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EXHIBIT A
SIGNIFICANT IMPACTS AND MITIGATION MEASURES FINDINGS
AND ALTERNATIVES FINDINGS
FINDINGS REGARDING SIGNIFICANT IMPACTS AND MITIGATION
MEASURES
Pursuant to Public Resources Code section 21081 and CEQA Guidelines section 15091, the City Council hereby makes these findings with respect to the potential for significant environmental impacts from adoption and implementation of Strive San Mateo General Plan 2040 (General Plan 2040 or proposed General Plan) and Climate Action Plan (CAP) Technical Update, hereinafter referred to together as “Project” and the means for mitigating those impacts. For the purpose of these findings, the term “Final Environmental Impact Report” (Final EIR) includes the Draft EIR, unless otherwise specified.
The findings provide a summary description of each impact, describe the applicable mitigation measures identified in the Final EIR and adopted by the City, and state the findings on the significance of each impact after imposition of the adopted mitigation measures. These findings do not attempt to describe the full analysis of each environmental impact contained in the Final EIR. A full explanation of these environmental findings and conclusions can be found in the Final EIR. These findings hereby incorporate by reference the discussion and analysis in the Final EIR that support the Final EIR's determinations regarding significant project impacts and mitigation measures designed to address those impacts. The facts supporting these findings are found in the record as a whole for the project.
In making these findings, the City ratifies, adopts, and incorporates into these findings the analysis and explanation in the Final EIR, and ratifies, adopts, and incorporates into these findings the determinations and conclusions of the Final EIR relating to environmental impacts and mitigation measures, except to the extent that any such determinations and conclusions are specifically and expressly modified by these findings.
FINDINGS REGARDING SIGNIFICANT AND UNAVOIDABLE IMPACTS
AIR QUALITY
Impact AQ-2: Construction of development projects that could occur from implementation of the Project would generate emissions that would exceed the Bay Area Air Quality Management District’s regional significance thresholds and cumulatively contribute to the nonattainment designations of the San Francisco Bay Area Air Basin.
Mitigation Measure AQ-2: Prior to discretionary approval by the City for development projects subject to CEQA (California Environmental Quality Act) review (i.e., nonexempt projects), future project applicants shall prepare and submit a technical assessment evaluating potential project construction- related air quality impacts to the City for review and approval. The evaluation shall be prepared in conformance with Bay Area Air Quality Management District (BAAQMD) methodology for assessing air A-2
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quality impacts identified in BAAQMD’s CEQA Air Quality Guidelines. If construction-related criteria air pollutants are determined to have the potential to exceed the BAAQMD-adopted thresholds of significance, the City shall require feasible mitigation measures to reduce air quality emissions.
Measures shall require implementation of the BAAQMD Best Management Practices for construction- related fugitive dust emissions, examples of best management practices include:
Water all exposed surfaces (e.g., parking areas, staging areas, soil piles, grading areas, and unpaved access roads) at least twice daily or as often as needed to control dust emissions. All haul trucks transporting soil, sand, or other loose material off-site shall be covered. All visible mud or dirt trackout onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day.
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 seedling 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 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 layer of compact layer of wood chips, mulch, or gravel. Prior to the commencement of construction activities, individual project proponents shall post a publicly visible sign with the telephone number and person to contact regarding dust complaints.
This person shall respond and take corrective action within 48 hours. The BAAQMD and City contact phone numbers shall also be visible to ensure compliance with applicable regulations.
Measures shall be incorporated into appropriate construction documents (e.g., construction management plans) and shall be verified by the City.
Finding: At the programmatic level, the mitigation measure cannot be determined to fully reduce the severity of Impact AQ-2 for all future development projects allowed by the Project; therefore, it remains significant and unavoidable.
Rationale for Finding: Mitigation Measure AQ-2 would reduce construction-related regional air impacts from construction equipment exhaust at the project level; however, potential future development projects under the Project could still exceed the BAAQMD significance thresholds for construction.
Therefore, implementation of the Project could result in significant construction-related regional air impacts from construction equipment exhaust. However, implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact AQ-2, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include supporting property investment and redevelopment, encouraging a multimodal transportation system, and promoting context-sensitive high-quality design. These findings are based on the entire record of proceedings for the Project, including but not limited to, the discussion and analysis on pages 4.2-53 to 4.2-56 of the Draft EIR, which includes a full statement of this impact.
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Resulting Significance: Significant and unavoidable.
Impact AQ-3: Operation of development projects under the Project would generate operational emissions that would exceed the Bay Area Air Quality Management District’s regional significance thresholds for volatile organic compounds (VOC) and nitrogen oxides (NOX).
Mitigation Measure AQ-3: Prior to discretionary approval by the City for development projects subject to California Environmental Quality Act (CEQA) review (i.e., nonexempt projects), future project applicants shall prepare and submit a technical assessment evaluating potential project operational air quality impacts to the City for review and approval. The evaluation shall be prepared in conformance with Bay Area Air Quality Management District (BAAQMD) methodology in assessing air quality impacts identified in BAAQMD’s current CEQA Air Quality Guidelines at the time that the project is considered.
If operation-related air pollutants are determined to have the potential to exceed the BAAQMD-adopted thresholds of significance, the City shall require the project applicant(s) to incorporate mitigation measures to reduce air pollutant emissions during operational activities. The identified measures shall be included as part of the conditions of approval or as part of a mitigation monitoring and reporting plan adopted for the project as part of the project CEQA review. Possible mitigation measures to reduce long- term emissions could include, but are not limited to the following:
Implementing commute trip reduction programs.
Unbundling residential parking costs from property costs. Expanding bikeway networks.
Expanding transit network coverage or hours.
Using cleaner-fueled vehicles.
Exceeding the current Title 24 Building Envelope Energy Efficiency Standards. Establishing on-site renewable energy generation systems. Requiring all-electric buildings.
Replacing gas-powered landscaping equipment with zero-emission alternatives. Implementing organics diversion programs.
Expanding urban tree planting.
Finding: At the programmatic level, the mitigation measure cannot be determined to fully reduce the severity of Impact AQ-3 for all future development projects that could occur under the Project; therefore, it remains significant and unavoidable.
Rationale for Finding: Mitigation Measure AQ-3 would apply to future development projects that are subject to CEQA (i.e., discretionary projects) and are allowed by the Project . The identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent individual projects that meet applicable thresholds of significance. While it is anticipated there will be project-level impacts related to this standard of significance, it is not feasible to fully evaluate and mitigate impacts at the project level due to the programmatic nature of this analysis. However, implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact AQ-3, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include supporting property investment and redevelopment, encouraging a multimodal transportation system, and promoting context-sensitive high-quality design. These findings are based on the entire record of A-4
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proceedings for the Project, including but not limited to the discussion and analysis on pages 4.2-56 to
4.2-63 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
Impact AQ-4: Construction emissions associated with development under the Project could expose air quality-sensitive receptors to substantial toxic air contaminant concentrations and exceed the Bay Area Air Quality Management District’s project-level and cumulative significance thresholds.
Mitigation Measure AQ-4: Prior to discretionary approval by the City, project applicants for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, nursing homes) or Overburdened Community (as defined by the Bay Area Air Quality Management District [BAAQMD] Community Air Risk Evaluation Program), as measured from the property line of the project to the property line of the nearest sensitive use, shall submit a health risk assessment (HRA) to the City for review and approval. The HRA shall be prepared in accordance with policies and procedures of the state Office of Environmental Health Hazard Assessment and BAAQMD. If the HRA shows that the cumulative and project-level incremental cancer risk, noncancer hazard index, and/or PM2.5 exceeds the respective threshold, as established by BAAQMD (all areas of the City and Sphere of Influence) and project-level risk of 6.0 in Equity Priority Communities (as defined in the City of San Mateo General Plan) at the time a project is considered, the project applicant will be required to identify best available control technologies for toxics (T-BACTs) and appropriate enforcement mechanisms, and demonstrate that they are capable of reducing potential cancer, noncancer risks, and PM2.5 to an acceptable level. T-BACTs may include but are not limited to:
Restricting idling on-site beyond Air Toxic Control Measures idling restrictions Electrifying warehousing docks
Requiring use of newer equipment
Requiring near-zero or zero-emission trucks for a portion of the vehicle fleet based on opening year. Truck Electric Vehicle (EV) Capable trailer spaces.
Restricting off-site truck travel through the creation of truck routes.
T-BACTs identified in the HRA shall be included as part of the conditions of approval or a mitigation monitoring and reporting plan adopted for applicable projects as part of their CEQA review.
Finding: At the programmatic level, the mitigation measure cannot be determined to fully reduce the severity of Impact AQ-4 on sensitive populations; therefore, it remains significant and unavoidable.
Rationale for Finding: Mitigation Measure AQ-4 would reduce project-level impacts of TAC and PM2.5 to less than significant levels. However, there is potential for future development projects allowed by the Project to contribute to significant cumulative risk in the Bay Area that could affect sensitive populations and Equity Priority Communities. Therefore, impacts would be significant and unavoidable. However, implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact AQ-4, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include supporting property investment and redevelopment, encouraging a multimodal transportation system, and promoting context-sensitive high-quality design. These findings are based on the entire record of A-5
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proceedings for the Project, including but not limited to, the discussion and analysis on pages 4.2-63 to
4.2-68 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
Impact AQ-6: Implementation of the Project would generate a substantial increase in emissions that exceeds the Bay Area Air Quality Management District’s significance thresholds and would cumulatively contribute to the nonattainment designations and health risk in the San Francisco Bay Area Air Basin.
Mitigation Measure AQ-6: Implement Mitigation Measures AQ-2, AQ-3, and AQ-4.
Finding: Due to the programmatic nature of the Project, no additional mitigation measures are available; therefore, impacts would be significant and unavoidable.
Rationale for Finding: Mitigation Measures AQ-2, AQ-3, and AQ-4 would help reduce project-related emissions to the extent feasible. However, criteria air pollutant emissions generated by land uses could exceed the BAAQMD regional thresholds. Therefore, air pollutant emissions associated with the Project would result in a cumulatively considerable contribution to air quality impacts and remain significant and unavoidable at the program level. Implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact AQ-6, as set forth in the Statement of Overriding Considerations in Exhibit B.
These benefits include supporting property investment and redevelopment, encouraging a multimodal transportation system, and promoting context-sensitive high-quality design. These findings are based on the entire record of proceedings for the Project, including but not limited to the discussion and analysis on pages 4.2-69 to 4.2-70 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
NOISE
Impact NOISE-1: Buildout under the Project is anticipated to result in unacceptable traffic noise with an increase of more than 5.0 dBA Ldn over existing conditions along one roadway segment (1st Avenue west of B Street) within the EIR Study Area.
Mitigation Measures: None available.
Finding: Because no feasible mitigation measures are available to avoid or further reduce the severity of Impact NOISE-2, it remains significant and unavoidable.
Rationale for Finding: Addressing traffic noise at the receiver rather than the source usually takes the form of noise barriers (i.e., sound walls). While constructing noise barriers along streets would reduce noise, the placement of sound walls between existing residences/businesses and local roadways would not be desirable as it would conflict with the community’s aesthetic, design, and character, and quality of life, and is therefore deemed infeasible. Therefore, there are no feasible mitigation measures to avoid or further reduce the severity of Impact NOISE-1. However, implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would A-6
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outweigh the significant adverse effects of Impact NOISE-1, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include supporting local shops and businesses, protecting open spaces, and promoting development of a climate change adaptation plan. These findings are based on the entire record of proceedings for the Project, including but not limited to the discussion and analysis on pages 4.11-37 to 4.11-46 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
Impact NOISE-4: Buildout under the Project is anticipated to result in unacceptable cumulative traffic noise within the EIR Study Area.
Mitigation Measures: None available.
Finding: Because no feasible mitigation measures are available to avoid or further reduce the severity of Impact NOISE-4, it remains significant and unavoidable.
Rationale for Finding: As discussed in impact discussion NOISE-1, there are no feasible mitigation measures to reduce this impact. However, implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact NOISE-4, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include supporting local shops and businesses, protecting open spaces, and promoting development of a climate change adaptation plan. These findings are based on the entire record of proceedings for the Project, including but not limited to the discussion and analysis on page
4.11-51 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
WILDFIRE
Impact WILD-2: Development under the Project would increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.
Mitigation Measures: None available.
Finding: Because no feasible mitigation measures are available to avoid or further reduce the severity of Impact WILD-2, it remains significant and unavoidable.
Rationale for Finding: The only way to fully avoid the wildfire impact from implementation is to prohibit development in areas in very high fire hazard severity zones (VHFHSZs) and the Wildland-Urban Interface (WUI). The majority of western San Mateo is in a VHFHSZ and/or the WUI. Prohibiting new development in this portion of San Mateo is not feasible or practical because the City has a responsibility to meet other, conflicting obligations, including reconstruction of homes burned by wildfires or allowing by right development under existing zoning. Any such development or reconstruction would have to meet fire codes, but still exacerbates wildfire risks. However, the development of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact WILD-2, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include protecting open spaces, A-7
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prioritizing development of a climate change adaptation plan, and reducing vehicle miles traveled and greenhouse gas (GHG) emissions. These findings are based on the entire record of proceedings for the Project, including but not limited to the discussion and analysis on pages 4.18-28 to 4.18-31 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
Impact WILD-5: Potential development under the Project could, in combination with other surrounding and future projects in the State Responsibility Areas, Very High Fire Hazard Severity Zones, or Wildland Urban Interface, result in cumulative impacts associated with the exposure of project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.
Mitigation Measures: None available.
Finding: Because no feasible mitigation measures are available to avoid or further reduce the severity of Impact WILD-5, it remains significant and unavoidable.
Rationale for Finding: Similar to the rational for Impact WILD-2, the only way to fully avoid the cumulative wildfire impact is to prohibit future development projects allowed by the Project in the State Responsibility Area (SRA), VHFHSZs, and WUI throughout the region. Prohibiting new development in this portion of San Mateo is not feasible or practical because the City has a responsibility to meet other, conflicting obligations, including reconstruction of homes burned by wildfires or allowing by right development under existing zoning. Any such development or reconstruction would have to meet fire codes, but could still exacerbate wildfire risks. However, implementation of the Project would provide specific economic, environmental, social, legal, technological, and other benefits that would outweigh the significant adverse effects of Impact WILD-5, as set forth in the Statement of Overriding Considerations in Exhibit B. These benefits include protecting open spaces, prioritizing development of a climate change adaptation plan, and reducing vehicle miles traveled and greenhouse gas (GHG) emissions. These findings are based on the entire record of proceedings for the Project, including but not limited to the discussion and analysis on pages 4.18-35 to 4.18-36 of the Draft EIR, which includes a full statement of this impact.
Resulting Significance: Significant and unavoidable.
FINDINGS REGARDING ALTERNATIVES
The CEQA Guidelines require than an EIR describe a reasonable range of alternatives that would feasibly attain most of the basic project objectives but would avoid or substantially lessen any of the significant environmental effects of the project, and then evaluate the comparative merits of such alternatives. (CEQA Guidelines §15126(a)). For the purpose of these findings, the term “Final EIR” includes the Draft EIR, unless otherwise specified.
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SIGNIFICANT AND UNAVOIDABLE IMPACTS
CEQA provides that decision-makers should not approve a project as proposed if there are feasible alternatives or feasible mitigation measures that would substantially lessen the significant impacts of the project (Public Resources Code §21002). The following impacts in the Final EIR remain significant after mitigation (i.e., significant and unavoidable) and no feasible mitigation or project alternative is identified or available to reduce these impacts to a level of less than significance:
1. Impact AQ-2: Construction of development projects that could occur from implementation of the Project would generate emissions that would exceed the Bay Area Air Quality Management District’s regional significance thresholds and cumulatively contribute to the nonattainment designations of the San Francisco Bay Area Air Basin.
2. Impact AQ-3: Operation of development projects under the Project would generate operational emissions that would exceed the Bay Area Air Quality Management District’s regional significance thresholds for volatile organic compounds (VOC) and nitrogen oxides (NOX).
3. Impact AQ-4: Construction emissions associated with development under the Project could expose air quality-sensitive receptors to substantial toxic air contaminant concentrations and exceed the Bay Area Air Quality Management District’s project-level and cumulative significance thresholds.
4. Impact AQ-6: Implementation of the Project would generate a substantial increase in emissions that exceeds the Bay Area Air Quality Management District’s significance thresholds and would cumulatively contribute to the nonattainment designations and health risk in the San Francisco Bay Area Air Basin.
5. Impact NOISE-1: Buildout under the Project is anticipated to result in unacceptable traffic noise with an increase of more than 5.0 dBA Ldn over existing conditions along one roadway segment (1st Avenue west of B Street) within the EIR Study Area.
6. Impact NOISE-4: Buildout under the Project is anticipated to result in unacceptable cumulative traffic noise within the EIR Study Area.
7. Impact WILD-2: Development under the Project would increase population, buildings, and infrastructure in wildfire-prone areas, thereby exacerbating wildfire risks.
8. Impact WILD-5: Potential development under the Project could, in combination with other surrounding and future projects in the State Responsibility Areas, Very High Fire Hazard Severity Zones, or Wildland Urban Interface, result in cumulative impacts associated with the exposure of project occupants to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire due to slope, prevailing winds, or other factors.
In compliance with CEQA, the following findings address whether there are any feasible alternatives or any additional feasible mitigation measures available that would reduce the significant and unavoidable impacts identified in the Final EIR for the Project to a less-than-significant level.
ALTERNATIVES CONSIDERED
Through the environmental review process, the City identified two (2) potential project alternatives for consideration. The following alternatives are evaluated in Chapter 5 of the Draft EIR:
No Project Alternative. Under CEQA, an evaluation of a “no project” alternative must be included in each EIR. Under the No Project Alternative, the current General Plan 2030 and Climate Action Plan (CAP) would remain in effect and would not be replaced by the Project. The Project would not A-9
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incorporate new topics that are now required by State law, such as environmental justice, and would not revise relevant policies and actions to meet those requirements. The No Project Alternative would also not address other emerging issues addressed in the proposed General Plan 2040, such as sea level rise, autonomous vehicles, and green infrastructure. Under the No Project Alternative, potential future development in San Mateo would continue to be subject to existing policies, regulations, development standards, and land use designations of the existing General Plan 2030 and the existing CAP.
Reduced Traffic Noise Alternative. The Reduced Traffic Noise Alternative is intended to reduce the level of traffic noise generated by the Project through enhanced transportation demand management (TDM) measures. Specifically, it is assumed that this alternative would involve a new TDM program applicable to new development as well as existing residences, employees, and businesses, and may require individual developers to participate in a City-established TDM program focused on reducing vehicle trips. In addition, this alternative would involve increased funding allocations to fully implement the City’s Bicycle Master Plan and Pedestrian Master Plan as expeditiously as possible, in order to provide expanded and safer alternatives to driving and encourage higher participation in TDM initiatives. The Reduced Traffic Noise Alternative would accommodate the same amount of proposed development as the Project and would involve the same proposed General Plan land use map, designations, goals, policies, and actions. This alternative would also include the same technical update to the City’s 2020 Climate Action Plan (CAP) that would occur under the Project.
The primary purpose of an EIR’s alternative analysis is to identify and evaluate possible alternatives to the Project that can avoid or substantially lessen the project’s significant environmental effects while still achieving the basic objectives of the project. The City has developed the following project objectives for General Plan 2040:
Identify the location and allowed density and intensity of San Mateo’s land uses including housing, businesses, industry, open space, schools, civic buildings, etc. Plan for future circulation and infrastructure improvements. Identify sufficient residential land to meet the current and future housing needs for people at all income levels.
Protect natural resources, such as water, air, trees, and hillsides, and preserve and improve open spaces, including open space for recreation, for habitat, or for public health and safety. Protect residents from harmful or disruptive levels of noise. Keep the community safe from natural and human-caused hazards, such as earthquakes, landslides, floods, and wildfires, including increased risks from climate change. Improve the safety and quality of life for residents of neighborhoods that face a combination of both higher-than-average pollution exposure and social and economic challenges such as low incomes, language barriers, or housing instability (Equity Priority Areas).
The fundamental objectives of the Project are to plan for the growth and conservation of San Mateo over a 20-year time horizon.
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FINDINGS REGARDING ALTERNATIVES
As further set forth below, the City has considered all of the possible alternatives identified and analyzed in the Final EIR and has elected to approve the Project described in Chapter 3 of the Draft EIR. While the Reduced Traffic Noise Alternative would reduce the Project’s significant and unavoidable noise impacts, the City finds that both alternatives would be infeasible for specific economic, social, or other considerations pursuant to Public Resources Code sections 21002 and 21081(a)(3), and CEQA Guidelines section 15091(a)(3), as described below. Based on the evaluation and analysis of project alternatives set forth in Chapter 5 of the Draft EIR, and on the entire record of proceedings for the Project, the City hereby makes the following findings:
Findings Relating to No Project Alternative. The City considered a No Project Alternative and declines to adopt it because it is inconsistent with all of the Project objectives. The existing General Plan 2030 was adopted in 2010 and included a horizon year of 2030. While this horizon year is still six years away (as of the time of publishing the Final EIR), in the years between 2010 and 2024 conditions inside and outside of San Mateo have changed, including the economic recovery from the Great Recession, a worsening housing crisis in California, ongoing impacts from climate change, and the COVID-19 pandemic that began in 2020. A number of State and federal laws guiding general plan policies have also been updated during this time. The No Project Alternative would not incorporate new topics that are now required by State law, nor would it address other emerging issues such as future infrastructure planning based on current conditions, responding to sea level rise, or improving environmental justice in San Mateo. Since the No Project Alternative would not implement the Project, the proposed goals, policies, and actions intended to address the objectives would not be adopted. Therefore, this alternative would not fully accomplish any of the project objectives. For these reasons, this alternative is infeasible, as supported by the administrative record for the Project.
Findings Relating to the Reduced Traffic Noise Alternative. The City considered a Reduced Traffic Noise Alternative and declines to adopt it because while it is consistent with the project objectives and would reduce the project’s significant and unavoidable impacts associated with traffic noise, it is financially and logistically infeasible. This alternative would require San Mateo residents to implement TDM measures typically implemented by employers rather than jurisdictions. In addition, this alternative would require increased funding allocations to fully implement bicycle and pedestrian improvements at a faster pace than anticipated in the City’s current capital improvement plan. TDM measures are evaluated separately and would need policy direction from City Council as well as financial analysis to ensure specific measures are not infeasible because of the associated cost burden. For these reasons, this alternative is infeasible, as supported by the administrative record for the Project.