are those
that are experienced from a publicly
accessible vantage point). If the project is
in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality? □ □ ■ □
d. Create a new source of substantial light or
glare that would adversely affect daytime
or nighttime views in the area? □ □ ■ □
Setting
The project site is nearly entirely developed. Existing on-site development consists of an approximately 207,000 square-foot industrial masonry building, an approximately 4,700 square-foot industrial masonry building, and paved surface parking lots, including a large surface parking lot covering the northern approximately half of the site. Unpaved or undeveloped portions of the site are limited to small islands of landscaping, such as a strip of landscaping around the cul-de-sac at the end of Hester Street and landscaping along the easternmost project site boundary. Existing landscaping is a mix of non-native and weedy ground cover consisting of grassland. Representative photographs of existing site conditions are shown on Figure 7. The existing buildings on-site are vacant.

The nearest officially designated or eligible State Scenic Highway is Interstate 580, which is officially designated as a State Scenic Highway north of San Leandro Creek and eligible for designation south of San Leandro Creek (California Department of Transportation 2018). The project site is approximately 3.6 miles northwest of the officially designated portion and approximately 2.7 miles City of San Leandro
880 Doolittle Drive Industrial Project
22 west of the eligible portion at their closest points. Due to intervening development and distance, the project site is not visible from either segment of Interstate 580.

A scenic vista is usually defined as a panoramic view from an elevated position or a long-range view from a public vantage point. This can include views of natural features or of the built environment, when architecture and landscaped boulevards offer high-value views of an area considered important to the sense of place. The San Leandro 2035 General Plan does not formally recognize specific scenic vistas in the city. However, the General Plan does designate scenic views, which the City has identified as aesthetic priorities that contribute to a sense of place. These scenic views include long-range views of the San Francisco Bay to the west and views of hills above Interstate 580 to the east.

Regulatory Setting
San Leandro 2035 General Plan
The following Land Use Element policy of the San Leandro 2035 General Plan includes the following policies that are relevant to the proposed project.

LAND USE ELEMENT
Policy CD-6.8 Improve the visual appearance of the City’s commercial and industrial areas by applying high standards of architectural design and landscaping for new commercial and industrial development and the re-use or remodeling of existing commercial and industrial buildings.

Policy LU-8.5: Maintain areas in the City that are appropriate for lumberyards, construction suppliers, automotive repair shops, and other commercial uses that are industrial in character or that are typically located in industrial areas. While development standards in these areas should respect the operational characteristics of these uses, they should still promote aesthetic improvements, adequate buffering for nearby uses, traffic safety, and a more positive visual image.

San Leandro Municipal Code
The project site is currently zoned as Industrial General. San Leandro Municipal Code establishes use and development regulations for industrial districts. These regulations are summarized below in Table 1.

Table 1 Industrial General Development Regulations
Feature Requirement
Minimum Lot Area 5,000 square feet
Minimum Lot Width 50 feet
Minimum Setback 20 feet (required for structures over 40 feet in height) Maximum Height Up to 50 feet with approval by the Zoning Enforcement Official Maximum Lot Coverage 75%, Floor Area Ratio (FAR) of 1.0 Minimum Site Landscaping 5%
The following section of San Leandro Municipal Code would also be applicable to the project.

Environmental Checklist
Aesthetics
Initial Study 23
Section 4.08.156 Lighting. Outdoor lighting in a landscaped parking area shall not employ a light source higher than 12 feet. Outdoor parking area lighting shall create no cone of direct illumination greater than 60 degrees from a light source higher than six feet and shall not directly shine onto an adjacent street. Maximum illumination at ground level shall be three foot candles and shall not exceed one-half foot candles in an R district.

Impact Analysis
a. Would the project have a substantial adverse effect on a scenic vista? The San Leandro 2035 General Plan does not formally recognize specific scenic vistas in the city.

However, the General Plan does designate scenic views, which the City has identified as aesthetic priorities that contribute to a sense of place. These scenic views include long-range views of the San Francisco Bay to the west and views of hills above Interstate 580 to the east. Due to intervening development and distance, there are no views of the San Francisco Bay through the project site from public viewpoints. Views of the hills above Interstate 580 are also obstructed by intervening development and landscaping. The project would replace existing buildings with a new one; views of the surrounding area would remain similar to the views currently available through the project site following implementation of the project. The proposed project would not substantially alter these views nor obstruct scenic views. The project would not result in a substantial adverse effect on a scenic vista, and there would be no impact.

NO IMPACT
b. Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? Interstate 580 is a designated State Scenic Highway north of San Leandro Creek and eligible for designation south of San Leandro Creek (California Department of Transportation 2018). Due to intervening development and distance, the project site is not visible from either highway segment.

Therefore, implementation of the project would have no effect on scenic resources in view of a State Scenic Highway. There would be no impact to scenic resources within a State Scenic Highway.

NO IMPACT
c. Would the project substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? The project site is in an urbanized area as defined in the CEQA Guidelines. The project site is currently developed with a parking lot and existing industrial buildings which would be demolished as part of the proposed project. The project site is within a fully developed area surrounded by other industrial uses and commercial uses. Table 2 and Table 3 below show policies and standards from the City’s General Plan and the San Leandro Municipal Code that govern scenic quality and demonstrates the project’s consistency with both.

City of San Leandro
880 Doolittle Drive Industrial Project
24 Table 2 Project Consistency with General Plan and Municipal Code Policy/Standard Project Consistency
City of San Leandro 2035 General Plan
Policy CD-6.8. Improve the visual appearance of
the City’s commercial and industrial areas by
applying high standards of architectural design and
landscaping for new commercial and industrial
development and the re-use or remodeling of
existing commercial and industrial buildings.

The project would achieve a high standard of architectural design through the use of concrete and metal panels, wooden trim, and glazing. The project would also incorporate landscaping on site including native trees and shrubs along the project boundary to provide a buffer between the project site and surrounding uses and enhance the overall appearance of the site.

Policy LU-8.5. Maintain areas in the City that are
appropriate for lumberyards, construction
suppliers, automotive repair shops, and other
commercial uses that are industrial in character or
that are typically located in industrial areas. While
development standards in these areas should
respect the operational characteristics of these
uses, they should still promote aesthetic
improvements, adequate buffering for nearby
uses, traffic safety, and a more positive visual
image.

Consistent. The project would involve construction and operation of a warehouse structure. Existing land uses surrounding the project site include industrial and commercial uses. Therefore, the proposed warehouse would be consistent with the existing commercial and industrial character of the project site surroundings. Additionally, as described in the Project Description, the proposed warehouse’s exterior would include concrete painted off-white and beige neutral colors, wood paneling, and metal trim, which would result in aesthetic improvements compared to existing conditions and promote a positive visual image in the project area. Therefore, the project would be consistent with this policy.

Source: City of San Leandro 2016
The project would involve combining the two existing parcels into a single lot. Table 3 below demonstrates that the proposed project would be in compliance with Industrial General standards, specifically those that regulate scale and massing, pursuant to San Leandro Zoning Code Section 2.12.300. Compliance with these standards would ensure that the scale and massing of the proposed project would be limited as required by the San Leandro Zoning Code; these standards regulate visual character related to scale and massing and would ensure that the project would be designed to be visually compatible with the surrounding area.

Table 3 Project Consistency with City Zoning Requirements Feature Zoning Requirements Proposed Warehouse Feature1 Minimum Lot Area 5,000 square feet 238,573 square feet
Minimum Lot Width 50 feet 300 feet
Minimum Setback 20 feet (required for structures over 40 feet in height) 39 feet minimum Maximum Height Up to 50 feet with Zoning Enforcement Official approval
50 feet
Maximum Lot Coverage Floor Area Ratio (FAR) of up to 1.0 FAR of 0.4 Minimum Site Landscaping 5% 7%
As shown above, the project would be consistent with applicable San Leandro General Plan policies and standards related to aesthetics. The project would comply with applicable San Leandro Zoning Code standards. Impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
Environmental Checklist
Aesthetics
Initial Study 25
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
The project site is in an urban area with moderate levels of existing lighting. Lighting sources around the project site include wall-mounted security lights on adjacent buildings, streetlights on neighboring streets such as Doolittle Drive, Hester Street, and Carden Street, and lights from vehicles on parking lots and roads near the project site. The primary source of glare in the area is sunlight reflected off light-colored and reflective building materials and finishes, and metallic and glass surfaces of existing buildings on-site and buildings and vehicles parked adjacent to the project site. The Oakland International Airport also includes many exterior lights.

The proposed warehouse building would be constructed of similar materials as the existing building on site and others in the vicinity. The proposed project would also include a parking lot and loading dock, similar to the existing development on site. Therefore, the project would not introduce a new source of substantial light or glare that is different from or greater than the light and glare already existing on and around the site. Further, the project would be located in a commercial area with existing sources of light and reflection and would not adversely affect daytime views of the area.

The project would be required to comply with applicable provisions of San Leandro Zoning Code Section 4.08.156, which sets requirements for lighting, and additional nighttime lighting at the project site would be consistent with surrounding land uses. The project site is not surrounded by residences and there are no parks or similar recreational or gathering spaces adjacent to the site.

The project would not substantially alter light and glare conditions in the vicinity. Therefore, impacts related to project light and glare would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
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880 Doolittle Drive Industrial Project
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Environmental Checklist
Agriculture and Forestry Resources
Initial Study 27
2 Agriculture and Forestry Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on maps prepared
pursuant to the Farmland Mapping and
Monitoring Program of the California
Resources Agency, to non-agricultural use? □ □ □ ■
b. Conflict with existing zoning for agricultural
use or a Williamson Act contract? □ □ □ ■
c. Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in
Public Resources Code Section 12220(g));
timberland (as defined by Public Resources
Code Section 4526); or timberland zoned
Timberland Production (as defined by
Government Code Section 51104(g))? □ □ □ ■
d. Result in the loss of forest land or
conversion of forest land to non-forest
use? □ □ □ ■
e. Involve other changes in the existing
environment which, due to their location
or nature, could result in conversion of
Farmland to non-agricultural use or
conversion of forest land to non-forest
use? □ □ □ ■
Setting
The project site is located within an urban area of San Leandro. The site was previously developed and is zoned for Industrial Uses.

The California Department of Conservation (DOC) manages the Farmland Mapping and Monitoring Program to assess and record suitability of land for agricultural purposes. In each county, the land is analyzed for soil and irrigation quality. The highest quality land is designated as Prime Farmland.

According to the Alameda County Important Farmland Map prepared by the DOC, the project site and vicinity are designated as Urban and Built-Up Land and the site does not have any identified agriculture or forest land (DOC 2018).

City of San Leandro
880 Doolittle Drive Industrial Project
28 Regulatory Setting
The DOC’s Farmland Mapping and Monitoring Program (FMMP) monitors the conversion of the State’s farmland to and from agricultural use. County-level data is collected, and a series of maps are prepared that identify eight classifications and uses based on a minimum mapping unit size of 10 acres. The program also produces a biennial report on the amount of land converted from agricultural to non-agricultural use. The program maintains an inventory of State agricultural land and updates the Important Farmland Series Maps every two years. The FMMP is an informational service only and does not constitute State regulation of local land use decisions. Agricultural land is rated according to several variables, including soil quality and irrigation status with Prime Farmland being considered the most optimal for farming practices. Other FMMP designations include Farmland of Local Importance, Grazing Land, and Water.

Land Conservation Act
Better known as the “Williamson Act” (California Administrative Code Section 51200 et seq.), the California Land Conservation Act of 1965 creates a legal arrangement whereby private landowners’ contract with local governments to voluntarily restrict land to agricultural and open space uses, protecting it from unnecessary or premature conversion to urban uses. In return, restricted parcels are assessed for property tax purposes at a rate consistent with their actual use rather than potential market value, which saves landowners from 20 percent to 75 percent in property tax liability each year.

Generally, Williamson Act contracts have an initial term of ten years, with renewal occurring automatically each year thereafter. The contracts run with the land and are binding on all succeeding landowners. Land must be in an agricultural preserve to enter into a Williamson Act contract. Agricultural preserves under Williamson Act contract contain at least 100 contiguous acres of agricultural land unless specific findings are made.

Non-renewal initiations are requested either by the landowner or the local government and are often filed in anticipation of converting farmland to other uses. Most contracted land is terminated through non-renewal. Upon the expiration of the contract, the restrictions are removed and the property tax assessment, which had been gradually increasing over the previous nine-year nonrenewal period, returns to full market value.

To characterize the environmental baseline for agricultural resources, Important Farmland Maps produced by the DOC were reviewed. Unless otherwise expressed, the future use of “Important Farmland” specifically includes the following definitions provided by the DOC:

Prime Farmland: Land which has the best combination of physical and chemical characteristics for producing crops. It has the soil quality, growing season, and moisture supply needed to produce sustained high yields of crops when treated and managed, including water management, according to current farming standards.

Unique Farmland: Land of lesser quality soils used for the production of specific high economic value crops. It has the special combination of soil quality, location, growing season and moisture supply needed to produce sustained high quality or high yields of a specific crop when treated and managed according to current farming methods. It is usually irrigated but may include non-irrigated orchards or vineyards as found in some climatic zones in California. Examples of crops include oranges, olives, avocados, rice, grapes and cut flowers.

Environmental Checklist
Agriculture and Forestry Resources
Initial Study 29
Farmland of Local Importance: Land of importance to the local agricultural economy as determined by each county’s board of supervisors following recommendations by a local advisory committee.

PRC Section 12220(g) defines forest land as:
…land that can support 10-percent native tree cover of any species, including hardwoods, under natural conditions, and that allows for management of one or more forest resources, including timber, aesthetics, fish and wildlife, biodiversity, water quality, recreation, and other public benefits.

PRC Section 4526 defines timberland as:
…land, other than land owned by the federal government and land designated by the board as experimental forest land, which is available for, and capable of, growing a crop of trees of a commercial species used to produce lumber and other forest products, including Christmas trees. Commercial species shall be determined by the board on a district basis.

Government Code Section 51104(g) defines a timberland production zone as:
…an area which has been zoned pursuant to Section 51112 or 51113 and is devoted to and used for growing and harvesting timber, or for growing and harvesting timber and compatible uses, as defined in subdivision (h).

Impact Analysis
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? The project site is not designated as, is not adjacent to, and is not proximate to lands classified as Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown by maps prepared by the DOC’s Farmland Mapping and Monitoring Program maps (DOC 2018). The project would not involve any rezoning and would therefore not convert farmland to non-agricultural use.

The project would have no impact on Prime Farmland, Unique Farmland, or Farmland of Statewide Importance.

NO IMPACT
b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract?
The project site and surrounding areas are not subject to Williamson Act contracts (DOC 2022).

Therefore, no Williamson Act contracts would be affected by the project. The project would have no impact.

NO IMPACT
City of San Leandro
880 Doolittle Drive Industrial Project
30 c. Would the project conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code Section 12220(g)); timberland (as defined by Public Resources Code Section 4526); or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
d. Would the project result in the loss of forest land or conversion of forest land to non-forest use? e. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
The project site does not currently provide forest and timber resources and would not be used for forest and timber resources. The project site does not contain trees and the site itself is not considered forest or timberland (California Department of Fish and Wildlife 2021). The project would remove up to five street trees just off of the project site, within the right-of-way of Hester Street. However, these trees are not a forest. As such, the project would not convert forest or timberland uses, and no impact would occur as a result of the project.

NO IMPACT
Environmental Checklist
Air Quality
Initial Study 31
3 Air Quality
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Would the project:
a. Conflict with or obstruct implementation
of the applicable air quality plan? □ □ ■ □
b. Result in a cumulatively considerable net
increase of any criteria pollutant for
which the project region is nonattainment under an applicable federal or state ambient air quality standard? □ ■ □ □
c. Expose sensitive receptors to substantial
pollutant concentrations? □ □ ■ □
d. Result in other emissions (such as those
leading to odors) adversely affecting a
substantial number of people? □ □ ■ □
Kimley Horn and Associates prepared an Air Quality Assessment (Appendix A) for the proposed project in November 2023. Kimley Horn and Associates also prepared a Health Risk Assessment for the project in November 2023 (Appendix B). Both documents were peer reviewed by Rincon Consultants, Inc. on behalf of the City. This section of the Initial Study is largely based on the Air Quality Assessment and Health Risk Assessment.

Overview of Air Pollution
The federal and State Clean Air Acts (CAA) mandate the control and reduction of certain air pollutants. Under these laws, the U.S. Environmental Protection Agency (USEPA) and the California Air Resources Board (CARB) have established the National Ambient Air Quality Standards and the California Ambient Air Quality Standards for “criteria pollutants” and other pollutants. Some pollutants are emitted directly from a source (e.g., vehicle tailpipe, an exhaust stack of a factory, etc.) into the atmosphere, including carbon monoxide, volatile organic compounds (VOC)/reactive organic gases (ROG),1 nitrogen oxides (NOX), particulate matter with diameters of ten microns or less (PM10) and 2.5 microns or less (PM2.5), sulfur dioxide, and lead. Other pollutants are created indirectly through chemical reactions in the atmosphere, such as ozone, which is created by atmospheric chemical and photochemical reactions primarily between ROG and NOX. Secondary pollutants include oxidants, ozone, and sulfate and nitrate particulates (smog).

Air pollutant emissions are generated primarily by stationary and mobile sources. Stationary sources can be divided into two major subcategories:
1 CARB defines VOC and ROG similarly as, “any compound of carbon excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate,” with the exception that VOC are compounds that participate in atmospheric photochemical reactions. For the purposes of this analysis, ROG and VOC are considered comparable in terms of mass emissions, and the term ROG is used in this IS-MND.

City of San Leandro
880 Doolittle Drive Industrial Project
32  Point sources occur at a specific location and are often identified by an exhaust vent or stack.

Examples include boilers or combustion equipment that produce electricity or generate heat.  Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and some consumer products.

Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and can also be divided into two major subcategories:
 On-road sources that may be legally operated on roadways and highways.  Off-road sources include aircraft, ships, trains, and self-propelled construction equipment.  Air pollutants can also be generated by the natural environment, such as when high winds suspend fine dust particles.

Air Quality Standards and Attainment
The project site is located in the San Francisco Bay Area Air Basin, which is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). BAAQMD has jurisdiction over much of the nine-county Bay Area, including Alameda County. As the local air quality management agency, BAAQMD is required to monitor air pollutant levels to ensure that the National Ambient Air Quality Standards and California Ambient Air Quality Standards are met and, if they are not met, to develop strategies to meet the standards. Depending on whether the standards are met or exceeded, the San Francisco Bay Area Air Basin is classified as being in “attainment” or “nonattainment.” In areas designated as non-attainment for one or more air pollutants, a cumulative air quality impact exists for those air pollutants, and the human health impacts associated with these criteria pollutants, presented in Table 4, are already occurring in that area as part of the environmental baseline condition.

Under state law, air districts are required to prepare a plan for air quality improvement for pollutants for which the district is in non-compliance. The San Francisco Bay Area Air Basin is designated a nonattainment area for the federal 8-hour ozone standard, federal PM2.5 24-hour standards, state 8-hour and 1-hour ozone standards, state PM10 annual and 24-hour standards, and the state PM2.5 annual standard (BAAQMD 2022). This nonattainment status is a result of several factors, such as mobile sources, wood burning, industrial combustion, and dust, in the San Francisco Bay Area Air Basin.

Table 4 Health Effects Associated with Non-Attainment Criteria Pollutants Pollutant Adverse Effects
Ozone (1) Short-term exposures: (a) pulmonary function decrements and localized lung edema in humans and animals and (b) risk to public health implied by alterations in pulmonary morphology and host defense in animals; (2) long-term exposures: risk to public health implied by altered connective tissue metabolism and altered pulmonary morphology in animals after long-term exposures and pulmonary function decrements in chronically exposed humans; (3) vegetation damage; and (4) property damage.

Suspended particulate
matter (PM10)
(1) Excess deaths from short-term and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease (including asthma).1 Environmental Checklist
Air Quality
Initial Study 33
Pollutant Adverse Effects
Suspended particulate
matter (PM2.5)
(1) Excess deaths from short- and long-term exposures; (2) excess seasonal declines in pulmonary function, especially in children; (3) asthma exacerbation and possibly induction; (4) adverse birth outcomes, including low birth weight; (5) increased infant mortality; (6) increased respiratory symptoms in children, such as cough and bronchitis; and (7) increased hospitalization for both cardiovascular and respiratory disease, including asthma.

Source: United States Environmental Protection Agency 2021 Toxic Air Contaminants
Toxic air contaminants (TACs) are a diverse group of air pollutants that may cause or contribute to an increase in deaths or serious illness, or that may pose a present or potential hazard to human health. TACs include both organic and inorganic chemical substances that may be emitted from a variety of common sources, including gasoline stations, motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching facilities. One of the main sources of TACs in California is diesel engine exhaust that contains solid material known as diesel particulate matter (DPM). More than 90 percent of DPM is less than one micron in diameter (about 1/70th the diameter of a human hair) and thus is a subset of PM2.5. Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lungs (CARB 2022).

TACs are different than criteria pollutants because ambient air quality standards have not been established for TACs. TACs occurring at extremely low levels may still cause health effects and it is typically difficult to identify levels of exposure that do not produce adverse health effects. TAC impacts are described by carcinogenic risk and by chronic (i.e., long duration) and acute (i.e., severe but of short duration) adverse effects on human health.

TACs include both organic and inorganic chemical substances. While DPM is a main source, TACs may be emitted from a variety of common sources, including gasoline stations, motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching facilities. People exposed to toxic air pollutants at sufficient concentrations and durations may have an increased chance of developing cancer or experiencing other serious health effects. These health effects can include damage to the immune system, as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory, and other health problems (USEPA 2020).

Regulatory Setting
California Clean Air Act
The California CAA, signed into law in 1988, requires all areas of the State to achieve and maintain the California Ambient Air Quality Standards by the earliest practical date. CARB is the State air pollution control agency and is a part of CalEPA. CARB is the agency responsible for coordination and oversight of State and local air pollution control programs in California, and for implementing the requirements of the California CAA. CARB overseas local district compliance with federal and California laws, approves local air quality plans, submits the State implementation plans to the U.S.

EPA, monitors air quality, determines and updates area designations and maps, and sets emissions standards for new mobile sources, consumer products, small utility engines, off-road vehicles, and fuels.

City of San Leandro
880 Doolittle Drive Industrial Project
34 California Low-Emission Vehicle Program
CARB first adopted Low-Emission Vehicle (LEV) program standards in 1990. These first LEV standards ran from 1994 through 2003. LEV II regulations, running from 2004 through 2010, represent continuing progress in emission reductions. As the State’s passenger vehicle fleet continues to grow and more sport utility vehicles and pickup trucks are used as passenger cars rather than work vehicles, the more stringent LEV II standards were adopted to provide reductions necessary for California to meet federally mandated clean air goals outlined in the 1994 SIP. In 2012, CARB adopted the LEV III amendments to California’s LEV regulations. These amendments, also known as the Advanced Clean Car Program, include more stringent emission standards for model years 2017 through 2025 for both criteria pollutants and greenhouse gas (GHG) emissions for new passenger vehicles.

California On-Road Heavy-Duty Vehicle Program
CARB has adopted standards for emissions from various types of new on-road heavy-duty vehicles.

Section 1956.8, Title 13, California Code of Regulations contains California’s emission standards for on-road heavy-duty engines and vehicles, and test procedures. CARB has also adopted programs to reduce emissions from in-use heavy-duty vehicles including the Heavy-Duty Diesel Vehicle Idling Reduction Program, the Heavy-Duty Diesel In-Use Compliance Program, the Public Bus Fleet Rule and Engine Standards, and the School Bus Program and others.

Verified Diesel Emission Control Strategies
USEPA and CARB tiered off-road emission standards only apply to new engines and off-road equipment can last several years. CARB has developed Verified Diesel Emission Control Strategies (VDECS), which are devices, systems, or strategies used to achieve the highest level of pollution control from existing off-road vehicles, to help reduce emissions from existing engines. VDECS are designed primarily for the reduction of diesel PM emissions and have been verified by CARB. There are three levels of VDECS, the most effective of which is the Level 3 VDECS. Tier 4 engines are not required to install VDECS because they already meet the emissions standards for lower tiered equipment with installed controls.

California Diesel Risk Reduction Plan
CARB Diesel Risk Reduction Plan has led to the adoption of new state regulatory standards for all new on-road, off-road, and stationary diesel-fueled engines and vehicles to reduce DPM emissions by about 90 percent overall from year 2000 levels. The projected emission benefits associated with the full implementation of this plan, including federal measures, are reductions in DPM emissions and associated cancer risks of 75 percent by 2010, and 85 percent by 2020.

Tanner Air Toxics Act and Air Toxics Hot Spots Information and Assessment Act Toxic Air Contaminants (TACs) in California are primarily regulated through the Tanner Air Toxics Act (AB 1807) and the Air Toxics Hot Spots Information and Assessment Act of 1987 (AB 2588), also known as the Hot Spots Act. To date, CARB has identified more than 21 TACs and has adopted the USEPA list of Hazardous Air Pollutants (HAPs) as TACs.

Environmental Checklist
Air Quality
Initial Study 35
Air Quality Management
Because the San Francisco Bay Area Air Basin currently exceeds the federal ozone and PM2.5 standards and the state ozone, PM10, and PM2.5 standards, BAAQMD is required to implement strategies to reduce pollutant levels to achieve attainment of the National Ambient Air Quality Standards and California Ambient Air Quality Standards. BAAQMD adopted the 2017 Clean Air Plan (2017 Plan) as an update to the 2010 Clean Air Plan. The 2017 Plan provides a regional strategy to protect public health and the climate. Consistent with the greenhouse gas (GHG) reduction targets adopted by the state, the 2017 Plan lays the groundwork for a long-term effort to reduce Bay Area GHG emissions to 40 percent below 1990 levels by 2030 and 80 percent below 1990 levels by 2050.

To fulfill state ozone planning requirements, the 2017 control strategy includes all feasible measures to reduce emissions of ozone precursors (ROG and NOX) and reduce transport of ozone and its precursors to neighboring air basins. In addition, the 2017 Plan builds upon and enhances BAAQMD’s efforts to reduce emissions of fine particulate matter and toxic air contaminants (TAC) (BAAQMD 2017).

Sensitive receptors are facilities or land uses that include members of the population who are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. According to BAAQMD, sensitive receptors are defined as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and people with illnesses. Examples include schools, hospitals and residential areas (BAAQMD 2017). The nearest sensitive receivers are residences approximately 500 feet northeast of the project site. The next nearest sensitive receptor is the Metropolitan Golf Links Course, which is approximately 700 feet west of the project site (Appendix A).

City of San Leandro General Plan
The current City of San Leandro General Plan contains objectives and policies that minimize air pollutant emissions and reduce population exposed to significant health risk. The following objectives and policies from the City’s General Plan are relevant to air quality and apply to the project:

Policy EH-3.1: Clean Air Plan Implementation. Cooperate with the appropriate regional, state, and federal agencies to implement the regional Clean Air Plan and enforce air quality standards.

Policy EH-3.2: Transportation Control Measures. Promote strategies that help improve air quality and reduce greenhouse gas emissions by reducing the necessity of driving. These strategies include more reliable public transportation demand management (TDM) programs, better provisions for bicyclists and pedestrians, and encouraging mixed use and higher density development around transit stations.

Policy EH-3.3: Land Use Compatibility. Discourage new uses with potential adverse air quality impacts, including the mission of toxic air contaminants and fine particulates, near residential neighborhoods, schools, hospitals, nursing homes, and other locations where public health could potentially be affected.

Policy EH-3.4: Design, Construction, and Operation. Require new development to be designed and constructed in a way that reduces the potential for future air quality problems, such as odors and the emission of any and all air pollutants. This should be done by:

City of San Leandro
880 Doolittle Drive Industrial Project
36 a) Requiring construction and grading practices that minimize airborne dust and particulate matter;
b) Ensuring that best available control technology is used for operations that could generate air pollutants;
c) Encouraging energy conservation and low-polluting energy sources; d) Promoting landscaping and tree planting to absorb carbon monoxide and other pollutants;
e) Implementing the complementary strategies to reduce greenhouse gases identified in the Climate Action Plan.

Policy EH-3.9: Alternative Fuels Vehicles. Promote the development of infrastructure which supports the use of alternative fuel (i.e., electric) vehicles, including electric charging stations and preferential parking for electric vehicles.

Policy EH-5.4: Separation from Sensitive Uses. Provide adequate and safe separation between areas where hazardous materials are present and sensitive uses such as schools, residences, and public facilities. Zoning and other development regulations should include performance standards to avoid safety hazards and achieve compatibility between uses.

Policy LU-10.2: Off-Site Impacts. Consider the setting and context of each site when evaluating proposals for development in industrial areas. The potential for impacts on adjacent uses, including the potential for land use conflicts and increased parking demand and truck traffic, should be a key consideration.

Significance Thresholds
The BAAQMD has adopted guidelines for quantifying and determining the significance of air quality emissions in its California Environmental Quality Act Air Quality Guidelines (BAAQMD 2022).

BAAQMD recommends that lead agencies determine appropriate air quality emissions thresholds of significance based on substantial evidence in the record. BAAQMD’s significance thresholds in the updated 2022 CEQA Air Quality Guidelines for project operations within the San Francisco Bay Area Air Basin are the most appropriate thresholds for use in determining air quality impacts of the project. BAAQMD developed screening criteria to provide lead agencies and project applicants with a conservative indication of whether a project could result in potentially significant air quality impacts.

Table 5 presents the significance thresholds for construction and operational-related criteria air pollutant and precursor emissions used for the purposes of this analysis. These represent the levels at which a project’s individual emissions of criteria air pollutants or precursors would result in a cumulatively considerable contribution to the San Francisco Bay Area Air Basin existing air quality conditions. For the purposes of this analysis, the project would result in a significant impact if construction or operational emissions would exceed any of the thresholds shown in Table 5.

Table 5 Criteria Air Pollutant Significance Thresholds
Pollutant
Construction Thresholds Operational Thresholds
Average Daily Emissions (lbs/day)
Average Daily Emissions
(lbs/day)
Maximum Annual Emissions
(tons/year)
ROG 54 54 10
Environmental Checklist
Air Quality
Initial Study 37
Pollutant
Construction Thresholds Operational Thresholds
Average Daily Emissions (lbs/day)
Average Daily Emissions
(lbs/day)
Maximum Annual Emissions
(tons/year)
NOX 54 54 10
PM10 82 (exhaust) 82 15
PM2.5 54 (exhaust) 54 10
Fugitive Dust Construction Dust Ordinance or
other Best Management Practices
Not Applicable
OG = reactive organic gases, NOX = nitrogen oxides, PM10 = particulate matter 10 microns in diameter or less, PM2.5 = particulate matter

2.5 microns in diameter or less; lbs/day = pounds per day, BAAQMD = Bay Area Air Quality Management District Source: BAAQMD 2022
BAAQMD maintains rules and regulations to regulate sources of air pollution. Applicable rules and regulations are listed below. Additionally, BAAQMD does not have quantitative thresholds for fugitive dust emissions during construction. Instead, BAAQMD recommends Best Management Practices (BMPs) be implemented to reduce fugitive dust emissions, which are also listed below.

BAAQMD Rules and Regulations
REGULATION 2, RULE 1 (PERMITS–GENERAL REQUIREMENTS)
The BAAQMD regulates new sources of air pollution and the modification and operation of existing sources through the issuances of authorities to construct and permits to operate. Regulation 2, Rule 1 provides an orderly procedure which the project would be required to comply with to receive authorities to construct or permits to operate from the BAAQMD, for new sources of air pollutants, as applicable.

REGULATION 2, RULE 5 (NEW SOURCE REVIEW PERMITTING)
The BAAQMD regulates backup emergency generators, fire pumps, and other sources of TACs through its New Source Review (Regulation 2, Rule 5) permitting process. Although emergency generators are intended to be used only during periods of power outages, monthly testing of each generator is required. BAAQMD limits testing to no more than 50 hours per year. Each emergency generator installed is assumed to meet a minimum of Tier 2 emission standards (before control measures). As part of the permitting process, the BAAQMD limits the excess cancer risk from any facility to no more than 10 per 1-million-population for any permits that are applied for within a 2- year period, and would require any source that would result in an excess cancer risk greater than 1 per 1 million to install Best Available Control Technology for Toxics.

REGULATION 6, RULE 1 (PARTICULATE MATTER–GENERAL REQUIREMENTS) The BAAQMD regulates PM emissions through Regulation 6 by means of establishing limitations on emission rates, emissions concentrations, and emission visibility and opacity. Regulation 6, Rule 1 provides existing standards for PM emissions that could result during project construction or operation that the project would be required to comply with, as applicable, such as the prohibition of emissions from any source for a period or aggregate periods of more than 3 minutes in any hour which are equal to or greater than 20 percent opacity.

City of San Leandro
880 Doolittle Drive Industrial Project
38 REGULATION 6, RULE 6, (PARTICULATE MATTER–PROHIBITION OF TRACKOUT) One rule by which the BAAQMD regulates PM includes Regulation 6, Rule 6, which prohibits PM trackout during project construction and operation. Regulation 6, Rule 6 requires the prevention or timely cleanup of trackout of solid materials onto paved public roads outside the boundaries of large bulk material sites, large construction sites, and large disturbed surface sides such as landfills.

REGULATION 8, RULE 3 (ARCHITECTURAL COATINGS)
This rule governs the manufacture, distribution, and sale of architectural coatings and limits the reactive organic gases content in paints and paint solvents. Although this rule does not directly apply to the project, it does dictate the ROG content of paint available for use during the construction.

REGULATION 8, RULE 15 (EMULSIFIED AND LIQUID ASPHALTS)
This rule dictates the reactive organic gases content of asphalt available for use during construction through regulating the sale and use of asphalt and limits the ROG content in asphalt. Although this rule does not directly apply to the project, it does dictate the ROG content of asphalt for use during the construction.

REGULATION 9, RULE 8 (ORGANIC COMPOUNDS)
This rule limits the emissions of nitrogen oxides and carbon monoxide from stationary internal combustion engines with an output rated by the manufacturer at more than 50 brake horsepower.

BAAQMD Best Management Practices for Construction-Related Fugitive Dust Emissions
The applicant shall require all construction contractors to implement the basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust emissions. Emission reduction measures will include, at a minimum, the following measures:
 All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
 All haul trucks transporting soil, sand, or other loose material off-site shall be covered.  All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.  All vehicle speeds on unpaved roads shall be limited to 15 mph.  All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.

Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used.
 All excavation, grading, and/or demolition activities shall be suspended when average wind speeds exceed 20 mph.
 All trucks and equipment, including their tires, shall be washed off prior to leaving the site.  Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch compacted layer of wood chips, mulch, or gravel.  Publicly visible signs shall be posted with the telephone number and name of the person to contact at the lead agency regarding dust complaints. This person shall respond and take corrective action within 48 hours. The Air District’s General Air Pollution Complaints number shall also be visible to ensure compliance with applicable regulations.

Environmental Checklist
Air Quality
Initial Study 39
In the absence of a qualified Community Risk Reduction Plan,2 BAAQMD has established the following Thresholds of Significance for local community risks and hazards associated with TACs and PM2.5 for assessing individual source impacts at a local level. Impacts would be significant if:
 The project would result in an increased cancer risk of > 10 in one million  The project would result in an increased non-cancer (i.e., Chronic or Acute) risk of > 1.0 Hazard Index
 The project would result in an ambient PM2.5 concentration increase of > 0.3 µg/m3 annual average
A project would be considered to have a cumulatively considerable impact if the aggregate total of current and proposed TAC sources within a 1,000 feet radius of the project fence-line in addition to the project would exceed the Cumulative Thresholds of Significance. Impacts would be significant if:
 The project would result in an increased cancer risk of > 100 in one million  The project would result in an increased non-cancer (i.e., Chronic or Acute) risk of > 10 Hazard Index
 The project would result in an ambient PM2.5 concentration increase of > 0.8 µg/m3 annual average
Excess cancer risks are defined as those occurring in excess of or above and beyond those risks that would normally be associated with a location or activity if toxic pollutants were not present. Noncarcinogenic health effects are expressed as a hazard index, which is the ratio of expected exposure levels to an acceptable reference exposure level.

BAAQMD defines sensitive receptors as facilities or land uses that include members of the population that are particularly sensitive to the effects of air pollutants, such as children, the elderly, and those with pre-existing health problems. These facilities include schools, parks, daycare centers and pre-schools, medical care facilities, and residential communities (BAAQMD 2022). The nearest sensitive receivers are residences approximately 500 feet northeast of the project site.

BAAQMD establishes operational screening criteria for criteria air pollutants and precursors. If a project meets the screening criteria outlined in Section 4.1.2 and Table 4-1 of the BAAQMD CEQA Guidelines (BAAQMD 2022), the project would not result in the generation of operational-related criteria air pollutants and/or precursors that exceed the emissions thresholds shown in Table 5 above. Although the proposed project would not exceed the size screening level of 452,000 square feet for warehouse projects, the project would include operation of a backup generator, which would be subject to BAAQMD rules and regulations. Therefore, an air quality analysis and quantification of operational project-generated air pollutants is required and provided as Appendix A.

Methodology
Construction emissions modeled include emissions generated by construction equipment used on site and emissions generated by vehicle trips associated with construction, such as workers and vendor trips (Appendix A). Project construction was analyzed based on the applicant-provided information regarding the construction schedule and types of construction equipment used. 2 The goal of a Community Risk Reduction Plan is to bring TAC and PM2.5 concentrations for the entire community covered by the Plan down to acceptable levels as identified by the local jurisdiction and approved by the Air District. This approach provides local agencies a proactive alternative to addressing communities with high levels of risk on a project-by-project approach. The Air District has developed detailed guidelines for preparing Community Risk Reduction Plans which can be found on the Air District web site at:
https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/draft_community_risk_reduction_plan_guidelines_may_2010.pdf City of San Leandro
880 Doolittle Drive Industrial Project
40 Standardized assumptions were used where project-specific information was unknown. This analysis also includes all applicable regulatory standards the project would be required to comply with. In particular, the project would comply with the 2022 Building Energy Efficiency Standards (Energy Code), CalGreen, the City of San Leandro’s General Plan, and BAAQMD’s rules and regulations.

Specifically, the project would be required to comply with BAAQMD Regulation 8, Rule 3, which limits the quantity of volatile organic compounds in architectural coatings.

Operational emissions modeled include mobile source emissions (i.e., passenger vehicle and truck emissions), and area source emissions (Appendix A). Mobile source emissions are generated by vehicle trips to and from the project site. CalEEMod default fleet mixes were adjusted to reflect light-duty and heavy-duty truck activity at the proposed warehouse, and the model considers emissions from idling in addition to vehicle travel. Mobile source emissions accounted for traffic that would result from the project, which was obtained from the project’s Transportation Impact Analysis report prepared by Kimley Horn in January 2024. The Transportation Impact Analysis is included as Appendix F. Area source emissions are generated by landscape maintenance equipment, consumer products and architectural coatings. There would also be local air pollutant emissions associated with energy sources, because the project would utilize natural gas.

Impact Analysis
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? The 2017 Clean Air Plan does not include control measures that apply directly to individual development projects. Instead, the control strategy includes control measures related to stationary sources, transportation, energy, buildings, agriculture, natural and working lands, waste management, water, and super GHG-pollutants. The 2017 Plan focuses on two goals:
 Protect air quality and health at the regional and local scale by attaining all national and state air quality standards and eliminating disparities among Bay Area communities in cancer health risk from TACs
 Protect the climate by reducing Bay Area GHG emissions to 40 percent below 1990 levels by 2030, and 80 percent below 1990 levels by 2050
Under BAAQMD’s methodology, a determination of consistency with the 2017 Plan should demonstrate that a project:
 Supports the primary goals of the air quality plan
 Includes applicable control measures from the air quality plan  Does not disrupt or hinder implementation of any air quality plan control measures A project that would not support the 2017 Plan’s goals would not be considered consistent with the 2017 Plan. On an individual project basis, consistency with BAAQMD quantitative thresholds is interpreted as demonstrating support for the clean air plan’s goals.

The project would include applicable control measures from the 2017 Plan. Applicable control measures such as green building construction, waste diversion, and water conservation would indicate support for the clean air plan goals on an individual project basis. The proposed project would include construction of 21 electric vehicle charging stations. Additionally, the proposed project includes natural gas connections, creating the potential for emissions from combustion of natural gas (see Appendix A). As shown in the response to CEQA checklist questions b and c (see below), the proposed project would not result in exceedances of BAAQMD 2017 thresholds for criteria air pollutants and thus, would not disrupt or hinder implementation of 2017 Clean Air Plan Environmental Checklist
Air Quality
Initial Study 41
control measures. The proposed project would replace an existing vacant warehouse on-site and not induce substantial new population growth exceeding projections for the area. Therefore, the proposed project would be consistent with the criteria of the 2017 Clean Air Plan. Impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
The San Francisco Bay Area Air Basin is designated as a nonattainment area for the National Ambient Air Quality Standards for ozone and PM 2.5, and the California Ambient Air Quality Standards for ozone, PM10 and PM2.5. The following subsections discuss emissions associated with construction and operation of the proposed project.

CONSTRUCTION EMISSIONS
Project construction would temporarily generate air pollutant emissions associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction equipment and construction vehicles in addition to ROG emissions that would be released during the drying phase of architectural coating. Table 6 summarizes the estimated maximum daily emissions of pollutants during project construction.

Table 6 Estimated Daily Construction Emissions of the Project Estimated Maximum Daily Emissions (lbs/day)
Construction Activity ROG NOX Exhaust PM10 Exhaust PM2.5 2024 3.36 37.60 1.39 1.30
2025 43.72 18.51 0.62 0.59
BAAQMD Thresholds 54 54 82 54
Threshold Exceeded? No No No No
ROG = reactive organic gases, NOX = nitrogen oxides, PM10 = particulate matter 10 microns in diameter or less, PM2.5 = particulate matter 2.5 microns in diameter or less; lbs/day = pounds per day, BAAQMD = Bay Area Air Quality Management District Notes: All emissions modeling was completed using CalEEMod in accordance with applicant-provided information and data. Emissions presented are the highest of the winter and summer modeled emissions.

See Appendix A for model inputs and corresponding output results.

As shown in Table 6, construction-related emissions would not exceed BAAQMD thresholds.

Therefore, project construction would not result in a cumulatively considerable net increase of a criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard.

Table 6 does not present fugitive dust emissions that would result from construction equipment operating on bare soil. Site preparation and grading, for example, may cause wind-blown dust that could contribute particulate matter into the local atmosphere. BAAQMD does not have quantitative thresholds for fugitive dust emissions during construction. Instead, BAAQMD recommends Best Management Practices (BMPs) be implemented to reduce fugitive dust emissions. The proposed project does not include these BMPs. Accordingly, construction impacts would be potentially significant. Implementation of Mitigation Measure AQ-1 is required.

City of San Leandro
880 Doolittle Drive Industrial Project
42 OPERATIONAL EMISSIONS
Operation of the project would generate criteria air pollutant emissions associated with area sources (e.g., architectural coatings, consumer products, and landscaping equipment), energy sources (i.e., nonrenewable energy sources) and mobile sources (i.e., vehicle trips and truck trips to and from the project site). Table 7 summarizes the project’s maximum annual operational emissions by emission source and maximum daily operational emissions.

Table 7 Estimated Operational Daily Emissions of the Project Emissions (lbs/day)
Emissions Source ROG NOx PM10 PM2.5
Annual Emissions (tons/year)
Area 6.14 <0.01 <0.01 <0.01
Energy 0.19 1.72 0.13 0.13
Mobile 1.88 18.96 0.22 0.21
Generators 3.38 9.42 0.50 0.50
Off-Road Equipment 1.10 8.58 0.15 0.13
Total Emissions 12.69 38.68 1.00 0.97
Significance Threshold (pounds/day) 54 54 82 54
Threshold Exceeded? No No No No
ROG = reactive organic gases, NOX = nitrogen oxides, PM10 = particulate matter 10 microns in diameter or less, PM2.5 = particulate matter 2.5 microns or less in diameter; lbs/day = pounds per day, BAAQMD = Bay Area Air Quality Management District Note: The updated emissions modeling was completed using CalEEMod in accordance with applicant-provided information and data.

Some numbers may not add up due to rounding. Emissions presented are the highest of the winter and summer modeled emissions.

See Appendix A for model input and corresponding output results.

As shown in Table 7, the estimated operational emissions of the project would not exceed BAAQMD thresholds for criteria pollutants. Therefore, project operation would not result in a cumulatively considerable net increase of a criteria pollutant for which the project region is in non-attainment.

Mitigation Measure
AQ-1 BAAQMD Best Management Practices for Construction-Related Fugitive Dust Emissions
The project applicant shall require all construction contractors to implement the basic construction mitigation measures recommended by BAAQMD to reduce fugitive dust emissions. Emission reduction measures will include, at a minimum, the following measures:

1. All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two Ɵmes per day.

2. All haul trucks transporƟng soil, sand, or other loose material off-site shall be covered.

3. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited.

4. All vehicle speeds on unpaved roads shall be limited to 15 mph.

5. All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible.

Building pads shall be laid as soon as possible aŌer grading unless seeding or soil binders are used.

Environmental Checklist
Air Quality
Initial Study 43

6. All excavaƟon, grading, and/or demoliƟon acƟviƟes shall be suspended when average wind speeds exceed 20 mph.

7. All trucks and equipment, including their Ɵres, shall be washed off prior to leaving the site.

8. Unpaved roads providing access to sites located 100 feet or further from a paved road shall be treated with a 6- to 12-inch compacted layer of wood chips, mulch, or gravel.

9. Publicly visible signs shall be posted with the telephone number and name of the person to contact at the lead agency regarding dust complaints. This person shall respond and take correcƟve acƟon within 48 hours. The Air District’s General Air PolluƟon Complaints number shall also be visible to ensure compliance with applicable regulaƟons.

Impacts would be less than significant with implementation of Mitigation Measure AQ-1.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
c. Would the project expose sensitive receptors to substantial pollutant concentrations? Kimley Horn and Associates conducted an assessment of potential health impacts to surrounding sensitive receptors resulting from construction toxic air contaminants (TAC) emissions, using the methodology described under Methodology in this section. The detailed assessment is provided in Appendix B.

The following four criteria based on BAAQMD health risk and hazard significance thresholds were applied to determine if the proposed project would significantly impact the exposure of sensitive receptors to project emissions (Appendix B). The project would have a significant impact if:
 Construction of the project would generate toxic air contaminants (TACs) that exceed health risk significance thresholds;
 The cumulative health impact would exceed cumulative health risk significance thresholds;  Operation of the project would result in an exceedance of the health risk significance thresholds;
 A carbon monoxide (CO) hotspot assessment demonstrates that the project would result in a CO hotspot which would exceed ambient air quality standards.

BAAQMD provides guidance for evaluating impacts from TACs in its CEQA Air Quality Guidelines document. As noted therein, an incremental cancer risk of greater than 10 cases per million at the Maximally Exposed Individual (MEI) will result in a significant impact. The BAAQMD considers exposure to annual PM2.5 concentrations that exceed 0.3 μg/m3 from a single source to be significant. The BAAQMD significance threshold for non-cancer hazards is 1.0.

PROJECT CONSTRUCTION HEALTH RISK ASSESSMENT
Certain population groups, such as children, the elderly, and people with health problems, are particularly sensitive to air pollution. Therefore, the majority of sensitive receptor locations are schools, hospitals, and residences. Sensitive receptors in the project vicinity include single- and multi-family residences located 500 feet northeast of the project site. Construction equipment and associated heavy-duty truck traffic generate diesel exhaust, which is a known TAC. Diesel exhaust from construction equipment operating at the site poses a health risk to nearby sensitive receptors.

Project construction would generate diesel particulate matter (DPM) emissions from the use of offroad diesel equipment required for grading and excavation, paving, and other construction activities. For construction activity, DPM is the primary TAC of concern. On-road diesel-powered City of San Leandro
880 Doolittle Drive Industrial Project
44 haul trucks traveling to and from the construction area to deliver materials and equipment are less of a concern because they would not stay on the site for long durations. Accordingly, they would also not operate for long durations in proximity to nearby sensitive receptors. Diesel exhaust from construction equipment operating at the site poses a health risk to nearby sensitive receptors.

Construction is temporary and would be transient throughout the site (i.e. move from location to location) and would not generate emissions in a fixed location for extended periods of time.

Construction is subject to and would comply with California regulations (e.g., California Code of Regulations, Title 13, Division 3, Article 1, Chapter 10, Sections 2485 and 2449), which reduce DPM and criteria pollutant emissions from in-use off-road diesel-fueled vehicles and limit the idling of heavy-duty construction equipment to no more than five minutes. These regulations would further reduce nearby sensitive receptors’ exposure to temporary and variable DPM emissions.

The PM2.5 emissions rates in grams per second from project construction were calculated from the total annual on-site exhaust emissions reported in CalEEMod (0.20 tons). Annual emissions were converted to grams per second and these emissions rates were input into AERMOD. Although project construction would occur for over a period of 17 months, the health risk computation was performed to determine the risk of developing an excess cancer risk calculated on a 3-year exposure scenario as recommended by the BAAQMD, and thus is conservative.

As noted above, maximum (i.e., worst case) PM2.5 exhaust construction emissions over the entire project construction period were used in AERMOD to approximate construction DPM emissions.

Risk levels were calculated with the CARB Hotspots Analysis and Reporting Program (HARP) Risk Assessment Standalone Tool (RAST) based on the California Office of Environmental Health Hazard Assessment (OEHHA) guidance document, Air Toxics Hot Spots Program Risk Assessment Guidelines (February 2015). Results of this assessment are summarized in Table 8 below. Table 8 refers to Maximally Impacted Receptor. BAAQMD developed a set of guidelines and thresholds for estimating health risks resulting from exposure to TACs at the Maximally Impacted Receptor. For the proposed project, the MIR includes single family residences located approximately 500 feet northeast of the project site. Table 8 also shows the health risk for recreation users in the area, such as the golf course approximately 700 feet from the project site, and the risk for project workers.

Table 8 Construction Risk
Cancer Risk
(risk per million)
Chronic Non-Cancer
Hazard Index1
Acute Hazard TAC Concentration
(micrograms per
cubic meter)
Residential Maximally
Impacted Receptor

0.53 0.001 0.071 0.004
Recreation 0.07 0.000 0.037 0.001
Project Worker 0.91 0.006 0.219 0.028
Significance Threshold 10 1 1.0 0.3
Threshold Exceeded? No No No No
MIR = Maximally Impacted Receptor
TAC = toxic air contaminants
1 Chronic non-cancer hazard index was estimated by dividing the annual DPM concentration (as PM2.5 exhaust) by the DPM reference exposure level of 5 micrograms per cubic meter
Threshold source: BAAQMD 2022. See Appendix B for the cancer health risk model output results. This assessment uses outputs from the CalEEMod modeling conducted using a previous model version, which estimated greater construction emissions than the updated CalEEMod outputs attached to the end of Appendix B. Therefore, this cancer risk assessment is more conservative in that is utilizes greater estimated emissions.

Environmental Checklist
Air Quality
Initial Study 45
As shown above, the proposed project’s construction emissions would not exceed applicable BAAQMD significance thresholds at the Maximally Impacted Receptor. Project construction would not result in significant health impacts to nearby sensitive receptors.

OPERATIONAL HEALTH RISK ASSESSMENT
Vehicle DPM emissions were estimated using emission factors for course particulate matter less than 2.5 microns in diameter (PM2.5) generated with the EMFAC developed by CARB. EMFAC is a mathematical model that was developed to calculate emission rates from motor vehicles that operate on highways, freeways, and local roads in California and is commonly used by CARB to project changes in future emissions from on-road mobile sources.

For this project, annual average PM2.5 emission factors were generated by running EMFAC for vehicles in the BAAQMD within Alameda County. EMFAC generates emission factors in terms of grams of pollutant emitted per vehicle activity and can calculate a matrix of emission factors at specific values of vehicle speed, temperature, and relative humidity. The model was run for heavyduty diesel vehicles traveling along Doolittle Drive, Adams Avenue, Hester Street, and Davis Street, as well as circulating the project site and idling at proposed loading areas on-site. Additionally, the operational run included one emergency generator.

Based on the AERMOD outputs, the highest expected annual average diesel PM2.5 emission concentrations from diesel truck traffic near sensitive receptors would be 0.001 µg/m3. The calculations conservatively assume no cleaner technology with lower emissions in future years. As shown in Table 9 below, the calculated carcinogenic risk resulting from the project is 0.31 per million for workers, 0.15 per million for recreation, and 0.11 per million for residents which are all below the BAAQMD threshold of 10 per million. Acute and chronic hazards also would be below the BAAQMD significance threshold of 1.0, as shown in Table 9.

Table 9 Operational Risk
Cancer Risk
(risk per million)
Chronic Non-Cancer
Hazard Index1
Acute Hazard TAC Concentration
(micrograms per
cubic meter)
Residential Maximally
Impacted Receptor

0.11 0.0001 0.005 0.002
Recreation 0.15 0.0002 0.011 0.003
Project Worker 0.31 0.0002 0.021 0.006
Significance Threshold 10 in one
million

1.0 1.0 0.3
Threshold Exceeded? No No No No
MIR = Maximally Impacted Receptor
TAC = toxic air contaminants
1 Chronic non-cancer hazard index was estimated by dividing the annual DPM concentration (as PM2.5 exhaust) by the DPM reference exposure level of 5 micrograms per cubic meter
Threshold source: BAAQMD 2022. See Appendix B for the cancer health risk model output results. This assessment uses outputs from the CalEEMod modeling conducted using a previous model version, which estimated greater construction emissions than the updated CalEEMod outputs attached to the end of Appendix B. Therefore, this cancer risk assessment is more conservative in that is utilizes greater estimated emissions.

City of San Leandro
880 Doolittle Drive Industrial Project
46 As shown in Table 9, the proposed project’s operational emissions would not exceed applicable BAAQMD significance thresholds at the Maximally Impacted Receptor. Project operation would not result in significant health impacts to nearby sensitive receptors.

CUMULATIVE HEALTH RISK ASSESSMENT
As discussed in the Health Risk Assessment prepared by Kimley Horn and Associates, stationary sources within a 1,000-foot-radius of the project site were identified using BAAQMD’s Stationary Source GIS Maps and consultation with the BAAQMD. As shown in Table 10, the cumulative impacts related to cancer risk and hazard would be less than cumulatively considerable and within acceptable limits (Appendix B) Additionally, cumulative residential PM2.5 would not exceed the BAAQMD’s cumulative threshold of 0.8 µg/m3, the primary contributor to those concentrations is the existing PCC Structural manufacturing site near the project area. The facility has a high PM2.5 of

0.374 µg/m3. The PCC Structural facility source represents approximately 60 percent of the total concentrations and are unrelated to the project. The project would represent less than 0.17 percent of total cumulative PM2.5 in the project area. Therefore, the project’s cumulative impacts would be less than significant.

Table 10 2020 Cumulative Health Risk
Emission Sources PM2.5 (µg/m3)
Cancer Risk
(per million) Hazard
Project Mobile Emissions 0.002 0.11 0.0003
Major Street Sources 0.024 1.065 0.096
Highway Sources 0.190 11.550 0.840
Railway Sources 0.008 5.483 0.032
Stationary Source –
California General
Partnership

0.000 0.092 0.000
Stationary Source – PCC
Structural

0.374 3.302 0.382
Stationary Source – Avis
Service Center

0.000 0.000 0.000
Cumulative Health Risk
Values

0.618 22.61 1.350
BAAQMD Threshold 0.8 100 10
Threshold Exceeded? No No No
Source: Appendix B

CO HOTSPOTS
CO emissions from traffic generated by the proposed project are a concern at the local level because congested intersections can result in high, localized concentrations of CO referred to as CO hotspots. BAAQMD recommends comparing a project’s attributes with the following screening criteria as a first step to evaluating whether the project would result in the generation of CO concentrations that would substantially contribute to an exceedance of the Thresholds of Environmental Checklist
Air Quality
Initial Study 47
Significance. The project would result in a less than significant impact to localized CO concentrations if:

1. The project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, the regional transportation plan, and local congestion management agency plans;

2. The project would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour; or

3. Project-generated traffic would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, underpass, natural or urban street canyon, below-grade roadway).

Based on the Traffic Impact Analysis (Appendix F) for the proposed project, the proposed project would not change level of service at intersections subject to the Alameda Congestion Management Plan. The Transportation Impact Analysis indicates that the proposed project would not result in deficiencies at intersections subject to the Alameda Congestion Management Plan that would not otherwise be deficient without the project. Additionally, no intersections in the project area would have traffic volumes exceeding 44,000 vehicles per hour. The busiest intersection studied in the Traffic Impact Analysis is the intersection of Davis Street and the ramps for I-880. At this intersection traffic volumes do not exceed 4,000 during peak hour, which is commonly called “rush hour.” The proposed project would generate approximately 1,543 vehicle trips daily (including 46 truck trips), which would not increase traffic volumes at an intersection to 24,000 vehicles per hour. Therefore, localized CO emissions would not be significant.

Overall, the proposed project would not expose sensitive receptors to substantial pollutant concentrations and impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
During construction activities, heavy equipment and vehicles would emit odors associated with vehicle and engine exhaust and during idling. However, these odors would be intermittent and temporary and would cease upon completion of construction activities, and odors would disperse with distance. Overall, project construction would not generate other emissions, such as those leading to odors, affecting a substantial number of people. Construction-related impacts would be less than significant.

Table 5-4 in the BAAQMD 2022 CEQA Air Quality Guidelines provides screening distances for land uses that have the potential to generate substantial odor complaints. The uses in the table include wastewater treatment plants, landfills or transfer stations, refineries, composting facilities, confined animal facilities, food processing facility, smelting plants, and chemical manufacturing facilities (BAAQMD 2022). Warehouse buildings are not included in this list, and operation of the project would not generate other emissions, such as those leading to odors, which would affect a substantial number of people. Furthermore, truck idling at the proposed warehouse would be limited to 5 minutes at any location as required by CARB’s Commercial Vehicle Idling Airborne Toxics Control Measure, which would minimize generation of odors from trucks at the project site. Impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
City of San Leandro
880 Doolittle Drive Industrial Project
48 This page intentionally left blank.

Environmental Checklist
Biological Resources
Initial Study 49
4 Biological Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Would the project:
a. Have a substantial adverse effect, either
directly or through habitat modifications,
on any species identified as a candidate,
sensitive, or special status species in local
or regional plans, policies, or regulations, or
by the California Department of Fish and
Wildlife or U.S. Fish and Wildlife Service? □ ■ □ □
b. Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional
plans, policies, or regulations, or by the
California Department of Fish and Wildlife
or U.S. Fish and Wildlife Service? □ □ □ ■
c. Have a substantial adverse effect on state
or federally protected wetlands (including,
but not limited to, marsh, vernal pool,
coastal, etc.) through direct removal, filling,
hydrological interruption, or other means? □ □ □ ■
d. Interfere substantially with the movement
of any native resident or migratory fish or
wildlife species or with established native
resident or migratory wildlife corridors, or
impede the use of native wildlife nursery
sites? □ □ □ ■
e. Conflict with any local policies or
ordinances protecting biological resources,
such as a tree preservation policy or
ordinance? □ □ ■ □
f. Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural
Community Conservation Plan, or other
approved local, regional, or state habitat
conservation plan? □ □ □ ■
The analysis in this section is largely based on a Biological Resources Analysis prepared by Moore Biological Consultants in September 2022 which was peer reviewed by Rincon Consultants on behalf of the City in October 2023. The Biological Resources Assessment is provided as Appendix C.

City of San Leandro
880 Doolittle Drive Industrial Project
50 Setting
The project site is currently developed with industrial buildings that are vacant. The site is in an urbanized area, surrounded by paved parking lots, commercial and industrial buildings, and landscaped areas and trees. The site is approximately 2.5 miles east of the San Francisco Bay, 5.8 miles northwest of San Lorenzo Creek, and 2.5 miles west of San Leandro Creek. The site is relatively flat with an elevation of approximately 10 feet.

There are five street trees along the driveway from Hester Street, however there are no other trees on the project site. Vegetation within the site consists of narrow fringes of ruderal grassland along fence lines and along the extreme edges of buildings within the site. Ruderal grassland best describes the highly disturbed upland vegetation found within the site.

Wetlands, riparian zones, and other natural communities do not occur on the project site. There were no mammals or signs of mammals observed during the site visit and the existing buildings did not show signs of roosting bats nor are they suitable for bat habitat due to the fact that they are metal structures without attics. The likelihood of occurrence of listed, candidate, and other specialstatus species in the site is generally low (Appendix C).

While the project site does not support special status species or trees, existing trees on Hester Street and elsewhere near the project site could contain bird nests. Migratory nesting birds are protected under the Migratory Bird Treaty Act (MBTA). Protected birds include all common songbirds, waterfowl, shorebirds, hawks, owls, eagles, ravens, crows, native doves and pigeons, swifts, martins, swallows, and others, including their body parts (feathers, plumes, etc.), nests, and eggs.

Regulatory Setting
Federal and State
Regulatory authority over biological resources is shared by federal, state, and local agencies under a variety of laws, ordinances, regulations, and statutes. Primary authority for biological resources lies with the land use control and planning authority of local jurisdictions (in this instance, the City of San Leandro).

The California Department of Fish and Wildlife (CDFW) is a trustee agency for biological resources throughout the state under CEQA and has direct jurisdiction under the California Fish and Game Code (CFGC). Under the California Endangered Species Act and the federal Endangered Species Act, the CDFW and the U.S. Fish and Wildlife Service (USFWS), respectively, have direct regulatory authority over species formally listed as threatened or endangered (and listed as rare for CDFW).

Native and/or migratory bird species are protected under the CFGC Sections 3503, 3503.5, and 3511.

Statutes in the Clean Water Act (CWA), CFGC, and CCR protect wetlands and riparian habitat. The U.S. Army Corps of Engineers (USACE) has regulatory authority over wetlands and waters of the United States under Section 404 of the CWA. The State Water Resources Control Board (SWRCB) and the nine Regional Water Quality Control Boards (RWQCBs) ensure water quality protection in California pursuant to Section 401 of the CWA and Section 13263 of the Porter-Cologne Water Quality Control Act. The CDFW regulates waters of the State under the CFGC Section 1600 et seq.

Special-status species are those plants and animals: 1) listed, proposed for listing, or candidates for listing as Threatened or Endangered by the USFWS and the National Marine Fisheries Service Environmental Checklist
Biological Resources
Initial Study 51
(NMFS) under the federal Endangered Species Act; 2) listed or proposed for listing as Rare, Threatened, or Endangered by the CDFW under the California Endangered Species Act; 3) recognized as California Species of Special Concern by the CDFW; 4) afforded protection under CFGC; and 5) occurring on Lists 1 and 2 of the CDFW California Rare Plant Rank (CRPR) system.

Local
Chapter 5-2 of the San Leandro Municipal Code establishes tree preservation requirements that would apply to the project. Section 5-2-205 establishes all street trees within the city as property of the City, and Section 5-2-220 outlines requirements for street tree planting and replacement.

SAN LEANDRO MUNICIPAL CODE SECTION 5-2-220
(a) Upon approval of the Director, any person may undertake privately, or by agreement with a private nursery or tree service, the planting of a street tree provided that the location, species and manner of planting are acceptable to the Director.
(b) The Director shall prepare a list of those tree species which are acceptable for use as street trees. The Director shall also establish such criteria relating to the location and manner of planting such street trees as will protect public safety and public and private improvement. (c) All new planting of street trees as replacements for street trees existing on the effective date of this Chapter shall conform to the species and planting criteria set forth in subsection (b) of this section.
(d) There may be imposed a condition of approval for all parcel and subdivision maps that the subdivider plant street trees at such locations and in such manner as may be determined by the Director.

Impact Analysis
a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
As described in the Setting section above, the project site is in an urbanized area of San Leandro and is currently fully developed with structures, surface parking lots, roadways, and limited perimeter landscaping, including ruderal grassland (Appendix C). Dominant grass species observed in the site include oats (Avena sp.), common mallow (Malva neglecta), fireweed (Epilobium brachycarpum), prickly lettuce (Lactuca serriola), field bindweed (Convolvulus arvensis) and common sow thistle (Sonchus oleraceus). The project site contains 5 street trees on Hester Street, which together do not meet the characteristics of a woodland.

The proposed project would involve construction work near street trees just off the project site near the driveway that connects to Hester Street which may affect protected nesting birds in existing trees. For example, construction noise could result in adult birds abandoning their nests. Project construction would also potentially require the removal of these trees, resulting in loss of nests if present. Impacts to migratory nesting birds would be potentially significant and implementation of Mitigation Measure BIO-1 is required.

City of San Leandro
880 Doolittle Drive Industrial Project
52 Mitigation Measure
BIO-1 Nesting Bird Avoidance and Minimization Measures
The following avoidance and minimization measures shall be implemented during project construction activities:
 Initial site disturbance shall occur outside the general avian nesting season (February 1 through September 15), if feasible.
 If initial site disturbance occurs in a work area within the general avian nesting season indicated above, a qualified biologist shall conduct a pre-construction nesting bird survey no more than 14 days prior to initial disturbances in the work area. The survey shall include the entire area of disturbance area plus a 50-foot buffer (relevant to non-raptor species) and 300-foot buffer (relevant to raptors) around the site. If active nests are located, all construction work shall be conducted outside a buffer zone from the nest to be determined by the qualified biologist. The buffer should be a minimum of 50 feet for non-raptor bird species and at least 300 feet for raptor species. Larger buffers may be required and/or smaller buffers may be established depending upon the species, status of the nest, and construction activities occurring in the vicinity of the nest. The buffer area(s) shall be closed to all construction personnel and equipment until the adults and young are no longer reliant on the nest site. A qualified biologist shall confirm that breeding/nesting is completed and young have fledged the nest prior to removal of the buffer.  If construction activities in a given work area cease for more than 14 days, additional surveys shall be conducted for the work area. If active nests are located, the aforementioned buffer zone measures shall be implemented.

Significance After Mitigation
Implementation of Mitigation Measure BIO-1 would reduce the potential for project construction activities to result in the loss of active bird nests through a pre-construction nesting bird survey and establishment of avoidance buffers around active nests, if present. Implementation of this measure would reduce this project impact to a less than significant level. This mitigation measure will be included in the EIR’s Executive Summary and in the project’s Mitigation Monitoring and Reporting Program.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
b. Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? d. Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? The project site is developed with vacant industrial uses and asphalt pavement, with small, isolated patches of grass. The site does not contain riparian habitat and is not located within a known regional wildlife movement corridor or other sensitive biological area as indicated by the USFWS Critical Habitat portal (USFWS 2022). The project site is fenced and surrounded by urban development, precluding its use as a wildlife movement corridor or wildlife nursery site.

Environmental Checklist
Biological Resources
Initial Study 53
Accordingly, the proposed project would have no impact on riparian habitat, sensitive natural communities, migratory fish, migratory corridors, or native wildlife nursery sites.

NO IMPACT
c. Would the project have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
The National Wetlands Inventory (NWI) was reviewed to determine if wetland and/or non-wetland waters had been previously documented and mapped on or in the vicinity of the project site (USFWS 2020). No such features occur on or adjacent to the project site according to the NWI mapper. This is consistent with observable conditions on site, which consist of structures and asphalt pavement, precluding wetlands (Appendix C). As described in Setting, the nearest creeks (San Leandro Creek and San Lorenzo Creek) are approximately 5.8 miles and 2.5 miles from the project site, respectively. Construction and operation of the proposed project would not involve or require the direct removal, filling, hydrological interruption, or other means to the bed, bank, channel, or adjacent upland area of any creek or wetland. No impact would occur.

NO IMPACT
e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
As described in the Project Description, construction activities associated with the proposed project would require the removal of up to five street trees. According to the Biological Resources Assessment (Appendix C), these trees are not protected by ordinance. Landscaping would also include new trees. New trees would be planted amongst shrubs along much of the site boundary, but also in landscaped parking islands within the surface parking area designed for passenger vehicles. Trees would also be planted around the proposed driveways on Hester Street, near the surface parking area designed for trailers. Trees would be a mix of conifers and deciduous species.

Landscaping shrubs and trees would consist of species native to California. Therefore, the project would not conflict with policies regarding tree preservation in San Leandro Municipal Code. There would be no impact.

LESS-THAN-SIGNIFICANT IMPACT
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
The project site is not located in an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan (City of San Leandro 2016a). Therefore, the project would not conflict with such a plan and no impact would occur.

NO IMPACT
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Environmental Checklist
Cultural Resources
Initial Study 55
5 Cultural Resources
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource
pursuant to §15064.5? □ □ □ ■
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ ■ □ □
c. Disturb any human remains, including
those interred outside of formal
cemeteries? □ □ ■ □
This section provides an analysis of the project’s impacts on cultural resources, including historical and archaeological resources, as well as human remains. This section is based largely on a Cultural Resources Memorandum that Basin Research Associates prepared for the proposed project in April 2024. The Cultural Resources Memorandum, which Rincon Consultants peer reviewed on behalf of the City, is included as Appendix D to this Initial Study.

Setting
According to the Cultural Resources Memorandum prepared by Basin Research Associates, none of the existing buildings on site qualify as an eligible historical resource (Appendix D). Additionally, no listed or known potential National Register of Historic Places and/or California Register of Historical Resources are located on or adjacent to the project site. No other significant or potentially significant local, state or federal cultural resources/historic properties, landmarks, points of interest, etc. have been identified on or immediately adjacent to the project site according to the Cultural Resources Memorandum.

The project site has been disturbed by development and demolition since approximately 1946, and substantial development surrounds the project site in all directions. No prehistoric-period archaeological or built environment resources were identified during the field survey on the project site (Appendix D). According to soil borings conducted for the geotechnical report (see Appendix E), undocumented fill material comprises soils on-site to depths ranging 1.5 to 7 feet below ground surface.

Regulatory Setting
CEQA requires a lead agency to determine whether a project may have a significant effect on historical resources (Public Resources Code [PRC], Section 21084.1). A historical resource is a resource listed in, or determined to be eligible for listing in, the California Register of Historical Resources (CRHR); a resource included in a local register of historical resources; or any object, City of San Leandro
880 Doolittle Drive Industrial Project
56 building, structure, site, area, place, record, or manuscript a lead agency determines to be historically significant (CEQA Guidelines, Section 15064.5[a] [1-3]).

A resource is considered historically significant in the California Register of Historical Resources if it:

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

In addition, if it can be demonstrated that a project would cause damage to a unique archaeological resource, the lead agency may require reasonable efforts be made to permit any or all of these resources to be preserved in place or left in an undisturbed state. To the extent that resources cannot be left undisturbed, mitigation measures are required (PRC, Section 21083.2[a], [b]).

PRC, Section 21083.2(g) defines a unique archaeological resource as an archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it:

1. Contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information;

2. Has a special and particular quality such as being the oldest of its type or the best available example of its type; or

3. Is directly associated with a scientifically recognized important prehistoric or historic event or person.

Methodology
Basin Research Associates conducted a prehistoric and historic sire records and literature search for a 0.25-mile radius from the project site. This included a records search of the California Historical Resources Information System (CHRIS) and of the Northwest Information Center (NWIC) at Sonoma State University on December 8, 2020. Basin Research Associates sent a Sacred Lands File (SLF) search request to the native American Heritage Commission (NAHC) in 2020 as well.

On December 14, 2020 Dr. Colin I. Busby completed an archaeological and built environment field review of the project site. Existing structures within the project site were also evaluated for eligibility for the NRHP and CRHR.

Impact Analysis
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
According to the Cultural Resources Memorandum prepared by Basin Research Associates, there are no historical resources within the project site or adjacent to the project site. Accordingly, because historical resources do not exist in or adjacent to the project site, the proposed project would have no impact on historical resources.

NO IMPACT
Environmental Checklist
Cultural Resources
Initial Study 57
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
According to the Cultural Resources Memorandum prepared by Basin Research Associates, there are no known archaeological resources within the project site. The site was previously graded for construction of the existing parking areas and buildings, and undocumented fill material comprises soils on-site to depths ranging 1.5 to 7 feet below ground surface, reducing the likelihood of intact below-ground resources, and the proposed project does not include below-ground space and would not require excavation substantially below previous disturbance. However, it is always possible that unanticipated archaeological deposits could be encountered and damaged during ground-disturbing activities. In the event that uncovering and damaging an unanticipated archaeological deposit occurs, the impact would be potentially significant. Accordingly, implementation of Mitigation Measure CR-1 would be required.

Mitigation Measures
CR-1 Unanticipated Discovery of Cultural Resources
In the event that archaeological resources are unexpectedly encountered during ground-disturbing activities, work within 50 feet of the find shall halt and an archaeologist meeting the Secretary of the Interior’s Professional Qualifications Standards for archaeology (National Park Service 1983) shall be contacted immediately to evaluate the find. If the resource is determined by the qualified archaeologist to be prehistoric, then a Native American representative shall also be contacted to participate in the evaluation of the resource. If the qualified archaeologist and/or Native American representative determines it to be appropriate, archaeological testing for CRHR eligibility shall be completed. If the resource proves to be eligible for the CRHR and impacts to the resource cannot be avoided via project redesign, a qualified archaeologist shall prepare a data recovery plan tailored to the physical nature and characteristics of the resource, per the requirements of CCR Guidelines Section 15126.4(b)(3)(C). The data recovery plan shall identify data recovery excavation methods, measurable objectives, and data thresholds to reduce any significant impacts to cultural resources related to the resource. Pursuant to the data recovery plan, the qualified archaeologist and Native American representative, as appropriate, shall recover and document the scientifically consequential information that justifies the resource’s significance. The City shall review and approve the treatment plan and archaeological testing as appropriate, and the resulting documentation shall be submitted to the regional repository of the CHRIS, per CCR Guidelines Section 15126.4(b)(3)(C).

Significance After Mitigation
Mitigation Measure CR-1 includes procedures for the appropriate handling of unanticipated discoveries of cultural resources. Implementation of Mitigation Measure CR-1 would reduce potential impacts to archeological resources to a less-than-significant level. This mitigation measure will be included in the EIR’s Executive Summary and in the project’s Mitigation Monitoring and Reporting Program.

LESS THAN SIGNIFICANT WITH MITIGATION INCORPORATED
City of San Leandro
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58 c. Would the project disturb any human remains, including those interred outside of dedicated cemeteries?
The cultural resources records search did not identify cemeteries or archaeological resources containing human remains within the project site (Appendix D). However, the discovery of human remains is always a possibility during ground disturbing activities, as would be required for development of the proposed project. Human burials outside of dedicated cemeteries often occur in prehistoric archaeological contexts. In addition to being potential archaeological resources, human burials have specific provisions for treatment in California Public Resources Code Section 5097. Additionally, the California Health and Safety Code (Sections 7050.5, 7051, and 7054) has specific provisions for the protection of human burial remains. Existing regulations address the illegality of interfering with human burial remains, and protects them from disturbance, vandalism, or destruction. Public Resources Code Section 5097.98 also addresses the disposition of Native American burials, protects such remains, and establishes the NAHC as the entity to resolve any related disputes.

If human remains are found, the State of California Health and Safety Code Section 7050.5 states that no further disturbance may occur until the County coroner has made a determination of origin and disposition pursuant to Public Resources Code Section 5097.98. In the event of an unanticipated discovery of human remains, the County coroner must be notified immediately. If the human remains are determined to be prehistoric, the coroner will notify the NAHC, which will determine and notify a most likely descendant (MLD). The MLD must complete the inspection of the site within 48 hours of notification and may recommend scientific removal and nondestructive analysis of human remains and items associated with Native American burials. Compliance with Public Resources Code Section 5097.98 and State of California Health and Safety Code Section 7050.5 would ensure that impacts to human remains are less than significant.

NO IMPACT
Environmental Checklist
Energy
Initial Study 59
6 Energy
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Would the project:
a. Result in a potentially significant
environmental impact due to wasteful,
inefficient, or unnecessary consumption
of energy resources, during project
construction or operation? □ □ ■ □
b. Conflict with or obstruct a state or local
plan for renewable energy or energy
efficiency? □ □ ■ □
Setting
Electricity is primarily consumed by the built environment for lighting, appliances, heating and cooling systems, and other uses such as industrial processes in addition to being consumed by alternative fuel vehicles. Most of California’s electricity is generated in state, with approximately 30 percent imported from the northwest and southwest regions of the United States in 2020 (California Energy Commission [CEC] 2021a). In addition, approximately 33 percent of California’s electricity supply in 2020 came from renewable energy sources, such as wind, solar photovoltaic, geothermal, and biomass (CEC 2021a). In 2018, Senate Bill 100 accelerated the state’s Renewable Portfolio Standards Program, codified in the Public Utilities Act, by requiring electricity providers to increase procurement from eligible renewable energy and zero-carbon resources to 33 percent of total retail sales by 2020, 60 percent by 2030, and 100 percent by 2045.

The smallest scale at which energy consumption information is readily available in California is at the county level. Therefore, energy consumption in Alameda County is used herein to characterize the existing consumption of electricity and natural gas in San Leandro. According to the California Energy Commission (CEC), Alameda County consumed approximately 10,395 GWh of electricity in 2022 from residential and non-residential uses (CEC 2022a). San Leandro is served by East Bay Community Energy (EBCE), which supplies electricity to all accounts (residential, business, and municipal) and is delivered through Pacific Gas and Electric (PG&E) infrastructure. EBCE buys power mainly from clean sources like wind, solar, and hydropower. ‘BCE’s Board of Directors established the goal of purchasing 100 percent clean power for all customers by 2030 (EBCE 2022). Alameda County consumed approximately 377 million therms of natural gas in 2019 in both residential and non-residential uses (CEC 2022b).

Petroleum fuels are primarily consumed by on-road vehicles and trucks and off-road equipment in addition to some industrial processes, with California being one of the top petroleum-producing states in the nation (CEC 2021b). Gasoline, which is used by light-duty cars, pickup trucks, and sport utility vehicles, is the most used transportation fuel in California with 12.6 billion gallons sold in 2020 (CEC 2021c). Diesel, which is used primarily by heavy duty-trucks, delivery vehicles, buses, trains, ships, boats and barges, farm equipment, and heavy-duty construction and military vehicles, City of San Leandro
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60 is the second most used fuel in California with 1.7 billion gallons sold in 2021 (CEC 2021c). Table 11 summarizes the petroleum fuel consumption for Alameda County, in which the project site would be located, as compared to statewide consumption.

Table 11 2020 Annual Gasoline and Diesel Consumption
Fuel Type
Alameda County
(millions of gallons)
California
(millions of gallons)
Proportion of
Statewide Consumption1
Gasoline 492 13,818 3.5%
Diesel 53 1,883 2.8%
1 For reference, the population of Alameda County (1,651,979 persons) is approximately 4.2 percent of the population of California (39,185,605 persons) (California Department of Finance 2022).

Source: CEC 2021c
Energy consumption is directly related to environmental quality in that the consumption of nonrenewable energy resources releases criteria air pollutant and GHG emissions into the atmosphere. The environmental impacts of air pollutant and GHG emissions associated with the project’s energy consumption are discussed in detail in Section 3, Air Quality, and Section 8, Greenhouse Gas Emissions, respectively.

Regulatory Setting
Title 24, California Code of Regulations (CCR)
CCR, Title 24, Part 6, is California’s Energy Efficiency Standards for Residential and Non-Residential Buildings. The CEC established Title 24 in 1978 in response to a legislative mandate to create uniform building codes to reduce California’s energy consumption and provide energy efficiency standards for residential and nonresidential buildings. The standards are updated on an approximately three-year cycle to allow consideration and possible incorporation of new efficient technologies and methods. In 2019, the CEC updated Title 24 standards with more stringent requirements effective January 1, 2020. All buildings for which an application for a building permit is submitted on or after January 1, 2020 must follow the 2019 standards. The 2022 update was adopted August 11, 2021 and goes into effect January 1, 2023. Energy efficient buildings require less electricity; therefore, increased energy efficiency reduces fossil fuel consumption and decreases GHG emissions. The building efficiency standards are enforced through the local plan check and building permit process. Local government agencies may adopt and enforce additional energy standards for new buildings as reasonably necessary due to local climatologic, geologic, or topographic conditions, provided that these standards exceed those provided in Title 24.

Part 6 (Building Energy Efficiency Standards)
Part 6 of Title 24 contains the 2016 Building Energy Efficiency Standards for new residential and CCR Title 24, Part 6 is the Building Energy Efficiency Standards or California Energy Code. This code, originally enacted in 1978, establishes energy-efficiency standards for residential and nonresidential buildings in order to reduce California’s energy demand. New construction and major renovations must demonstrate their compliance with the current Energy Code through submittal and approval of a Title 24 Compliance Report to the local building permit review authority and the California Energy Commission (CEC). The 2022 Energy Code encourages efficient electric heat pumps, establishes electric-ready requirements, expands solar and battery storage standards, and other stricter requirements.

Environmental Checklist
Energy
Initial Study 61
California Green Building Standards Code (2022), CCR Title 24, Part 11 California’s green building code, referred to as CALGreen, was developed to provide a consistent approach to green building within the State. CALGreen lays out the minimum requirements for newly constructed residential and nonresidential buildings to reduce GHG emissions through improved efficiency and process improvements. The requirements pertain to energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and internal air contaminants. It also includes voluntary tiers to further encourage building practices that improve public health, safety, and general welfare by promoting a more sustainable design.

Plan Bay Area 2050
Plan Bay Area 2050 is a State-mandated, integrated long-range transportation, land-use, and housing plan, known as a Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), that would support a growing economy, provide more housing and transportation choices, and reduce transportation-related pollution in the nine-county San Francisco Bay Area (ABAG/MTC 2021). Plan Bay Area 2050 focuses on advancing equity and improving resiliency in the Bay Area by creating strategies in the following four elements: Housing, Economy, Transportation, and Environment. Strategies include allowing higher-density in proximity to transit-corridors, optimizing the existing roadway network, creating complete streets, providing subsides for public transit, and reducing climate emissions, which will reduce overall per capita energy use from nonrenewable resources.

San Leandro Municipal Code
San Leandro’s Municipal Code Chapter 7.5.7, Energy Code, mandates the implementation of California Building Standards Code, Title 24, Part 6, the California Energy Code, which has specific requirements for building design to reduce energy consumption. Some of the measures in the California Energy Code include the use of certain building materials to ensure a greater degree of energy efficiency during building operation and construction and energy efficiency standards for appliances, lighting amenities, and water fixtures, among other project components. San Leandro’s Municipal Code Chapter 3.19 requires all new municipal building projects to meet the United States Green Building Council LEED Silver rating. San Leandro Municipal Code Chapter 7.5.6, Green Building Code, adopts California Building Standards Code, Title 24, part 11, Green Building Standards Code (CALGreen).

San Leandro 2021 Climate Action Plan
In July 2021, the City of San Leandro adopted an update to its Climate Action Plan (CAP), a citywide strategy to reduce greenhouse gas emissions (GHG). Chapter 4 of the CAP includes strategies that target energy reduction through energy efficiency and conservation, including prioritizing increasing and installing renewable energy generation systems and energy storage systems on rental homes, multi-family buildings, and affordable housing; reducing automobile dependency and increasing transit-oriented development; and committing to developing a reach code limiting natural gas use in new construction, or as directed by the State or regional agencies(City of San Leandro 2021). 2035 General Plan
There are several energy-related policies of the 2035 General Plan in the Open Space and Conservation, Environmental Hazards, Land Use, and Transportation Elements. Policies include using best practices for energy conservation in building and construction, using renewable energy sources City of San Leandro
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62 where possible, utilizing energy-reducing transportation strategies and alternative fuel vehicles, reducing VMT and increasing active transportation options, and reducing emissions.

Impact Analysis
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Construction of the proposed project would result in short-term consumption of energy from the use of construction equipment and processes. Energy use during construction would be primarily from fuel consumption to operate heavy equipment, light-duty vehicles, machinery, and generators.

Energy use during construction would be temporary in nature, and construction equipment used would be typical of industrial and warehouse construction projects, such as standard backhoes and dump trucks. It is reasonable to assume contractors would avoid wasteful, inefficient, and unnecessary fuel consumption during construction to reduce construction costs. Construction of the project would comply with the California Air Resources Board’s In-Use Off-Road Diesel-Fueled Fleets Regulation, which imposes limits on idling and restricts the use of older vehicles, which are typically less fuel efficient compared with newer vehicles and equipment. The CALGreen Building Standards Code, which are mandatory, includes specific requirements related to recycling, construction materials, and energy efficiency standards that would apply to construction of the proposed project to minimize wasteful, inefficient, and unnecessary energy consumption.

Operational energy use would include the use of transportation fuel. California requires that all motorists use California Reformulated Gasoline, a cleaner formulation of gasoline that results in lower emissions of ozone, CO and other air pollutants when burned. While the proposed project would result in vehicle trips, the trips would be due to the introduction of new employees associated with the proposed project. It is reasonable to assume that employees associated with the proposed project would be employed elsewhere if not at the project site. Therefore, the energy consumption of transportation fuels occurs regardless of the proposed project, and the fuel consumed for vehicle trips would not be wasteful or excessive.

In addition to transportation energy use, operation of the project would consume electricity for building power, lighting, and water conveyance, among other operational requirements. The proposed project would negligibly increase the amount of electricity consumed in San Leandro because the project is a warehouse that would be used primarily for storage of goods with only minimal office space. Additionally, the proposed project would utilize natural gas for heat, also consuming energy.

The project would be required to comply with all standards set in the latest iteration of the California Building Standards Code (California Code of Regulations Title 24), which would minimize the wasteful, inefficient, or unnecessary consumption of energy resources by the built environment during operation. California’s CalGreen standards (California Code of Regulations Title 24, Part 11) require implementation of energy-efficient light fixtures and building materials into the design of new construction projects. The City of San Leandro also requires new construction to comply with the California Green Building Standards Code and incorporates requirements to be consistent with the City’s greenhouse gas reduction goals. Further, the 2022 Building Energy Efficiency Standards (California Code of Regulations Title 24, Part 6) require newly constructed buildings to meet energy performance standards set by the CEC. These standards are specifically crafted for new buildings to result in energy efficient performance so that the buildings do not result in wasteful, inefficient, or Environmental Checklist
Energy
Initial Study 63
unnecessary consumption of energy. Therefore, it would be expected that building energy consumption associated with the proposed project would not be more inefficient, wasteful, or unnecessary than for any other similar buildings in the region. Pursuant to CalGreen, all plumbing fixtures used for the proposed project would be high-efficiency fixtures, which would minimize the potential inefficient or wasteful consumption of energy related to water and wastewater.

Project operation would not result in potentially significant environmental effects due to the wasteful, inefficient, or unnecessary consumption of energy, and impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
The City of San Leandro’s 2035 General Plan and Climate Action Plan (CAP) include energy conservation and energy efficiency strategies intended to enable the State and the City to achieve GHG reduction and energy conservation goals. As shown in Table 12 and Table 13, the project would be consistent with (and not conflict with nor obstruct) State and local renewable energy and energy efficiency plans.

Table 12 Project Consistency with State Renewable Energy and Energy Efficiency Plans Renewable Energy or Energy Efficiency Plan Proposed Project Consistency 2019 Integrated Energy Policy Report. The 2019
report highlights the implementation of California’s
innovative policies and the role they have played in
establishing a clean energy economy, as well as
provides more detail on several key energy policies,
including decarbonizing buildings, increasing energy
efficiency savings, and integrating more renewable
energy into the electricity system.

Consistent. The project would be required to comply with San Leandro Municipal Code Chapter 7.5.7, which mandates the implementation of Title 24. Further, electricity would be provided either by PG&E or EBCE, which source some or all their power from renewable sources. Given these features, the project would involve reduced GHG emissions from
power, an increase in energy efficiency savings, and
integration of more renewable energy into the electricity system. Therefore, the project would not conflict with or obstruct implementation of the 2019 Integrated Energy Policy Report.

California Renewable Portfolio Standard. California’s
RPS obligates investor-owned utilities, energy service
providers, and community choice aggregators to
procure 33 percent total retail sales of electricity from renewable energy sources by 2020, 60 percent by
2030, and 100 percent by 2045.

Consistent. EBCE and PG&E supply electricity in the city and they are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. EBCE already has an option for residents to source 100 percent renewable energy. Because PCE and PG&E would provide electricity service to the project site, the project would not conflict with or obstruct implementation of the California Renewable Portfolio Standard.

Energy Action Plan. In the October 2005, the CEC and
CPUC updated their energy policy vision by adding
some important dimensions to the policy areas
included in the original EAP, such as the emerging
importance of climate change, transportation-related
energy issues, and research and development
activities. The CEC adopted an update to the EAP II in
February 2008 that supplements the earlier EAPs and
examines the state’s ongoing actions in the context of
global climate change. The nine major action areas in
the EAP include energy efficiency, demand response,
renewable energy, electricity
Consistent. Development facilitated by the project would be required to comply with San Leandro Municipal Code Chapter

7.5.7, which mandates the implementation of Title 24.

Further, electricity would be provided either by PG&E or EBCE, which source some or all their power from renewable sources. While the project would also utilize natural gas, electricity would power most of the project. Given these features, the project would involve reduced GHG emissions from power, an increase in energy efficiency savings, and integration of more renewable energy into the electricity system. Therefore, the project would not conflict with or obstruct implementation of the EAP.

City of San Leandro
880 Doolittle Drive Industrial Project
64 Renewable Energy or Energy Efficiency Plan Proposed Project Consistency adequacy/reliability/infrastructure, electricity market structure, natural gas supply/demand/infrastructure,
transportation fuels supply/demand/infrastructure,
research/development/demonstration, and climate
change.

AB 1007: State Alternative Fuels Plans. The State
Alternative Fuels Plan assessed various alternative
fuels and developed fuel portfolios to meet
California’s goals to reduce petroleum consumption,
increase alternative fuels use, reduce GHG emissions,
and increase in-state production of biofuels without
causing a significant degradation of public health and
environmental quality.

Bioenergy Action Plan, EO S-06-06. The EO
establishes the following targets to increase the
production and use of bioenergy, including ethanol
and biodiesel fuels made from renewable resources:
produce a minimum of 20 percent of its biofuels in
California by 2010, 40 percent by 2020, and 75
percent by 2050.

Consistent. The project would not interfere with or obstruct the production of biofuels in California. Vehicles used by future project site tenants would be fueled by gasoline and diesel fuels blended with ethanol and biodiesel fuels as required by CARB regulations. Therefore, the project would not conflict with or obstruct implementation of the Bioenergy Action Plan or the State Alternative Fuels Plan.

Title 24, CCR – Part 6 (Building Energy Efficiency
Standards) and Part 11 (CALGreen). The 2022 Building
Energy Efficiency Standards move toward cutting
energy use in new homes by more than 50 percent
and will require installation of solar photovoltaic
systems for single-family homes and multi-family
buildings of three stories and less.

The CALGreen Standards establish green building
criteria for residential and nonresidential projects. The 2022 Standards include the following: increasing the
number of parking spaces that must be prewired for
electric vehicle chargers in residential development;
requiring all residential development to adhere to the
Model Water Efficient Landscape Ordinance; and
requiring more appropriate sizing of HVAC ducts.

Consistent. The project would be required to comply with San Leandro Municipal Code Chapter 7.5.7, which mandates the implementation of Title 24. Therefore, the project would not conflict with or obstruct implementation of the Title 24 standards. The project would also be required to comply with CALGreen standards pursuant to Section 7-5-600 of the San Leandro Municipal Code. Therefore, the project would not conflict with or obstruct implementation of CALGreen.

Table 13 Project Consistency with the 2035 General Plan and Climate Action Plan Renewable Energy or Energy Efficiency Plan Proposed Project Consistency General Plan Policies
Goal OSC-8: Energy. Promote the efficient use of
energy and the increased use of renewable energy by
San Leandro residents and businesses.

Policy OSC-8.2: Planning and Building Practices.

Encourage construction, landscaping, and site
planning practices that minimize heating and cooling
costs and ensure that energy is efficiently used. Local building codes and other City regulations and
procedures should meet or exceed state and federal
standards for energy conservation and efficiency and
support the City’s greenhouse gas reduction goals.

Consistent. The project would be required to comply with San Leandro Municipal Code Chapter 7.5.7, which mandates the implementation of Title 24. The project would be required to use efficient lighting and appliances. EBCE and PG&E supply electricity in the city and they are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. EBCE already has an option with 100 percent renewable energy sources, which is the default option for businesses and residences.

Because EBCE and PG&E would provide electricity service to the project site, the project would be consistent with the general plan’s goals and policies regarding energy efficiency and renewable energy mix.

Climate Action Plan Measures
Environmental Checklist
Energy
Initial Study 65
Renewable Energy or Energy Efficiency Plan Proposed Project Consistency Measure RE-1: Encourage San Leandro households
and businesses to switch from PG&E electricity
supplies to East Bay Community Energy, and commit
to defaulting to Renewable 100 tier for 100-percent
renewable energy.

Consistent. EBCE and PG&E supply electricity in the City and they are required to generate electricity that would increase renewable energy resources to 60 percent by 2030 and 100 percent by 2045. EBCE already has an option for residents to source 100 percent renewable energy. Because PCE and PG&E would provide electricity service to the project site, the project would not conflict with or obstruct implementation of the City’s CAP.

The project would be required to comply with San Leandro Municipal Code Chapter 7.5.7, which mandates the
implementation of Title 24. Therefore, the project would not conflict with or obstruct implementation of the Title 24 standards.

Source: City of San Leandro 2016, 2021
As shown in Table 12 and Table 13, The project would be consistent with State plans and the City’s adopted energy conservation and efficiency strategies contained in the 2035 General Plan, San Leandro Municipal Code, and the City’s CAP. Therefore, impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
City of San Leandro
880 Doolittle Drive Industrial Project
66 This page intentionally left blank.

Environmental Checklist
Geology and Soils
Initial Study 67
7 Geology and Soils
Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less-than -
Significant
Impact No Impact
Would the project:
a. Directly or indirectly cause potential
substantial adverse effects, including the
risk of loss, injury, or death involving:

1. Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial evidence
of a known fault? □ □ ■ □

2. Strong seismic ground shaking? □ □ ■ □

3. Seismic-related ground failure,
including liquefaction? □ □ ■ □

4. Landslides? □ □ ■ □
b. Result in substantial soil erosion or the
loss of topsoil? □ □ ■ □
c. Be located on a geologic unit or soil that
is unstable, or that would become
unstable as a result of the project, and
potentially result in on- or off-site
landslide, lateral spreading, subsidence,
liquefaction, or collapse? □ □ ■ □
d. Be located on expansive soil, as defined
in Table 18-1-B of the Uniform Building
Code (1994), creating substantial direct
or indirect risks to life or property? □ □ ■ □
e. Have soils incapable of adequately
supporting the use of septic tanks or
alternative wastewater disposal systems
where sewers are not available for the
disposal of wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ ■ □
City of San Leandro
880 Doolittle Drive Industrial Project
68 Analysis in this section is based in part on the geotechnical investigation prepared for the project by Cornerstone Earth Group in September 2020. The geotechnical investigation is included as Appendix E.

Setting
Active faults are defined by the State of California to be a fault that has surface displacement within the Holocene time (approximately the last 10,000 years). Potentially active faults as defined by the State of California to be a fault that has shown evidence of surface displacement during the Quaternary (last 1.6 million years). Any fault that is sufficiently active describes a fault that has some evidence of Holocene displacement on one or more of its segments or branches. Associated issues with earthquakes include liquefaction, which is the rapid transformation of sediment to a fluid-like state. It occurs when water-saturated, loose to medium dense, relatively clay-free sands and silts are subjected to earthquake ground motion.

The Bay Area contains both active and potentially active faults. Major active faults near the project site are the Hayward, San Andreas, Rodgers Creek, and Calaveras. The project site itself is not located within an Earthquake Fault Zone (Appendix E).

The project site is within a state-designated liquefaction hazard zone and soils encountered on the project site indicated they are potentially liquefiable (Appendix E).

Expansive soils are soils that swell in density and volume as they absorb water and contract as they lose water. Associated problems include cracking and deterioration of roadway surface, as they expand and contract during seasonal wet and dry cycles. The project site does have highly expansive clay soils approximately three to seven feet below the surface (Appendix E). The soils encountered on site have a high expansion potential which indicates they are potentially liquefiable soils.

Regulatory Setting
Alquist-Priolo Earthquake Fault Zoning Act
Following the 1989 Loma Prieta earthquake, the Seismic Hazards Mapping Act (SHMA) was passed by the California legislature in 1990. The SHMA (PRC Chapter 7.8, Section 2690-2699.6) directs the Department of Conservation, California Geological Survey to identify and map areas prone to liquefaction, earthquake-induced landslides and amplified ground shaking. It also requires that agencies only approve projects in seismic hazard zones following site-specific geotechnical investigations to determine if the identified hazard is present and the inclusion of appropriate mitigation to reduce earthquake-related hazards.

Seismic Hazards Mapping Act
The Seismic Hazards Mapping Act of 1990 was enacted, in part, to address seismic hazards not included in the Alquist-Priolo Act, including strong ground shaking, landslides, and liquefaction.

Under the Alquist-Priolo Act, the State Geologist is responsible for identifying and mapping seismic hazards. CGS Special Publication 117, adopted in 1997 by the State Mining and Geology Board, constitutes guidelines for evaluating seismic hazards other than surface faulting and for recommending mitigation measures as required by PRC Section 2695(a). In accordance with the mapping criteria, the CGS seismic hazard zone maps identifies areas with the potential for a ground shaking event that corresponds to 10 percent probability of exceedance in 50 years.

Environmental Checklist
Geology and Soils
Initial Study 69
The purpose of the Seismic Hazards Mapping Act is to reduce the threat to public health and safety and to minimize the loss of life and property by identifying and mitigating seismic hazards. Cities, counties, and state agencies are directed to use seismic hazard zone maps developed by CGS in their land-use planning and permitting processes. The Seismic Hazards Mapping Act requires site-specific geotechnical investigations prior to permitting most urban development projects in seismic hazard zones.

California Building Code
The California Building Code, Title 24, Part 2, provides building codes and standards for the design and construction of structures in California. The purpose of the California Building Code is to establish minimum standards to safeguard the public health, safety, and general welfare through structural strength, means of egress facilities, and general stability by controlling the design, construction, quality of materials, use and occupancy, location, and maintenance of building and structures. The California Building Code contains specific requirements for seismic safety, excavation, foundations, retaining walls, soil conditions, and site demolition. It also regulates grading activities, including drainage and erosion control. Chapter 16 of the California Building Code contains definitions of seismic sources and the procedure used to calculate seismic forces on structures.

The California Building Code is updated every three years by order of the legislature, with supplements published in intervening years. State law mandates that local governments enforce the California Building Code. In addition, a city and/or county may establish more restrictive building standards reasonably necessary because of local climatic, geological, or topographical conditions.

The 2022 California Building Code is based on the International Building Code.

City of San Leandro 2035 General Plan
Policy EH-1. Risk Management. Minimize risks from geologic, seismic, flood, and climate changerelated hazards by ensuring the appropriate location, site planning, and design of new development. The City’s development review process, and its engineering and building standards, should ensure that new construction is designed to minimize the potential for damage.

Impact Analysis
a.1. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? The project site is not within an Earthquake Fault Zone as defined by the Alquist-Priolo Earthquake Fault Zoning Act, and no known active or potentially active faults exist on the site (Appendix E). The nearest mapped active fault, the Hayward Fault, is approximately one mile east of the project site (CGS 2016). Direct ground rupture of a known earthquake fault would be unlikely because no faults are known to occur in the project site. Impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
City of San Leandro
880 Doolittle Drive Industrial Project
70 a.2. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving strong seismic ground shaking? The nearest mapped active fault, the Hayward Fault, is approximately one mile east of the project site. The United States Geological Survey (USGS) has stated that there is a 72 percent chance of at least one magnitude 6.7 or greater earthquake striking the San Francisco Bay region between 2014 and 2043 (USGS 2016). Therefore, the site could be subjected to at least one moderate to severe earthquake that would cause strong ground shaking. Project construction would be required to comply with the seismic safety requirements in the International Building Code, the California Building Code, and the City of San Leandro Building Code, which include standards to reduce the potential for seismic damage to buildings. Compliance with such requirements would reduce seismic ground shaking impacts to the maximum extent practicable with current engineering methods. In addition, the project includes only warehouse and office uses and does not include habitable space.

Therefore, impacts related to strong seismic ground shaking would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
a.3. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving seismic-related ground failure, including liquefaction? c. Would the project be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
The geotechnical investigation prepared for the project (Appendix E) analyzed the potential for liquefaction induced settlements and provided recommendations for the design of the proposed structure’s foundation. This report indicated that the project site is located in an identified liquefaction zone according to maps prepared by CGS, and included recommendations for the proposed structure’s foundation such as the use of shallow foundations. Furthermore, pursuant to San Leandro Municipal Code Section 7-5-100, the City of San Leandro adopted the California Building Code; Section 1803.1.1.3 of the California Building Code states that the building department of each locality (in this case the San Leandro Building & Safety Division) would need to approve the soil investigation or geotechnical investigation (Appendix E) if it determines that the recommended action is likely to prevent structural damage. As a condition of the building permit, the approved recommended action must be incorporated into project construction. Therefore, pursuant to the San Leandro Municipal Code and the California Building Code, the recommendations included in the geotechnical investigation (Appendix E) would be incorporated into the design of the project and verified by the City prior to issuance of a building permit. In addition, the project includes only warehouse and office uses and does not include habitable space.

With adherence to San Leandro Municipal Code, the California Building Code, and implementation of recommendations in the design-level geotechnical investigation, impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
a.4. Would the project directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving landslides?
Earthquakes can trigger landslides that may cause injuries and damage many types of structures.

Landslides are typically a hazard on or near slopes or hillside areas, rather than on level or nearly level areas, like the project site. The project site is not within an area mapped as having landslides Environmental Checklist
Geology and Soils
Initial Study 71
(CGS 2019). While the project includes grading, the final grade would not include steep or substantial slopes. Therefore, the project has a low potential for slope instability occurring at the site, and impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
b. Would the project result in substantial soil erosion or the loss of topsoil? Project construction, particularly grading and site preparation, could result in erosion and loss of topsoil from the project site. The project developer would be required to follow applicable California Building Code and San Leandro Municipal Code requirements to reduce soil erosion, including San Leandro Municipal Code Section 7-12-230, which requires erosion and sedimentation control measures and drainage plans to be prepared by a civil engineer and submitted to the City for approval prior to issuance of a grading permit. Where appropriate, the control measures must include measures including, but not limited to, short-term erosion control planting, waterproof slope covers, stormwater retention basins, and devices to trap, store, and filter sediment during project construction and operation. Project construction would also disturb more than 1 acre of land, which mandates preparation and implementation of a Stormwater Pollution Prevention Plan (SWPPP), pursuant to state regulations. The SWPPP must contain measures that are implemented at the site to prevent soil erosion and soil loss. Compliance with federal, State, and City regulations would reduce impacts related to soil erosion and the loss of topsoil to less-than-significant levels.

LESS-THAN-SIGNIFICANT IMPACT
d. Would the project be located on expansive soil, as defined in Table 1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? Expansive soils are those that have a potential to undergo significant changes in volume, either shrinking or swelling, due to their composition and moisture content. Periodic shrinking and swelling of expansive soils can cause extensive damage to other structures and roads constructed on these soils. According to the geotechnical report for the project site, there are highly expansive soils near the ground surface of the project site. The geotechnical report recommends that to reduce the potential for damage associated with these expansive soils, foundation slabs on grade should have sufficient reinforcement and be supported by a layer of non-expansive fill. The geotechnical report also includes additional recommendations to reduce the impact of expansive soils on site including the limiting of watering of vegetation on site. As discussed under Threshold a.3. and Threshold c above, pursuant to the San Leandro Municipal Code and the California Building Code, the recommendations included in the geotechnical investigation (Appendix E) must be incorporated into the design of the project and verified by the City prior to issuance of a building permit. In addition, the project includes only warehouse and office uses and does not include habitable space. With incorporation of these recommendations and adherence to applicable regulations such as the California Building Code, impacts would be less than significant.

LESS-THAN-SIGNIFICANT IMPACT
City of San Leandro
880 Doolittle Drive Industrial Project
72 e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
The project site would be served by the municipal sewer system and would not require the installation of an on-site septic tank or alternate wastewater treatment systems. Therefore, no impacts from septic systems or alternative wastewater disposal systems would occur.

NO IMPACT
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Paleontological resources, or fossils, are the evidence of once-living organisms preserved in the rock record. They include both the fossilized remains of ancient plants and animals and the traces thereof (e.g., trackways, imprints, burrows, etc.). Paleontological resources are not found in “soil” but are contained within the geologic deposits or bedrock that underlies the soil layer. Typically, fossils are greater than 5,000 years old (i.e., older than middle Holocene in age) and are typically preserved in sedimentary rocks. Although rare, fossils can also be preserved in volcanic rocks and low-grade metamorphic rocks under certain conditions (Society of Vertebrate Paleontology [SVP] 2010). Fossils occur in a non-continuous and often unpredictable distribution within some sedimentary units, and the potential for fossils to occur within sedimentary units depends on several factors. It is possible to evaluate the potential for geologic units to contain scientifically important paleontological resources, and therefore evaluate the potential for impacts to those resources and provide mitigation for paleontological resources if they are discovered during construction of a development project.

According to soil borings conducted for the geotechnical report, undocumented fill material comprises soils on-site to depths ranging 1.5 to 7 feet below ground surface. Therefore, excavation required for construction of the proposed project would occur mostly within fill material. As fill material, there is no potential for paleontological resources because such resources predate fill material generated by humans. However, in areas where undocumented fill is shallow or not present, the underlying geology is late-Holocene-era Basin deposits (United States Geologic Survey 2020). The Holocene era began approximately 11,700 years before present day, and late-Holocene era is even more recent. According to the United States Bureau of Land Management, geologic units generally 10,000 years of age or younger haw low potential for fossils (2016). Given the Holocene era dates back only 11,700 years, and the underlying geology on the site is late-Holocene era, the potential for paleontological resources is low. Impacts to paleontological resources would be less than significant.

San Leandro City CouncilMay 5, 2025

San Leandro City Council
May 5, 2025