San Ramon City Council
November 28, 2023

hearing to receive public comment on the adequacy and accuracy of the Draft EIR; and WHEREAS, the verbal public comments from the September 19, 2023 Planning Commission public hearing as well as responses to verbal comments received during the public review period are included in the Final EIR Response to Comments document; and WHEREAS, on or before October 16, 2023, the City received comment letters from California Geologic Survey; California Governor’s Office of Emergency Services; California Department of Transportation; Krupka Consulting; and Greenfire Law and a responses to written comments received during the public review period are included in the Final EIR Response to Comments document; and
WHEREAS, on November 3, 2023, the City distributed the Final EIR-Responses to Comments on the Draft EIR, to all commenting agencies/parties and made the Final EIR available to the public at the City Hall, San Ramon Library, Dougherty Station Library, and on the City website; and
WHEREAS, on November 7, 2023, the Planning Commission held a duly noticed public hearing to review and discuss the Final EIR-Responses to Comments and to discuss the proposed revisions and changes to the San Ramon General Plan 2040 Project and to receive input from the public; and
WHEREAS, the Final EIR consists of the Draft EIR, the EIR-Responses to Comments, and MMRP, any and all appendices thereto, and any and all documents or materials incorporated into the EIR by reference (Exhibit 2); and
WHEREAS, the Planning Commission reviewed, commented on, and acknowledges all documents and materials prepared by and relied upon by its consultants in preparing the EIR; and WHEREAS, the EIR evaluated the potential environmental impacts that could result from the approval of the Project (and in particular, focused on potentially significant impacts), alternatives to the Project, and the General Plan Implementing Policies designed to mitigate or avoid the potentially significant impacts of the Project; and WHEREAS, the EIR finds that Alternative 2 to the Project is a feasible alternative, and it would result in lesser environmental impacts related to cultural resources, wildfire exposure risk, and transportation and would achieve the plan objectives. In addition, Alternative 2 more effectively addresses some of the non-environmental concerns raised by residents related to the low retail vacancy rates and better protects retail development within the City to support existing and expected population growth; and
WHEREAS, where applicable, General Plan Implementing Policies were identified in the Final EIR to reduce those potential impacts to a less-than-significant level or to avoid those impacts, where feasible; and
WHEREAS, the EIR was prepared, published, circulated and reviewed and completed in accordance with the requirements of CEQA, the CEQA Guidelines and the San Ramon Municipal

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Packet Pg. 654 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update

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Packet Pg. 655
Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update

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Packet Pg. 656
Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Exhibit 1
CEQA Findings and
Statement of Overriding Considerations
for the
San Ramon 2040 General Plan
Pursuant to CEQA Guidelines Sections 15091 and 15093
and Public Resources Code Section 21081
The Final Environmental Impact Report (EIR) prepared for the update to the San Ramon General Plan, including eleven respective General Plan elements, amendment to the San Ramon Village Specific Plan, repeal of the North Camino Ramon Specific Plan, and the San Ramon Zoning Ordinance update (collectively referred to herein as the 2040 General Plan) consists of errata to the Draft EIR and Response to Comments on the Draft EIR. The Final EIR identifies significant environmental impacts that will result from implementation of the 2040 General Plan. The City of San Ramon (City) finds that the inclusion of certain mitigation measures as part of approval of the 2040 General Plan will reduce all but the following significant impacts to levels that are less than significant: transportation (project-level and cumulative impacts related to vehicle miles traveled [VMT]). No feasible mitigation measures have been identified to reduce these impacts to a lessthan-significant level or mitigation measures have been identified but would not reduce impacts to a level of less than significant; thus, these impacts will remain significant unavoidable impacts of the 2040 General Plan. These impacts will be overridden due to specific considerations that are described within this document.

As required by the California Environmental Quality Act (CEQA), the City, in adopting these CEQA Findings of Fact (Findings) and Statement of Overriding Considerations, also adopts a Mitigation Monitoring and Reporting Program (MMRP) for the 2040 General Plan. The City finds that the MMRP, which is incorporated herein by reference, meets the requirements of Public Resources Code Section 21081.6 by providing for the implementation and monitoring of measures intended to mitigate potentially significant effects of the 2040 General Plan. In accordance with CEQA and the CEQA Guidelines, the City adopts these findings as part of approval of the 2040 General Plan.

Pursuant to Public Resources Code Section 21082.1(c)(3), the City also finds that the Final EIR reflects the City’s independent judgment as the lead agency for the 2040 General Plan.

Consideration and Certification of the EIR
In accordance with CEQA, and on the formal recommendation of the Planning Commission following notice and public hearing, the City Council certifies that the EIR has been completed in compliance with CEQA. The City Council has independently reviewed the record and the EIR prior to certifying the EIR and approving the 2040 General Plan. By these findings, the City Council confirms, ratifies, and adopts the findings and conclusions of the EIR as supplemented and modified by these findings.

The EIR and these findings represent the independent judgment and analysis of the City and the City Council. The City Council recognizes the EIR may contain clerical errors. The City Council reviewed the entirety of the EIR and bases its determination on the substance of the information it contains.

The City Council certifies that the EIR is adequate to support the approval of the action that is the

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Packet Pg. 657 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update subject of the staff report to which these CEQA findings are attached. The City Council certifies that the EIR is adequate to support approval of the 2040 General Plan described in the EIR, each component and phase of the 2040 General Plan described in the EIR, any variant of the 2040 General Plan described in the EIR, any minor modifications to the 2040 General Plan or variants of the 2040 General Plan described in the EIR and the components of the 2040 General Plan.

Absence of Significant New Information
The City Council recognizes the Final EIR incorporates information obtained and produced after the Draft EIR was completed, and that the Final EIR contains additions, clarifications, and modifications.

On the recommendation of the Planning Commission following notice and public hearing, the City Council has reviewed and considered the Final EIR and all of this information. The Final EIR does not add significant new information to the Draft EIR that would require recirculation of the EIR under CEQA. The new information added to the EIR does not involve a new significant environmental impact, a substantial increase in the severity of an environmental impact, or a feasible mitigation measure or alternative considerably different from others previously analyzed that the City Council declines to adopt and that would clearly lessen the significant environmental impacts of the 2040 General Plan. No information indicates that the Draft EIR was inadequate or conclusory or that the public was deprived of a meaningful opportunity to review and comment on the Draft EIR. Thus, recirculation of the EIR is not required. The City Council finds that the changes and modifications made to the EIR after the Draft EIR was circulated for public review and comment do not individually or collectively constitute significant new information within the meaning of Public Resources Code section 21092.1 or the CEQA Guidelines section 15088.5.

Severability
If any term, provision, or portion of these Findings or the application of these Findings to a particular situation is held by a court of competent jurisdiction to be invalid, void or unenforceable, the remaining provisions of these Findings, or their application to other actions related to General Plan 2040, shall continue in full force and effect unless amended or modified by the City.

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Packet Pg. 658 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Table of Contents
Findings of Fact/Statement of Overriding Considerations i Table of Contents
1 Introduction.................................................................................................................................... 1

1.1 Statutory Requirements for Findings.................................................................................. 1

1.2 Procedural Findings............................................................................................................. 2

1.3 Findings Required Under CEQA........................................................................................... 4

1.4 Record of Proceedings........................................................................................................ 4

1.5 Findings............................................................................................................................... 5 2 2040 General Plan........................................................................................................................... 6

2.1 Plan Objectives.................................................................................................................... 6

2.2 Project Description.............................................................................................................. 6 3 Impacts Determined to be Less than Significant or No Impact...................................................... 7 4 Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures ......................................................................................................................................13 5 Impacts Determined to be Significant and Unavoidable..............................................................27 6 Feasibility of Project Alternatives.................................................................................................31

6.1 Alternatives.......................................................................................................................32

6.2 Alternative 1: Adopted General Plan Buildout (i.e., “No Project”)...................................33

6.3 Alternative 2: New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative.........................................................................................................................34

6.4 Alternative 3: New Infill Mixed Use within the City Core Alternative ..............................36

6.5 Environmentally Superior Alternative ..............................................................................37 7 Significant Irreversible Effects and Growth Inducement..............................................................39

7.1 Significant Irreversible Effects...........................................................................................39

7.2 Growth Inducement..........................................................................................................40 8 Statement of Overriding Considerations......................................................................................42

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Packet Pg. 659 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
ii
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Packet Pg. 660 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update San Ramon 2040 General Plan
Final Environmental Impact Report
State Clearinghouse #: 2022060549
prepared for
City of San Ramon
Planning Services Division
7000 Bollinger Canyon Road
San Ramon, California 94583
Contact: Cindy Yee, Senior Planner
prepared by
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
November 2, 2023

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Packet Pg. 661 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Introduction
Findings of Fact/Statement of Overriding Considerations 1 1 Introduction

1.1 Statutory Requirements for Findings
These Findings of Fact (Findings) and Statement of Overriding Considerations address the potentially significant environmental impacts identified by the Environmental Impact Report (EIR) for the update to the General Plan by the City of San Ramon, California (referred to herein as the 2040 General Plan). The Findings and Statement of Overriding considerations are made pursuant to California Environmental Quality Act (CEQA) Guidelines Section 15091, which states that:
(a) No public agency shall approve or carry out a project for which an Environmental Impact Report (EIR) has been certified which identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings for each of those significant effects, accompanied by a brief explanation of the rationale for each finding. The possible findings are:
(1) Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR.
(2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency. (3) Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR. (b) The findings required by subdivision (a) shall be supported by substantial evidence in the record.

Section 15092 of the CEQA Guidelines further stipulates that:
(a) After considering the final EIR and in conjunction with making findings under Section 15091, the Lead Agency may decide whether or how to approve or carry out the project. (b) A public agency shall not decide to approve or carry out a project for which an EIR was prepared unless either:
(1) The project as approved will not have a significant effect on the environment, or (2) The agency has:
(A) Eliminated or substantially lessened all significant effects on the environment where feasible as shown in findings under Section 15091, and
(B) Determined that any remaining significant effects on the environment found to be unavoidable under Section 15091 are acceptable due to overriding concerns as described in Section 15093.

In short, CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to avoid or mitigate significant environmental impacts that will otherwise occur with

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Packet Pg. 662 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
2 implementation of the project. Project mitigation or alternatives are not required, however, where they are infeasible or where the responsibility for modifying the project lies with another agency.1 For those significant effects that cannot be mitigated to a less-than-significant level, the public agency is required to find that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment.2 The CEQA Guidelines state in Section 15093 that:
“If the specific economic, legal, social, technological, or other benefits of a propos[ed] project outweigh the unavoidable adverse environmental effects, the adverse environmental effects may be considered ‘acceptable.”

1.2 Procedural Findings
The City Council of the City of San Ramon (City) finds as follows:

Based on the nature and scope of the 2040 General Plan, the City Council of San Ramon determined, based on substantial evidence, that the 2040 General Plan may have a significant effect on the environment and prepared an EIR (State Clearinghouse No. 2022060549). The EIR was prepared, noticed, published, circulated, reviewed and completed in full compliance with the CEQA Public Resources Code Sections 21000 et seq. CEQA and the CEQA Guidelines (14 California Code of Regulations Sections 15000 et. Seq.), as follows:
 Notice of Preparation (NOP). After deciding that an EIR is required, the lead agency (the City) must file an NOP with the State Clearinghouse and distribute the NOP to responsible and trustee agencies and parties previously requesting notice in writing (CEQA Guidelines Section 15082; Public Resources Code [PRC] Section 21092.2). The NOP must be posted in the County Clerk’s office for 30 days. The City distributed the NOP for the 2040 General Plan EIR for a 30- day agency and public review period starting on June 24, 2022 and ending on July 25, 2022, during which time the NOP was posted in the Contra Costa County Clerk’s office.  Scoping Hearing. Pursuant to CEQA Guidelines Section 15082 the lead agency must conduct at least one EIR Scoping Meeting for projects of statewide, regional, or areawide significance. The City held an EIR Scoping Meeting on July 5, 2022.
 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; h) discussion of irreversible changes, and i) any identified areas of controversy. The City prepared a Draft EIR, which was circulated for a 48-day public review period that began on August 30, 2023 and ended on October 16, 2023. A corresponding Notice of Availability (NOA) was published to provide notification when the Draft EIR became available for public review.
 Notice of Availability (NOA) and Notice of Completion (NOC). Pursuant to CEQA Guidelines Section 15087, the lead agency must circulate an NOA and file an NOC with the State Clearinghouse when it completes a Draft EIR. The lead agency must place the NOA in the County Clerk’s office for 30 days. Additionally, public notice of Draft EIR availability must be given through at least one of the following methods: a) publication in a newspaper of general circulation; b) physical signage posting on and off the project site; and c) direct mailing to 1 CEQA Guidelines Section 15091 (a), (b). 2 Public Ressources Code Section 21081(b).

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Packet Pg. 663 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Introduction
Findings of Fact/Statement of Overriding Considerations 3 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 (PRC Sections 21104 and 21153). An NOA and NOC were prepared and submitted to the State Clearinghouse with the Draft EIR, which was published by the State Clearinghouse on August 30, 2023. The NOA was posted with the Contra Costa County Clerk, at City Hall, and on the City and Plan San Ramon websites (http://www.sanramon.ca.gov/ and http://plansanramon.com/) on August 20, 2023.

The NOA was published in the San Ramon Valle Times on September 1, 2023. The NOA was distributed via mail or email to agencies, organizations, Native American Tribes, known interested parties, and approximately 400 property owners on August 30, 2023.  Final EIR. Pursuant to CEQA Guidelines Section 15132, a Final EIR must include a) the Draft EIR and subsequent revisions; b) copies of comments received during public review; c) list of persons, organizations, and public agencies commenting; and d) responses to significant environmental issues raised in the comments. The City prepared a Final EIR, which was published and submitted to the State Clearinghouse on December 14, 2023.  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 the Final EIR reflects the lead agency’s independent judgement 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, that a) the project has been changed to avoid or substantially reduce the magnitude of the impact; b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted by such other agency; or c) specific economic, social, 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.
 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 adopted or made conditions of project approval to mitigate significant effects (CEQA Guidelines Section 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, and with the State Clearinghouse if the project requires discretionary approval by any State agency. The NOD must be posted for 30 days and sent to anyone requesting notice previously. Posting of the NOD starts a 30-day statute of limitations on CEQA legal challenges (PRC Section 21167[c]).

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Packet Pg. 664 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
4 1.3 Findings Required Under CEQA
The City Council (the final decision-making body) of the City of San Ramon (the CEQA Lead Agency) will determine whether to certify the EIR for the project. Because the Draft EIR identified a potentially significant environmental impact, the City Council must also make certain “findings” as part of its action to certify that the EIR has been completed in compliance with CEQA and to approve the 2040 General Plan. Pursuant to CEQA Guidelines Section 15091 and PRC Section 21081, no public agency shall approve or carry out a project for which an environmental impact report has been certified, which identifies one or more significant effects on the environment that would occur if the project is approved or carried out, unless the public agency makes one or more findings for each of those significant effects, accompanied by a brief explanation of the rationale of each finding.

The possible findings, which must be supported by substantial evidence in the record, are:
 Changes or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR.  Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.  Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR.

1.4 Record of Proceedings
For purposes of CEQA and these findings, the record before the City Council includes the following:
 The Draft EIR and appendices to the Draft EIR
 The Final EIR including errata to the Draft EIR, comments on the Draft EIR, and responses to comments
 Public notices issued by the City in connection with the 2040 General Plan, including the NOP, NOA, NOC, and NOD
 Studies conducted for the 2040 General Plan and contained in, or referenced by, the Draft EIR or the Final EIR
 All documents cited, incorporated by reference, or referred to in the Draft EIR and Final EIR  Written and verbal comments submitted to the City by agencies, organization, and members of the public on the 2040 General Plan, Notice of Preparation, Draft EIR, and Final EIR (before, during, and after the close of the public comment periods)  Minutes or video recordings of Planning Commission and/or City Council joint workshops and City Council hearings held by the City in connection with the 2040 General Plan  The Findings and Statement of Overriding Conditions, Mitigation Monitoring and Reporting Program, and Resolutions adopted by the City in connection with the 2040 General Plan  Any other materials required to be in the record of proceedings by Public Resources Code Section 21167.6, subdivision (e).

The custodian of the documents and other materials that constitute the record of the proceedings upon which the City’s decisions are based is the City Clerk, or her designee. Such documents and

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Packet Pg. 665 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Introduction
Findings of Fact/Statement of Overriding Considerations 5 other material are located at San Ramon City Hall, 7000 Bollinger Canyon Road, San Ramon, CA 94583.

1.5 Findings
The Draft EIR and Final EIR are incorporated into these findings in its entirety. Without limitation, this incorporation is intended to elaborate on the scope and nature of mitigation measures, the basis for determining the significance of impacts, the comparative analysis of alternatives, and the reasons for approving 2040 General Plan in spite of the potential for associated significant and unavoidable adverse impacts.

For the purposes of these findings, the impact discussions include the relevant policies and implementing actions, as well as the separate mitigation measures imposed to reduce the impacts where the policies and implementing actions did not result in a less than significant impact. In the findings that follow, impact numbers are provided. The impact numbers correspond to the impact discussions in the Draft EIR that contain an expanded discussion of impacts. Please refer to the referenced impact sections of the Draft EIR for more detail.

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Packet Pg. 666 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
6 2 2040 General Plan

2.1 Plan Objectives
Pursuant to CEQA Guidelines Section 15124(b), the EIR project description must include “[a] statement of objectives sought by the proposed project. The statement of objectives should include the underlying purpose of the project.” The 2040 General Plan is intended to achieve the following project objectives:
 Outline a vision for San Ramon’s long-range physical and economic development and resource conservation that reflects the aspirations of the community and the smart growth mandate of Measure G (1999);
 Provide strategies and specific implementing actions that will allow this vision to be accomplished;
 Establish a basis for judging whether specific development proposals and public projects are in harmony with Plan policies and standards;
 Allow City departments, other public agencies, and private developers to design projects that will enhance the character of the community, preserve and enhance critical environmental resources, and minimize hazards; and
 Provide the basis for establishing and setting priorities for detailed plans and implementing programs, such as the Zoning Ordinance, the Capital Improvement Program (CIP), Climate Action Plan, specific plans, etc.

2.2 Project Description
The 2040 General Plan is an update to the San Ramon General Plan, including eleven respective General Plan elements, amendment to the San Ramon Village Specific Plan, repeal of the North Camino Ramon Specific Plan, and the San Ramon Zoning Ordinance update (collectively referred to herein as the 2040 General Plan). The 2040 General Plan elements include: Land Use; Housing; Traffic and Circulation; Safety; Open Space and Conservation; Parks and Recreation; Public Facilities and Utilities; Noise, Air Quality and GHG Emissions, Growth Management, and Economic Development. San Ramon Zoning Ordinance updates would occur to ensure consistency with the updated General Plan. The 2040 General Plan would serve as a long-term framework for future growth across the San Ramon Planning Area (the General Plan area), reflect issues identified from community input and changes in State law, and provide updates to the various elements of the General Plan. Refer to Chapter 2, Project Description, of the Draft EIR for the complete project description.

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Packet Pg. 667 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less than Significant or No Impact Findings of Fact/Statement of Overriding Considerations 7 3 Impacts Determined to be Less than
Significant or No Impact
Certain impacts were found to be less than significant or to have no impact due to the inability of the 2040 General Plan to create such impacts, the absence of 2040 General Plan characteristics producing effects of this type, or due to the absence of certain environmental characteristics or resources within the city. The City, having received, reviewed, and considered the entire record, both written and oral, related to the 2040 General Plan and Draft and Final EIR, finds that the following impacts would not be significant adverse impacts or would create no impact and therefore no additional Findings are needed.

No Impact
City finds that, based upon substantial evidence in the record, as discussed below, the 2040 General Plans would result in no impacts associated with the following topics:

Biological Resources
Impact BIO-5: Development facilitated by the 2040 General Plan would not conflict with an adopted Habitat Conservation Plan (HCP), Natural Community Conservation Plan (NCCP), or other approved local, regional, or State habitat conservation plan. No impact would occur.

Impact BIO-8. Development facilitated by the 2040 General Plan would not result in the conversion of land used for forestry purposes nor conflict with existing zoning for forestry or timberland use.

No impact would occur.

Geology/ Soils and Mineral Resources
Impact GEO-5. Development facilitated by the 2040 General Plan would occur on urbanized sites that are served by existing sanitation infrastructure. New development would not include septic systems. There would be no impact.

Impact GEO-7. Development facilitated by the 2040 General Plan would not have the potential to impact mineral resources. There would be no impact.

Hazards/ Hazardous Materials and Wildfire
Impact HAZ-3. Development facilitated by the 2040 General Plan would not be located within an airport land use plan or within two miles of an airport. No impacts would occur.

Less than Significant Impacts
The City finds that, based upon substantial evidence in the record, as discussed below, the 2040 General Plan’s impacts associated with the following topics would be less than significant:

Aesthetics
Impact AES-1. The 2040 General Plan would facilitate development in areas along urbanized corridors that do not offer notable scenic vistas through the plan area. Impacts would be less than significant.

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Packet Pg. 668 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
8 Impact AES-2. Development facilitated by the 2040 General Plan could affect scenic resources visible from a designated scenic highway. Impacts would be less than significant.

Impact AES-3. The 2040 General Plan would facilitate infill and redevelopment projects within existing urban areas and allow for increased intensity of development on underutilized sites that could affect visual character or quality of views. Impacts would be less than significant.

Impact AES-4. Development facilitated by the 2040 General Plan would create new sources of light or glare that could adversely affect daytime or nighttime views in the area. Compliance with the San Ramon Municipal Code and 2040 General Plan development standards related to lighting and glare would ensure this impact is less than significant.

Air Quality
Impact AQ-1. Implementation of the 2040 General Plan would be consistent with the BAAQMD 2017 Clean Air Plan. Impacts would be less than significant.

Impact AQ-4. The 2040 General Plan could create objectionable odors that could adversely affect a substantial number of people. Impacts related to odors would be less than significant.

Biological Resources
Impact BIO-2. Development facilitated by the 2040 General Plan could adversely impact riparian habitat, other sensitive natural communities, or protected wetlands in the General Plan area.

Implementation of federal, State, and local regulations and policies would ensure riparian habitat and wetlands are not significantly impacted. Impacts would be less than significant.

Impact BIO-3. Development facilitated by the 2040 General Plan would avoid impacts to wildlife movement corridors by conserving Open Space areas in the General Plan area, as directed by policies in the 2040 General Plan. Impacts would be less than significant.

Impact BIO-4. Development facilitated by the 2040 General Plan would be required to conform with applicable local policies and ordinances protecting biological resources. Impacts would be less than significant.

Impact BIO-6. Development facilitated by the 2040 General Plan would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland) to non-agricultural use. Impacts would be less than significant.

Impact BIO-7. Development facilitated by the 2040 General Plan would not conflict with existing zoning for agricultural use or a Williamson Act contract. Impacts would be less than significant.

Cultural and Tribal Cultural Resources
Impact CR-3. The discovery of human remains is always a possibility during ground-disturbing activities. Ground disturbance associated with development carried out under the 2040 General Plan may disturb or damage known or unknown human remains. This impact would be less than significant with adherence to existing regulations.

Geology and Soils
Impact GEO-1. The 2040 General Plan is located within an Alquist Priolo Earthquake Fault Zone, and, therefore, the 2040 General Plan would likely be subject to effects involving rupture of a known

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Packet Pg. 669 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less than Significant or No Impact Findings of Fact/Statement of Overriding Considerations 9 earthquake fault. Implementation of proposed general plan policies and existing state and local regulations would reduce seismic hazards to less than significant.

Impact GEO-2. Development facilitated by the 2040 General Plan could result in exposure of people or structures to a risk of loss, injury, or death from seismic events. Development facilitated by the 2040 General Plan could be located on a geologic unit or soil that is unstable or could become unstable resulting in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.

However, with compliance with applicable laws, regulations, and applicable General Plan Goals and Policies, this impact would be less than significant.

Impact GEO-3. Construction facilitated by the 2040 General Plan would include ground disturbance such as excavation and grading that would result in loose or exposed soil. Disturbed soil could be eroded by wind or rain during a storm event, which could result in the loss of topsoil. Adherence to existing regulatory requirements would ensure that this impact would be less than significant.

Impact GEO-4. Future seismic events could result in liquefaction and lateral spreading of soils within the city. Development in the General Plan area could be subject to liquefaction hazards. Compliance with the CBC would reduce liquefaction hazards. Proposed Health, Safety, and HazMat goals and policies apply to development facilitated by the 2040 General Plan in hazard zones for liquefaction or lateral spreading of soils. Impacts would be less than significant.

Greenhouse Gas Emissions and Energy
Impact GHG-2. The 2040 General Plan would implement a land-use strategy and policies that would promote greater overall energy efficiency. Wasteful, inefficient, or unnecessary consumption of energy would not occur. impacts would be less than significant.

Impact GHG-3. The 2040 General Plan would be consistent with applicable energy efficiency goals and regulations included in relevant provisions of CALGreen (Title 24, Part 11). However, San Ramon has not adopted the California Building Energy Efficiency Standards (Title 24, Part 6). Development facilitated by the 2040 General Plan would not be consistent with State energy efficiency plans until Title 24, Part 6 is adopted by San Ramon. this impact would be less than significant with mitigation.

Hazards/Hazardous Materials and Wildfire
Impact HAZ-1. Development facilitated by the 2040 General Plan could result in the release of potentially hazardous materials, which may occur within 0.25 mile of a school. However, compliance with local, regional, State, and federal regulations related to hazardous materials would minimize the risk of releases and exposure to these materials. Impacts would be less than significant.

Impact HAZ-2. Development facilitated by the 2040 General Plan could result in development on sites contaminated with hazardous materials. However, compliance with applicable regulations relating to site remediation would minimize impacts from development on contaminated sites, resulting in a less than significant impact.

Impact HAZ-4. Development facilitated by the 2040 General Plan would result in additional population and vehicle miles traveled in the city. The 2040 General Plan could result in changes to emergency evacuation routes or would substantially increase roadway congestion such that the use of an evacuation route would be hindered. Adherence to existing hazard mitigation plans and evacuation plans would reduce risk of hindering evacuation route use. impacts would be less than significant.

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Packet Pg. 670 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
10 Hydrology and Water Quality
Impact HYD-1. Implementation of the 2040 General Plan would involve ground-disturbing activities during construction that could temporarily increase the potential for water quality to be affected by sedimentation or an accidental spill or release of hazardous materials. However, with adherence to applicable water quality standards, waste discharge requirements, and proposed General Plan policies, impacts would be less than significant.

Impact HYD-2. Development facilitated by the 2040 General Plan would not pump water from the local groundwater basin and would not introduce substantial new areas of impermeable surfaces such that the rates or patterns of groundwater recharge from infiltration would be affected. Impacts would be less than significant.

Impact HYD-3. Development facilitated by the 2040 General Plan would not alter the course of a stream or river or substantially alter existing drainage patterns, including through new impervious surfaces, and regulatory requirements as well as policies to protect and improve drainage patterns would minimize erosion, flooding, and runoff. Impacts would be less than significant.

Impact HYD-4. Development facilitated by the 2040 General Plan would not increase existing potential for inundation within flood hazard areas to occur and would not introduce substantial new pollutant sources that could potentially be released due to inundation. Impacts would be less than significant.

Impact HYD-5. Development facilitated by the 2040 General Plan would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Impacts would be less than significant.

Land Use/Planning and Population/Housing
Impact LU-1. Implementation of the proposed 2040 General Plan would maintain orderly development in San Ramon and would not physically divide an established community. Impacts would be less than significant.

Impact LU-2. Implementation of the 2040 General Plan would be generally consistent with applicable land use plans, policies, or regulations adopted to avoid or mitigate environmental effects, such as the SRVSP and ABAG/MTC Plan Bay Area 2050. Impacts would be less than significant.

Impact LU-3. Implementation of the 2040 General Plan would facilitate the construction of new housing in San Ramon. Proposed development could result in an increase in population that would exceed ABAG population forecasts by 35 percent by 2040. However, the 2040 General Plan is intended to accommodate and plan for population growth. Impacts would be less than significant.

Impact LU-4. Development facilitated by the 2040 General Plan would not result in the displacement of substantial numbers of housing or people. The 2040 General Plan would facilitate the development of new housing in accordance with State and local housing requirements, while preserving existing residential neighborhoods. Impacts would be less than significant.

Noise
Impact NOI-3. Development facilitated by the 2040 General Plan would not expose people residing or working in the plan area to excessive noise levels related to airstrip/airport operation. There would be no impact.

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Packet Pg. 671 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less than Significant or No Impact Findings of Fact/Statement of Overriding Considerations 11 Public Services & Recreation
Impact PS-1. Development facilitated by the 2040 General Plan would increase the population of San Ramon, generating additional need for fire protection services. However, compliance with the 2040 General Plan would result in impacts related to the need for new or altered fire facilities that are less than significant.

Impact PS-2. Development facilitated by the 2040 General Plan would increase population in San Ramon, generating additional need for police protection services. However, compliance with 2040 General Plan policies would result in impacts related to the need for new or altered police facilities that are less than significant.

Impact PS-3. Development facilitated by the 2040 General Plan would result in an increase in population of school-aged children in San Ramon. This would increase demand for school services and potentially create the need for new school facilities. Operational impacts of new school facilities would be less than significant with payment of school impact fees.

Impact PS-4. Development facilitated by the 2040 General Plan would result in an increase in San Ramon population. This would increase demand for and use of parks and potentially create the need for new or altered park and recreational facilities. However, compliance with 2040 General Plan policies would result in impacts related to increased use or the need for new or altered parks or recreational facilities that are less than significant.

Impact PS-5. Development facilitated by the 2040 General Plan would result in an increase in the City’s population. This would increase demand for public facilities, specifically libraries, and potentially create the need for new libraries. However, compliance with 2040 General Plan policies would result in impacts related to need for new or altered public facilities that are less than significant.

Transportation and Traffic
Impact TRA-3. Implementation of the 2040 General Plan would not substantially increase hazards because of a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment). Impacts would be less than significant.

Impact TRA-4. Implementation of the 2040 General Plan would not have the potential to result in inadequate emergency access. This impact would be less than significant.

Utilities and Service Systems
Impact UTL-2. Development facilitated by the 2040 General Plan would increase demand for water supply. However, with adherence to the 2040 General Plan goals and policies, water supplies would be adequate to support future development. Impacts would be less than significant.

Impact UTL-3. Development projected by the 2040 General Plan would increase demand for wastewater treatment. However, the existing wastewater treatment plant has sufficient capacity for future development, and the 2040 General Plan contains policies to ensure treatment is adequate.

Impacts would be less than significant.

Impact UTL-4. Development facilitated under the 2040 General Plan would increase the volume of solid waste generated in San Ramon. However, existing infrastructure that serves the city, as well as policies within the 2040 General Plan, would ensure that the City has adequate capacity to accept

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Packet Pg. 672 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
12 the increase in solid waste and comply with federal, State, and local management reduction regulations. Impacts would be less than significant.

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Packet Pg. 673 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 13 4 Impacts Determined to be Less Than
Significant Level After Implementation of
Mitigation Measures
These topical areas contain impacts of the 2040 General Plan that are reduced to a less-thansignificant level through the implementation of mitigation measures. Pursuant to California Public Resources Code Section 21081(a)(1) and CEQA Section 15091(a)(1), as to each impact, the City, based on the evidence in the record before it, finds that changes or alterations incorporated into the 2040 General Plan mitigate, avoid, or substantially lessen to a level of insignificance these environmental impacts of the Project. The basis for the finding for each impact is set forth below.

Air Quality
Impact AQ-2
Implementation of the 2040 General Plan would result in the generation of air pollutants during construction and operation of individual projects, which could affect local air quality. However, construction and operational impacts would be less than significant with implementation of Mitigation Measures AQ-1 and AQ-2. Implementation of the 2040 General Plan would not result in a cumulatively considerable net increase of operational criteria pollutants with mitigation.

MITIGATION MEASURE AQ-1 REDUCE CONSTRUCTION CRITERIA POLLUTANT EMISSIONS To reduce temporary increases in criteria air pollutant emissions during the construction phase for discretionary development projects that are subject to CEQA and exceed the screening sizes in the Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines, the City shall require such projects to evaluate project- specific construction emissions in conformance with the BAAQMD methodology. If construction-related criteria air pollutants exceed the BAAQMD thresholds of significance, the project applicant shall mitigate the impacts to a less-than-significant level.

MITIGATION MEASURE AQ-2: REDUCE OPERATIONAL CRITERIA POLLUTANT EMISSIONS To reduce long-term increases in air pollutants during the operation phase for discretionary development projects that are subject to CEQA and exceed the screening sizes in the Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines, the City shall require such projects to evaluate project- specific operation emissions in conformance with BAAQMD CEQA Guidelines. If operation- related air pollutants exceed the BAAQMD-adopted thresholds of significance, the project applicant shall mitigate the impact to a less-than-significant level.

Finding
The City finds that with incorporation of Mitigation Measures AQ-1 and AQ-2, impacts related to a cumulatively considerable net increase of criteria pollutant would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

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Packet Pg. 674 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
14 Impact AQ-3
Construction activities for individual projects facilitated by the 2040 General Plan lasting longer than two months or located within 1,000 feet of sensitive receptors could expose sensitive receptors to substantial pollutant concentrations. Implementation of the 2040 General Plan may also expose sensitive receptors to additional operational sources of TACs. Impacts would be less than significant with implementation of Mitigation Measures AQ-3 and AQ-4.

MITIGATION MEASURE AQ-3: CONDUCT AND IMPLEMENT CONSTRUCTION HEALTH RISK ASSESSMENT To identify and reduce potential risk exposure to nearby sensitive receivers during construction of individual projects (excluding ADUs, single-family residences, and duplexes) where construction activities would a) occur within 1,000 feet of sensitive receptors, b) last longer than two months, and c) not utilize equipment rated US EPA Tier 4 for equipment of 50 horsepower or more, construction equipment fitted with Level 3 Diesel Particulate Filters for all equipment of 50 horsepower or more, and/or alternative fuel construction equipment, the project applicant shall coordinate with the City to determine if a construction health risk assessment (HRA) shall be performed. If an HRA is to be performed, the HRA shall determine potential risk and compare the risk to the following BAAQMD thresholds:
 Non-compliance with Qualified Community Risk Reduction Plan;  Increased cancer risk of > 10.0 in a million;
 Increased non-cancer risk of > 1.0 Hazard Index (Chronic or Acute); or  Ambient PM2.5 increase of > 0.3 µg/m3 annual average
If risk exceeds the thresholds, measures such as requiring the use of Tier 4 engines, Level 3 Diesel Particulate Filters, and/or alternative fuel construction equipment shall be incorporated to reduce the exposure risk to acceptable levels.

MITIGATION MEASURE AQ-4: REDUCE OPERATIONAL TOXIC AIR CONTAMINANTS To identify and reduce potential risk exposure to nearby sensitive receivers during the operation phase for discretionary development projects that are subject to CEQA and exceed the screening sizes in the Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines, the City shall require applicants for commercial land uses that would generate substantial diesel truck travel (i.e., 100 diesel trucks per day or 40 or more trucks with diesel-powered transport refrigeration units per day) to contact BAAQMD to determine the appropriate level of operational health risk assessment (HRA) required. If required, the operational HRA shall be prepared in accordance with the Office of Environmental Health Hazard Assessment and BAAQMD requirements and include mitigation to reduce the exposure risk to an acceptable level. Typical measures to reduce risk impacts may include, but are not limited to:
a. Restricting idling on-site beyond Air Toxic Control Measures idling restrictions, as feasible. b. Electrifying warehousing docks.
c. Truck Electric Vehicle (EV) Capable trailer spaces.
d. Requiring use of newer equipment and/or vehicles.
e. Restricting off-site truck travel through the creation of truck routes.

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Packet Pg. 675 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 15 Finding
The City finds that with incorporation of Mitigation Measures AQ-3 and AQ-4, impacts related to exposure of sensitive receptors to substantial pollutant concentrations would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Biological Resources
Impact BIO-1
Development facilitated by the 2040 General Plan could result in direct or indirect impacts to special-status species or their associated habitats including impacts to migratory bird nest sites.

Impacts would be less than significant with implementation of Mitigation Measures BIO-1 and BIO2.

MITIGATION MEASURE BIO-1 CONDUCT PRE-CONSTRUCTION BIRD SURVEYS AND IMPLEMENT

AVOIDANCE AND MINIMIZATION MEASURES
For construction activities initiated during the bird nesting season (February 1 – September 15) involving removal of vegetation that could potentially serve as habitat for special-status bird species or other nesting bird habitat, including abandoned structures and other man-made features, a preconstruction nesting bird survey shall be conducted no more than 14 days prior to initiation of ground disturbance and vegetation removal activities. The nesting bird pre-construction survey shall be conducted on foot and shall include a buffer around the construction site at a distance determined by a qualified biologist. The survey shall be conducted by a biologist familiar with the identification of avian species known to occur in California Bay Area communities (i.e., qualified biologist). If nests are found, an avoidance buffer shall be determined by a qualified biologist dependent upon the species, the proposed work activity, and existing disturbances associated with land uses outside of the site. The buffer shall be demarcated by the biologist with bright orange construction fencing, flagging, construction lathe, or other means to demarcate the boundary. All construction personnel shall be notified as to the existence of the buffer zone and to avoid entering the buffer zone during the nesting season. No ground disturbing activities shall occur within the buffer until the biologist has confirmed that breeding/nesting is completed, and the young have fledged the nest. Encroachment into the buffer shall occur only at the discretion of the qualified biologist on the basis that the encroachment will not be detrimental to an active nest. A report summarizing the pre-construction survey(s) shall be prepared by a qualified biologist and shall be submitted to the City prior to the commencement of construction activities.

Future project site plans shall include a statement acknowledging compliance with the federal MBTA and California Fish and Game Code that includes avoidance of active bird nests and identification of Best Management Practices to avoid impacts to active nests, including checking for nests prior to construction activities during February 1 to September 15 and what to do if an active nest is found so that the nest is not inadvertently impacted during grading or construction activities.

MITIGATION MEASURE BIO-2 CONDUCT PRE-CONSTRUCTION ROOSTING BATS SURVEYS AND

IMPLEMENT AVOIDANCE MEASURES PRIOR TO REMOVAL
Prior to the removal or alteration of trees and structures that may serve as roosting habitat for special-status bat species, a qualified biologist shall conduct a focused survey of all trees and

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Packet Pg. 676 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
16 structures to be removed or impacted by construction activities to determine whether active roosts of special-status bats are present on site. The survey shall be conducted during seasonal periods of bat activity (March 1 through October 15). The biologist shall have access to all structures and interior attics, as needed. If a colony of bats is found roosting in any structure, tree or other habitat, further surveys, such as night emergent surveys, shall be conducted sufficient to determine the species present and the type of roost (day, night, maternity, etc.).

Tree or structure removal shall be planned for either the spring or the fall and timed to ensure both suitable conditions for the detection of bats and adequate time for tree and/or structure removal to occur during seasonal periods of bat activity exclusive of the breeding season, as described below.

Trees and/or structures containing suitable potential bat roost habitat features shall be clearly marked or identified. If no bat roosts are found, the results of the survey will be documented and submitted to the City within 30 days of the survey, after which no further action will be required.

If day roosts are present, the biologist shall prepare a site-specific roosting bat protection plan to be implemented by the contractor following the City’s approval. The plan shall incorporate the following guidance as appropriate:
 When possible, removal of trees/structures identified as suitable roosting habitat shall be conducted during seasonal periods of bat activity, including the following:
a) Between September 1 and about October 15, or before evening temperatures fall below 45 degrees Fahrenheit and/or more than 0.5 inch of rainfall within 24 hours occurs. b) Between March 1 and April 15, or after evening temperatures rise above 45 degrees Fahrenheit and/or no more than 0.5 inch of rainfall within 24 hours occurs.  If a tree /structure must be removed during the maternity season and is identified as potentially containing a colonial maternity roost, then a qualified biologist shall conduct acoustic emergence surveys or implement other appropriate methods to further evaluate if the roost is an active maternity roost. Under the biologist’s guidance, the contractor shall implement measures that consist of (or exceed) the following:
a) If it is determined that the roost is not an active maternity roost, then the roost may be removed in accordance with the other requirements of this measure. b) If it is found that an active maternity roost of a colonial roosting species is present, the roost shall not be disturbed during the maternity season (April 15 to August 31) or until the maternity roost has dispersed.
 Tree removal procedures shall be implemented using a two-step tree removal process. This method is conducted over two consecutive days and works by creating noise and vibration by cutting non-habitat branches and limbs from habitat trees using chainsaws only (no excavators or other heavy machinery) on day one. The noise and vibration disturbance, together with the visible alteration of the tree, is very effective in causing bats that emerge nightly to feed to not return to the roost that night. The remainder of the tree is removed on day two.  Prior to the demolition of vacant structures within the project site, a qualified biologist shall conduct a focused habitat assessment of all structures to be demolished. The habitat assessment shall be conducted enough in advance to ensure the commencement of building demolition can be scheduled during seasonal periods of bat activity (see above), if required. If no signs of day roosting activity are observed, no further actions will be required. If bats or signs of day roosting by bats are observed, a qualified biologist will prepare specific recommendations such as partial dismantling to cause bats to abandon the roost, or humane eviction, both to be conducted during seasonal periods of bat activity, if required. Should maternity roosts be observed the roost shall not be disturbed during the maternity season (April 15 to August 31) or until maternity roost has

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Packet Pg. 677 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 17 dispersed. If project schedules do not allow for maternity season avoidance, a bat habitat mitigation and monitoring plan shall be developed to reduce risks to bat pups and consultation with CDFW would be required.

If the qualified biologist determines a roost is used by a large number of bats (large hibernaculum), bat boxes shall be installed near the project site. The number of bat boxes installed will depend on the size of the hibernaculum and shall be determined through consultation with CDFW. If a maternity colony has become established, all construction activities shall be postponed within a 500-foot buffer around the maternity colony until it is determined by a qualified biologist that the young have dispersed. Once it has been determined that the roost is clear of bats, the roost shall be removed immediately.

Finding
The City finds that with incorporation of Mitigation Measures BIO-1 and BIO-2, construction impacts to special status species would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Cultural Resources
Impact CR-1
The 2040 General Plan has the potential to result in significant impacts if development carried out under the plan would cause a substantial adverse change in the significance of a historical resource.

This impact would be less than significant with implementation of Mitigation Measure CR-1.

MITIGATION MEASURE CR-1 PREPARE A HISTORICAL RESOURCES EVALUATION PRIOR TO APPROVAL FOR PROJECTS INVOLVING BUILDINGS 45 YEARS OR OLDER AND IMPLEMENT MITIGATION PRIOR TO AND DURING CONSTRUCTION.

A historic resources evaluation for projects involving buildings 45 years or older shall be prepared as follows:
 All properties 45 years of age or older as deemed appropriate by the San Ramon Community Development Director shall be evaluated within their historic context and documented in a report meeting the State Office of Historic Preservation guidelines. The evaluation shall be prepared by a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualifications Standards in architectural history or history (as defined in Code of Federal Regulations, Title 36, Part 61). The qualified architectural historian or historian shall conduct an intensive-level evaluation in accordance with the guidelines and best practices promulgated by the State Office of Historic Preservation to identify potential historical resources within the proposed development site. Such evaluated properties shall be documented on Department of Parks and Recreation Series 523 Forms. The report shall be submitted to the City for review and concurrence. If the property is already listed in the NRHP or CRHR, the historical resources evaluation described above shall not be required.  If historical resources are identified within the site of a proposed development, efforts shall be made to the extent feasible to ensure that impacts are mitigated. Application of mitigation shall generally be overseen by a qualified architectural historian or historic architect meeting the Professional Qualification Standards, unless unnecessary in the circumstances (e.g., preservation in place). In conjunction with a development application that may affect the historical resource,

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Packet Pg. 678 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
18 the historical resources evaluation report shall also identify and specify the treatment of character-defining features and construction activities.  Efforts shall be made to the greatest extent feasible to ensure that the relocation, rehabilitation, or alteration of the resource is consistent with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings. Application of the Standards shall be overseen by a qualified architectural historian or historic architect meeting the Professional Qualification Standards. In conjunction with a development application that may affect the historical resource, a report identifying and specifying the treatment of character-defining features and construction activities shall be provided to the City for review and concurrence. As applicable, the report shall demonstrate how a project complies with the Standards and be submitted to the City for review and approval prior to the issuance of permits.
 If significant historical resources are identified on a development site and compliance with the Standards and or avoidance is not possible, appropriate site-specific mitigation measures shall be established and undertaken. Mitigation measures may include documentation of the historical resource in the form of a Historic American Building Survey (HABS) report, or equivalent. The report shall comply with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation and shall generally follow the HABS Level III requirements, including digital photographic recordation, detailed historic narrative report, and compilation of historic research. The documentation shall be completed by a qualified architectural historian or historian who meets the Professional Qualification Standards and submitted to the City prior to issuance of any permits for demolition or alteration of the historical resource.

Finding
The City finds that with incorporation of Mitigation Measure CR-1, impacts to historical resources would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Impact CR-2
The 2040 general Plan has the potential to result in significant impacts if development carried out under the plan would cause a substantial adverse change in the significance of an archaeological resource, including those that qualify as historical resources. This impact would be less than significant with implementation of Mitigation Measures CR-2 and CR-3.

MITIGATION MEASURE CR-2 PREPARE AN ARCHAEOLOGICAL RESOURCES ASSESSMENT PRIOR TO PROJECT APPROVAL AND IMPLEMENT MITIGATION PRIOR TO AND DURING CONSTRUCTION.

An archaeological resources assessment for projects involving ground disturbance shall be prepared as follows:
 Assessments shall include a California Historical Resources Information System records search at the Northwest Information Center (NAHC) and a Sacred Lands File search maintained by the Native American Heritage Commission. The records searches will characterize the results of previous cultural resource surveys and disclose any cultural resources that have been recorded and/or evaluated in and around a project site. A Phase I pedestrian survey shall be undertaken at a project site that is on previously undeveloped land in order to locate any surface cultural materials. By performing a records search, consultation with the NAHC, and a Phase I survey, a

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Packet Pg. 679 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 19 qualified archaeologist shall be able to classify a project site as having high, medium, or low sensitivity for archaeological resources.
 If the Phase I archaeological survey identifies resources that may be affected by a project, the archaeological resources assessment shall also include Phase II testing and evaluation. If resources are determined significant or unique through Phase II testing and site avoidance is not possible, appropriate site-specific mitigation measures shall be identified in the Phase II evaluation. These measures shall include, but would not be limited to, a Phase III data recovery program, avoidance, or other appropriate actions to be determined by a qualified archaeologist in consultation with the City and any interested Tribes, as stated in the 2040 General Plan Tribal Consultation Implementation Program outlined by Guiding Policy ENV-5. If significant archaeological resources cannot be avoided, impacts may be reduced to less-than-significant levels by adding fill soils on top of the sites rather than cutting into cultural deposits.

Alternatively, and/or in addition, a data collection program may be warranted, including mapping the location of artifacts, surface collection of artifacts, or excavation of the cultural deposit to characterize the nature of the buried portions of sites. Curation of the excavated artifacts or samples shall occur as specified by the archaeologist in consultation with the City and any interested Tribes. As stated in the 2040 General Plan Tribal Consultation Implementation Program outlined by Guiding Policy ENV-5 and Guiding Policy 8.7-G-1, the final disposition of artifacts not directly associated with Native American graves shall be negotiated during consultation with interested tribes. If Native American tribes do not accept the artifact, it shall be offered to an institution staffed by qualified professionals, as determined by the City Planner.

Artifacts include material recovered from all phases of work, including the initial survey, testing, indexing, data recovery, and monitoring.

MITIGATION MEASURE CR-3 STOP WORK IN THE EVENT OF UNANTICIPATED CULTURAL RESOURCES

DISCOVERIES DURING CONSTRUCTION
If cultural resources are encountered during ground-disturbing activities for a project, work in the immediate area shall be halted and an archaeologist meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology in either prehistoric or historic archaeology shall be contacted immediately to evaluate the find. If necessary, the evaluation may require preparation of a treatment plan and archaeological testing for CRHR eligibility. If the discovery proves to be significant under CEQA and cannot be avoided by a project, additional work such as excavating the cultural deposit to fully characterize its extent, and collecting and curating artifacts may be warranted to mitigate any significant impacts to cultural resources. In the event that archaeological resources of Native American origin are identified during project construction, a qualified archaeologist will consult with the City to begin Native American consultation procedures.

Finding
The City finds that with incorporation of Mitigation Measures CR-2 and CR-3, impacts to archeological resources would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental.

Impact CR-4
Development facilitated by the 2040 general plan has the potential to impact unidentified tribal cultural resources. Impacts would be less than significant with implementation of Mitigation Measure CR-4.

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Packet Pg. 680 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
20 MITIGATION MEASURE CR-4 SUSPEND WORK AROUND TRIBAL CULTURAL RESOURCES IDENTIFIED DURING CONSTRUCTION.

In the event that cultural resources of Native American origin are identified during construction of a project implemented under the 2040 General Plan, all earth-disturbing work in the vicinity 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 Americans, 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 mitigation 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. 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.

Finding
The City finds that with incorporation of Mitigation Measure CR-4, impacts to tribal cultural resources would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Geology/Soils and Mineral Resources
Impact GEO-6
Development facilitated by the 2040 General Plan has the potential to impact paleontological resources. Impacts would be less than significant with implementation of Mitigation Measure GEO1.

MITIGATION MEASURE GEO-1 PROTECT PALEONTOLOGICAL RESOURCES The City of San Ramon shall provide for the protection of paleontological resources. The City shall require the following:
 A Qualified Professional Paleontologist (as defined by SVP14) must be retained to conduct a paleontological resources analysis prior to the beginning of projects involving ground disturbance in geologic units with high paleontological sensitivity to determine whether there is a potential for significant impacts to paleontological resources.

If potential impacts to paleontological resources are found to be significant, then a Qualified Professional Paleontologist shall be retained to develop and implement a Paleontological Resources Mitigation Program to ensure that impacts to paleontological resources are less than significant.

Finding
The City finds that with incorporation of Mitigation Measure GEO-1, impacts to paleontological resources would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, 2040 General Plan that avoid or substantially lessen the significant environmental effect.

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Packet Pg. 681 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 21 Greenhouse Gas Emissions and Energy
Impact GHG-1
San Ramon does not have a Climate Action Plan that includes targets to meet State 2030 and 2045 goals. Therefore, implementation of the 2040 General Plan would not meet State 2030 and 2045 goals. Mitigation Measure GHG-1 would result in adoption of San Ramon CEQA greenhouse gas (GHG) thresholds and a Climate Action Plan. Impacts related to GHG emissions and conflict with greenhouse plans, policies, and regulations would be less than significant with implementation of Mitigation Measure GHG-1.

MITIGATION MEASURE GHG-1 ADOPT AND IMPLEMENT A SAN RAMON QUALIFIED CLIMATE ACTION

PLAN AND SAN RAMON CEQA GHG EMISSIONS THRESHOLDS
The City shall adopt an updated, qualified San Ramon Climate Action Plan (CAP) by the end of 2024 and include targets that reflect those set by California SB 32 to reduce GHG emissions by 40 percent below the 1990 levels by 2030 and California AB 1279 to achieve carbon neutrality by 2045. The updated, qualified San Ramon CAP shall be implemented and tracked/monitored by the City in accordance with the CAP-established timeline and details.

The City shall also adopt San Ramon CEQA GHG Emissions Thresholds of Significance that are consistent with an updated, qualified San Ramon Climate Action Plan by the end of 2024 for use in future CEQA GHG emissions analyses through 2030 and consistent with SB 32. In addition, upon completion of future climate action plan updates and as necessary, the City shall update the CEQA GHG emissions thresholds of significance to be consistent with each climate action plan update.

Finding
The City finds that with incorporation of Mitigation Measure GHG-1, impacts related to greenhouse gas emissions and conflicts with greenhouse plans, policies, and regulations would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Hazards/Hazardous Materials and Wildfire
Impact HAZ-5
San Ramon is not located within or near a Very High Fire Hazard Severity Zone or State Responsibility area; however, portions of San Ramon are located in and near a High Fire Hazard Severity Zone, a Local Responsibility area, and areas of vegetated open space. Mitigation and compliance with applicable codes and regulations would reduce the risk of loss, injury, or death from wildfire. Impacts would be less than significant with implementation of Mitigation Measure HAZ-5.

MITIGATION MEASURE HAZ-1 CONDUCT PROJECT LANDSCAPE AND SLOPE DESIGN WILDFIRE RISK

REDUCTION
The City shall require projects adjacent to High Fire Hazard Zones to conduct landscape and slope design wildfire risk reduction. Project landscape plans (as made available when project applications are submitted) shall include fire-resistant vegetation native to Contra Costa County and/or the local microclimate of the site and prohibit the use of fire-prone species especially non-native, invasive

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Packet Pg. 682 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
22 species. Also, if a project site is within a known landslide area (see Figure 3.5-5 in Section 3.5, Geology and Soils), the site shall be subject to geotechnical review regarding potential post-fire slope instability.

Finding
The City finds that with incorporation of Mitigation Measure HAZ-1, impacts related to wildfire would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Noise
Impact NOI-1
Construction of individual projects facilitated by the 2040 General Plan would temporarily increase noise levels, potentially affecting nearby noise-sensitive land uses. Development facilitated by the 2040 General Plan would also introduce new noise sources and contribute to increases in operational noise. The continued regulation of noise, consistent with the City Code, implementation of proposed 2040 General Plan policies, and identified mitigation would minimize disturbance to adjacent land uses. Impacts would be less than significant with implementation of Mitigation Measures NOI-1 and NOI-2.

MITIGATION MEASURE NOI-1 INCLUDE AND IMPLEMENT CONSTRUCTION NOISE REDUCTION

MEASURES
To minimize noise during construction, construction contractors shall implement the following measures for construction activities conducted within San Ramon. Construction plans submitted to the City shall include construction noise analysis and identify these measures on demolition, grading, and construction plans submitted to the City. The City of San Ramon Building Division and/or Public Works Department shall verify that grading, demolition, and/or construction plans submitted to the City include these notations prior to issuance of demolition, grading and/or building permits.
 Mufflers. During excavation and grading construction phases, all construction equipment, fixed or mobile, shall be operated with closed engine doors and shall be equipped with properly operating and maintained mufflers consistent with manufacturers’ standards.  Stationary Equipment. All stationary construction equipment shall be placed so that emitted noise is directed away from the nearest sensitive receivers.  Equipment Staging Areas. Equipment staging shall be located in areas that will create the greatest distance feasible between construction-related noise sources and noise-sensitive receivers.
 Smart Back-up Alarms. Mobile construction equipment shall have smart back-up alarms that automatically adjust the sound level of the alarm in response to ambient noise levels.

Alternatively, back-up alarms shall be disabled and replaced with human spotters to ensure safety when mobile construction equipment is moving in the reverse direction in compliance with applicable safety laws and regulations.
 Electrically-Powered Tools and Facilities. Electrical power shall be used to run air compressors and similar power tools and to power any temporary structures, such as construction trailers or caretaker facilities, where feasible.

9.1.f
Packet Pg. 683 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 23  Noise Disturbance Coordinator. The project applicant shall designate a “noise disturbance coordinator” responsible for responding to any local complaints about construction noise. The disturbance coordinator shall determine the cause of any noise complaint and shall require that reasonable measures be implemented to correct the problem. A telephone number for the disturbance coordinator and the City shall be posted at the construction site.  Temporary Noise Barriers. Erect temporary noise barriers, where feasible, when construction noise is predicted to exceed the acceptable standards (e.g., 80 dBA Leq at residential receivers, schools or other sensitive receptors during the daytime) and when the anticipated construction duration is greater than is typical (e.g., two years or greater). Temporary noise barriers shall be constructed with solid materials (e.g., wood) with a density of at least 1.5 pounds per square foot with no gaps from the ground to the top of the barrier. If a sound blanket is used, barriers shall be constructed with solid material with a density of at least 1 pound per square foot with no gaps from the ground to the top of the barrier and be lined on the construction side with acoustical blanket, curtain or equivalent absorptive material rated sound transmission class (STC) 32 or higher.

NOI-2 IMPLEMENT OPERATIONAL ROADWAY VEHICLE NOISE REDUCTION MEASURES To reduce operational roadway vehicle noise, the City shall implement a developer fair share mitigation program to fund the following measures for projects operated on the following roadway segments within San Ramon: Dougherty Road between Bollinger Canyon Road (north) and Bollinger Canyon Road (South), San Ramon Valley Boulevard between the northern City limit and Crow Canyon Road, Camino Ramon between Crow Canyon Road and Norris Canyon Road, and Camino Ramon between Norris Canyon Road and Bollinger Canyon Road. The City shall retain a qualified acoustical consultant to prepare a San Ramon-wide Roadway Vehicle Noise Reduction Study that specifies, at a minimum, the specific locations, extent, height of sound walls, and other design details such as “quiet pavement” to reduce roadway vehicle noise impacts at impacted roadways throughout San Ramon. The study shall also include an estimated cost of improvement along each impacted roadway segment to inform the developer fair share mitigation program. Roadway vehicle noise reduction measures may include, but are not limited to:

A. Sound Barrier Walls. The City shall construct sound barriers (e.g., walls or solid fences) along impacted roadways where there are no driveways that would break continuity, and along the residential portions or other sensitive receptor locations of such roadways. The sound walls would be continuous from grade to top, with no cracks or gaps, and have a minimum surface density of four pounds per square foot and a minimum height of six feet, as measured from the base elevation; and/or
B. Special Roadway Paving. The City shall install “quiet pavement” roadway improvements, such as rubberized asphalt or open-grade asphalt concrete overlays along impacted roadway segments (Dougherty Road between Bollinger Canyon Road (north) and Bollinger Canyon Road (South), San Ramon Valley Boulevard between the City limit and Crow Canyon Road, Camino Ramon between Crow Canyon Road and Norris Canyon Road, and Camino Ramon between Norris Canyon Road and Bollinger Canyon Road) where sound barriers (NOI-2A) are determined not to be feasible.

Finding
The City finds that with incorporation of Mitigation Measures NOI-1 and NOI-2, noise impacts would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

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Packet Pg. 684 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
24 Impact NOI-2
Construction of individual projects facilitated by the 2040 General Plan would temporarily generate groundborne vibration and noise, potentially affecting nearby land uses. Operation of development facilitated by the 2040 General Plan would not result in substantial groundborne vibration and noise. This impact would be less than significant with implementation of Mitigation Measure NOI-3.

MITIGATION MEASURE NOI-3 PREPARE A NOISE AND VIBRATION ANALYSIS AND IMPLEMENT

CONSTRUCTION VIBRATION CONTROL MEASURES AND SCREENING DISTANCES Prior to issuance of a building permit for a project requiring a) pile driving during construction within 135 feet of fragile structures such as historical resources, 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no plaster); b) a vibratory roller within 40 feet of fragile historical resources or 25 feet of any other structure; and/or c) a dozer or other large earthmoving equipment within 20 feet for a fragile historical structure or 15 feet of any other structure, the project applicant shall prepare a groundborne noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these construction activities. This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed FTA architectural damage thresholds (e.g., 0.12 in/sec PPV for fragile or historical resources,

0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower horsepower earthmoving equipment shall be used. If necessary, construction vibration monitoring shall be conducted to ensure FTA vibration thresholds are not exceeded.

Finding
The City finds that with incorporation of Mitigation Measure NOI-3, construction impacts related to vibration would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Transportation and Traffic
Impact TRA-1
Implementation of the 2040 General Plan could conflict with a program, plan, ordinance, or policy addressing the circulation system, including roadway, transit, bicycle, and pedestrian facilities during construction. However, operational impacts would not conflict with policies addressing the circulation system. Impacts would be less than significant with implementation of Mitigation Measure TRA-1.

MITIGATION MEASURE TRA-1 PREPARE AND IMPLEMENT CONSTRUCTION TRAFFIC MANAGEMENT PLANS
Prior to issuance of building permits, the contractor for an individual development project that requires off-site staging, lane closures, or substantial hauling of cut and fill on a local street (i.e., not under Caltrans’ jurisdiction) shall prepare a Construction Traffic Management Plan that includes measures such as, but not limited to, the following as deemed necessary by the City. The approved Construction Traffic Management Plan shall be implemented during construction.

9.1.f
Packet Pg. 685 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Less Than Significant Level After Implementation of Mitigation Measures Findings of Fact/Statement of Overriding Considerations 25  Provide a temporary traffic signal, if necessary
 Project Staging Plan to maximize on-site storage of materials and equipment  A set of comprehensive traffic control measures, including scheduling of major truck trips and deliveries to avoid peak-hours; lane closure proceedings; signs, cones, and other warning devices for drivers; and designation of construction access routes  Permitted construction hours
 Location of construction staging
 Identification of parking areas for construction employees, site visitors, and inspectors, including on-site locations
 Provisions for street sweeping to remove construction related debris on public streets Finding
The City finds that with incorporation of Mitigation Measure TRA-1, construction impacts related to conflicts with a program, plan, ordinance, or policy addressing the circulation system, including roadway, transit, bicycle, and pedestrian facilities would be less than significant. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

Utilities and Service Systems
Impact UTL-1
Development under the 2040 General Plan would increase demand for water, wastewater, stormwater, and telecommunications services. Utility facilities and infrastructure development and relocation facilitated by the 2040 General Plan would occur in developed areas of San Ramon where such facilities exist, impacts would be less than significant with implementation of Mitigation Measures AQ-1, AQ-2, AQ-3, BIO-1, BIO-2, CR-1, CR-2, CR-2, CR-3, CR-4, GEO-1, GHG-1, HAZ-1, NOI1, NOI-2, NOI-3, TRA-1 (included above), and TRA-2 (included in Section 5) and Mitigation Measures UTL-1 and UTL-2 (included below).

MITIGATION MEASURE UTL-1 PROVIDE ADEQUATE WATER SUPPLY AND TREATMENT FOR PROJECTS To ensure adequate water supply, as well as consistency with existing utility providers and State regulations, the City shall implement the following measures:
 Infrastructure Maintenance. Collaborate with water providers in their efforts to maintain wastewater conveyance, treatment, and disposal infrastructure in good working conditions within San Ramon.
 Water Services Requirement. Require that water services for new developments do not negatively affect service to existing uses.
 Water Provider Coordination. Coordinate with water providers to ensure that new proposed development can be adequately served by the water supply system prior to approving the development.
 Commercial and Business Water Conservation. Require new or remodeled commercial and industrial development to make changes that conserve water, to the extent feasible. This could include utilizing efficient plumbing fixtures, installing drought-tolerant and water-wise landscaping, and harvesting rainwater for irrigation.
 Water Conservation Measures. Reduce the amount of water used by development by requiring compliance with adopted water conservation measures.

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Packet Pg. 686 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
26 MITIGATION MEASURE UTL-2 PROVIDE ADEQUATE WASTEWATER INFRASTRUCTURE AND TREATMENT FOR

PROJECTS
To ensure adequate wastewater infrastructure and treatment, as well as consistency with existing utility providers and State regulations, the City shall implement the following measures:
 Infrastructure Maintenance. Infrastructure Maintenance. Collaborate with Central San and Dublin San Ramon Services District in their efforts to maintain wastewater conveyance, treatment, and disposal infrastructure in good working conditions within San Ramon.  New Development. Coordinate the review of development proposals with Central San to ensure that new development can be adequately served.
 Wastewater Services Requirement. Require that wastewater services for new development do not negatively affect service to existing uses.
 Capital Improvements Program. When updating the Capital Improvements Program, identify and include the following:
 Projects that could also support green infrastructure improvements.  Street improvements consistent with emergency vehicle access standards.  City-sponsored projects necessary to maintain or improve levels of performance.

Finding
The City finds that with incorporation of Mitigation Measures AQ-1, AQ-2, AQ-3, BIO-1, BIO-2, CR-1, CR-2, CR-2, CR-3, CR-4, GEO-1, GHG-1, HAZ-1, NOI-1, NOI-2, NOI-3, TRA-1, TRA-2 UTIL-1, and UTIL-2, impacts related to potential need for new or expanded utility infrastructure and facilities would be reduced to a less than significant level. Pursuant to CEQA Guidelines Section 15091 (a)(1), changes or alterations have been required in, or incorporated into, the 2040 General Plan that avoid or substantially lessen the significant environmental effect.

9.1.f
Packet Pg. 687 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Significant and Unavoidable
Findings of Fact/Statement of Overriding Considerations 27 5 Impacts Determined to be Significant
and Unavoidable
This topical area contains impacts of the 2040 General Plan that would remain significant and unavoidable after implementation of mitigation measures. Pursuant to California Public Resources Code Section 21081(a)(1) and CEQA Section 15091(a)(1), as to each impact, the City, based on the evidence in the record before it, finds that changes or alterations incorporated into the 2040 General Plan mitigate, avoid, or substantially lessen to a level of insignificance these environmental impacts of the Project; however, a significant unavoidable impact would remain even after implementation of mitigation. Avoidance of the impact altogether is infeasible taking into account economic, legal, social, technological and/or other considerations, including considerations for the provision of employment for highly trained workers (California Public Resources Code Section 21081(a)(3) and CEQA Section 15091(a)(3).

Transportation
Impact TRA-2
Development facilitated by the 2040 General Plan would result in marginal reductions in vehicle miles traveled (VMT) per capita and VMT per employee compared to existing conditions, but VMT per employee would still exceed the significance threshold of 15 percent below the existing baseline. Implementing the 2040 General Plan policies would reduce VMT through promoting accessibility, encouraging non-vehicle transportation modes, and improving access to transit services. Even with the 2040 General Plan policies to reduce VMT, it is possible that VMT per employee would still remain above the significance threshold.

Available project characteristics modification and Transportation Demand Management Program (TDM) measures are included in Mitigation Measure TRA-2. Contra Costa Transportation Authority (CCTA) also includes participation in a CCTA-approved VMT impact fee program and/or VMT mitigation exchange/banking program, but CCTA is still developing such a program. City of San Ramon requirement to participate in this program is included in Mitigation Measure TRA-2.

However, due to unknown future conditions at the time of future projects facilitated by the 2040 General Plan and the uncertainty of the effectiveness of VMT reduction measures included in Mitigation Measure TRA-2 to guarantee a reduction of VMT below thresholds, operational VMT impacts of the 2040 General Plan would remain significant and unavoidable even with mitigation.

Therefore, Implementation of the 2040 General Plan would conflict with or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b). Impacts would be significant and unavoidable even with mitigation. No additional feasible mitigation measures were identified that would reduce the impact’s level of significance.

Mitigation Measures
MITIGATION MEASURE TRA-2 PREPARE AND IMPLEMENT VMT REDUCTION MEASURES The Contra Costa Transportation Authority’s (CCTA’s) VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022)

9.1.f
Packet Pg. 688 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
28 describes options for mitigation of VMT impacts. The first two options below apply to development projects and plans, and the third applies at a General Plan area-wide scale.

1. A project applicant shall modify a project’s characteristics to reduce VMT generated by such project prior to issuance of an occupancy permit. This might involve changing the density or mixture of land uses on a project site, or changing a project’s location to one that is more accessible by transit or other travel modes.

2. A project applicant shall implement transportation demand management (TDM) or physical design measures to reduce VMT generated by a project prior to issuance of an occupancy permit.

3. The City shall participate in a CCTA-approved VMT impact fee program and/or VMT mitigation exchange/banking program, once it is completed and published by CCTA. (Note that CCTA is developing such a program for Contra Costa County.)
When option 2 (TDM plan) is applied for future land use development projects facilitated by the 2040 General Plan that do not meet CCTA screening criteria and thresholds, the City shall require preparation and implementation of a project-level TDM plan with the following TDM measures.

TDM Measures
CAPCOA Handbook Measure Types of Projects Core Elements T-7: Commute Trip Reduction Marketing Employment-based *Thoughtful marketing strategy *Readily available commute information
*Designated TDM Coordinator
*Guaranteed Ride Home
T-8: Provide Ridesharing Program Employment-based *Participation in a TMA with ride-matching program *Preferential parking policies for carpools
*Promotions and incentives such as gas cards at
carpool formation
T-9: Implement Subsidized or Discounted
Transit Program
Residential, School,
Employment-based
*Location within 1/2 mile of major transit stop or
high-quality transit corridor
*Participation in Commuter Benefits Program
*Easy to sign up for incentives
T-11: Provide Employer Sponsored
Vanpool / Point-to-Point Shuttles
Employment-based *Coordinate logistics of vanpool program *Cover vanpool fares for riders through commute
benefits program
*Promote and facilitate vanpool creation
T-12: Price Workplace Parking Employment-based *Location within 1/2 mile of transit service *Priced at least $5 per day
*On-street parking nearby is not readily available
T-13: Implement Employee Parking
Cashout
Employment-based *Parking is provided as benefit
*On-street parking nearby is not readily available
*Participants pledge to not drive to work
T-16: Unbundle Residential Parking Costs Residential *On-street parking nearby is not readily available *All parking is priced at a rate at least $30
per month

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Packet Pg. 689 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Impacts Determined to be Significant and Unavoidable
Findings of Fact/Statement of Overriding Considerations 29 CAPCOA Handbook Measure Types of Projects Core Elements T-23: Community-Based Travel Planning Residential, Retail, School
*Proactive outreach to all households in service
area or project
*Program Coordinator designated as lead in
promoting non-auto transportation
T-10: Provide End-of-Trip Bicycle
Facilities
All Projects *Provision of secure bicycle parking in the form of lockers, a locked storage room, or an attended
storage facility
*(For non-residential): Provision of lockers, showers,
and changing rooms
T-21A: Implement Carshare Program /
Provide Carshare Parking
All Projects *Dedicate parking for carshare vehicles
*Identify carshare partner
T-15 Reduce Parking Supply Residential *On-street parking nearby is not readily available T-18: Provide Pedestrian Network
Improvements:

All Projects Completion of one or more projects identified in the San Ramon Bicycle Master Plan
T-19-A and T-19-B: Construct or Improve
Bicycle Facility/Bicycle Boulevard
All Projects
T-20: Expand Bikeway Network All Projects
T-26 Increase Transit Frequency All Projects in PDAs Increase the frequency of transit service by providing funding for more operators and vehicles
T-25 Increase Transit Coverage All Projects Expand transit service to areas without access to it, or expand to later/earlier hours.

T-23: Community-Based Travel Planning Residential, Retail, School
*Proactive outreach to all households in service
area or project
*Program Coordinator designated as lead in
promoting non-auto transportation
T-22: Bikeshare/Scootershare All Projects in PDAs Fund and implement program providing e-bikes or scooters available on demand. Ideally pursue a
"dockless" system.

Free E-Bike Program All Projects Provide e-bikes free of charge to households pledging to reduce vehicle trips
Source: Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Change Vulnerabilities, and Advancing Health and Equity (CAPCOA, December 2021).

Feasible options listed in the table above to reduce VMT below CCTA thresholds shall be implemented for individual projects facilitated by the 2040 General Plan. VMT reduction measures shall be included at project design review and be reviewed and approved by the City prior to issuance of construction permits.

Finding
The City finds that development facilitated by the 2040 General Plan would result in operational VMT that would exceed significance thresholds. Mitigation Measure TRA-2 has been adopted to reduce potential impacts related to operational VMT; however, impacts would remain significant and unavoidable. As such, changes or alterations have been required in, or incorporated into, the project that substantially lessen the significant environmental effect related to operational VMT, but a significant unavoidable impact remains even after mitigation. Avoidance of the impact altogether is infeasible taking into account economic, legal, social, technological and/or other considerations, including considerations for the provision of employment for highly trained workers.

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Packet Pg. 690 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
30 Cumulative Impacts
With the exception of the unavoidable impacts to transportation (operational VMT), the 2040 General Plan would have no impact, a less than significant impact, or a less than significant impact after mitigation with respect to all environmental issues. With the exception of transportation (operational VMT), cumulative impacts would be less than significant.

For analyzing cumulative VMT impacts, the Office of Planning and Research (OPR) provides the following guidance regarding cumulative impacts analysis and VMT:

When using an absolute VMT metric, i.e., total VMT (as recommended below for retail and transportation projects), analyzing the combined impacts for a cumulative impacts analysis may be appropriate. However, metrics such as VMT per capita or VMT per employee, i.e., metrics framed in terms of efficiency (as recommended below for use on residential and office projects), cannot be summed because they employ a denominator. A project that falls below an efficiency-based threshold that is aligned with long-term environmental goals and relevant plans would have no cumulative impact distinct from the project impact. Accordingly, a finding of a less-than-significant project impact would imply a less than significant cumulative impact, and vice versa.

The year 2040 total Countywide VMT per service population (all residents and employees) was considered in the cumulative analysis. The total Countywide VMT per service population reflects VMT generated by all trips by all land uses in Contra Costa County, as well as non-County generated trips traveling on County roadways (i.e., all VMT within the Contra Costa County boundary).

Countywide boundary VMT per service population would decrease with the 2040 General Plan, reflecting the travel efficiency that generally results from more dense, mixed-use development provided with the 2040 General Plan. While VMT per service population would decrease Countywide, based on OPR’s guidance included above, cumulative impacts would be commensurate with the project-level VMT impacts of the 2040 General Plan. Because the analysis for the proposed 2040 General Plan is based on Home-Based VMT and Home-Work VMT, the significant VMT impact finding implies that the 2040 General Plan would also have a cumulatively considerable contribution to a significant cumulative impact even after implementation of Mitigation Measure TRA-2. Since project-level significance thresholds were designed to support long-term environmental goals, they inherently also address potential cumulative VMT impacts. As such, VMT would be cumulatively considerable. Therefore, the cumulative impact related to VMT would be significant and unavoidable.

Finding
The City finds that development facilitated by the 2040 General Plan would result in cumulative VMT that would exceed significance thresholds. Mitigation Measure TRA-2 has been adopted to reduce potential impacts related to cumulative VMT; however, impacts would remain significant and unavoidable. As such, changes or alterations have been required in, or incorporated into, the project that substantially lessen the significant environmental effect related to cumulative VMT, but a significant unavoidable impact remains even after mitigation. Avoidance of the impact altogether is infeasible taking into account economic, legal, social, technological and/or other considerations, including considerations for the provision of employment for highly trained workers.

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Packet Pg. 691 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Feasibility of Project Alternatives
Findings of Fact/Statement of Overriding Considerations 31 6 Feasibility of Project Alternatives
CEQA requires that an EIR include an analysis of a reasonable range of feasible alternatives to a project capable of avoiding or substantially lessening any significant adverse environmental impact associated with the Project. Public Resources Code § 21002. With the exception of the “no project” alternative, the specific alternatives or types of alternatives that must be assessed are not specified.

CEQA “establishes no categorical legal imperative as to the scope of alternatives to be analyzed in an EIR. Each case must be evaluated on its own facts, which in turn must be reviewed in light of the statutory purpose.” Citizens of Goleta Valley v. Board of Supervisors, 52 Cal.3d. 553, 556 (1990). The legislative purpose of CEQA is to protect public health, welfare and the environment from significant impacts associated with all types of development, by ensuring that agencies regulate activities so that major consideration is given to preventing environmental damage while providing a decent home and satisfying living environment for every Californian. Public Res. Code § 21000. In short, the objective of CEQA is to avoid or mitigate environmental damage associated with development. This objective has been largely accomplished in the 2040 General Plan through the inclusion of modifications and mitigation measures that reduce the potentially significant impacts to an acceptable level.

The CEQA Guidelines state that the “range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic purposes of the project and could avoid or substantially lessen one of more of the significant effects.” CEQA Guidelines § 15126(d)(2).

Thus, an evaluation of the 2040 General Plan objectives is key to determining which alternatives should be assessed in the EIR.

The discussion of alternatives is required to include the “No Project” alternative. CEQA requires further that the City identify an environmentally superior alternative. If the “No Project” alternative is the environmentally superior alternative, an environmentally superior alternative must be identified from among the other alternatives (CEQA Guidelines, Section 15126.6). However, “CEQA did not require the City to choose the environmentally superior alternative. It simply required the City to consider environmentally superior alternatives, explain the considerations that led it to conclude that those alternatives were infeasible, weigh those considerations against the environmental harm that the Plan would cause, and make findings that the benefits of those considerations outweighed the harm.” (California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 1005–1006).

Whether to reject or approve any of the alternatives is a decision only for the decisionmakers. “They may reject alternatives that are undesirable from a policy standpoint as well as alternatives that fail to meet project objectives.” (Ocean Street Extension Neighborhood Assn. v. City of Santa Cruz (2021) 73 Cal.App.5th 985, 1016 (citations omitted).) “While it is up to the EIR preparer to identify alternatives as potentially feasible, the decision-making body “may or may not reject those alternatives as being infeasible” when it comes to project approval. Rejection by the decisionmakers does not undermine the validity of the EIR's alternatives analysis.” (California Native Plant Society v. City of Santa Cruz (2009) 177 Cal.App.4th 957, 999 [99 Cal.Rptr.3d 572, 602 (citations omitted).)

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Packet Pg. 692 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
32 6.1 Alternatives
The general goal of the proposed plan is to update the City of San Ramon General Plan, including eleven respective General Plan elements, amendment to the San Ramon Village Specific Plan, repeal of the North Camino Ramon Specific Plan, and the San Ramon Zoning Ordinance update (collectively referred to in this EIR as the 2040 General Plan).

Five specific project objectives are discussed at page 2-6 of the DEIR, and are incorporated herein by reference. The CEQA Guidelines state that the “range of potential alternatives to the proposed project shall include those that could feasibly accomplish most of the basic purposes of the project and could avoid or substantially lessen one or more of the significant effects.” Based on the project objectives and anticipated environmental consequences, and pursuant to CEQA Guidelines Section 15126.6(f), the following alternatives were selected for analysis in the Draft EIR:
 Alternative 1: Adopted General Plan Buildout (“No Project”): The Adopted General Plan Buildout Alternative (or Alternative 1) assumes that the current land use and zoning designations would not change from the City’s existing, adopted (2035) General Plan. The 2040 General Plan would not be adopted. Current land uses for residential units and non-residential areas would remain unchanged under Alternative 1. Future buildout would continue to follow the current designations, resulting in a net change between 2022 and 2040 of 5,392 residential units and 4,900,000 gsf of non-residential land uses. For purposes of the environmental analysis, it was assumed that the San Ramon population net change estimate from 2022 to 2040 would be 13,033, which represents a relative population decrease of 13,236 compared to the proposed 2040 General Plan. Alternative 1 would not update the San Ramon General Plan.

Without the 2040 General Plan, San Ramon would lack a long-term blueprint for development throughout the General Plan area and not meet 2023-2031 RHNA requirements.

Alternative 2: New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative: The New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative (or Alternative 2) would adopt the 2040 General Plan but instead re-designate an approximately 130-acre portion of the Bishop Ranch Business Park from “Office” to “Downtown Mixed Use – South.” The purpose of the Downtown Mixed‐Use, South (DMU‐S) zone is to encourage an integrated transit-oriented and mixed use neighborhood, extending the activity of City Center across Bollinger Canyon Road with shops, offices, and a diversity of housing opportunities set in an urban environment of walkable streets, parks and trails. The intent is to promote a broad mix of uses which incorporates a transition of primarily commercial uses adjacent to the freeway and Bollinger Canyon Road, with residential uses located behind or above the primary commercial uses in close proximity to transportation networks. The allowed density in the DMU-S zone ranges from a minimum of 20 dwelling units per acre to a maximum of 60 dwelling units per acre. Development is generally intended to be more vertical in nature and allowance for higher density closer to the arterial roadway, with an appropriate transitional buffer adjacent to existing residential uses located to the south. Commercial uses (i.e., restaurants and retail) are encouraged along major streets. Development could be stand-alone, vertical, or horizontal mixed-use configurations. DMU-S would be a transit-oriented and mixed-use neighborhood extending the activity of City Center across Bollinger Canyon Road with commercial businesses and diverse housing opportunities. 41.4-acres within four existing Mixed Use shopping centers would be re-designated to “Retail Shopping,” and consists of twenty-two (22) parcels. This

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Packet Pg. 693 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Feasibility of Project Alternatives
Findings of Fact/Statement of Overriding Considerations 33 would promote infill development within the large parcels of the Bishop Ranch Business Park, which supports higher density, mixed use development, while also retaining retail shopping opportunities in the City.
 Alternative 3: New Infill Mixed Use within the City Core Alternative: The New Infill Mixed Use within the City Core Alternative (or Alternative 3) would adopt the 2040 General Plan, but instead re-designate approximately 130-acre portion of the Bishop Ranch Business park from “Office” to “Downtown Mixed Use – South.” The purpose of the Downtown Mixed‐Use, South (DMU‐S) zone is to encourage an integrated transit-oriented and mixed use neighborhood, extending the activity of City Center across Bollinger Canyon Road with shops, offices, and a diversity of housing opportunities set in an urban environment of walkable streets, parks and trails. The intent is to promote a broad mix of uses which incorporates a transition of primarily commercial uses adjacent to the freeway and Bollinger Canyon Road, with residential uses located behind or above the primary commercial uses in close proximity to transportation networks. The allowed density in the DMU-S zone ranges from a minimum of 20 dwelling units per acre to a maximum of 60 dwelling units per acre. Development is generally intended to be more vertical in nature and allowance for higher density closer to the arterial roadway, with an appropriate transitional buffer adjacent to existing residential uses located to the south.

Commercial uses (i.e., restaurants and retail) are encouraged along major streets. Development could be stand-alone, vertical, or horizontal mixed-use configurations. DMU-S would be a transit-oriented and mixed-use neighborhood extending the activity of City Center across Bollinger Canyon Road with commercial businesses and diverse housing opportunities. DMU-S would be a transit-oriented and mixed-use neighborhood extending the activity of City Center across Bollinger Canyon Road with commercial businesses and diverse housing opportunities.

This would promote infill intensification of the City core within the large parcels that comprise the Bishop Ranch Business Park and focus solely on mixed-use buildout in the area. These parcels are located within a regional employment center, near the City Center Project, and public transit and are, thus, positioned to support higher density, mixed use development.

Refer to Chapter 5, Alternatives, of the Draft EIR for the complete alternatives analysis. The findings, and support for the findings, for the three alternatives, are detailed below.

6.2 Alternative 1: Adopted General Plan Buildout (i.e., “No Project”)
The Adopted General Plan Buildout Alternative (or Alternative 1) assumes that the current land use and zoning designations would not change from the City’s existing, adopted (2035) General Plan.

Current land uses for residential units and non-residential areas would remain unchanged under Alternative 1. Future buildout would continue to follow the current designations from the Adopted General Plan. Compared to the 2040 General Plan, Alternative 1 would result in development of fewer residential units and increased non-residential development, consistent with allowed existing zoning.

Under Alternative 1, VMT per resident in San Ramon would be higher than the Countywide average VMT per resident. Furthermore, changes in VMT per resident and per employee would follow current zoning development standards, which current do not include plans to implement a TDM plan to reduce VMT generated by an individual project. Alternative 1 would have a greater impact related to transportation compared to the 2040 General Plan due to the current lack of plans

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Packet Pg. 694 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
34 towards reducing any future individual project VMT increases. Alternative 1 also would not meet the 2040 General Plan goal to align with the vision smart mandated growth without transportationrelated impacts (specifically VMT) being accounted for or managed. Alternative 1 would not avoid the significant and unavoidable impact related to transportation (operational-related VMT).

In addition, Alternative 1 would result in additional significant and unavoidable impacts related to greenhouse gas emissions and energy, wildfire risk, and land use planning and population growth compared to the 2040 General Plan. Impacts related to aesthetics, air quality, biological resources, cultural resources, and geology/soils, would be greater but remain at a similar significance level as the 2040 General Plan. Impacts related to public services and utilities would also be lesser but remain at a similar significance level as the 2040 General Plan. Impacts related to hydrology/water quality and noise would have a similar significance and impact level as the 2040 General Plan.

Alternative 1 would not meet the plan’s objectives, as it would not increase the residential and community opportunities or facilitate identified needed development in the proposed General Plan area, thus not meeting the current RHNA. Alternative 1 would not allow City departments, other public agencies, and private developers to design projects that will enhance the character of the community, preserve and enhance critical environmental resources, and minimize hazards. It would also not incorporate any of the mitigation or preventative measures that the 2040 General Plan would incorporate.

Finding
Alternative 1 would result in greater VMT impacts and would not avoid the significant and unavoidable VMT impact. Alternative 1 would result in additional significant and unavoidable impacts related to greenhouse gas emissions and energy, wildfire risk, and land use planning and population growth. Alternative 1 would result in greater impacts related to aesthetics, air quality, biological resources, cultural resources, and geology/soils. Furthermore, Alternative 1 would not achieve any of the plan’s objectives.

The City rejects Alternative 1 as infeasible because it would not achieve the objectives of the 2040 General Plan, would not avoid the significant and unavoidable VMT impact, and would result in greater impacts and more significant unavoidable impacts than the 2040 General Plan. The City makes this determination after taking into account economic, legal, social, technological and/or other considerations, including the provision of employment opportunities for highly trained workers.

6.3 Alternative 2: New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative
The New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative (or Alternative 2) would adopt the 2040 General Plan but instead re-designate an approximately 130- acre portion of the Bishop Ranch Business Park from “Office” to “Downtown Mixed Use – South.” The purpose of the Downtown Mixed‐Use, South (DMU‐S) zone is to encourage an integrated transit-oriented and mixed use neighborhood, extending the activity of City Center across Bollinger Canyon Road with shops, offices, and a diversity of housing opportunities set in an urban environment of walkable streets, parks and trails. In addition, 41.4-acres within four existing Mixed Use shopping centers would be re-designated to “Retail Shopping,” and consists of twenty-two (22) parcels.

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Packet Pg. 695 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Feasibility of Project Alternatives
Findings of Fact/Statement of Overriding Considerations 35 The re-designated 41.1-acres of Retail Shopping would remove the residential option on these parcels, reducing overall housing unit capacity by 1,243 units. Residential unit yield would be reduced in Crow Canyon Commons shopping center by 654 units, Marketplace shopping center by 266 units, Country Club shopping center by 203 units, and Magnolia Square shopping center by 120 units. However, an existing 1.3 million square feet of office space would be removed from the DMUS to instead incorporate 125,000 square feet (2.9 acres) of new commercial uses and a residential buildout capacity of 2,900 units with approximately 80 percent as multi-family unit, resulting in an overall decrease in non-residential GSF and no net loss of residential capacity. The DMU-S area will allow a density range of 20 to 60 dwelling units per acre with at least 35 percent of the gross site area dedicated to circulation and open space. In addition, these parcels are located within a regional employment center, near the City Center Project, and public transit. Future buildout under Alternative 2 would result in a net change between 2022 and 2040 of 11,812 more residential units and 827,000 less gsf of non-residential land uses. For purposes of the environmental analysis, it was assumed that the San Ramon population net change estimate from 2022 to 2040 would be 30,874, which represents a relative population increase of 4,605 compared to the 2040 General Plan.

Under Alternative 2, a greater amount of residential units and lesser amount of non-residential development would occur compared to the 2040 General Plan. Development under Alternative 2 would be similar to the 2040 General plan buildout, but with 130 acres of the Bishop Ranch Business Park would be re-designated from “Office” to “Downtown Mixed Use – South” (DMU-S). 41.1 acres of existing “Mixed Use” throughout the City would be re-designated to “Retail Shopping” and would consist of retail shopping buildout. Alternative 2 buildout would result in VMT per capita and VMT per employee that would still exceed the impact threshold. Moreover, additional residential units and commercial development would be added to the Bishop Ranch Business Park, which would support higher density, mixed use development. The proximity of residential units to potential job opportunities would potentially lower VMT. However, even with implementation of mitigation to reduce VMT, it is possible that VMT per employee would remain above applicable thresholds.

Therefore, Alternative 2 transportation impacts would be similar but less compared to the 2040 General Plan, but VMT impacts would remain significant and unavoidable.

In addition, compared to the 2040 General Plan, Alternative 2 would have a similar impact level with lesser significance related to cultural resources. However, transportation impacts would remain at a significant and unavoidable impact level. In addition, land use and population impacts would be at an increased significance level, but impacts would still be less than significant. Furthermore, this alternative would also result in a similar impact level with greater significance related to noise, public services, and utilities. Aesthetics, air quality, biological resources, geological resources, wildfire risk, and hydrology/water quality impacts under Alternative 2 would have a significance level similar to the 2040 General Plan. However, this alternative would advance the plan objectives related to smart growth, promoting the City of San Ramon’s vision to reflect the aspirations of the community, and protecting resources.

Finding
As detailed below in Section 6.5, Environmentally Superior Alternative, Alternative 2 is the environmentally superior alternative. Alternative would generally result in overall similar environmental impacts compared to the 2040 General Plan; however, development would be more centralized and result in lesser impacts related to cultural resources, wildfire risk, and transportation. However, VMT impacts would remain significant and unavoidable. Alternative 2 would result in greater impacts related to land use, noise, public services/recreation, and utilities

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Packet Pg. 696 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
36 compared to the 2040 General Plan. Overall, this alternative would advance the plan objectives to outline a vision for San Ramon’s long-range physical and economic development and resource conservation that reflects the aspirations of the community and the smart growth mandate.

The City finds that Alternative 2 is a feasible alternative, and it would result in lesser environmental impacts related to cultural resources, wildfire exposure risk, and transportation and would achieve the plan objectives. In addition, Alternative 2 more effectively addresses some of the nonenvironmental concerns raised by residents related to the low retail vacancy rates and better protects retail development within the City to support existing and expected population growth.

The City makes this determination after taking into account economic, legal, social, technological and/or other considerations, including the provision of employment opportunities for highly trained workers.

6.4 Alternative 3: New Infill Mixed Use within the City Core Alternative
The New Infill Mixed Use within the City Core Alternative (or Alternative 3) would adopt the 2040 General Plan, but instead re-designate approximately 130-acre portion of the Bishop Ranch Business park from “Office” to “Downtown Mixed Use – South.” The existing 1.3 million square feet of office would be replaced with 125,000 square feet of new commercial uses and a residential buildout capacity of 2,900 with approximately 80 percent as multi-family unit. The 130-acre DMU-S area would allow a density range of 20 to 60 dwelling units per acre with at least 35 percent of the gross site area dedicated to circulation and open space. Future buildout would result in a net change between 2022 and 2040 of 13,055 more residential units and 827,000 less gsf of non-residential land uses. For purposes of the environmental analysis, it is assumed that the San Ramon population net change estimate from 2022 to 2040 would be 34,328, which represents a relative population increase of 8,059 compared to the 2040 General Plan.

As stated above, under Alternative 3, a greater amount of residential units and lesser amount of non-residential development would occur compared to the 2040 General Plan. As such, Alternative 3 buildout would result in VMT per capita and per employee that would still exceed thresholds.

Moreover, additional residential units and commercial development would be added to the Bishop Ranch Business Park, which supports higher density, mixed use development. The proximity of residential units to potential job opportunities would potentially lower VMT. However, even with implementation of mitigation to reduce VMT, it is possible that VMT per employee would remain above applicable thresholds. Therefore, while Alternative 3 would have a lesser impact related to transportation (operational-related VMT) impacts, it would not avoid the significant and unavoidable significance level.

In addition, impacts related to wildfire, noise, public services, and utilities would have a greater impact level than the 2040 General Plan, but remain at the same significance levels. However, land use and population impacts would be increased to less than significant with mitigation incorporated.

Furthermore, impacts related to aesthetics, air quality, biological resources, cultural resources, geological resources, greenhouse gas emissions, and hydrological resources would be similar to the 2040 General Plan.

This alternative would satisfy the plan objective to promote the vision of the City of San Ramon’s goal to reflect the aspirations of the community and protect resources. However, this alternative would struggle to support the plan objective that would assist in establishing a basis for judging

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Packet Pg. 697 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Feasibility of Project Alternatives
Findings of Fact/Statement of Overriding Considerations 37 whether specific development and projects would be in harmony with General Plan policies and standards, as the increase in residential development impacts would require further planning and further mitigation measures and policies not anticipated by the 2040 General Plan.

Finding
Alternative 3 would generally result in overall similar environmental impacts compared to the 2040 General Plan; however, Alternative 3 would result in lesser impacts related to transportation; however VMT impacts would remain significant and unavoidable. Due to the increase in residential development and thus availability, Alternative 3 would result in greater impacts related to wildfire risk, land use planning, noise, public services/recreation, and utilities. Alternative 3 would not fully meet the plan objectives because it would not fully assist in providing a basis for establishing and setting priorities for detailed plans and programs, as further mitigation measures and policies would be required.

The City rejects Alternative 3 as infeasible because it would not avoid the significant and unavoidable VMT impact and would not fully meet the plan objectives. The City makes this determination after taking into account economic, legal, social, technological and/or other considerations, including the provision of employment opportunities for highly trained workers.

6.5 Environmentally Superior Alternative
The CEQA Guidelines state an EIR shall identify an environmentally superior alternative. If the environmentally superior alternative is the No Project Alternative, the EIR shall also identify an environmentally superior alternative among the other alternatives (CEQA Guidelines Section 15126.6(e)(2)).

The New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative (Alternative 2) would result in reduced impacts compared to the New Infill Mixed Use within the City Core Alternative (Alternative 3). Alternative 3 would result in greater impacts related to wildfires and public services, although not to the extent of increasing the significance level, due to the 8,059 population increase under Alternative 3 compared to the 2040 General Plan versus the 4,605 population increase under Alternative 2 compared to the 2040 General Plan. Comparatively, while most Alternative 3 impacts are similar in significance to the 2040 General Plan, Alternative 3 would not meet some plan objectives. Alternative 2 would meet more plan objectives in comparison as well as result in a lesser impact related to cultural resources, although not to the extent of reducing the significance level. In addition, while some of the plan objectives would be met under Alternative 3, comparatively Alternative 2 would further advance plan objectives to outline a vision for San Ramon’s long-range physical and economic development and resource conservation that reflects the aspirations of the community and the smart growth mandate. In addition, Alternative 2 better supports the local concerns related to maintenance and enhancement of retail development within the City.

Overall, of the three alternatives evaluated, the New Infill Mixed Use within the City Core and Additional Retail Shopping Alternative (Alternative 2) would be the environmentally superior alternative. As detailed above, the City finds that Alternative is a feasible alternative that is also environmentally superior, because it would result in lesser environmental impacts related to cultural resources, wildfire exposure risk, and transportation and would achieve the plan objectives.

In conclusion, the City has determined that Alternative 2 is the preferred alternative for 2040 General Plan adoption consideration.

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2040 General Plan
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Findings of Fact/Statement of Overriding Considerations 39 7 Significant Irreversible Effects and Growth
Inducement

7.1 Significant Irreversible Effects
CEQA Guidelines Section 15126.2(d) requires a discussion of any significant irreversible environmental changes that would be caused by a project should it be implemented. Such significant irreversible environmental changes may include the following:
• Use of non-renewable resources during the initial and continued phases of the project that would be irreversible because a large commitment of such resources makes removal or nonuse unlikely • Primary impacts and, particularly secondary impacts (such as highway improvements that provide access to a previously inaccessible area) that generally commit future generations to similar uses
• Irreversible damage which may result from environmental accidents associated with the project
CEQA also requires decision-makers to balance the benefits of a project against its unavoidable environmental risks in determining whether to approve a project. This section addresses the use of non-renewable resources, the commitment of future generations to the proposed development and land use changes, and irreversible impacts associated with the development that would be facilitated by implementation of the 2040 General Plan.

Construction activity associated with planned development accommodated under the 2040 General Plan would include the use of building materials and energy, some of which would be nonrenewable resources. Consumption of these resources would occur with any development in the Bay Area region and would not be unique to San Ramon or the 2040 General Plan. The addition of new residential and non-residential development in San Ramon through 2040 would irreversibly increase local demand for non-renewable energy resources such as petroleum and natural gas.

Increasingly efficient building fixtures and automobile engines, as well as implementation of policies included in the 2040 General Plan, are expected to offset the demand for non-renewable energy to some degree. Growth resulting from implementation of the 2040 General Plan is not anticipated to significantly affect local or regional energy supplies.

Growth facilitated by the 2040 General Plan would require an irreversible commitment of City services, water supply, and wastewater treatment. Impacts to public services would be reduced to a less-than-significant level with implementation of policies included in the 2040 General Plan.

Impacts to utilities would be less than significant after mitigation as they relate to construction and operation of utility infrastructure for development facilitated by the 2040 General Plan.

Growth through 2040 associated with the 2040 General Plan would incrementally increase local VMT (VMT), noise levels, and regional air pollutant and greenhouse gas emissions. Implementation of the 2040 General Plan policies, regional air pollution programs, and mitigation measures would reduce the air pollutant and greenhouse gas emissions associated with individual future development projects. Implementation of the 2040 General Plan policies, historical resources regulations, and mitigation measures would be reduced to below significant thresholds.

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Packet Pg. 700 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
40 Implementation of the 2040 General Plan policies and mitigation measures would reduce the noise impacts associated with future growth to a less-than-significant level. The policies in the 2040 General Plan and mitigation measures would reduce many transportation impacts to a less-thansignificant level; however, changes in land use and population growth facilitated by the proposed plan would reduce vehicles miles traveled (VMT) per capita; however, VMT per capita would still exceed thresholds, resulting in significant and unavoidable traffic impacts.

7.2 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. A 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.

The buildout anticipated under the 2040 General Plan could accommodate an estimated 26,269 new residents and 10,155 net new dwelling units in San Ramon. With the estimated growth under the 2040 General Plan, San Ramon would have a 2040 population of 110,089. Additionally, the Association of Bay Area Governments estimates that San Ramon would have an additional 17,775 jobs by 2040 for a total of 71,775 within San Ramon. Note that these growth assumptions are conservative and unlikely to come to complete fruition.

It is anticipated that buildout under the 2040 General Plan would directly support the population growth and subsequent housing needs within San Ramon’s projected growth estimates. Since much of San Ramon is currently developed and used for residential, commercial, and various other uses, implementation of the 2040 General Plan would largely entail the development of vacant and underutilized parcels throughout San Ramon. The 2040 General Plan aims to intensify and densify development within the 2040 General Plan area to accommodate anticipated population growth and housing needs within San Ramon. Proposed 2040 General Plan land use and planning policies aim to provide guidance for orderly development while balancing the land use needs for housing, residential and commercial services, civic needs, and jobs.

It is the specific purpose of the 2040 General Plan to guide growth and development in San Ramon such that infill development would be prioritized, and open space areas would be preserved and enhanced. Therefore, by its nature, the 2040 General Plan is intended to reduce the potential for uncontrolled growth and associated environmental impacts. For the reasons discussed above, implementation of the 2040 General Plan would not lead to direct or indirect growth impacts beyond what is anticipated and planned for by San Ramon.

Much of San Ramon is developed, and the 2040 General Plan encourages infill development to meet San Ramon’s anticipated population and employment growth and housing needs. Although development of some vacant land within San Ramon could require new utility connections, new development is anticipated to occur where existing roads, water, parking lots, and sewer and other utilities are in place and in a manner that minimizes the impact of development on existing infrastructure and services. Major infrastructure extensions are not envisioned due to the level of existing development within San Ramon, and improvements would be primarily limited to the replacement and/or upgrade of aging facilities and enhancement of existing infrastructure as needed on a future project-by-project basis. All new development envisioned as part of the 2040

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Packet Pg. 701 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Significant Irreversible Effects and Growth Inducement
Findings of Fact/Statement of Overriding Considerations 41 General Plan would occur within the San Ramon Planning Area (i.e., the General Plan area).

Therefore, because new development would use existing facilities and major infrastructure extensions would not occur, the 2040 General Plan would not remove obstacles to unplanned growth within San Ramon.

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Packet Pg. 702 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon
2040 General Plan
42 8 Statement of Overriding Considerations
CEQA requires the decision-making agency to balance the benefits of a project against its significant unavoidable impacts when determining whether to approve a project. If the benefits of the project outweigh its unavoidable adverse environmental effects, those effects may be considered acceptable (CEQA Guidelines Section 15093(a)). CEQA requires the agency to state in writing the specific reasons for considering a project acceptable when significant impacts are not avoided or substantially lessened. Those reasons must be based on substantial evidence in the Draft EIR, Final EIR, or elsewhere in the administrative record (CEQA Guidelines Section 15093(b)). The 2040 General Plan, as proposed, could result in significant unavoidable impacts related to transportation (project-level and cumulative VMT). These significant unavoidable impacts are identified and discussed in Section 5 of these Findings.

The City adopts and makes this Statement of Overriding Considerations regarding the significant unavoidable impacts and anticipated benefits of the 2040 General Plan. The City finds and determines that the majority of the 2040 General Plan impacts will be reduced to acceptable levels through implementation of the policies set forth in the self-mitigating 2040 General Plan. The City further finds that each of the benefits set forth below in this Statement of Overriding Considerations constitutes a separate and independent ground for finding that the benefits of the 2040 General Plan outweigh the risks of the potential significant adverse environmental impacts. The benefits of the 2040 General Plan, which constitute the specific economic, legal, social, technological and other considerations that justify the approval of the 2040 General Plan are as follows:
 The 2040 General Plan updates outdated policies in a manner that meets current State legal requirements for General Plans.
 The 2040 General Plan would amend the existing Zoning Ordinance to ensure compatibility with the General Plan and to allow for development intensities and uses that are consistent with the General Plan.
 The 2040 General Plan brings the General Plan up to date in response to latest State and regional plans and regulations related to housing, climate-related hazards, emergency evacuation routes and access, water supply, and mobility.  The 2040 General Plan provides a more user-friendly document that will make use of the General Plan easier for decision makers, staff, and the public.  The 2040 General Plan would focus new growth inward through the intensification of land use density by encouraging infill and redevelopment projects within the existing urban areas, thus minimizing pressure to develop within the remaining open space in San Ramon.  The 2040 General Plan would encourage infill development to meet San Ramon’s anticipated population growth and housing needs.
 The 2040 General Plan would meet the objectives of the State of California by preserving and creating affordable housing in proximity to jobs for those employed in Contra Costa County.
 The 2040 General Plan outlines a vision for San Ramon’s long-range physical development and resource conservation. The 2040 General Plan provides strategies and specific implementing actions that will allow this vision to be accomplished.

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Packet Pg. 703 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Statement of Overriding Considerations
Findings of Fact/Statement of Overriding Considerations 43  The 2040 General Plan establishes a basis for judging whether specific development proposals and public projects are in harmony with the General Plan policies and standards.  The 2040 General Plan would allow City departments, other public agencies, and private developers to design projects that would enhance the character of the community, preserve and enhance critical environmental resources, and minimize hazards.  The 2040 General Plan would provide the basis for establishing and setting priorities for detailed plans and implementing programs, such as the Zoning Ordinance, the Capital Improvement Program (CIP), Climate Action Plan, specific plans, etc.  The 2040 General plan was shaped by an extensive public outreach process that engaged the community and decision-makers. The City hosted a series of Planning Commission study sessions, public workshops, and public hearings on the 2040 General Plan. The 2040 General Plan developed with all this public input and consideration and represents the desires of the community as a whole in shaping the future of the City.  Alternative 2 meets the above objectives and provides the additional support requested by the residents of the City to protect and enhance retail development within the City in order to better serve current and anticipated population growth and provide to a sturdy economic footprint.

On balance, the City finds that there are specific considerations associated with the 2040 General Plan that serve to override and outweigh the 2040 General Plan’s significant unavoidable effects.

Therefore, pursuant to CEQA Guidelines Section 15093(b), these adverse effects are considered acceptable.

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Packet Pg. 705 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update EXHIBIT 2
SAN RAMON 2040 GENERAL PLAN PROJECT

FINAL ENVIRONMENTAL IMPACT REPORT
SCH No. 2022060549
Introduction
Final Environmental Impact Report-Response to Comments
(dated November 2, 2023)
Mitigation Monitoring and Reporting Program (dated November 2, 2023) Final Environmental Impact Report-Errata to DEIR (dated November 2, 2023) Draft Environmental Impact Report and associated Appendices (dated August 30, 2023, previously provided to Planning Commission and City Council and incorporated by reference)

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Packet Pg. 706 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Introduction
2040 General Plan
Final Environmental Impact Report 1-1
Introduction
In accordance with the California Environmental Quality Act (CEQA) Guidelines Section 15088, the City of San Ramon has evaluated the comments received on the San Ramon 2040 General Plan Draft Environmental Impact Report (EIR). The responses to the comments and errata, which are included in this document – together with the Draft EIR, the Draft EIR appendices, and the Mitigation Monitoring and Reporting Program – form the Final EIR for use by the City of San Ramon in its review.

This document is organized into three chapters:
 Chapter 1 – Introduction
 Chapter 2 – Responses to Comments. Provides a list of the agencies, organizations, and individuals who provided written comments on the Draft EIR. Copies of all of the letters received regarding the Draft EIR and responses thereto are included in this section.  Chapter 3 – Errata. Lists refinements to and clarifications on the Draft EIR.

The Final EIR includes the following contents:
 Draft EIR (provided under separate cover)
 Draft EIR appendices (provided under separate cover)
 Responses to Comments on the Draft EIR and Errata (Chapters 2 and 3 of this document)  Mitigation Monitoring and Reporting Program (provided under separate cover) Environmental Review Process
Pursuant to the California Environmental Quality Act (CEQA), lead agencies are required to consult with public agencies having jurisdiction over a proposed project and to provide the general public with an opportunity to comment on the Draft EIR.

The City of San Ramon distributed a Notice of Preparation (NOP) of the programmatic EIR for a 32- day agency and public review period commencing June 24, 2022 and public comment closed on July 25, 2022. In addition, the City held a hybrid in-person/virtual Scoping Meeting on July 5, 2022. The meeting was aimed at providing information about the proposed plan to members of public agencies, interested stakeholders and residents/community members, and at receiving comments on the scope and content of the EIR.

The Draft EIR was made available for public review for a 48-day comment period that began on August 30, 2023 and ended on October 16, 2023. The Notice of Availability of a Draft EIR was posted with the County Clerk, sent to the State Clearinghouse, and posted on the City’s website.

The City received written comment letters on the Draft EIR from three agencies, two organizations, and five individual commenters. Copies of written comments are included in Chapter 2 of this document.

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Packet Pg. 707 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Introduction
2040 General Plan
Final Environmental Impact Report 1-2
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Packet Pg. 708 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Responses to Comments
This Final Environmental Impact Report (EIR) chapter includes comments received during the public circulation of the Draft EIR prepared for the City of San Ramon 2040 General Plan as well as responses to such comments.

The Draft EIR was circulated for a 48-day public review period that began on August 30, 2023 and ended on October 16, 2023. The City of San Ramon received seven written comment letters on the Draft EIR as well as four verbal comments on the Draft EIR during the September 19, 2023 Draft EIR Public Meeting. Agency letters that were received are labeled with an “A” and numbered in the order they were received. Comment letters received from organizations are labeled with a “O” and numbered in the order they were received. Comment letters received from individual persons are labeled with a “P” and numbered in the order they were received. The comment identification label as well commenters’ names/associations and the dates comment letters were received are listed below.

Letter ID and Commenter Name/Association Date Received
Agency Letters
A1 Brian Olson, California Geologic Society 09/21/23
A2 Constantin Raether, California Office of Emergency Services 09/29/23 A3 Yunsheng Luo, California Department of Transportation 10/13/23 Organization Letters
O1 Paul Krupka, Krupka Consulting 10/16/23
O2 Ariel Strauss, Greenfire Law 1 10/16/23
O3 Ariel Strauss, Greenfire Law 2 (verbally received during Draft EIR public mtg) 09/19/23 Individual Person Letters
P1 Sue Bock 10/3/23
P2 Wendy Lee 10/11/23
P3 Call-in User 1 (verbally received during Draft EIR public mtg) 09/19/23 P4 Jim Blickenstaff (verbally received during Draft EIR public mtg) 09/19/23 P5 Vice Chair Kuznik (verbally received during Draft EIR public mtg) 09/19/23 The comment letters and responses follow. The comment letters have been numbered sequentially, and each separate issue raised by the commenter has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response A1-1, for example, indicates that the response is for the first issue raised in comment Letter A1).

In some cases, specific changes to the text of the Draft EIR have been made in response to comments received. In no case do these revisions result in a greater number of impacts or impacts of a substantially greater severity than those set forth in the Draft EIR. Where revisions to the Draft EIR text are called for, the page and paragraph are set forth, followed by the appropriate revision.

Added text is indicated with underlined and deleted text is indicated with strikeout. Page numbers correspond to the page numbers of the Draft EIR. Revisions to the Draft EIR are included in Section 3, Errata, of this Final EIR.
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Packet Pg. 709 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update From: Olson, Brian@DOC <[email protected]> Sent: Thursday, September 21, 2023 2:06 PM
To: Planning Services (public) <[email protected]> Cc: OLRA@DOC <[email protected]>; OPR State Clearinghouse <[email protected]>; Gomez, DarylAnne@DOC <[email protected]> Subject: San Ramon 2040 General Plan
SCH Number
2022060549
Lead Agency
City of San Ramon
Document Title
San Ramon 2040 General Plan
Document Type
EIR - Draft EIR
Received
8/30/2023
Document Description
As part of a comprehensive planning process, the City of San Ramon proposes to adopt an update to the San Ramon General Plan, including eleven respective General Plan elements, amendment to the San Ramon Village Specific Plan, repeal of the North Camino Ramon Specific Plan, and the San Ramon Zoning Code update. The 2040 General Plan elements include: Land Use; Housing; Traffic and Circulation; Safety; Open Space and Conservation; Parks and Recreation; Public Facilities and Utilities; Noise, Air Quality and GHG Emissions, Growth Management, and Economic Development.

Hello, Cindy—
Thank you for providing the City’s Draft EIR for the 2040 General Plan for our review. This email conveys the following recommendations from CGS concerning geologic issues within the General Plan documents:

1. Liquefaction and Landside Hazards
• The Draft EIR discusses both liquefaction and landsliding as potential seismic hazards and provides maps of "Liquefaction Potential" (Figure 3.5-4) and "Landslide Susceptibility" (Figure

3.5-5). The liquefaction potential map appears to depict liquefaction susceptibility based on USGS mapping and the landslide map uses existing CGS Landslide Inventory mapping. The City should be aware that new Earthquake Zones of Required Investigation (EZRI) for liquefaction and earthquake-induced landsliding for the Diablo Quadrangle, which covers the northern portion of the City, will be officially available on February 22, 2024. The City should provide a discussion of EZRIs and include a map of these zones within the General Plan area. • FYI: New seismic hazard zones for liquefaction and landsliding within the Contra Costa County portion of the Dublin Quadrangle (including the southern portion of the City) are in-progress and should be preliminarily available by summer 2024. When they are available, the zones will be posted online at the websites below.
• CGS seismic hazard zone maps and data are available here:

Letter A1
A1-1
A1-2
A1-3
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Packet Pg. 710 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update https://maps-cnra-cadoc.opendata.arcgis.com/datasets/cadoc::cgs-seismic-hazards-programliquefaction-zones-1/about https://maps-cnra-cadoc.opendata.arcgis.com/datasets/cadoc::cgs-seismic-hazards-programlandslide-zones-doc-hosted/about https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=regulatorymaps https://maps.conservation.ca.gov/cgs/EQZApp/app/
• Cities and counties affected by EZRI must regulate certain development projects within them. The Seismic Hazards Mapping Act (1990) also requires sellers of real property (and their agents) within a mapped hazard zone to disclose at the time of sale that the property lies within such a zone.

2. Fault Rupture Hazards
• The City has a map depicting the locations of Alquist-Priolo Earthquake Fault traces (Figure 3.5- 3). They should consider adding the Zones of Required Investigations around these fault traces to this map.
• The DEIR states the Alquist-Priolo Earthquake Fault Zoning Act "requires geologic/seismic studies of most proposed development within 50 feet of the zone" (page 3.5-18). This statement is incorrect. The A-P EFZ Act requires fault investigation studies for proposed buildings for human occupancy anywhere within the zone. The City should consider updating the DEIR anywhere that the Act is referenced and described.
• A CGS map that is continually updated with fault traces and zones is available here:
https://maps.conservation.ca.gov/cgs/EQZApp/app/
Please let me know if you have any questions.
@CAgeosurvey
FOLLOW US!
Brian Olson, CEG
Senior Engineering Geologist
Seismic Hazards Program
California Geological Survey
320 W. 4th Street, Suite 850, Los Angeles, CA 90013
M: (213) 507-1080
E: [email protected]
“A team is not a group of people who work together.

A team is a group of people who trust each other.” – Simon Sinek CONFIDENTIALITY NOTICE: This communication with its contents may contain confidential and/or legally privileged information. It is solely for the use of the intended recipient(s). Unauthorized interception, review, use, or disclosure is prohibited and may violate applicable laws, including the Electronic Communications Privacy Act. If you are not the intended recipient, please contact the sender and destroy all copies of the communication.

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A1-4
A1-5
A1-6
A1-7
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Packet Pg. 711 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter A1
COMMENTER: Brian Olson, Senior Engineering Geologist California Geologic Society DATE: September 21, 2023
Response A1-1
The commenter states that that liquefaction potential maps (figures 3.5-4 and 3.5-5) in Section 3.5, Geology and Soils, of the Draft EIR appear to depict liquefaction susceptibility based on United States Geologic Survey (USGS) mapping and the landslide susceptibility is based on existing California Geologic Survey (CGS) Landslide Inventory mapping. The comment states the Draft EIR should include a discussion and maps of the new Earthquake Zones of Required Investigation (EZRI) for liquefaction and earthquake-induced landsliding for the Diablo Quadrangle which will be available on February 22, 2024.

The City acknowledges that new liquefaction and landslide maps for the Diablo Quadrangle will be available in February 2024. The analysis in the Draft EIR was based on the most current information available at the time the Notice of Preparation was circulated for public review in June 2022. The maps referenced by the commenter are not available for inclusion in the Final EIR because they will not be available until February 2024. Therefore, no revisions to the Draft EIR are required in response to this comment. However, individual development projects within the City would undergo development review, at which time project design and analysis of impacts related to geology and soils would consider the most current landslide and liquefaction maps.

Response A1-2
The commenter states that new seismic hazard zones for liquefaction and landsliding for the Dublin Quadrangle will be preliminarily available by summer 2024.

The City acknowledges that new liquefaction and landslide maps for the Dublin Quadrangle will be available in February 2024. As discussed in Response A1-1, the most current liquefaction and landslide maps will be considered during the design and environmental review of individual development projects. No revisions to the Draft EIR are required in response to this comment.

Response A1-3
The commenter provides links to the CGS seismic hazard zone maps.

The City acknowledges the CGS seismic hazard zone maps provided by the commenter. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR.

No further response is required.

Response A1-4
This comment states that cities and counties must regulate development projects within EZRI zones and that property sellers must disclose that a property is with in an EZRI zone.

This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.
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Packet Pg. 712 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Response A1-5
The commenter states that the Draft EIR incorrectly states that the Alquist-Priolo Earthquake Fault Zoning Act requires geologic/seismic studies of most proposed development within 50 feet of the zone. The commenter states that investigation studies are required for all proposed buildings for human occupancy anywhere within the zone.

This comment is acknowledged. In response to this comment, the following revision has been made to Section 3.5, Geology and Soils, Pages 3.5-18 and 3.5-19 of the Draft EIR:

The Alquist-Priolo Earthquake Fault Zoning Act regulates development near the surface traces of active faults to mitigate the hazard of surface fault rupture. Essentially, this Act contains two requirements: (1) it prohibits the location of most structures for human occupancy across the trace of active faults; and (2) it establishes Earthquake Fault Zones and requires geologic/seismic studies of most proposed development of buildings for human occupancy within 50 feet of the zone. The Earthquake Fault Zones are delineated and defined by the State Geologist and identify areas where potential surface rupture along a fault could occur. The nearest Alquist-Priolo Earthquake Fault Zone is located along the Calaveras Fault to the west of I-680 in the western portion of San Ramon and extends in a north to south direction.

Response A1-6
The commenter requests that the Zones of Required Investigations around the Alquist-Priolo Earthquake Fault Traces be added to Figure 3.5-3 in Section 3.5, Geology and Soils, of the Draft EIR.

As stated by the commenter in Comment A1-5, and stated on Pages 3.5-18 in Section 3.5, Geology and Soils, of the Draft EIR, the required area for geologic/seismic studies is within 50 feet of an Alquist-Priolo Earthquake Fault Zone. The Calaveras Fault, an Alquist-Priolo Earthquake Fault Zone, is located in the western portion of San Ramon to the west of I-680. The addition of a 50-foot “Required Investigation Zone” around this fault would not be legible at the scale of Figure 3.5-3. In addition, the discussion on Pages 3.5-18 of Draft EIR discloses that geologic/seismic studies within 50 feet of an Alquist-Priolo Earthquake Fault Zone. No revisions to the Draft EIR are required in response to this comment.

Response A1-7
The commenter provides a link to the CGS fault maps.

The City acknowledges the CGS fault maps provided by the commenter. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.
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Packet Pg. 713 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update From: Raether, Constantin@CalOES <[email protected]> Sent: Friday, September 29, 2023 2:12 PM
To: Cindy Yee <[email protected]>
Cc: Boemecke, Wendy@CalOES <[email protected]>; CalOES Mitigation Planning <[email protected]>; LaMar-Haas, Victoria@CalOES <Victoria.LaMar[email protected]> Subject: City of San Ramon Safety Element Update
Good afternoon,
The California Governor’s Office of Emergency Services (Cal OES) Local Hazard Mitigation Planning Team has taken the time to review the proposed updates/changes to your General Plan. Government Code 65302(g)(8) states “before preparing or revising its Safety Element, each city and county shall consult…. the Office of Emergency Services for the purpose of including information known by and available to the department.”
The Cal OES Local Hazard Mitigation Planning Team reviews and compares your current Safety Element hazards against those listed in the most recent Federal Emergency Management Agency (FEMA) approved Contra Costa County Multi-Jurisdictional Local Hazard Mitigation Plan (MJLHMP).

Our office has reviewed your proposed Safety Element and found no substantive changes to your hazard profiles when compared against the most recent FEMA approved Contra Costa County MJLHMP. Our office has no further comments at this time.

Should you need further assistance or have questions please email our team at [email protected].

Constantin Raether, Environmental Planner
Local Mitigation Planning | Recovery Directorate
California Governor’s Office of Emergency Services
Office: (916) 328-7778
Cell: (916) 715-9408
www.caloes.ca.gov/HMGP
Letter A2
A2-1
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Packet Pg. 714 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter A2
COMMENTER: Constantin Raether, Environmental Planner, California Governor’s Office of Emergency Services
DATE: September 29, 2023
Response A2-1
The commenter states that the Office of Emergency Services has reviewed the Safety Element and found no substantive changes to the hazard profiles when compared against the Consta Costa County Multi-Jurisdictional Local Hazard Mitigation Plan.

This comment is acknowledged. The comment pertains to the 2040 General Plan and not the Draft EIR. The comment does not contain a substantive comment on the analysis or findings of the Draft EIR, and no further response is required.
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Packet Pg. 715 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update “Provide a safe and reliable transportation network that serves all people and respects the environment” DISTRICT 4

OFFICE OF REGIONAL AND COMMUNITY PLANNING
P.O. BOX 23660, MS–10D | OAKLAND, CA 94623-0660
www.dot.ca.gov
October 13, 2023 SCH #: 2022060549
GTS #: 04-CC-2022-00714
GTS ID: 26840
Co/Rt/Pm: CC/680/VAR
Cindy M Yee, Senior Planner
City of San Ramon
7000 Bollinger Canyon Road
San Ramon, CA 94583
Re: San Ramon 2040 General Plan – Draft Environmental Impact Report (DEIR) Dear Cindy M Yee:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the San Ramon 2040 General Plan. We are committed to ensuring that impacts to the State’s multimodal transportation system and to our natural environment are identified and mitigated to support a safe, sustainable, integrated and efficient transportation system.

The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the August 2023 DEIR.

Project Understanding
The proposed project is to adopt an update to the San Ramon General Plan, including eleven respective General Plan elements, amendment to the San Ramon Village Specific Plan, repeal of the North Camino Ramon Specific Plan, and the San Ramon Zoning Code update. The 2040 General Plan would provide the framework for development up to 10,155 net new residential units and up to 347,339 new nonresidential gross square feet. This project area is bisected by I-680.

Travel Demand Analysis
With the enactment of Senate Bill (SB) 743, Caltrans is focused on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. For more information on how Caltrans assesses Transportation Impact Studies, please review Caltrans’ Transportation Impact Study Guide (link).

Letter A3
A3-1
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Packet Pg. 716 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Cindy M. Yee, Senior Planner
October 13, 2023

“Provide a safe and reliable transportation network that serves all people and respects the environment” The DEIR states that the operational Vehicle Miles Traveled (VMT) impact of the 2040 General Plan would be significant and unavoidable. Caltrans encourages policies and programs related to land use and circulation that increase density, improve regional accessibility, and reduce VMT. For additional TDM options, please refer to the Federal Highway Administration’s Integrating Demand Management into the Transportation Planning Process: A Desk Reference, Chapter 8 (link).

Multimodal Transportation Planning
Please review and include the reference to the Caltrans District 4 Pedestrian Plan (2021) and the Caltrans District 4 Bike Plan (2018) in the DEIR. These two plans studied existing conditions for walking and biking along and across the State Transportation Network (STN) in the nine-county Bay Area and developed a list of location-based and prioritized needs.

Please note that any Complete Streets reference should be updated to reflect Caltrans Director’s Policy 37 (link) that highlights the importance of addressing the needs of non-motorists and prioritizing space-efficient forms of mobility, while also facilitating goods movement in a manner with the least environmental and social impacts. This supersedes Deputy Directive 64-R1, and further builds upon its goals of focusing on the movement of people and goods.

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter or for future project referrals, please contact [email protected].

Sincerely,

YUNSHENG LUO
Branch Chief, Local Development Review
Office of Regional and Community Planning
c: State Clearinghouse
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Packet Pg. 717 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter A3
COMMENTER: Yunsheng Luo, Senior Planner, California Department of Transportation DATE: October 13, 2023
Response A3-1
The commenter summarizes the proposed plan and explains Caltrans’ focus on maximizing efficient development patterns, innovative travel demand reduction strategies, and multimodal improvements. The commenter encourages policies and programs related to land use and circulation that increase density, improve regional accessibility, and reduce vehicle miles traveled (VMT) given the Draft EIR’s significant and unavoidable finding. The commenter references the Federal Highway Administration Integrating Demand Management into the Transportation Planning Process: A Desk Reference, Chapter 8 as a source of Transportation Demand Management (TDM) options.

The City acknowledges the commenter’s suggestion. As noted by the commenter, the Draft EIR analysis has found that the 2040 General Plan’s VMT impacts would be significant and unavoidable, and provides Mitigation Measure TRA-2, which is designed to reduce VMT impacts by requiring project-level VMT analysis, application of TDM measures and project design measures that would reduce VMT, and participation in a regional VMT impact fee program or exchange/banking program if and when one is implemented. The Draft EIR impact discussion also references City General Plan policies that would reduce VMT through promoting accessibility, encouraging non-vehicle transportation modes, and improving access to transit services.

The commenter’s reference to the FHWA Desk Reference on Integrating Demand Management into the Transportation Planning Process is noted. Chapter 8 of this reference covers integration of TDM at the local planning level. The 2040 General Plan includes policies related to integrating TDM into local development planning and participating in regional TDM efforts, consistent with the Desk Reference’s recommendations. No revisions to the Draft EIR are required in response to this comment.

Response A3-2
The commenter encourages the City to review and include Caltrans District 4 Pedestrian Plan (2021) and the Caltrans District 4 Bike Plan (2018) in the Draft EIR. The commenter also notes that any Complete Streets reference should be updated to reflect Caltrans Director’s Policy 37 (which supersedes Deputy Directive 64) that highlights the importance of addressing the needs of nonmotorists and prioritizing space-efficient forms of mobility, while also facilitating goods movement in a manner with the least environmental and social impacts.

The City is familiar with the Caltrans District 4 Pedestrian Plan (2021) and Caltrans District 4 Bike Plan (2018), and references to these plans will be included in the Transportation Setting of the Final EIR. The Bike Plan contains one mid-tier project to reconstruct and square up the ramp ends at the Bollinger Canyon Road/I-680 interchange and provide bike lanes and conflict striping through the interchange. The City of San Ramon looks forward to working with Caltrans to plan and implement these improvements. The City also looks forward to working with Caltrans to provide pedestrian improvements at other I-680 crossings in San Ramon, as recommended in the Pedestrian Plan. The City notes that no specific projects are identified in the Pedestrian Plan. 2-10

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Packet Pg. 718 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
This comment is acknowledged. In response to this comment, the reference to Caltrans District 4 Pedestrian Plan (2021) and Caltrans District 4 Bike Plan (2018), and the Caltrans Director’s Policy 37 have been added to EIR Section 3.12, Transportation, starting on Page 3.12-15 under the California Department of Transportation Planning Documents header of the Draft EIR:

CALTRANS DISTRICT 4 PEDESTRIAN PLAN (2021)
The Caltrans District 4 Pedestrian Plan (2021) implements the Vision Statement and Goals in Toward an Active California, the statewide bicycle and pedestrian plan, and is part of a comprehensive planning process to identify locations with bicycle and pedestrian needs in each Caltrans district across California. The plan is used by Caltrans staff, as well as regional and local agency partners, to address high priority needs along and across the State Transportation Network, which includes the State Highway System and all other multimodal facilities owned and operated by Caltrans, including parallel paths, frontage roads, and other facilities. This plan complements the District 4 Bike Plan, which was completed in 2018 and is described below1.

CALTRANS DISTRICT 4 BIKE PLAN (2018)
The Caltrans District 4 Bike Plan (2018) identifies infrastructure improvements that can enhance bicycle safety and mobility throughout District 4 and remove some of the barriers to bicycling in the region. The plan was developed in cooperation with local and regional partners to ensure that the improvements on the State highway system complement proposals for local networks.2
CALTRANS DIRECTOR’S POLICY 37
The Caltrans’ Director’s Policy 37 (December 2021) supersedes policy DD-64-R2 (October 2014) and notes that all transportation projects funded or overseen by Caltrans will provide comfortable, convenient, and connected complete streets facilities for people walking, biking, and taking transit or passenger rail unless an exception is documented and approved3.
1 California Department of Transportation. 2021. District 4 Pedestrian Plan for the Bay Area. https://dot.ca.gov/-/media/dotmedia/programs/transportation-planning/documents/active-transportation-complete-streets/district4-finalreport-a11y.pdf (accessed October 2023).
2 California Department of Transportation. 2018. District 4 Bike Plan for the San Francisco Bay Area. https://dot.ca.gov/-/media/dotmedia/district-4/documents/d4-bike-plan/caltransd4bikeplan_report_lowres-r6.pdf (accessed October 2023). 3 California Department of Transportation. 2021. Director’s Policy 37. December 7, 2021. https://dot.ca.gov/-/media/dotmedia/programs/esta/documents/dp-37-complete-streets-a11y.pdf (accessed October 2023). 2-11

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Packet Pg. 719 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update October 16, 2023
By email only to Cindy Yee [[email protected]]
Ms. Cindy Yee, Senior Planner
City of San Ramon
7000 Bollinger Canyon Road
San Ramon, CA 94583
RE: Comments on San Ramon General Plan Update Draft Environmental Impact Report:

Transportation Section and Appendix E Transportation Impact Analysis Report Dear Ms. Yee:

I am pleased to submit my comments on the Transportation Section (TS) and Appendix E Transportation Impact Analysis Report (TIA) of the San Ramon General Plan Update Draft Environmental Report (DEIR). This letter presents my summary qualifications and comments 1 on each of these documents. The words below convey my opinion of matters that require revision to provide clear, complete descriptions and details of the analyses conducted.

Summary of Qualifications
I am a registered Civil Engineer and Traffic Engineer in California and have over 40 years of diverse experience covering all phases of project delivery, including preliminary assessment, conceptual planning, feasibility, design, and construction. I have demonstrated expertise in transportation, traffic, and transit planning, engineering, and design related to transit-oriented development, transit facilities, parking facilities, roadway and highway improvements, large and small development projects, neighborhood, community, downtown, city, subarea, county, and sub-regional plans, and transit and highway corridors. Finally, I have authored and managed dozens of transportation and circulation studies supporting environmental impact reports for transportation improvements and development projects of all kinds and sizes.

Comments on the TS

1. (p. 3.12-19) The “CCTA VMT Guidance for Member Agencies” paragraph is confusing and should be revised to clarify this critical guidance.

1. Both of the cited CCTA references contain a document called "VMT Analysis Methodology for Land Use Projects in Contra Costa." This document is in Appendix F in the Growth Management Implementation Guide, dated February 17, 2021, and Appendix A in the Final Technical Procedures, dated November 2022. Both documents contain a flow chart titled "Figure 1 - CCTA VMT Analysis Process." Finally, quoting from the opening paragraph of the subject VMT Analysis Methodology for Land Use Projects in Contra Costa: "This guidance is intended to assist lead agencies in their CEQA VMT analysis consistent with new requirements of the CCTA Growth Management Program (GMP)."
Documents reviewed: San Ramon General Plan Update Draft Environmental Report (DEIR) > 1 Transportation Section (Rincon Consultants, Inc., August 30, 2023) and Appendix E Transportation Impact Analysis Report (Fehr & Peers, Revised Draft San Ramon 2040 General Plan Transportation Impact Assessment, June 2023)

KRUPKA CONSULTING
431 Yale Drive | San Mateo, CA | 94402
650.504.2299 | [email protected] | pkrupkaconsulting.com Letter O1
O1-1
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Packet Pg. 720 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Ms. Cindy Yee, October 16, 2023, Page 2

2. This section should clearly state that the City will follow the latest CCTA guidance referred to as "VMT Analysis Methodology for Land Use Projects in Contra Costa," which is Appendix A in the CCTA Final Technical Procedures, dated November 2022, to evaluate land use projects that are subject to CEQA as discussed in Section 3.12.4, Impacts and Mitigation Measures.

2. (p. 3.12-21) In the last bullet on this page, please clarify that the model land uses were adjusted to reflect the non-residential building area proposed in addition to housing units, as cited in Table 2-1 on page 2-6. This comment applies to other such references in the document.

3. (p. 3.12-35) The first sentence in the first paragraph is incomplete because it says that ONLY 2040 General Plan VMT per employee would exceed the impact threshold; Table 3.12 -2 states that General Plan VMT per resident also exceeds the impact threshold. The third sentence in the first paragraph repeats this error. Also, the use of the general terms “VMT per capita” and “VMT per employee” instead of the more specific terms “Home-Based VMT per Resident” and “Home-Work VMT per Employee” can confuse the reader and should be revised.

4. (p. 3.12-35) The second and third paragraphs qualify Mitigation Measure TRA-2 should be reviewed for relevance and, if suitable, included there. Apparently preconceived, the “conclusion" (third paragraph) should logically be placed after describing the mitigation measure elements.

5. p. 3.12-35 - 3.12-37 Mitigation Measure TRA-2 Prepare and Implement VMT Reduction Measures as written is inadequate because it does not state what the City shall do to comply with the CCTA Growth Management Program requirements in light of the significant and unavoidable finding. I believe the language used in Section 1.3.4.2.3 of the TIA could replace the entirety of this discussion to resolved this inadequacy, provided it addresses my other TIA comments below.

6. p. 3.12-40 The remark below about cumulative impacts shown in Table 3.12-5 is a stretch given the reduction in VMT between the existing value and proposed plan value - 0.02 VMT/Service Population - is essentially null (0.001%).

1. “Countywide boundary VMT per service population would decrease with the proposed plan, reflecting the travel efficiency that generally results from more dense, mixed-use development provided with the proposed plan.” Comments on the TIA

1. (p. 17) The “CCTA VMT Guidance for Member Agencies” paragraph is confusing and should be revised to clarify this critical guidance. See Comment 1 (TS) above.

2. (p. 22) In the third bullet on this page, please clarify that the model land uses were adjusted to reflect the non-residential building area proposed in addition to housing units.

3. (p. 23) Guiding policies highlighted in this section 1.3.4 of the TIA appear to mimic those cited in the DEIR 3.12. Given each document employs a different presentation style regarding facilities covered, it would be prudent for the City team to cross-check all referenced policies in the two documents to confirm there are no conflicting statements.

4. (p. 27) The concluding statement regarding this impact would be enhanced and better highlighted with language like that used for Impact 2 on page 30.

5. (p. 36) The Impact 5 introduction would be enhanced and consistent with previous statements by adding “conflict with CEQA Guidelines section 15064.3, subdivision (b) because it would” between “would” and “generate”.

6. (p. 37) In the last paragraph, second sentence, the addition of “A” after “Appendix” would clarify this reference.

7. (p. 39) Referring to the last paragraph, third sentence, see Comment 6 (TS) above.

O1-1
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Packet Pg. 721 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Ms. Cindy Yee, October 16, 2023, Page 3

8. (p. 39) The last sentence on this page contradicts this respective statement on page

3.12-41 in the TS, which I believe to be true: “Therefore, the cumulative impact related to VMT would be significant and unavoidable.”

9. (p. 40) The first sentence under Section 1.3.4.2.3 is misleading given it states “…(i.e. no specific employment use changes were identified)…”. As noted in Comment 2 above, please clarify that non-residential land use changes were identified.

10. (p. 40) In the second paragraph, the third sentence ends with “…Appendix F (CCTA Recommended Methodology) describes options for mitigation of VMT impacts.” This needs careful review and clarification to blend elements of the noted reference material to meet the needs of this TIA.

1. In fact, the referenced guiding document is titled "VMT Analysis Methodology for Land Use Projects in Contra Costa" and describes the assumptions and procedures I believe the City intends to apply to “implement VMT reduction measures” as the title of this mitigation measure indicates.

2. The subsequent text describing “options” is out of place and confusing to me, given I believe the author’s use of “shall” means the noted types of mitigations shall be considered.

3. Finally, as noted in Comment 1 (TS) above, the CCTA Final Technical Procedures, dated November 2022, contains a newer version of the "VMT Analysis Methodology for Land Use Projects in Contra Costa” (see Appendix A) than one the CCTA Growth Management Implementation Guide, which is referenced in the TIA. Shouldn’t the newer version be referenced?

11. (p. 40) The end of item 1 of the list here includes “Part 3, above.” Please clarify this is a reference to material in the CCTA document. This is another example of the larger matter discussed in Comment 10 above.

12. (p. 40) The last paragraph should be revised to reflect it is pertinent to VMT analysis and not limited to the referenced VMT reduction measures. This could be addressed by replacing “with the following TDM” with “incorporating, but not limited to, VMT reduction mitigation measures listed in Table 5”.

13. (p. 42) The style break noted in Comment 5 above is repeated here for Impact 6 and on page 46 for Impact 7. Using consistent “would not” language for these impact threshold discussions would enhance reader interpretation.

14. (Appendix A) To be clear to the reader that this is part of the TIA, the information documented herein should include source and date as well as Fehr & Peers report identification (footer).

Conclusion
The TS and TIA do not clearly and completely document critical context, procedures, and results as noted above. Revisions should be made to enhance these documents to aid the public and City officials in rendering necessary judgments regarding their adequacy.

Please contact me if you have any questions or other requests.

Sincerely,

KRUPKA CONSULTING
Paul J. Krupka, PE
Sole Proprietor
Registered Professional Engineer in California > Civil C 47497, Traffic TR 1574 O1-14
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Packet Pg. 722 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter O1
COMMENTER: Paul Krupka, Registered Professional Engineer, Krupka Consulting DATE: October 16, 2023
Response O1-1
The commenter states that the “CCTA VMT Guidance for Member Agencies” paragraph in Draft EIR Section 3.12, Transportation, is confusing and should be rewritten, and provides information on the VMT Analysis Methodology for Land Use Projects in Contra Costa County.

The text describing and referencing the CCTA VMT analysis guidance in EIR Section 3.12, Transportation¸ on Pages 3.12-19, 3.12-20, and 3.12-35 are revised to refer to the most recent version. Note that the guidance published in the CCTA Technical Procedures in November 2022 is essentially unchanged from the guidance published in the Growth Management Implementation Guide in February 2021, with the exception of updated references to source documents published by Caltrans and the California Air Pollution Control Officers Association.

EIR Section 3.12, Transportation, on Pages 3.12-19, 3.12-20, and 3.12-35 are revised as follows:

CCTA VMT Guidance for Member Agencies
The CCTA has developed guidance for member jurisdictions to use in developing their own VMT analysis methods, metrics, and thresholds of significance. The latest CCTA’s guidance is VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in Growth Management Program Implementation Guide (Revised February 17, 2021) and CCTA’s Final Technical Procedures, Appendix F (CCTA Recommended Methodology November 2022) describes the recommendations. A flow chart describing the recommended methodology is included in the Technical Appendix (Appendix 1) to Appendix E. At the time of publishing, the City of San Ramon has chosen to follow the CCTA guidance. More detail on the VMT analysis methodology, metrics, and thresholds of significance are provided in Section 3.12.4, Impacts and Mitigation Measures.

VMT Impact Methodology and Assumptions
Since SB 743 eliminated the use of level of service (LOS) for CEQA impact analysis purposes, that method is not utilized in this analysis. The analysis in this document examines potential roadway transportation impacts under current CEQA criteria. The primary quantitative measure of roadway impacts is VMT. The VMT analysis methodology utilizes the procedures described in the CCTA’s Growth Management Program Implementation Guide (revised February 17, 2021), Appendix F VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022). The procedures are summarized below.

MITIGATION MEASURE TRA-2 PREPARE AND IMPLEMENT VMT REDUCTION MEASURES The CCTA’s Growth Management Program Implementation Guide (revised February 17, 2021), Appendix F (CCTA Recommended Methodology) VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022) 2-15

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Packet Pg. 723 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
describes options for mitigation of VMT impacts. The first two options below apply to development projects and plans, and the third applies at a General Plan area-wide scale.

Response O1-2
The commenter requests that Section 3.12, Transportation, be clarified to state that the model land uses were adjusted to reflect the housing units and non-residential building areas proposed.

The non-residential land uses in the VMT modelling were taken from the Contra Costa Countywide Travel Demand Model and were not adjusted for this analysis. Please refer to Response O2-4 for further explanation. No revisions to the Draft EIR are necessary.

Response O1-3
The commenter states that Section 3.12, Transportation, incorrectly states that only 2040 General Plan VMT per employee would exceed thresholds; however, the section also states that the General Plan VMT per resident also exceeds thresholds.

The referenced sentences in the first paragraph on Page 3.12-35 of Section 3.12, Transportation is revised to include VMT per capita. Note that the finding that both VMT rates would exceed the threshold is also provided in the last paragraph on Page 3.12-14. Regarding the use of terms ‘VMT per Employee’ and ‘VMT per Capita’ in certain instances, as opposed to the more complete ‘HomeBased VMT per Resident’ and ‘Home-Work VMT per Employee’, these choices were made to improve readability and the City maintains that the information is clear as written.

EIR Section 3.12, Transportation, on Page 3.12-35 is revised as follows:

Development facilitated by the 2040 General Plan would result in marginal reductions in VMT per capita and VMT per employee from existing conditions, but VMT per capita and VMT per employee would still exceed the impact threshold. Implementing the 2040 General Plan policies listed above under Impact TRA-1 would reduce VMT through promoting accessibility, encouraging non-vehicle transportation modes, and improving access to transit services. Even with the 2040 General Plan policies to reduce VMT, it is possible that VMT per capita and per employee would still remain above applicable thresholds. Although VMT per capita and employee would be reduced as a result of the 2040 General Plan, according to OPR guidance on the application of SB 743, a VMT impact is still significant if VMT per capita or employee remains above 15 percent below the existing baseline. Thus, with respect to consistency with CEQA Guidelines Section 15064.3, subdivision (b), the operational VMT impact of the 2040 General Plan would be significant and unavoidable since VMT per resident and employee would be greater than 17.3 and 12.8, respectively, in the 2040 General Plan area, and Mitigation Measure TRA-2 would be required.

Response O1-4
The commenter requests that the second and third paragraphs on Page 3.12-35 in Section 3.12, Transportation, be added to Mitigation Measure TRA-2 if suitable to include.

In EIR Section 3.12, Transportation, on Page 3.12-35, the second and third paragraphs are intended to introduce the mitigation measure and describe its expected effectiveness. The finding that the impact would remain significant and unavoidable is provided after the description of the mitigation measure. No revisions to the Draft EIR are necessary.
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Packet Pg. 724 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Response O1-5
The commenter states that Mitigation Measure TRA-2 is inadequate, because it does not state what the City will do to comply with the CCTA Growth Management Program.

The City believes that the wording of Mitigation Measure TRA-2 adequately describes how the City would comply with the CCTA Growth Management Program Guidelines. The measure states that projects have the option of changing the project’s characteristics to reduce VMT, or implementing a TDM plan to reduce VMT, and that the City shall require preparation of TDM plans for projects that do not meet the CCTA screening criteria and thresholds. While the wording of Mitigation Measure TRA-2 is somewhat different than the wording in Transportation Impact Assessment (TIA) (Appendix E to the Draft EIR) in Section 1.3.4.2.3, the intent and proposed City action is nonetheless clear. No revisions to the Draft EIR are necessary.

Response O1-6
The commenter questions the accuracy of the statement in Section 3.21, Transportation, that “Countywide boundary VMT per service population would decrease with the proposed plan, reflecting the travel efficiency that generally results from more dense, mixed-use development provided with the proposed plan” given that the reduction in VMT is essentially null (0.001%).

The referenced reduction in countywide boundary VMT per service population is small, but the effect is nonetheless a reduction, and should be disclosed. VMT changes on a countywide scale are generally expected to be small when considering development changes in only one city. No revisions to the Draft EIR are necessary.

Response O1-7
The commenter states that the “CCTA VMT Guidance for Member Agencies” paragraph in the TIA is confusing and should be revised to clarify the guidance.

The reference to the CCTA guidance is revised throughout the TIA (Appendix E to the Draft EIR), similar to the revisions in Draft EIR Section 3.12, Transportation. See Response O1-1 for further explanation.

Response O1-8
The commenter requests that that the TIA be clarified to state that the model land uses were adjusted to reflect the housing units and non-residential building areas proposed.

See Response O1-7. No further revisions to the Draft EIR are necessary.

Response O1-9
The commenter requests that the policies in Section 3.1.4 of the TIA be cross-checked against Section

3.12, Transportation, of the Draft EIR to ensure they do not conflict.

The content referenced by the commenter is included Draft EIR Section 3.12, Transportation, and is consistent. No revisions to the Draft EIR are necessary. 2-17

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Packet Pg. 725 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Response O1-10
The commenter states that the conclusion under “Roadway Facilities” in Impact 1 in the TIA should be enhanced and consistent with the language used in the conclusion of Impact 2.

The concluding statement requested is provided on page 26 of the TIA, after the listing of relevant 2040 General Plan policies. No revisions to the Draft EIR are necessary.

Response O1-11
The commenter provides suggested revisions to the introduction of Impact 5 in the TIA.

The comment is noted. The requested wording is provided directly above the impact statement, so was not repeated in the interest of enhancing readability. No revisions to the Draft EIR are necessary.

Response O1-12
This commenter suggests revising the TIA to revise reference to the “Appendix to “Appendix A.” As there is only one appendix to the TIA, such an edit is not warranted. No revisions to the Draft EIR are necessary.

Response O1-13
This commenter refers to the previous comment.

See Response O1-12. No revisions to the Draft EIR are necessary.

Response O1-14
This commenter states that the conclusion in the TIA that cumulative VMT impacts would be less than significant conflicts with the conclusion in the Draft EIR that cumulative VMT impacts would be significant and unavoidable.

The finding in the Draft EIR Section 3.12, Transportation, Page 3.12-41 is the City’s CEQA finding for the cumulative VMT impact and is based on the OPR guidance cited on Draft EIR Page 3.12-40. A long-term plan’s cumulative impact should generally be considered to have the same significance conclusion as its project-level impact. In contrast, the TIA includes a finding of less than significant based on the fact that the analysis shows the cumulative boundary VMT within the County would be reduced with the proposed plan. The TIA is intended to present the analysis results and provide input for the Draft EIR; additional CEQA expertise and judgment on the part of the City and its CEQA document preparers is then applied to prepare the Draft EIR. In this instance, the Draft EIR made a conservative VMT impact conclusion. This explains the different descriptions of the cumulative impact in the two documents. No revisions to the Draft EIR are necessary.

Response O1-15
This comment states that the first sentence in Section 1.3.4.2.3 of the TIA is misleading. The commenter also requests that the TIA be revised to clarify that non-residential land use changes were identified.

See Response O1-2. No revisions to the Draft EIR are necessary. 2-18

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Packet Pg. 726 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Response O1-16
The commenter provides suggested revisions to the second paragraph on page 40 of the TIA.

Regarding the reference to the VMT analysis guidance, the revisions were made under Response O1-7. Regarding the use of the term “options”, this text is a summary of the content in the VMT analysis guidance. The rest of the mitigation measure text describes how the City would implement VMT reduction measures for projects, through requiring VMT screening analysis and full analysis for projects that do not screen out and requiring TDM plans for projects with VMT impacts. Regarding the CCTA guidance please refer to Response O1-7. No further revisions to the Draft EIR are necessary.

Response O1-17
The commenter requests that a reference to the CCTA document be added to page 40 of the TIA.

Items 1 – 3 on page 40 on the TIA are presented as a direct excerpt from the VMT analysis guidance, and the reference to “Part 3, above” should be understood as referring to that document. As noted in Response to Comment O1-7, the reference to the VMT guidance is updated to refer to the most recent version. No further revisions to the Draft EIR are necessary.

Response O1-18
The commenter provides suggested edits to page 40 of the TIA.

On page 40 of the TIA, the last paragraph is intended to introduce a list of mitigation measures, displayed in Table 5, to be included in project-level TDM plans. This is not an exhaustive list of the measures that could be included. No revisions to the Draft EIR are necessary.

Response O1-19
The commenter proposes the use of similar wording as they noted under Response O1-11 to enhance readability.

See Response O1-11. No revisions to the Draft EIR are necessary.

Response O1-20
The commenter states that Appendix A of the TIA should include a source, date, and footer.

The TIA (Draft EIR Appendix E) includes the source (Fehr & Peers) and date (June 2023) on the cover page of the report itself. No additional change is needed. 2-19

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Packet Pg. 727 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update 1 October 16, 2023
Via Electronic Mail
To: Ms. Cindy Yee, Senior Planner, City of San Ramon
[email protected]; [email protected]
RE: Comments on Draft Environmental Impact Report for the San Ramon 2040 General Plan (State Clearinghouse No. 2022060549)
Dear Ms. Yee:

On behalf of Citizens Against Market Place Apartment/Condo Development, I am writing to provide comments on the Draft Environmental Impact Report for the San Ramon 2040 General Plan (“DEIR”). I relayed similar positions in my oral statements to the Planning Commission on September 19th. These comments focus on three primary deficiencies in the DEIR: (1) The failure to account for the vehicle miles traveled (“VMT”) impacts of increasing number of residents driving farther to meet retail demand that are and will be unmet within the City; (2) the failure to identify “areas of known controversy” related to the insufficiency of local retail and the environmental impact of that shortage; and (3) the failure to consider a realistic alternative that specifically improves protection of retail, similar to environmentally superior Alternative 2, but without the very unpopular, extreme core residential densification.

1. The Problem of Retail Deficiency is Not Addressed by the DEIR Land use arrangement is one of the most significant drivers of automobile trips. In a heavily car-dependent community with limited public transit, situating retail far from residences makes it impractical to access it by foot or bicycle. The City is facing a population boom while failing to craft long-term zoning policies to accommodate the retail needs of current and future residents. This will have tremendous vehicle traffic-related environmental impacts that are not discussed in the DEIR.

Ariel Strauss, Of-Counsel
2748 Adeline Street, Ste. A
Berkeley, CA 94703
510-900-9502 x 702
[email protected]
www.greenfirelaw.com
Letter O2
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Packet Pg. 728 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update 2 “[A]s part of the City of San Ramon’s General Plan Update process[,]” in May 2022, The Natelson Dale Group, Inc., provided the City a San Ramon: Retail Development Opportunities Analysis (“Retail Opportunity Analysis”).1 This analysis detailed “substantial existing ‘leakage’ [purchases lost to surrounding cities] of resident retail demand” in the amount of approximately $280 million annually and projected an opportunity for between 1,100,000 and 1,800,000 square feet of new net retail space through 2040.2 The DEIR incorporated this projection by recounting that “retail floor area is expected to have a demand of up to 1,800,000 square feet.”3 The DEIR estimates that the proposed project “could result in an increase in population that would exceed ABAG population forecasts by 35 percent by 2040.”4 At the same time, the project would add only approximately 347,000 square feet for all non-residential building types, including office space, retail and industrial.5 This is dramatically less than what would be appropriate based on the Retail Opportunity Analysis and also far less than under the current General Plan (no project option): “4,900,000 gsf of non- residential buildout is anticipated under the adopted (2035) San Ramon General Plan, compared to 347,339 gsf of non-residential buildout anticipated under the proposed plan.”6
The DEIR is deficient by failing to consider the necessity to provide for increasing local retail needs and accurately account for the VMT impacts of that failure. Under the California Environmental Quality Act (“CEQA”), the City must consider activities causing either a direct or reasonably foreseeable indirect physical change to the environment.7 VMT analysis must assess the “significance of transportation impacts” of the project; “‘vehicle miles traveled’ refers to the amount and distance of automobile travel attributable to a project.”8 The Office of Planning and Research Technical Advisory on Evaluation Transportation Impacts in CEQA (December 2018) (“Technical Advisory”) clarifies that VMT is not calculated merely by looking at the trips to-and-from the site.

The assessment should cover the full area in which driving patterns are expected to change.

As with other types of projects, the VMT estimation should not be truncated at a modeling 1 Retail Opportunity Analysis at 3.
2 Id. at 2, 6
3 DEIR at 2-11.
4 Id. at ES-18.
5 Id. at 2-6.
6 Id. at 5-3.
7 Pub. Res. Code, § 21065.
8 CEQA Guidelines, § 15064.3.

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Packet Pg. 729 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update 3 or jurisdictional boundary for convenience of analysis when travel behavior is substantially affected beyond that boundary.9
With respect to retail in particular, the Technical Advisory further explains:

By adding retail opportunities into the urban fabric and thereby improving retail destination proximity, local-serving retail development tends to shorten trips and reduce VMT. Thus, lead agencies generally may presume such development creates a less-than-significant transportation impact. Regional-serving retail development, on the other hand, which can lead to substitution of longer trips for shorter ones, may tend to have a significant impact.10 However, the DEIR categorically neglects to discuss City-wide VMT benefits of improved shopping access. The Transportation Impact Assessment (June 2023) by Fehr Peers attached to the DEIR has only four passing references to “retail” (primarily as quotes from the General Plan or generic headings). It entirely fails to include any mention of the impact of community-serving retail square footage falling further out of proportion with a growing population, and the resultant need to drive farther to meet every-day needs. The discussion of VMT is limited to considering trips created by traveling to and from development in the City but does not consider the consequences of forcing residents to drive farther on account of the lack of access to local retail. The mismatch between residential development and commercial access is arguably the most significant environmental problem facing the City, but it is ignored by the DEIR. The DEIR claims that “All environmental issue areas are analyzed in detail in this EIR.”11 This is plainly incorrect.

2. Lack of Sufficient Community-Serving Retail is an “Area of Known Controversy”
“The EIR scoping process did not identify areas of known controversy for the proposed plan.” 12 This is unreasonable and shows a lack of due diligence. The failure of the City to provide adequate retail, and the VMT-related impacts of that problem, was the focus of thousands of comments by the public in connection with the Market Place project approval (DP 2022-0007) and a central element of an active CEQA lawsuit filed against the City (Contra Costa Superior Court Case No. N23-0770, filed April 19, 2023). The City is obligated to identify 9 Technical Advisory at 19.
10 Id. at 13; see also, p. 26 (“As an illustration, assessing the total change in VMT for a grocery store built in a food desert that diverts trips from more distant stores could reveal a net VMT reduction.”). 11 DEIR at ES-2.
12 Id.

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Packet Pg. 730 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update 4 known areas of controversy related to potential environmental impacts.13 This section of the DEIR is plainly noncompliant.

3. The DEIR does Not Include Sufficient Consideration of Alternatives to the Proposed Project
The DEIR recognizes that “the proposed 2040 General Plan already meets and exceeds the RHNA requirements, meaning that an increase in residential buildout under this potential alternative would far exceed RHNA requirements beyond the need for additional residential development.”
14 In connection with the Market Place project application review, thousands of residents expressed strong opposition to extreme residential densification and high rises while demanding more and better community-serving retail opportunities. Yet, the DEIR did not consider an alternative that protects retail without residential densification in excess of the level of the proposed project.

The DEIR notes it scoped but did not analyze a “reduced residential” alternative that would not meet the City’s mandatory Regional Housing Needs Allocation (“RHNA”) requirements.15 Of course, the City should not consider a legally noncompliant option. Instead of offering a straw man, however, the City must evaluate an option that meets RHNA requirements and incorporates the retail protections of environmentally-superior Alternative 2 (such as a “retail shopping” designation) without adding significant high density residential.

Adding these protections to the proposed project or an alternative would reduce the environmental impact of the project and further numerous City objectives, including the following policies:16
• 5.6-I-20: Encourage local commerce to reduce commute distances for employment and shopping needs.
• 2.3-G-2: Provide adequate land use designations to accommodate planned development, with business and commercial areas complementing residential and public development in location/access, mix of uses, attractiveness, and environmental quality. • 2.3-G-5: Strengthen the retail sector in San Ramon in order to expand retail and restaurant options for residents and employees and to increase the tax base. 13 CEQA Guidelines, § 15123, subd. (b)(2); see also, City of Maywood v. Los Angeles Unified School Dist. (2012) 208 Cal.App.4th 362, 373.
14 DEIR at 5-27.
15 Id.
16 Id. at 2-45, 2-46
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Packet Pg. 731 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update 5 “[P]ublic agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]”17 Consequently, the City must consider a politically feasible alternative the protects and promotes community-serving retail.

4. Conclusion
The City is obligated to respond to and discuss these comments in the final EIR.18 Furthermore, because the DEIR is deficient, it must be revised to accurately analyze the VMT impacts of inadequate retail and consider an alternative that will seek to remedy this deficiency.

Respectfully,

GREENFIRE LAW, PC
Ariel Strauss, Of-Counsel
Attorneys for Citizens Against Market Place Apartment/Condo Development 17 Pub. Resources Code, § 21002.
18 CEQA Guidelines, §15088(c).

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Packet Pg. 732 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter O2
COMMENTER: Ariel Strauss, Of-Counsel, Greenfire Law, Attorneys for Citizens Against Market Place Apartment/Condo Development
DATE: October 16, 2023
Response O2-1
The commenter states that their comments focus on three primary deficiencies in the Draft EIR: (1) The failure to account for the vehicle miles traveled (“VMT”) impacts of increasing number of residents driving farther to meet retail demand that are and will be unmet within the City; (2) the failure to identify “areas of known controversy” related to the insufficiency of local retail and the environmental impact of that shortage; and (3) the failure to consider a realistic alternative that specifically improves protection of retail, similar to environmentally superior Alternative 2, but without the very unpopular, extreme core residential densification.

See Responses O2-2 through O2-6.

Response O2-2
The commenter states that land use arrangement is one of the most significant drivers of the automobile trips and would have vehicle-related environmental impacts that are not discussed in the Draft EIR.

The City agrees that land use mix and location is an important factor contributor to the amount of VMT generated within a city or region, and that longer trips between uses will generally make walking and bicycling for those trips less practical. Traffic congestion is not a required topic under CEQA pursuant to California Senate Bill 743, which mandates the use of VMT to analyze transportation-related environmental impacts instead of the use of level of service. With regard to the VMT impacts discussed in the Draft EIR, see Response O2-4. No revisions to the Draft EIR are necessary.

Response O2-3
The commenter states that the population growth and non-residential development identified in the Draft EIR is less than what would be appropriate based on the Retail Opportunity Analysis and the current General Plan.

Draft EIR Table 2-1 shows the overall land use components and associated population summary for the 2040 General Plan. This indicates the net change in residential units (10,155), non-residential gross square footage (347,339), and population (26,269) between existing baseline (2022) and projected 2040 General Plan buildout (2040). The residential units are based on the 2023-2031 Housing Element projections and infill redevelopment opportunities, and the non-residential gross square footage is per the City’s understanding of growth potential within existing and recently vacated specific plan areas as well as mixed-use designated areas that informed development of the 2040 General Plan Land Use Element. Per the table footnote, the 2040 population estimate assumes approximately 2.92 persons per household per California Department of Finance, and then a 5 percent projected vacancy rate was applied to further adjust. Furthermore, CEQA analysis focuses 2-25

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Packet Pg. 733 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
on the environmental impacts of the proposed plan and is not required to address economic effects, including those related to retail opportunities. No revisions to the Draft EIR are necessary.

Response O2-4
The commenter states that the Draft EIR is deficient, because it fails to consider the necessity to provide local retail needs and accurately account for VMT impacts.

Regarding the VMT analysis provided in the Draft EIR, the analysis methodology follows the commenter’s referenced guidance in OPR’s Technical Advisory on Evaluating Transportation Impacts in CEQA, as well as the Contra Costa Transportation Authority’s guidance on VMT analysis which is contained in Appendix A of the CCTA Technical Procedures (November 2022). Specifically, Homebased VMT per resident and Home-work VMT per employee are assessed for the city as a whole, including the full trip lengths for all trips (i.e., trip lengths are not truncated at the city or county boundary). A separate, cumulative analysis is also provided that assesses the net change in total year 2040 VMT within Contra Costa County, with the project; this analysis captures the net effect of the project on travel behavior changes, within the county in which San Ramon sits.

With regard to the non-residential (office, retail, and industrial) land use assumptions in the VMT analysis, the 2040 No Project (current 2035 General Plan) and 2040 With Project (2040 General Plan) analyses rely on the land use data included in the Contra Costa Countywide Travel Demand Model, which includes substantial growth in all three non-residential categories. In the model, a growth of approximately 8,700 employees, very roughly corresponding to about 4.6 million square feet of non-residential development, is included within the city of San Ramon. Roughly 750,000 square feet of this development is in the retail category. The CCTA developed the model’s land use assumptions based on ABAG population and employment forecasts for the Bay Area and individual counties, and the process included review and input from individual cities with regard to the geographic allocation of the growth. Because the model’s objective is to be consistent with regional land use forecasts, significant deviation from the model’s assumptions would require a re-allocation of development potential to other cities and counties represented in the model. Because (1) the City of San Ramon does not control planning and zoning decisions for other jurisdictions, (2) ultimately the development market plays a primary role in determining the location, type and density of development, and (3) such a reallocation would introduce substantial uncertainty into the VMT analysis, a re-allocation of the model’s non-residential land uses in San Ramon was not undertaken.

It is also important to note that such a re-allocation, if performed, would need to apply to both the 2040 No Project (2035 General Plan) and 2040 With Project (2040 General Plan) scenarios, since the 2035 General Plan would also not be expected to have calculated non-residential land uses that are substantially lowers than the model’s assumptions.

As noted in the comment’s second excerpt from the Technical Advisory¸ local-serving retail may be found to reduce VMT while regional-serving retail may increase VMT. Such determinations require more project details than are available in a programmatic General Plan EIR analysis, and would thus need to be made on a project-by-project basis. As such, the Draft EIR cannot provide a quantitative assessment of any citywide benefits of adding retail, as the comment suggests. The analysis provided in the Draft EIR does include the effect of trips travelling between all residences in San Ramon to all destinations within San Ramon, the County, and the region. Therefore, no revisions to the Draft EIR are necessary.
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9.1.f
Packet Pg. 734 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Response O2-5
The commenter states that Draft EIR fails to identify lack of sufficient community-serving retail as an area of known controversy.

CEQA solely requires the identification of areas of known controversy as they relate to physical environmental impacts. As such, economic effects, including related to amount of retail included in the 2040 General Plan Land Use Element, are not required to be included in the EIR as an area of known controversy. In addition, this comment does not disagree with the EIR conclusions or mitigation related to environmental impacts. No revisions to the Draft EIR are necessary.

Response O2-6
The commenter states that the Draft EIR does not include sufficient consideration of alternatives, because it did not consider an alternative that protects retail without residential densification in excess of the level of the proposed 2040 General Plan.

In Draft EIR Chapter 5, EIR Alternatives, EIR Alternative 2 included and assessed both the residential units to meet the Regional Housing Needs Allocation (RHNA) requirement as well as new infill mixed use within the City Core and additional retail shopping compared to the proposed plan. The retail preservation under EIR Alternative 2 is assumed specifically with redevelopment of the Chevron site.

The anticipated overall non-residential gross square footage reduction under EIR Alternative 2 would be the result of a reduction in office land uses rather than retail land uses across San Ramon.

EIR Alternative 2 would focus on more transit-oriented, mixed-use land uses, including shops and a diversity of housing opportunities, and redesignate 41.4-acres within four existing mixed-use shopping centers as “Retail Shopping” to promote infill development. CEQA analysis focuses on the environmental impacts of the proposed plan and is not required to address economic effects, including those related to retail opportunities. Nonetheless, EIR Alternative 2 was deemed the environmentally superior alternative in the Draft EIR Alternatives comparison analysis (see Draft EIR p. 5-29) and will be considered by the City as part of EIR Findings. Furthermore, this comment does not disagree with the EIR Alternatives conclusions related to environmental impacts. No revisions to the Draft EIR are necessary.

Response O2-7
This comment states that the Draft EIR is deficient and should be revised to accurately analyze the VMT impacts of inadequate retail and consider an alternative that will seek to remedy this deficiency.

See Responses O2-2 through O2-6.
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9.1.f
Packet Pg. 735 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Verbal Comment Received During September 19, 2023 Draft EIR Public Meeting Greenfire Law (attorneys for CAMPAD), Ariel Strauss
• Concerned about the lack of adequate protection of retail. Does not like idea of converting retail to residential.
• There is no EIR Alternative to protect retail.
• EIR pp. 2-6 identifies there is less non-residential development expected by General Plan 2040 buildout than what is recommended by the 2022 retail development opportunity study and far less than the non-residential development estimate from the General Plan 2035 shown on EIR pp. 5-3.
• No alternative considered that targets protection of retail without the extreme increase in core densification.
• The DEIR exclusively focuses on VMT trips between home and work; were VMT impacts considered for longer trips for shopping outside of San Ramon? Letter O3
O3-1
O3-2
O3-3
O3-4
O3-5
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9.1.f
Packet Pg. 736 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter O3
COMMENTER: Ariel Strauss, Of-Counsel, Greenfire Law, Attorneys for Citizens Against Market Place Apartment/Condo Development
DATE: September 19, 2023
Response O3-1
The commenter expresses concern about the lack of adequate protection of retail. The commenter expresses opposition to conversion of retail to residential uses.

The commenter’s opposition to conversion of retail is acknowledged. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.

Response O3-2
The commenter states that the Draft EIR does not include an alternative that protects retail.

See Response O2-6.

Response O3-3
The commenter states that page 2-6 of the Draft EIR identifies less non-residential development expected by the General Plan 2040 buildout than what is recommended by the 2022 retail development opportunity study and far less than the non-residential development estimate from the General Plan 2035.

See Response O2-3.

Response O3-4
The commenter states that the Draft EIR does not include an alternative that protects retail without the extreme increase in core densification.

See Response O2-6.

Response O3-5
The commenter asks if VMT impacts considered longer trips for shopping outside of San Ramon.

See Response O2-4.
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Packet Pg. 737 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Ticket: [#20231003231814]
Name: sue bock
e-mail: [email protected]
Climate Action Plan Comment:

We request that our voices in San Ramon be heard regarding the CAP evolution. San Ramon city council needs to be aware of the impacts their decisions will determine their impact on the environment and 1. Take advantage of the governmental monies that are available for San Ramon can benefit everyone. 2. Is the city ready to claim the monies and what will happen if we miss th opportunities.

Page title: Home
Letter P1
P1-1
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Packet Pg. 738 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter P1
COMMENTER: Sue Bock
DATE: October 3, 2023
Response P1-1
The commenter states that City’s decisions on the CAP will impact the environment and that the City should take advantage of government funds that are available.

The San Ramon Climate Action Plan (CAP) is still in the planning stages. Once the City is further in the CAP planning process, the City plans on holding a public meeting regarding the proposed CAP greenhouse gas emissions reduction measures as well as regarding the Draft CAP document itself.

This comment is not related to the Draft EIR, and no revisions to the Draft EIR are necessary. 2-31

9.1.f
Packet Pg. 739 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Ticket: [#20231011185105]
Name: Wendy
e-mail: [email protected]
Climate Action Plan Comment:

Hello. I am looking for information on AB 1346 (signed by Governor Newsom in 2021 to take effect in 2024) in the Plan and what the City of San Ramon and residents can do to prepare for the changes brought about by this legislation. This legislation addresses greenhouse gas emissions, air quality, and noise, three important areas of the Plan. Thank you.

Page title: Home
P2-1
Letter P2
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Packet Pg. 740 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter P2
COMMENTER: Wendy Lee
DATE: October 11, 2023
Response P2-1
The commenter requests additional information on Assembly Bill 1346 and what residents can do to prepare for changes resulting from the legislation.

Assembly Bill 1346 requires the California Air Resources Board (CARB) to adopt cost-effective and technologically feasible regulations by July 1, 2022 to prohibit engine exhaust emissions from new small off-road engines, which are often used in lawn and garden equipment. The regulations would apply to engines produced on or after January 1, 2024, or as soon as CARB determines it is feasible, whichever is later. To support the transition to zero-emission small off-road equipment, the bill requires CARB to identify and, to the extent feasible, make available funding for commercial rebate or similar incentive funding as part of any updates to existing applicable funding program guidelines, for local air districts to implement. Because the United States Environmental Protection Agency (EPA) has exclusive jurisdiction over emissions regulations, the EPA must approve any changes to CARB’s regulations before they are adopted by CARB. CARB’s amendments to their Small Off-Road Engine Regulation to comply with Assembly Bill 1346 are currently undergoing review by the United States Environmental Protection Agency.

CARB and the local air districts are responsible for developing and implementing regulations to achieve zero emissions from small off-road engines sold in California. It is not the City’s responsibility to phase out the use of the small off-road equipment that the bill addresses, and is therefore not applicable to the policies outlined in the 2040 General Plan. No revisions to the Draft EIR are necessary.
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9.1.f
Packet Pg. 741 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Verbal Comment Received During September 19, 2023 Draft EIR Public Meeting Call-in User 1 (name not provided)
• Have concerns with zoning amendment to remove creek setback regulations. • Have issues with my own property and soil settlement issues that went through an extensive legal process with the HOA.
• Referenced the submitted Federal Realty public comment letter and stated no response or change has been provided.
• Retail is very important to the community.

Letter P3
P3-1
P3-2
P3-3
P3-4
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Packet Pg. 742 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter P3
COMMENTER: Call-in User 1
DATE: September 19, 2023
Response P3-1
The commenter states that they have concerns with zoning amendment to remove creek setback regulations.

The commenter’s concern with the zoning amendment to remove creek setback regulations is acknowledged. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.

Response P3-2
The comment states their property has soil settlement issues.

The comment is acknowledged. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.

Response P3-3
The commenter stated no responses to Federal Realty’s public comment letter on the 2040 General Plan non-retail policy have been provided.

The comment is acknowledged. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.

Response P3-4
The commenter states that retail is very important to the community.

The commenter’s support for retail development is acknowledged. This comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR. No further response is required.
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Packet Pg. 743 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Verbal Comment Received During September 19, 2023 Draft EIR Public Meeting Jim Blickenstaff
• Visual/Aesthetics impacts were not considered; ambitiously building a lot of housing and those will have negative visual impacts and should be clarified as a significant impact in the EIR. • Wants DEIR public review/comment period extended.

Letter P4
P4-1
P4-2
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Packet Pg. 744 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter P4
COMMENTER: Jim Blickenstaff
DATE: September 19, 2023
Response P4-1
The commenter states that aesthetics was not covered in the Draft EIR, and that negative visual impacts from additional housing should be identified as a significant impact.

Impacts related to aesthetics were addressed in Section 4.1, Aesthetics, of the Draft EIR. Specifically, as required by CEQA Guidelines Appendix G, the Draft EIR analyzed impacts related to scenic vistas, scenic resources within a state scenic highway, conflicts with applicable zoning and other regulations governing scenic quality, and light and glare.

Impacts to scenic vistas was discussed under Impact AES-1 in Section 4.1. As discussed under Impact AES-1, development facilitated by the 2040 General Plan would occur within the urbanized areas of the General Plan area. These areas are highly developed with retail, restaurant, commercial, and residential land uses ranging up to 85 feet tall. Publicly available views throughout the General Plan area are largely limited by intervening development and topography, mature landscaping, and large street or median trees. None of the scenic views of open space areas are designated as “vistas” or “scenic corridors” within the adopted 2035 San Ramon General Plan or the proposed 2040 General Plan. However, the 2040 General Plan Land Use Element and Open Space and Conservation Element contain guiding policies and implementing policies that would minimize impacts to scenic views of the surrounding hills and natural features from future residential development would be less than significant.

Impacts to scenic resources within a State scenic highway was discussed under Impact AES-2 in Section 4.1. As discussed in AES-2, the 2040 General Plan would direct future development in such a way as to minimize the impacts of growth by emphasizing the intensification and reuse of already developed areas, thus minimizing pressure to develop on the remaining open space that could contain scenic resources within State scenic highways in San Ramon and instead directing growth and development to infill areas. Therefore, impacts related to damage of scenic resources within a State scenic highway would be less than significant.

Impacts related to scenic quality were analyzed in Impact AES-3. The significance criterion listed in CEQA Guidelines Appendix G thresholds include the following question related to scenic quality:
a) In non-urbanized areas, would the project substantially degrade existing visual character or quality of public views of the site and its surroundings? If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? As discussed under Impact AES-3, San Ramon is characterized as a suburban residential community, as approximately 60 percent of the General Plan area’s developed land is occupied with residential uses. The 2040 General Plan would facilitate infill development and redevelopment projects within existing urban areas, as such Section 4.1, Aesthetics, of the Draft EIR appropriately considers whether the 2040 General Plan would conflict with applicable zoning or other regulations governing scenic quality. As stated in the Draft EIR, implementation of the guiding policies and implementing policies of the 2040 General Plan EIR, partnered with conformance to San Ramon Municipal Code and Zoning Code requirements, would ensure that development facilitated by the 2040 General 2-37

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Packet Pg. 745 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Plan would be visually compatible with San Ramon’s overall form and would improve underutilized parcels through architectural and landscape design. As such, the 2040 General Plan would not conflict with San Ramon regulations governing visual character or quality and impacts would be less than significant. Because San Ramon is located in an urbanized area, CEQA does not require that the Draft EIR consider if the project substantially degrade existing visual character or quality of public views of the site and its surroundings, because this significance criterion is only applicable to nonurbanized areas.

Impacts from additional light and glare resulting from residential development facilitated by the 2040 General Plan were considered under Impact AES-4 in Section 4.1. While development facilitated by the 2040 General Plan would create new sources of light and glare in the General Plan area, the 2040 General Plan would reinforce and improve lighting standards and requirements outlined in the San Ramon Municipal Code to reduce light pollution and glare. Compliance with 2040 General Plan goals and policies and the San Ramon Municipal Code would ensure that impact related to light and glare would be less than significant.

The commenter does not provide any specifics or substantiation as to why negative visual impacts from additional housing should be identified as a significant impact. The Draft EIR considers visual impacts resulting from the 2040 General Plan and concludes that impacts would be less than significant, and no revisions to the Draft EIR are required.

Response P4-2
The commenter requested that the public review period on the Draft EIR be extended.

CEQA Guidelines Section 21091(a) states that a Draft EIR be circulated for at least 30-days and that a Draft EIR be circulated for at least 45-days for projects where a state agency is the lead agency, a responsible agency, or a trustee agency; a state agency otherwise has jurisdiction by law; or the project is of sufficient statewide, regional, or areawide significance. The duration of the public review period complied with the requirements of CEQA Guidelines Section 21091(a). Specifically, the Draft EIR was circulated for a 48-day public review period from August 30, 2023 through October 16, 2023, which exceeded the required 45-day public review period being a “project” of areawide significance as a citywide general plan update. An extension of the Draft EIR public review period is not required. Furthermore, this comment does not contain a substantive comment on the analysis or conclusions in the Draft EIR; as such, no revisions to the EIR are required, 2-38

9.1.f
Packet Pg. 746 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Verbal Comment Received During September 19, 2023 Draft EIR Public Meeting Vice Chair Kuznik
• As we are adding housing, we are adding sensitive receptors. It does not seem like there is a mechanism for which the EIR monitors or accounts for more noise.

Letter P5
P5-1
2-39

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Packet Pg. 747 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Responses to Comments
2040 General Plan
Final Environmental Impact Report
Letter P5
COMMENTER: Vice Chair Kuznik
DATE: September 19, 2023
Response P5-1
The commenter states that Draft EIR does not account for increased noise resulting from more housing and additional sensitive receptors.

The California Supreme Court in a December 2015 opinion (California Building Industry Assn. v. Bay Area Air Quality Management District) confirmed that CEQA is concerned with the impacts of a project on the environment, not the effects the existing environment may have on a project.

Therefore, the Draft EIR analyzes noise generated from additional residential development, and not noise impacts to additional residents (which are considered sensitive receptors). Population growth resulting from the development of additional housing was factored into the noise analysis under Impact N-1 in Section 3.10, Noise, of the Draft EIR. As discussed in Section 3.10.4 of the Draft EIR, implementation of the 2040 General Plan would allow additional buildout, which would generate new vehicle trips that could incrementally increase the exposure of land uses along roadways to operation roadway vehicle noise. Increases in roadway vehicle noise levels for the General Plan 2040 Buildout condition compared to existing conditions were estimated based on predicted future roadway volumes, which account for population growth resulting from General Plan 2040 Buildout.

Impact N-1 of the Draft EIR also considers that noise generated from increased residential development, such as from landscaping, maintenance activities, and mechanical equipment such as ground-level and rooftop ventilation and heating (HVAC) systems. No revisions to the Draft EIR are required.
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Packet Pg. 748 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Errata
2040 General Plan
Final Environmental Impact Report 3-1
Errata
The following are revisions to the Draft Environmental Impact Report (EIR) for the San Ramon 2040 General Plan. These revisions are minor modifications and clarifications to amplify, correct, supplement, or clarify, information in the public review Draft EIR. The revisions do not constitute “significant new information,” because they do not result in a new avoidable significant impact, substantially increase the severity of any environmental impacts, identify a feasible plan alternative considerably different from others previously analyzed, or involve new mitigation measures or substantial revisions to mitigation measures that were included in the Draft EIR (State CEQA Guidelines Section 15088.5). Therefore, recirculation of the Draft EIR is not warranted.

The revisions are listed by the section and page number. All additions to the text are underlined (underlined), and all deletions from the text are stricken (stricken).

Text Changes in Response to Public Comments
The following text changes to the Draft EIR were made in response to public comments received during public circulation of the Draft EIR. Refer to Chapter 2 for the responses to public comments.

Executive Summary
Mitigation Measure TRA-2 was updated for accuracy on Page ES-22 in Table ES-1 in the Executive Summary section of the Draft EIR:

MITIGATION MEASURE TRA-2 PREPARE AND IMPLEMENT VMT REDUCTION MEASURES The CCTA’s Growth Management Program Implementation Guide (revised February 17, 2021), Appendix F (CCTA Recommended Methodology) VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022) describes options for mitigation of VMT impacts. The first two options below apply to development projects and plans, and the third applies at a General Plan area-wide scale.

This revision adds more accurate information to Mitigation Measure TRA-2. As noted below under “Transportation,” this revision to Mitigation Measure TRA-2 was also made in Section 3.12, Transportation. This revision to the Draft EIR is not a substantial revision to Mitigation Measure TRA2 and does not change the environmental impacts disclosed in the Draft EIR.

Section 3.5, Geology and Soils
Pages 3.5-18 and 3.5-19
Regulatory setting information was updated for accuracy on Pages 3.5-18 and 3.5-19 under the Alquist-Priolo Earthquake Fault Zoning Act heading in Section 3.5, Geology and Soils, of the Draft EIR:

The Alquist-Priolo Earthquake Fault Zoning Act regulates development near the surface traces of active faults to mitigate the hazard of surface fault rupture. Essentially, this Act contains two requirements: (1) it prohibits the location of most structures for human

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Packet Pg. 749 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Errata
2040 General Plan
Final Environmental Impact Report 3-2
occupancy across the trace of active faults; and (2) it establishes Earthquake Fault Zones and requires geologic/seismic studies of most proposed development of buildings for human occupancy within 50 feet of the zone. The Earthquake Fault Zones are delineated and defined by the State Geologist and identify areas where potential surface rupture along a fault could occur. The nearest Alquist-Priolo Earthquake Fault Zone is located along the Calaveras Fault to the west of I-680 in the western portion of San Ramon and extends in a north to south direction.

This revision adds more accurate and complete information to the geology and soils regulatory setting. This revision to the Draft EIR does not change the environmental impacts disclosed in the Draft EIR.

Section 3.12, Transportation

Regulatory setting information was added for accuracy and completeness on Page 3.12-15 under the California Department of Transportation Planning Documents heading in Section 3.12, Transportation, of the Draft EIR:

CALTRANS DISTRICT 4 PEDESTRIAN PLAN (2021)
The Caltrans District 4 Pedestrian Plan (2021) implements the Vision Statement and Goals in Toward an Active California, the statewide bicycle and pedestrian plan, and is part of a comprehensive planning process to identify locations with bicycle and pedestrian needs in each Caltrans district across California. The plan is used by Caltrans staff, as well as regional and local agency partners, to address high priority needs along and across the State Transportation Network, which includes the State Highway System and all other multimodal facilities owned and operated by Caltrans, including parallel paths, frontage roads, and other facilities. This plan complements the District 4 Bike Plan, which was completed in 2018 and is described below1.

CALTRANS DISTRICT 4 BIKE PLAN (2018)
The Caltrans District 4 Bike Plan (2018) identifies infrastructure improvements that can enhance bicycle safety and mobility throughout District 4 and remove some of the barriers to bicycling in the region. The plan was developed in cooperation with local and regional partners to ensure that the improvements on the State highway system complement proposals for local networks.2
CALTRANS DIRECTOR’S POLICY 37
The Caltrans’ Director’s Policy 37 (December 2021) supersedes policy DD-64-R2 (October 2014) and notes that all transportation projects funded or overseen by Caltrans will provide comfortable, convenient, and connected complete streets facilities for people walking, 1 California Department of Transportation. 2021. District 4 Pedestrian Plan for the Bay Area. https://dot.ca.gov/-/media/dotmedia/programs/transportation-planning/documents/active-transportation-complete-streets/district4-finalreport-a11y.pdf (accessed October 2023).
2 California Department of Transportation. 2018. District 4 Bike Plan for the San Francisco Bay Area. https://dot.ca.gov/-/media/dotmedia/district-4/documents/d4-bike-plan/caltransd4bikeplan_report_lowres-r6.pdf (accessed October 2023).

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Packet Pg. 750 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Errata
2040 General Plan
Final Environmental Impact Report 3-3
biking, and taking transit or passenger rail unless an exception is documented and approved3.

This revision adds more accurate and complete information to the transportation regulatory setting.

This revision to the Draft EIR does not change the environmental impacts disclosed in the Draft EIR.

Regulatory setting information was updated for accuracy on Page 3.12-19 under the CCTA VMT Guidance for Member Agencies heading in Section 3.12, Transportation, of the Draft EIR:

CCTA VMT Guidance for Member Agencies
The CCTA has developed guidance for member jurisdictions to use in developing their own VMT analysis methods, metrics, and thresholds of significance. The latest CCTA’s guidance is VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in Growth Management Program Implementation Guide (Revised February 17, 2021) and CCTA’s Final Technical Procedures, Appendix F (CCTA Recommended Methodology November 2022) describes the recommendations. A flow chart describing the recommended methodology is included in the Technical Appendix (Appendix 1) to Appendix E. At the time of publishing, the City of San Ramon has chosen to follow the CCTA guidance. More detail on the VMT analysis methodology, metrics, and thresholds of significance are provided in Section 3.12.4, Impacts and Mitigation Measures.

This revision adds more accurate and complete information to the transportation regulatory setting.

This revision to the Draft EIR does not change the environmental impacts disclosed in the Draft EIR.

The Approach to Analysis section was updated for accuracy on Page 3.12-20 under the VMT Impact Methodology and Assumptions heading in Section 3.12, Transportation, of the Draft EIR:

VMT Impact Methodology and Assumptions
Since SB 743 eliminated the use of level of service (LOS) for CEQA impact analysis purposes, that method is not utilized in this analysis. The analysis in this document examines potential roadway transportation impacts under current CEQA criteria. The primary quantitative measure of roadway impacts is VMT. The VMT analysis methodology utilizes the procedures described in the CCTA’s Growth Management Program Implementation Guide (revised February 17, 2021), Appendix F VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022). The procedures are summarized below.

This revision adds more accurate and complete information to the transportation Approach to Analysis section. This revision to the Draft EIR does not change the environmental impacts disclosed in the Draft EIR.
3 California Department of Transportation. 2021. Director’s Policy 37. December 7, 2021. https://dot.ca.gov/-/media/dotmedia/programs/esta/documents/dp-37-complete-streets-a11y.pdf (accessed October 2023).

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Packet Pg. 751 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update City of San Ramon Errata
2040 General Plan
Final Environmental Impact Report 3-4

Mitigation Measure TRA-2 was updated for accuracy on Page 3.12-35 under the Mitigation Measure heading in Section 3.12, Transportation, of the Draft EIR:

MITIGATION MEASURE TRA-2 PREPARE AND IMPLEMENT VMT REDUCTION MEASURES The CCTA’s Growth Management Program Implementation Guide (revised February 17, 2021), Appendix F (CCTA Recommended Methodology) VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022) describes options for mitigation of VMT impacts. The first two options below apply to development projects and plans, and the third applies at a General Plan area-wide scale.

This revision adds more accurate information to Mitigation Measure TRA-2. This revision to the Draft EIR is not a substantial revision to Mitigation Measure TRA-2 and does not change the environmental impacts disclosed in the Draft EIR.

Impact TRA-2 was updated for accuracy on Page 3.12-35 under the Operation heading in Section

3.12, Transportation, of the Draft EIR:

Development facilitated by the 2040 General Plan would result in marginal reductions in VMT per capita and VMT per employee from existing conditions, but VMT per capita and VMT per employee would still exceed the impact threshold. Implementing the 2040 General Plan policies listed above under Impact TRA-1 would reduce VMT through promoting accessibility, encouraging non-vehicle transportation modes, and improving access to transit services. Even with the 2040 General Plan policies to reduce VMT, it is possible that VMT per capita and per employee would still remain above applicable thresholds. Although VMT per capita and employee would be reduced as a result of the 2040 General Plan, according to OPR guidance on the application of SB 743, a VMT impact is still significant if VMT per capita or employee remains above 15 percent below the existing baseline. Thus, with respect to consistency with CEQA Guidelines Section 15064.3, subdivision (b), the operational VMT impact of the 2040 General Plan would be significant and unavoidable since VMT per resident and employee would be greater than 17.3 and 12.8, respectively, in the 2040 General Plan area, and Mitigation Measure TRA-2 would be required.

This revision adds more accurate and complete information to the impact analysis included in the transportation section. This revision to the Draft EIR does not change the findings or significance conclusions disclosed in the Draft EIR.

Appendix E, Traffic Impact Assessment
The following changes were made to the Traffic Impact Assessment (Appendix E of the Draft EIR).

Regulatory setting information was updated for accuracy on Page 17 of the Traffic Impact Assessment under the CCTA VMT Guidance for Member Agencies heading in Appendix E of the Draft EIR:

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1.2.3.4 CCTA VMT Guidance for Member Agencies
The CCTA has developed guidance for member jurisdictions to use in developing their own VMT analysis methods, metrics, and thresholds of significance. The latest CCTA guidance is VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022). Growth Management Program Implementation Guide (Revised February 17, 2021), Appendix F (CCTA Recommended Methodology) describes the recommendations. A flow chart describing the recommended methodology is included in the Technical Appendix. At the time of publishing, the City of San Ramon has chosen to follow the CCTA guidance. More detail on the VMT analysis methodology, metrics, and thresholds of significance are provided in Section 4.14.3, Methodology and Assumptions.

This revision adds more accurate and complete information to the regulatory setting in the Traffic Impact Assessment. This revision to the Traffic Impact Assessment does not change the environmental impacts disclosed in the Draft EIR.

Section 1.3.3, Methodology and Assumptions for VMT Analysis, was updated for accuracy on Page 20 of the Traffic Impact Assessment in Appendix E of the Draft EIR:

The VMT analysis methodology utilizes the procedures described in the CCTA’s Growth Management Program Implementation Guide (Revised February 17, 2021), Appendix F VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022). The procedures are summarized below.

This revision adds more accurate and complete information to the methodology and assumptions in the Traffic Impact Assessment. This revision to the Traffic Impact Assessment does not change the environmental impacts disclosed in the Draft EIR.

Section 1.3.4.2.3, Mitigation Measure: Implement VMT Reduction Measures, was updated for accuracy on Page 40 of the Traffic Impact Assessment in Appendix E of the Draft EIR:

Individual housing project development proposals that do not screen out from VMT impact analysis shall provide a quantitative VMT analysis using the methods applied in this EIR, with modifications if appropriate based on future changes the City of San Ramon practices and CCTA VMT analysis methodology guidelines. Projects which result in a significant impact shall include travel demand management measures and physical measures to reduce VMT.

The CCTA’s Growth Management Program Implementation Guide (Revised February 17, 2021), Appendix F (CCTA Recommended Methodology) VMT Analysis for Land Use Projects in Contra Costa, which is found in Appendix A in CCTA’s Final Technical Procedures (November 2022) describes options for mitigation of VMT impacts. The first two options below apply to development projects and plans, and the third applies at a Citywide scale.

This revision adds more accurate information to the mitigation measures in the Traffic Impact Assessment. This revision is not a substantial revision to the proposed mitigation measures and does not change the environmental impacts disclosed in the Draft EIR.

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Additional Text Changes
In addition to text changes made in response to public comments, the following text changes were made to the Draft EIR for accuracy and completeness.

Executive Summary
Page ES-9
Mitigation Measure CR-1 was updated for accuracy on Page ES-9 in Table ES-1 in the Executive Summary section of the Draft EIR:

CR-1 Prepare a Historical Resources Evaluation Prior to Approval for Projects Involving Buildings 45 Years or Older and Implement Mitigation Prior to and During Construction. A historic resources evaluation for projects involving buildings 45 years or older shall be prepared as follows:
 All properties 45 years of age or older as deemed appropriate by the San Ramon Community Development Director shall be evaluated within their historic context and documented in a report meeting the State Office of Historic Preservation guidelines. The evaluation shall be prepared by a qualified architectural historian or historian who meets the Secretary of the Interior’s Professional Qualifications Standards in architectural history or history (as defined in Code of Federal Regulations, Title 36, Part 61). The qualified architectural historian or historian shall conduct an intensive-level evaluation in accordance with the guidelines and best practices promulgated by the State Office of Historic Preservation to identify potential historical resources within the proposed development site. All properties 45 years of age or older as deemed appropriate by the San Ramon Community Development Director shall be evaluated within their historic context and documented in a report meeting the State Office of Historic Preservation guidelines. Such evaluated properties shall be documented on Department of Parks and Recreation Series 523 Forms. The report shall be submitted to the City for review and concurrence. If the property is already listed in the NRHP or CRHR, the historical resources evaluation described above shall not be required.  If historical resources are identified within the site of a proposed development, efforts shall be made to the extent feasible to ensure that impacts are mitigated. Application of mitigation shall generally be overseen by a qualified architectural historian or historic architect meeting the Professional Qualification Standards, unless unnecessary in the circumstances (e.g., preservation in place). In conjunction with a development application that may affect the historical resource, the historical resources evaluation report shall also identify and specify the treatment of character-defining features and construction activities.
 Efforts shall be made to the greatest extent feasible to ensure that the relocation, rehabilitation, or alteration of the resource is consistent with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings. Application of the Standards shall be overseen by a qualified architectural historian or historic architect meeting the Professional Qualification Standards. In conjunction with a development application that may affect the historical resource, a report identifying

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and specifying the treatment of character-defining features and construction activities shall be provided to the City for review and concurrence. As applicable, the report shall demonstrate how a project complies with the Standards and be submitted to the City for review and approval prior to the issuance of permits.  If significant historical resources are identified on a development site and compliance with the Standards and or avoidance is not possible, appropriate site-specific mitigation measures shall be established and undertaken. Mitigation measures may include documentation of the historical resource in the form of a Historic American Building Survey (HABS) report, or equivalent. The report shall comply with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation and shall generally follow the HABS Level III requirements, including digital photographic recordation, detailed historic narrative report, and compilation of historic research. The documentation shall be completed by a qualified architectural historian or historian who meets the Professional Qualification Standards and submitted to the City prior to issuance of any permits for demolition or alteration of the historical resource.

This revision to Mitigation Measure CR-1 was made for consistency with Section 3.4, Cultural and Tribal Cultural Resources. This revision to the Draft EIR is not a substantial revision to Mitigation Measure CR-1 and does not change the environmental impacts disclosed in the Draft EIR.

Page ES-10
Mitigation Measure CR-2 was updated for accuracy on Page ES-10 in Table ES-1 in the Executive Summary section of the Draft EIR:

Mitigation Measure CR-2: Prepare an Archaeological Resources Assessment prior to Project Approval and Implement Mitigation prior to and during Construction. An archaeological resources assessment for projects involving ground disturbance shall be prepared as follows:
 Assessments shall include a California Historical Resources Information System records search at the Northwest Information Center (NAHC) and a Sacred Lands File search maintained by the Native American Heritage Commission. The records searches will characterize the results of previous cultural resource surveys and disclose any cultural resources that have been recorded and/or evaluated in and around a project site. A Phase I pedestrian survey shall be undertaken at a project site that is on previously undeveloped land in order to locate any surface cultural materials. By performing a records search, consultation with the NAHC, and a Phase I survey, a qualified archaeologist shall be able to classify a project site as having high, medium, or low sensitivity for archaeological resources.
 If the Phase I archaeological survey identifies resources that may be affected by a project, the archaeological resources assessment shall also include Phase II testing and evaluation. If resources are determined significant or unique through Phase II testing and site avoidance is not possible, appropriate site-specific mitigation measures shall be identified in the Phase II evaluation. These measures shall include, but would not be limited to, a Phase III data recovery program, avoidance, or other appropriate actions to be determined by a qualified archaeologist in consultation with the City and any interested Tribes, as stated in the 2040 General Plan Tribal Consultation Implementation Program outlined by Guiding Policy ENV-5 and Guiding Policy 8.7-G-1. If

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Final Environmental Impact Report 3-8
significant archaeological resources cannot be avoided, impacts may be reduced to lessthan-significant levels by adding fill soils on top of the sites rather than cutting into cultural deposits. Alternatively, and/or in addition, a data collection program may be warranted, including mapping the location of artifacts, surface collection of artifacts, or excavation of the cultural deposit to characterize the nature of the buried portions of sites. Curation of the excavated artifacts or samples shall occur as specified by the archaeologist in consultation with the City and any interested Tribes. As stated in the 2040 General Plan Tribal Consultation Implementation Program outlined by Guiding Policy ENV-5 and Guiding Policy 8.7-G-1, the final disposition of artifacts not directly associated with Native American graves shall be negotiated during consultation with interested tribes. If Native American tribes do not accept the artifact, it shall be offered to an institution staffed by qualified professionals, as determined by the City Planner.

Artifacts include material recovered from all phases of work, including the initial survey, testing, indexing, data recovery, and monitoring.

This revision to Mitigation Measure CR-2 was made for consistency with Section 3.4, Cultural and Tribal Cultural Resources. This revision to the Draft EIR is not a substantial revision to Mitigation Measure CR-2 and does not change the environmental impacts disclosed in the Draft EIR.

Page ES-14
Mitigation Measure GHG-1 was updated for accuracy on Page ES-14 in Table ES-1 in the Executive Summary section of the Draft EIR:

GHG-1 Adopt and Implement a San Ramon Qualified Climate Action Plan and San Ramon CEQA GHG Emissions Thresholds. The City shall adopt an updated, qualified San Ramon Climate Action Plan (CAP) by the end of 2024 and include targets that reflect those set by SB 32 to reduce GHG emissions by 40 percent below the 1990 levels by 2030 and AB 1279 to achieve carbon neutrality by 2045. The updated, qualified San Ramon CAP shall be implemented and tracked/monitored by the City in accordance with the CAP-established timeline and details.

Implementation measures in an updated Climate Action Plan to achieve the 2030 and 2045 targets shall include, but are not limited to, the following:
 Develop and adopt Zero Net Energy requirements for new and remodeled residential and non-residential development;
 Develop and adopt a building electrification ordinance for existing and proposed structures;
 Expand charging infrastructure and parking for electric vehicles;  Implement carbon sequestration by expanding the urban forest, participating in soilbased or compost application sequestration initiatives, supporting regional open space protection, and/or incentivizing rooftop gardens; and
 Implement policies and measures included in the 2022 California Climate Change Scoping Plan, such as mobile source strategies for increasing clean transit options and zero emissions vehicles by providing electric vehicle charging stations.

The City shall also adopt San Ramon CEQA GHG Emissions Thresholds of Significance that are consistent with an updated, qualified San Ramon Climate Action Plan by the end of 2024 for use in future CEQA GHG emissions analyses through 2030 and consistent with SB 32. In addition, upon completion of future climate action plan updates and as necessary, the City

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Final Environmental Impact Report 3-9
shall update the CEQA GHG emissions thresholds of significance to be consistent with each climate action plan update.

This revision to Mitigation Measure GHG-1 was made for consistency with Section 3.6, Greenhouse Gas Emissions and Energy. This revision to the Draft EIR is not a substantial revision to Mitigation Measure GHG-1 and does not change the environmental impacts disclosed in the Draft EIR.

Page ES-18
Mitigation Measure NOI-1 was updated for accuracy on Page ES-18 in Table ES-1 in the Executive Summary section of the Draft EIR:

NOI-1 Include and Implement Construction Noise Reduction Measures. To minimize noise during construction, construction contractors shall implement the following measures for construction activities conducted within the City San Ramon. Construction plans submitted to the City shall include construction noise analysis and identify these measures on demolition, grading, and construction plans submitted to the City. The City of San Ramon Building Division and/or Public Works Department shall verify that grading, demolition, and/or construction plans submitted to the City include these notations prior to issuance of demolition, grading and/or building permits.

This revision to Mitigation Measure NOI-1 was made for consistency with Section 3.10, Noise. This revision to the Draft EIR is not a substantial revision to Mitigation Measure NOI-1 and does not change the environmental impacts disclosed in the Draft EIR.

Page ES-19
Mitigation Measure NOI-2 was updated for accuracy on Page ES-19 in Table ES-1 in the Executive Summary section of the Draft EIR:

NOI-2 Implement Operational Roadway Vehicle Noise Reduction Measures. To reduce operational roadway vehicle noise, the City shall implement a developer fair share mitigation program to fund the following measures for projects operated on the following roadway segments within the City San Ramon: Dougherty Road Boulevard between Bollinger Canyon Road (north) and Bollinger Canyon Road (South), San Ramon Valley Boulevard between the northern City limit and Crow Canyon Road, Camino Ramon between Crow Canyon Road and Norris Canyon Road, and Camino Ramon between Norris Canyon Road and Bollinger Canyon Road. The City shall retain a qualified acoustical consultant to prepare a San Ramon-wide Roadway Vehicle Noise Reduction Study that specifies, at a minimum, the specific locations, extent, height of sound walls, and other design details such as “quiet pavement” to reduce roadway vehicle noise impacts at impacted roadways throughout San Ramon. The study shall also include an estimated cost of improvement along each impacted roadway segment to inform the developer fair share mitigation program. Roadway vehicle noise reduction measures may include, but are not limited to:

This revision to Mitigation Measure NOI-2 was made for consistency with Section 3.10, Noise. This revision to the Draft EIR is not a substantial revision to Mitigation Measure NOI-2 and does not change the environmental impacts disclosed in the Draft EIR.

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Final Environmental Impact Report 3-10
Page ES-20
Mitigation Measure NOI-3 was updated for accuracy on Page ES-20 in Table ES-1 in the Executive Summary section of the Draft EIR:

NOI-3 Prepare a Noise and Vibration Analysis and Implement Construction Vibration Control Measures and Screening Distances. Prior to issuance of a building permit for a project requiring a) pile driving during construction within 135 feet of fragile structures such as (historical resources), 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings), b) or within 75 feet of engineered concrete and masonry (no plaster); bc) a vibratory roller within 40 feet of fragile historical resources or 25 feet of any other structure; or a dozer or other large earthmoving equipment within 20 feet for a fragile historical structure and/or cd) 15 feet of any other structure, the project applicant shall prepare a groundborne noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these construction activities. This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed FTA architectural damage thresholds (e.g.,

0.12 in/sec PPV for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower horsepower earthmoving equipment shall be used. If necessary, construction vibration monitoring shall be conducted to ensure FTA vibration thresholds are not exceeded. This revision to Mitigation Measure N-3 was made for consistency with Section 3.10, Noise. This revision to the Draft EIR is not a substantial revision to Mitigation Measure N-3 and does not change the environmental impacts disclosed in the Draft EIR.

This revision to Mitigation Measure NOI-3 was made for consistency with Section 3.10, Noise. This revision to the Draft EIR is not a substantial revision to Mitigation Measure NOI-3 and does not change the environmental impacts disclosed in the Draft EIR.

Page ES-25
Impact UTIL-1 was updated for accuracy on Page ES-22 in Table ES-1 in the Executive Summary section of the Draft EIR:

Impact UTL-1. Development under the 2040 General Plan would increase demand for water, wastewater, stormwater, and telecommunications services. While uUtility facilities and infrastructure development and relocation facilitated by the proposed plan would occur in developed areas of San Ramon where such facilities exist, construction-related impacts would be significant and Unavoidable even with mitigation. impacts would be less than significant with mitigation.

This revision corrects the information in the Executive Summary for consistency with Section 3.13, Utilities and Service Systems, of the Draft EIR. This revision to the Draft EIR does not result in a new avoidable significant effect or substantially increase the severity of any environmental impacts identified in the Draft EIR.

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Page ES-25
The Mitigation Measure(s) column was updated for accuracy under Utilities and Service Systems on Page ES-25 in Table ES-1 in the Executive Summary section of the Draft EIR:

Mitigation Measures AQ-1, AQ-2, AQ-3, BIO-1, BIO-2, CR-1, CR-2, CR-2, CR-3, CR-4, GEO-1, GHG-1, HAZ-1, NOI-1, NOI-2, NOI-3, TRA-1, TRA-2, UTL-1, and UTL-2 This revision corrects the information in the Executive Summary for consistency with Section 3.13, Utilities and Service Systems, of the Draft EIR. This revision to the Draft EIR does not result in a new avoidable significant effect or substantially increase the severity of any environmental impacts identified in the Draft EIR.

Page ES-26
Mitigation Measure was updated for accuracy on Page ES-26 in Table ES-1 in the Executive Summary section of the Draft EIR:

UTL-2 Provide Adequate Wastewater Infrastructure and Treatment for Projects. To ensure adequate wastewater infrastructure and treatment, as well as consistency with existing utility providers and State regulations, the City shall adopt implement the following measures General Plan policy:
 New Policy: The City shall ensure that adequate wastewater facilities and services are available to meet the needs of existing and future development through the following measures:
 Infrastructure Maintenance. Infrastructure Maintenance. Collaborate with Central San and Dublin San Ramon Services District in their efforts to maintain wastewater conveyance, treatment, and disposal infrastructure in good working conditions within San Ramon.
 New Development. Coordinate the review of development proposals with Central San to ensure that new development can be adequately served.
 Wastewater Services Requirement. Require that wastewater services for new development do not negatively affect service to existing uses.  Capital Improvements Program. When updating the Capital Improvements Program, identify and include the following:
 Projects that could also support green infrastructure improvements.  Street improvements consistent with emergency vehicle access standards.  City-sponsored projects necessary to maintain or improve levels of performance.

This revision to Mitigation Measure UTL-2 was made for consistency with Section 3.13, Utilities and Service Systems, of the Draft EIR. This revision to the Draft EIR is not a substantial revision to Mitigation Measure NOI-3 and does not change the environmental impacts disclosed in the Draft EIR.

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Section 3.10, Noise

Mitigation Measure NOI-3 was updated for accuracy on Page 3.10-30 in Section 3.10, Noise, of the Draft EIR:

NOI-3 Prepare a Noise and Vibration Analysis and Implement Construction Vibration Control Measures and Screening Distances. Prior to issuance of a building permit for a project requiring pile driving during construction a) within 135 feet of fragile structures (historical resources), 100 feet of non-engineered timber and masonry buildings [e.g., most residential buildings], b) or within 75 feet of engineered concrete and masonry (no plaster); c) b) a vibratory roller within 40 feet of fragile historical resources or 25 feet of any other structure; and/or d) c) a dozer or other large earthmoving equipment within 20 feet for a fragile historical structure or 15 feet of any other structure, the project applicant shall prepare a groundborne noise and vibration analysis to assess and mitigate potential noise and vibration impacts related to these construction activities. This noise and vibration analysis shall be conducted by a qualified and experienced acoustical consultant or engineer. The vibration levels shall not exceed FTA architectural damage thresholds (e.g.,

0.12 in/sec PPV for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings, and 0.3 in/sec PPV for engineered concrete and masonry). If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower horsepower earthmoving equipment shall be used. If necessary, construction vibration monitoring shall be conducted to ensure FTA vibration thresholds are not exceeded.

This revision to Mitigation Measure NOI-3 was made for accuracy. This revision to the Draft EIR is not a substantial revision to Mitigation Measure NOI-3 and does not change the environmental impacts disclosed in the Draft EIR.

Section 3.13, Utilities and Service Systems

Mitigation Measure UTL-2 was updated for accuracy on Page 3.13-23 in Section 3.13, Utilities and Service Systems, of the Draft EIR:

MITIGATION MEASURE UTL-2: PROVIDE ADEQUATE WASTEWATER INFRASTRUCTURE AND TREATMENT FOR

PROJECTS
To ensure adequate wastewater infrastructure and treatment, as well as consistency with existing utility providers and State regulations, the City shall implement the following measures:
 Infrastructure Maintenance. Infrastructure Maintenance. Collaborate with Central San and Dublin San Ramon Services District in their efforts to maintain wastewater conveyance, treatment, and disposal infrastructure in good working conditions within San Ramon.  New Development. Coordinate the review of development proposals with Central San to ensure that new development can be adequately served.
 Wastewater Services Requirement. Require that wastewater services for new development do not negatively affect service to existing uses.

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 Capital Improvements Program. When updating the Capital Improvements Program, identify and include the following:
 Projects that could also support green infrastructure improvements.  Street improvements consistent with emergency vehicle access standards.  City-sponsored projects necessary to maintain or improve levels of performance.

This revision to Mitigation Measure UTL-2 was made for accuracy. This revision to the Draft EIR is not a substantial revision to Mitigation Measure UTL-2 and does not change the environmental impacts disclosed in the Draft EIR.

Chapter 4, Other CEQA Sections

Section 4.1.2, Removal of Obstacles to Growth, was updated for accuracy on Page 4-2 in Chapter 4, Other CEQA Sections, of the Draft EIR:

As discussed under Impact LU-1 and LU-2 in Section 3.9, Land Use/Planning and Population/ Housing, much of San Ramon is developed, and the proposed plan encourages infill development to meet San Ramon’s anticipated population and employment growth and housing needs.

This revision adds more accurate information to Chapter 4, Other CEQA Sections. This revision to the Draft EIR does not change the environmental impacts disclosed in the Draft EIR.

The following two paragraphs in Section 4.2, Irreversible Environmental Effects, were updated for accuracy on Page 4-3 in Chapter 4, Other CEQA Sections, of the Draft EIR:

Growth facilitated by the proposed plans would require an irreversible commitment of City services, water supply, and wastewater treatment. As discussed in Section 3.12, Public Services and Recreation, impacts to public services would be reduced to a less-thansignificant level with implementation of policies included in the proposed plans. As discussed in Section 3.13. Utilities and Service Systems, impacts to utilities would remain significant and unavoidable be less than significant after implementation of mitigation as they relate to construction and operation of development facilitated by the proposed plan utility infrastructure.

As discussed in Section 3.10, Noise, implementation of proposed policies and mitigation measures would reduce the noise impacts associated with future growth to a less-thansignificant level. As discussed in Section 3.12, Transportation, the policies in the proposed plan and mitigation measures would reduce many transportation impacts to a less-thansignificant level; however, changes in land use and population growth facilitated by the proposed plan combined with regional population growth would reduce vehicles miles traveled (VMT) per capita; however, VMT per capita would still exceed thresholds result in additional vehicle trips on area roadways, resulting in significant and unavoidable traffic impacts on several roadways.

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Final Environmental Impact Report 3-14
These revisions correct the information in Chapter 4, Other CEQA Sections, for consistency with the impacts analysis in Sections 3.12, Transportation, and 3.13, Utilities and Service Systems, of the Draft EIR. These revisions to the Draft EIR do not result in a new avoidable significant effect or substantially increase the severity of any environmental impacts identified in the Draft EIR.

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https://cdnsm5-
hosted.civiclive.com/UserFiles/Servers/Server_10826046/File/Our%20City/Depart ments/Community%20Development/Planning/General%20Plan%202040%20Upd ate/SR2040GeneralPlan_DraftEIRwithAppendices.pdf

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Packet Pg. 763 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Mitigation Monitoring and Reporting Program
1 Mitigation Monitoring and Reporting Program
for the San Ramon 2040 General Plan
CEQA requires that a reporting or monitoring program be adopted for the conditions of plan or project approval that are necessary to mitigate or avoid significant effects on the environment (Public Resources Code 21081.6). This mitigation monitoring and reporting program is intended to track and ensure compliance with adopted mitigation measures during the San Ramon 2040 General Plan implementation phase. For each mitigation measure recommended in the Draft and Final Environmental Impact Report (EIR)1 for the San Ramon 2040 General Plan, specifications are made herein that identify the action required, the monitoring that must occur, and the agency or department responsible for oversight.
1 Mitigation measures language was updated in Mitigation Measure TRA-2 between Draft EIR and Final EIR for the San Ramon 2040 General Plan. That revision is reflected in this Mitigation Monitoring and Reporting Program.

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2040 General Plan
2 Mitigation Measure Action Required Timing
Monitoring
Frequency
Responsible
Agency
Compliance
Verification
Initial
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Date
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Comments
Air Quality
AQ-1 Reduce Construction Criteria Pollutant Emissions
To reduce temporary increases in criteria air
pollutant emissions during the construction phase
for discretionary development projects that are
subject to the California Environmental Quality Act
(CEQA) and exceed the screening sizes in the Bay
Area Air Quality Management District (BAAQMD)
CEQA Guidelines, the City shall require such
projects to evaluate project- specific construction
emissions in conformance with the BAAQMD
methodology. If construction-related criteria air
pollutants exceed the BAAQMD thresholds of
significance, the project applicant shall mitigate the
impacts to a less-than-significant level.

The City shall review and
approve a construction
emissions analysis for
discretionary
development projects
that are subject to CEQA
and exceed BAAQMD
screening sizes
Prior to project
approval
Periodically City of San
Ramon
Planning
Services
Division
AQ-2 Reduce Operational Criteria Pollutant Emissions
To reduce long-term increases in air pollutants
during the operation phase for discretionary
development projects that are subject to CEQA and
exceed the screening sizes in the Bay Area Air
Quality Management District (BAAQMD) CEQA
Guidelines, the City shall require such projects to
evaluate project- specific operation emissions in
conformance with BAAQMD CEQA Guidelines. If
operation- related air pollutants exceed the
BAAQMD-adopted thresholds of significance, the
project applicant shall mitigate the impact to a lessthan-significant level.

The City shall review and
approve an operations
emissions analysis for
discretionary
development projects
that are subject to CEQA
and exceed BAAQMD
screening sizes
Prior to project
approval
Periodically City of San
Ramon
Planning
Services
Division
AQ-3 Conduct and Implement Construction Health Risk Assessment To identify and reduce potential risk exposure to
nearby sensitive receivers during construction of
individual projects (excluding accessory dwelling
units (ADUs), single-family residences, and
duplexes) where construction activities would a)
occur within 1,000 feet of sensitive receptors, b)
last longer than two months, and c) not utilize
equipment rated United States Environmental
Protection Agency (USEPA) Tier 4 for equipment of
50 horsepower or more, construction equipment
The City shall review and
approve a construction
HRA or proof that an HRA
is not required for
discretionary
development projects
Prior to project
approval
Periodically City of San
Ramon
Planning
Services
Division

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3 Mitigation Measure Action Required Timing
Monitoring
Frequency
Responsible
Agency
Compliance
Verification
Initial
Compliance
Verification
Date
Compliance Verification
Comments
fitted with Level 3 Diesel Particulate Filters for all
equipment of 50 horsepower or more, and/or
alternative fuel construction equipment, the
project applicant shall coordinate with the City to
determine if a construction health risk assessment
(HRA) shall be performed. If an HRA is to be
performed, the HRA shall determine potential risk
and compare the risk to the following BAAQMD
thresholds:
 Non-compliance with Qualified
Community Risk Reduction Plan;
 Increased cancer risk of > 10.0 in a
million;
 Increased non-cancer risk of > 1.0
Hazard Index (Chronic or Acute); or
 Ambient PM2.5 increase of > 0.3 µg/m3
annual average
If risk exceeds the thresholds, measures such as
requiring the use of Tier 4 engines, Level 3 Diesel
Particulate Filters, and/or alternative fuel
construction equipment shall be incorporated to
reduce the exposure risk to acceptable levels.

AQ-4 Reduce Operational Toxic Air Contaminants
To identify and reduce potential risk exposure to
nearby sensitive receivers during the operation
phase for discretionary development projects that
are subject to CEQA and exceed the screening sizes
in the Bay Area Air Quality Management District
(BAAQMD) CEQA Guidelines, the City shall require
applicants for commercial land uses that would
generate substantial diesel truck travel (i.e., 100
diesel trucks per day or 40 or more trucks with
diesel-powered transport refrigeration units per
day) to contact BAAQMD to determine the
appropriate level of operational health risk
assessment (HRA) required. If required, the
operational HRA shall be prepared in accordance
with the Office of Environmental Health Hazard
Assessment and BAAQMD requirements and
include mitigation to reduce the exposure risk to an
The City shall review and
approve an operational
HRA or proof that an HRA
is not required for
discretionary commercial
development projects
that would generate
substantial diesel truck
travel
Prior to project
approval
Periodically City of San
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acceptable level. Typical measures to reduce risk
impacts may include, but are not limited to:
a. Restricting idling on-site beyond Air Toxic
Control Measures idling restrictions, as feasible.
b. Electrifying warehousing docks.
c. Truck Electric Vehicle (EV) Capable trailer
spaces.
d. Requiring use of newer equipment and/or
vehicles.

Restricting off-site truck travel through the creation
of truck routes.

Biological Resources
BIO-1 Conduct Pre-Construction Bird Surveys and Implement Avoidance and Minimization Measures For construction activities initiated during the bird
nesting season (February 1 – September 15)
involving removal of vegetation that could
potentially serve as habitat for special-status bird
species or other nesting bird habitat, including
abandoned structures and other man-made
features, a pre-construction nesting bird survey
shall be conducted no more than 14 days prior to
initiation of ground disturbance and vegetation
removal activities. The nesting bird preconstruction survey shall be conducted on foot and shall include a buffer around the construction site
at a distance determined by a qualified biologist.

The survey shall be conducted by a biologist
familiar with the identification of avian species
known to occur in California Bay Area communities
(i.e., qualified biologist). If nests are found, an
avoidance buffer shall be determined by a qualified
biologist dependent upon the species, the
proposed work activity, and existing disturbances
associated with land uses outside of the site. The
buffer shall be demarcated by the biologist with
bright orange construction fencing, flagging,
construction lathe, or other means to demarcate
the boundary. All construction personnel shall be
notified as to the existence of the buffer zone and
to avoid entering the buffer zone during the nesting
The City shall verify that
the pre-construction
nesting bird survey
requirement is included
in the construction plans
and specification and site
plans for development
projects. For projects
where construction
activities would be
initiated during the bird
nesting season, the City
shall verify that a
qualified biologist
conducts the preconstruction nesting bird
survey, prepares a survey
report, and implements
the recommendations
specified in the survey
report.

Prior to the
commencement of
construction activities
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season. No ground disturbing activities shall occur
within the buffer until the biologist has confirmed
that breeding/nesting is completed, and the young
have fledged the nest. Encroachment into the
buffer shall occur only at the discretion of the
qualified biologist on the basis that the
encroachment will not be detrimental to an active
nest. A report summarizing the pre-construction
survey(s) shall be prepared by a qualified biologist
and shall be submitted to the City prior to the
commencement of construction activities.

Future project site plans shall include a statement
acknowledging compliance with the federal
Migratory Bird Treaty Act (MBTA) and California
Fish and Game Code that includes avoidance of
active bird nests and identification of Best
Management Practices to avoid impacts to active
nests, including checking for nests prior to
construction activities during February 1 to
September 15 and what to do if an active nest is
found so that the nest is not inadvertently
impacted during grading or construction activities.

BIO-2 Conduct Pre-Construction Roosting Bats Surveys and Implement Avoidance Measures Prior to Removal Prior to the removal or alteration of trees and
structures that may serve as roosting habitat for
special-status bat species, a qualified biologist shall conduct a focused survey of all trees and structures
to be removed or impacted by construction
activities to determine whether active roosts of
special-status bats are present on site. The survey
shall be conducted during seasonal periods of bat
activity (March 1 through October 15). The biologist
shall have access to all structures and interior
attics, as needed. If a colony of bats is found
roosting in any structure, tree or other habitat,
further surveys, such as night emergent surveys,
shall be conducted sufficient to determine the
species present and the type of roost (day, night,
maternity, etc.).

Tree or structure removal shall be planned for
either the spring or the fall and timed to ensure
The City shall verify that
special status bat species
habitat assessment
surveys and emergence
surveys are conducted
and site-specific roosting
bat protection plan is
prepared, if required, for
development projects
where trees, abandoned
structures, or other
habitat for roosting bats
is present and
construction activities
may occur during
seasonal periods of bat
activity.

Prior to the
commencement of
construction activities
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both suitable conditions for the detection of bats
and adequate time for tree and/or structure
removal to occur during seasonal periods of bat
activity exclusive of the breeding season, as
described below. Trees and/or structures
containing suitable potential bat roost habitat
features shall be clearly marked or identified. If no
bat roosts are found, the results of the survey will
be documented and submitted to the City within 30
days of the survey, after which no further action
will be required.

If day roosts are present, the biologist shall prepare
a site-specific roosting bat protection plan to be
implemented by the contractor following the City’s
approval. The plan shall incorporate the following
guidance as appropriate:  When possible, removal of trees/structures identified as suitable roosting habitat shall be
conducted during seasonal periods of bat
activity, including the following:
a) Between September 1 and about October
15, or before evening temperatures fall
below 45 degrees Fahrenheit and/or more
than 0.5 inch of rainfall within 24 hours
occurs.
b) Between March 1 and April 15, or after
evening temperatures rise above 45
degrees Fahrenheit and/or no more than

0.5 inch of rainfall within 24 hours occurs.
 If a tree /structure must be removed during
the maternity season and is identified as
potentially containing a colonial maternity
roost, then a qualified biologist shall conduct
acoustic emergence surveys or implement
other appropriate methods to further evaluate if the roost is an active maternity roost. Under the biologist’s guidance, the
contractor shall implement measures that
consist of (or exceed) the following:

The City shall ensure that
CDFW has provided
consultation and
approval for bat
mitigation and/or
management plans
created for sites where
special-status bat species
are documented and the
roost site cannot be
avoided by the project.

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a) If it is determined that the roost is not an
active maternity roost, then the roost may
be removed in accordance with the other
requirements of this measure.
b) If it is found that an active maternity roost
of a colonial roosting species is present,
the roost shall not be disturbed during the
maternity season (April 15 to August 31)
or until the maternity roost has dispersed.
 Tree removal procedures shall be
implemented using a two-step tree
removal process. This method is
conducted over two consecutive days
and works by creating noise and
vibration by cutting non-habitat
branches and limbs from habitat trees
using chainsaws only (no excavators or
other heavy machinery) on day one. The
noise and vibration disturbance,
together with the visible alteration of
the tree, is very effective in causing bats
that emerge nightly to feed to not
return to the roost that night. The
remainder of the tree is removed on day
two.
 Prior to the demolition of vacant
structures within the project site, a
qualified biologist shall conduct a
focused habitat assessment of all
structures to be demolished. The habitat
assessment shall be conducted enough
in advance to ensure the
commencement of building demolition
can be scheduled during seasonal
periods of bat activity (see above), if
required. If no signs of day roosting
activity are observed, no further actions
will be required. If bats or signs of day
roosting by bats are observed, a
qualified biologist will prepare specific
recommendations such as partial

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dismantling to cause bats to abandon
the roost, or humane eviction, both to
be conducted during seasonal periods of
bat activity, if required. Should
maternity roosts be observed the roost
shall not be disturbed during the
maternity season (April 15 to August 31)
or until maternity roost has dispersed. If
project schedules do not allow for
maternity season avoidance, a bat
habitat mitigation and monitoring plan
shall be developed to reduce risks to bat
pups and consultation with CDFW would
be required.

If the qualified biologist determines a roost is used
by a large number of bats (large hibernaculum), bat
boxes shall be installed near the project site. The
number of bat boxes installed will depend on the
size of the hibernaculum and shall be determined
through consultation with California Department of
Fish and Wildlife (CDFW). If a maternity colony has
become established, all construction activities shall
be postponed within a 500-foot buffer around the
maternity colony until it is determined by a
qualified biologist that the young have dispersed.

Once it has been determined that the roost is clear
of bats, the roost shall be removed immediately.

Cultural Resources
CR-1 Prepare a Historical Resources Evaluation Prior to Approval for Projects Involving Buildings 45 Years or Older and Implement Mitigation Prior to and During Construction A historic resources evaluation for projects
involving buildings 45 years or older shall be
prepared as follows:
 All properties 45 years of age or older as
deemed appropriate by the San Ramon
Community Development Director shall
be evaluated within their historic
context and documented in a report
meeting the State Office of Historic
Preservation guidelines. The evaluation
shall be prepared by a qualified
architectural historian or historian who
The City shall review and
approve the historical
resources evaluation
report, prepared by a
qualified architectural
historian or historian, for
projects that would alter
or demolish any historical
age features (i.e.,
structures over 45 years
of age)
Prior to project
approval for
development projects
that would alter or
demolish a historical
resource
Periodically City of San
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Planning
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meets the Secretary of the Interior’s
Professional Qualifications Standards in
architectural history or history (as
defined in Code of Federal Regulations,
Title 36, Part 61). The qualified
architectural historian or historian shall
conduct an intensive-level evaluation in
accordance with the guidelines and best
practices promulgated by the State
Office of Historic Preservation to identify
potential historical resources within the
proposed development site. .Such
evaluated properties shall be
documented on Department of Parks
and Recreation Series 523 Forms. The
report shall be submitted to the City for
review and concurrence. If the property
is already listed in the National Register
of Historic Places (NRHP) or California
Register of Historical Resources (CRHR),
the historical resources evaluation
described above shall not be required.
 If historical resources are identified
within the site of a proposed
development, efforts shall be made to
the extent feasible to ensure that
impacts are mitigated. Application of
mitigation shall generally be overseen by
a qualified architectural historian or
historic architect meeting the
Professional Qualification Standards,
unless unnecessary in the circumstances
(e.g., preservation in place). In
conjunction with a development
application that may affect the historical
resource, the historical resources
evaluation report shall also identify and
specify the treatment of characterdefining features and construction activities.
 Efforts shall be made to the greatest
extent feasible to ensure that the

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relocation, rehabilitation, or alteration
of the resource is consistent with the
Secretary of the Interior’s Standards for
the Treatment of Historic Properties
with Guidelines for Preserving,
Rehabilitating, Restoring, and
Reconstructing Historic Buildings.

Application of the Standards shall be
overseen by a qualified architectural
historian or historic architect meeting
the Professional Qualification Standards.

In conjunction with a development
application that may affect the historical
resource, a report identifying and
specifying the treatment of character-
defining features and construction
activities shall be provided to the City for
review and concurrence. As applicable,
the report shall demonstrate how a
project complies with the Standards and
be submitted to the City for review and
approval prior to the issuance of
permits.
 If significant historical resources are
identified on a development site and
compliance with the Standards and or
avoidance is not possible, appropriate
site-specific mitigation measures shall
be established and undertaken.

Mitigation measures may include
documentation of the historical resource
in the form of a Historic American
Building Survey (HABS) report, or
equivalent. The report shall comply with
the Secretary of the Interior’s Standards
for Architectural and Engineering
Documentation and shall generally
follow the HABS Level III requirements,
including digital photographic
recordation, detailed historic narrative
report, and compilation of historic
research. The documentation shall be

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completed by a qualified architectural
historian or historian who meets the
Professional Qualification Standards and
submitted to the City prior to issuance
of any permits for demolition or
alteration of the historical resource.

CR-2 Prepare an Archaeological Resources Assessment prior to Project Approval and Implement Mitigation prior to and during Construction An archaeological resources assessment for
projects involving ground disturbance shall be
prepared as follows:
 Assessments shall include a California Historical
Resources Information System records search
at the Northwest Information Center (NAHC)
and a Sacred Lands File search maintained by
the Native American Heritage Commission. The
records searches will characterize the results of
previous cultural resource surveys and disclose
any cultural resources that have been recorded
and/or evaluated in and around a project site. A
Phase I pedestrian survey shall be undertaken
at a project site that is on previously
undeveloped land in order to locate any surface
cultural materials. By performing a records
search, consultation with the NAHC, and a
Phase I survey, a qualified archaeologist shall be
able to classify a project site as having high,
medium, or low sensitivity for archaeological
resources.
 If the Phase I archaeological survey identifies
resources that may be affected by a project, the
archaeological resources assessment shall also
include Phase II testing and evaluation. If
resources are determined significant or unique
through Phase II testing and site avoidance is
not possible, appropriate site-specific
mitigation measures shall be identified in the
Phase II evaluation. These measures shall
include, but would not be limited to, a Phase III
data recovery program, avoidance, or other
appropriate actions to be determined by a
qualified archaeologist in consultation with the
The City shall review and
approve the
archeological resources
assessment for projects
involving ground
disturbance.

Prior to project for
projects involving
ground disturbance
Periodically City of San
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Engineering
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9.1.f
Packet Pg. 774 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
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City and any interested Tribes, as stated in the
2040 General Plan Tribal Consultation
Implementation Program outlined by Guiding
Policy ENV-5. If significant archaeological
resources cannot be avoided, impacts may be
reduced to less-than-significant levels by adding
fill soils on top of the sites rather than cutting
into cultural deposits. Alternatively, and/or in
addition, a data collection program may be
warranted, including mapping the location of
artifacts, surface collection of artifacts, or
excavation of the cultural deposit to
characterize the nature of the buried portions
of sites. Curation of the excavated artifacts or
samples shall occur as specified by the
archaeologist in consultation with the City and
any interested Tribes. As stated in the 2040
General Plan Tribal Consultation
Implementation Program outlined by Guiding
Policy ENV-5 and Guiding Policy 8.7-G-1, the
final disposition of artifacts not directly
associated with Native American graves shall be
negotiated during consultation with interested
tribes. If Native American tribes do not accept
the artifact, it shall be offered to an institution
staffed by qualified professionals, as
determined by the City Planner. Artifacts
include material recovered from all phases of
work, including the initial survey, testing,
indexing, data recovery, and monitoring.

CR-3 Stop Work in the Event of Unanticipated Cultural Resources Discoveries during Construction If cultural resources are encountered during
ground-disturbing activities for a project, work in
the immediate area shall be halted and an
archaeologist meeting the Secretary of the
Interior’s Professional Qualification Standards for
archaeology in either prehistoric or historic
archaeology shall be contacted immediately to
evaluate the find. If necessary, the evaluation may
require preparation of a treatment plan and
archaeological testing for California Register of
The City shall verify that
the requirement to halt
work in the event
cultural resources are
encountered during
construction are noted in
projects construction
plans and specification
for project involving
ground disturbance. The
Prior to and during
construction
Periodically City of San
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Planning
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City of San
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Engineering

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Historical Resources (CRHR) eligibility. If the
discovery proves to be significant under CEQA and
cannot be avoided by a project, additional work
such as excavating the cultural deposit to fully
characterize its extent, and collecting and curating
artifacts may be warranted to mitigate any
significant impacts to cultural resources. In the
event that archaeological resources of Native
American origin are identified during project
construction, a qualified archaeologist will consult
with the City to begin Native American consultation
procedures.

City shall verify that a
qualified archaeologist is
retained on project sites
whose Phase I
archaeological survey
identifies archaeological
resources that may be
affected. The City shall
review and approve
reports of the findings
and subsequent
evaluations conducted.

Services
Division
CR-4 Suspend Work around Tribal Cultural Resources Identified during Construction In the event that cultural resources of Native
American origin are identified during construction
of a project implemented under the 2040 General
Plan, all earth-disturbing work in the vicinity 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 Americans, 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 mitigation 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. 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.

The City shall verify that
the requirement to halt
work in the event tribal
cultural resources are
encountered during
construction are noted in
projects construction
plans and specification
for project involving
ground disturbance. In
the event of a find, the
City shall consult with
local Native American
Tribes to determine the
nature of the find and
shall confirm a mitigation
plan is prepared and
implemented if the find
is a tribal cultural
resource.

Prior to and during
construction
Periodically City of San
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Engineering
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Geology and Soils and Mineral Resources

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GEO-1 Protect Paleontological Resources
The City of San Ramon shall provide for the
protection of paleontological resources. The City
shall require the following:
 A Qualified Professional Paleontologist
(as defined by SVP14) must be retained
to conduct a paleontological resources
analysis prior to the beginning of
projects involving ground disturbance in
geologic units with high paleontological
sensitivity to determine whether there is
a potential for significant impacts to
paleontological resources.

If potential impacts to paleontological resources
are found to be significant, then a Qualified
Professional Paleontologist shall be retained to
develop and implement a Paleontological
Resources Mitigation Program to ensure that
impacts to paleontological resources are less than
significant.

The City shall review and
approve the
paleontological resources
analysis, prepared by a
Qualified Professional
Paleontologist, for
projects involving ground
disturbance. If required,
the City shall ensure that
a Qualified Professional
Paleontologist prepares
and implements a
Paleontological
Resources Mitigation
Program.

Prior to and during
construction
Periodically City of San
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Greenhouse Gas Emissions
GHG-1 Adopt and Implement a San Ramon Qualified Climate Action Plan and San Ramon CEQA Greenhouse Gas (GHG) Emissions Thresholds The City shall adopt an updated, qualified San
Ramon Climate Action Plan (CAP) by the end of
2024 and include targets that reflect those set by
California Senate Bill 32 to reduce GHG emissions
by 40 percent below the 1990 levels by 2030 and
California Assembly Bill 1279 to achieve carbon
neutrality by 2045. The updated, qualified San
Ramon CAP shall be implemented and
tracked/monitored by the City in accordance with
the CAP-established timeline and details.

The City shall also adopt San Ramon CEQA GHG
Emissions Thresholds of Significance that are
consistent with an updated, qualified San Ramon
Climate Action Plan by the end of 2024 for use in
future CEQA GHG emissions analyses through 2030
and consistent with SB 32. In addition, upon
completion of future climate action plan updates
and as necessary, the City shall update the CEQA
The City shall adopt a
Qualified Climate Action
Plan and CEQA GHG
Emissions thresholds of
for use in future CEQA
GHG emissions analyses
through 2030.

By the end of 2024 Once City of San
Ramon
Planning
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GHG emissions thresholds of significance to be
consistent with each climate action plan update.

Hazards and Hazardous Materials and Wildfire
HAZ-1 Conduct Project Landscape and Slope Design Wildfire Risk Reduction The City shall require projects adjacent to High Fire
Hazard Zones to conduct landscape and slope
design wildfire risk reduction. Project landscape
plans (as made available when project applications
are submitted) shall include fire-resistant
vegetation native to Contra Costa County and/or
the local microclimate of the site and prohibit the
use of fire-prone species especially non-native,
invasive species. Also, if a project site is within a
known landslide area (see Figure 3.5-5 in Section

3.5, Geology and Soils), the site shall be subject to
geotechnical review regarding potential post-fire
slope instability.

The City shall review and
approve landscape plans
for projects adjacent to
High Fire Hazard Zones to
ensure they include
landscape and slope
design wildfire risk
reduction measures. The
City shall ensure that
projects within a
landslide area undergo
geotechnical review
regarding potential postfire slope instability.

Prior to project
approval for projects
adjacent to High Fire
Hazard Zones and
landslide areas
Periodically City of San
Ramon
Planning
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Noise
NOI-1 Include and Implement Construction Noise Reduction Measures To minimize noise during construction, construction
contractors shall implement the following measures
for construction activities conducted within San
Ramon. Construction plans submitted to the City
shall include construction noise analysis and
identify these measures on demolition, grading,
and construction plans submitted to the City. The
City of San Ramon Building Division and/or Public
Works Department shall verify that grading,
demolition, and/or construction plans submitted to
the City include these notations prior to issuance of
demolition, grading and/or building permits.
 Mufflers. During excavation and grading
construction phases, all construction
equipment, fixed or mobile, shall be
operated with closed engine doors and
shall be equipped with properly
operating and maintained mufflers
The City shall ensure that
noise reduction
measures are included
on demolition, grading,
and construction plans
for construction projects.

Prior to issuance of
building permits
Prior to issuance of
grading/site
development permits
Periodically City of San
Ramon
Building
Division
City of San
Ramon
Public Works
Department

9.1.f
Packet Pg. 778 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
2040 General Plan
16 Mitigation Measure Action Required Timing
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consistent with manufacturers’
standards.
 Stationary Equipment. All stationary
construction equipment shall be placed
so that emitted noise is directed away
from the nearest sensitive receivers.
 Equipment Staging Areas. Equipment
staging shall be located in areas that will
create the greatest distance feasible
between construction-related noise
sources and noise-sensitive receivers.
 Smart Back-up Alarms. Mobile
construction equipment shall have smart
back-up alarms that automatically adjust
the sound level of the alarm in response
to ambient noise levels. Alternatively,
back-up alarms shall be disabled and
replaced with human spotters to ensure
safety when mobile construction
equipment is moving in the reverse
direction in compliance with applicable
safety laws and regulations.
 Electrically-Powered Tools and
Facilities. Electrical power shall be used
to run air compressors and similar
power tools and to power any
temporary structures, such as
construction trailers or caretaker
facilities, where feasible.

9.1.f
Packet Pg. 779 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Mitigation Monitoring and Reporting Program
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 Noise Disturbance Coordinator. The
project applicant shall designate a
“noise disturbance coordinator”
responsible for responding to any local
complaints about construction noise.

The disturbance coordinator shall
determine the cause of any noise
complaint and shall require that
reasonable measures be implemented
to correct the problem. A telephone
number for the disturbance coordinator
and the City shall be posted at the
construction site.
 Temporary Noise Barriers. Erect
temporary noise barriers, where
feasible, when construction noise is
predicted to exceed the acceptable
standards (e.g., 80 dBA Leq at residential
receivers, schools or other sensitive
receptors during the daytime) and when
the anticipated construction duration is
greater than is typical (e.g., two years or
greater). Temporary noise barriers shall
be constructed with solid materials (e.g.,
wood) with a density of at least 1.5
pounds per square foot with no gaps
from the ground to the top of the
barrier. If a sound blanket is used,
barriers shall be constructed with solid
material with a density of at least 1
pound per square foot with no gaps
from the ground to the top of the barrier
and be lined on the construction side
with acoustical blanket, curtain or
equivalent absorptive material rated
sound transmission class (STC) 32 or
higher.

NOI-2 Implement Operational Roadway Vehicle Noise Reduction Measures To reduce operational roadway vehicle noise, the
City shall implement a developer fair share
mitigation program to fund the following measures
The City shall develop
and implement a
Prior to approval of
development projects
Once City of San
Ramon
Planning

9.1.f
Packet Pg. 780 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
2040 General Plan
18 Mitigation Measure Action Required Timing
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for projects operated on the following roadway
segments within San Ramon: Dougherty Road
between Bollinger Canyon Road (north) and
Bollinger Canyon Road (South), San Ramon Valley
Boulevard between the northern City limit and
Crow Canyon Road, Camino Ramon between Crow
Canyon Road and Norris Canyon Road, and Camino
Ramon between Norris Canyon Road and Bollinger
Canyon Road. The City shall retain a qualified
acoustical consultant to prepare a San Ramon-wide
Roadway Vehicle Noise Reduction Study that
specifies, at a minimum, the specific locations,
extent, height of sound walls, and other design
details such as “quiet pavement” to reduce
roadway vehicle noise impacts at impacted
roadways throughout San Ramon. The study shall
also include an estimated cost of improvement
along each impacted roadway segment to inform
the developer fair share mitigation program.

Roadway vehicle noise reduction measures may
include, but are not limited to:

A. Sound Barrier Walls. The City shall construct
sound barriers (e.g., walls or solid fences) along
impacted roadways where there are no
driveways that would break continuity, and
along the residential portions or other sensitive
receptor locations of such roadways. The sound
walls would be continuous from grade to top,
with no cracks or gaps, and have a minimum
surface density of four pounds per square foot
and a minimum height of six feet, as measured
from the base elevation; and/or
developer fair share
mitigation program.

The City shall retain a
qualified acoustical
consultant to prepare a
Traffic Noise Reduction
Study
on identified roadway
segments
Services
Division
City of San
Ramon
Engineering
Services
Division

9.1.f
Packet Pg. 781 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Mitigation Monitoring and Reporting Program
19 Mitigation Measure Action Required Timing
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B. Special Roadway Paving. The City shall install
“quiet pavement” roadway improvements,
such as rubberized asphalt or open-grade
asphalt concrete overlays along impacted
roadway segments (Dougherty Boulevard
between Bollinger Canyon Road (north) and
Bollinger Canyon Road (South), San Ramon
Valley Boulevard between the City limit and
Crow Canyon Road, Camino Ramon between
Crow Canyon Road and Norris Canyon Road,
and Camino Ramon between Norris Canyon
Road and Bollinger Canyon Road) where sound
barriers (NOI-2A) are determined not to be
feasible.

NOI-3 Prepare a Noise and Vibration Analysis and Implement Construction Vibration Control Measures and Screening Distances Prior to issuance of a building permit for a project
requiring pile driving during construction a) within
135 feet of fragile structures (historical resources),
100 feet of non-engineered timber and masonry
buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no
plaster); b) a vibratory roller within 40 feet of
fragile historical resources or 25 feet of any other
structure; and/or c) a dozer or other large
earthmoving equipment within 20 feet for a fragile
historical structure or 15 feet of any other
structure, the project applicant shall prepare a
groundborne noise and vibration analysis to assess
and mitigate potential noise and vibration impacts
related to these construction activities. This noise
and vibration analysis shall be conducted by a
qualified and experienced acoustical consultant or
engineer. The vibration levels shall not exceed FTA
architectural damage thresholds (e.g., 0.12 in/sec
PPV for fragile or historical resources, 0.2 in/sec
PPV for non-engineered timber and masonry
buildings, and 0.3 in/sec PPV for engineered
concrete and masonry). If vibration levels would
exceed this threshold, alternative uses such as
drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower
The City shall review and
approve groundborne
noise and vibration
analysis for development
projects meeting the
criteria outlined in the
measure.

The City shall verify that
vibration monitoring is
conducted during
construction of
development projects if
necessary.

Prior to issuance of
building permits for
projects requiring pile
driving
Periodically City of San
Ramon
Planning
Services
Division
City of San
Ramon
Engineering
Services
Division

9.1.f
Packet Pg. 782 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
2040 General Plan
20 Mitigation Measure Action Required Timing
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horsepower earthmoving equipment shall be used.

If necessary, construction vibration monitoring shall
be conducted to ensure FTA vibration thresholds
are not exceeded.

Transportation
TRA-1 Prepare and Implement Construction Traffic Management Plans.

Prior to issuance of building permits, the contractor
for an individual development project that requires
off-site staging, lane closures, or substantial hauling of cut and fill on a local street (i.e., not under
Caltrans’ jurisdiction) shall prepare a Construction
Traffic Management Plan that includes measures
such as, but not limited to, the following as deemed
necessary by the City. The approved Construction
Traffic Management Plan shall be implemented
during construction.
 Provide a temporary traffic signal, if
necessary
 Project Staging Plan to maximize on-site
storage of materials and equipment
 A set of comprehensive traffic control
measures, including scheduling of major
truck trips and deliveries to avoid peakhours; lane closure proceedings; signs, cones, and other warning devices for
drivers; and designation of construction
access routes
 Permitted construction hours
 Location of construction staging
 Identification of parking areas for
construction employees, site visitors,
and inspectors, including on-site
locations
Provisions for street sweeping to remove
construction related debris on public streets
The City shall review and
approve a Construction
Management Plan for
development projects
requiring off-site staging,
lane closures, or
substantial hauling of cut
and fill on a local street
Prior to issuance of
building permits
Prior to issuance of
grading/site
development permits.

Periodically City of San
Ramon
Building
Services
Division
City of San
Ramon
Engineering
Services
Division
TRA-2 Prepare and Implement VMT Reduction Measures
The Contra Costa Transportation Authority’s
(CCTA’s) VMT Analysis for Land Use Projects in
Contra Costa, which is found in Appendix A in
For development
projects that require
mitigation to reduce VMT
Prior to issuance of
building permits
Periodically City of San
Ramon
Planning

9.1.f
Packet Pg. 783 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Mitigation Monitoring and Reporting Program
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CCTA’s Final Technical Procedures (November
2022) describes options for mitigation of VMT
impacts. The first two options below apply to
development projects and plans, and the third
applies at a General Plan area-wide scale.

1. A project applicant shall modify a project’s
characteristics to reduce VMT generated by
such project prior to issuance of an occupancy
permit. This might involve changing the density
or mixture of land uses on a project site, or
changing a project’s location to one that is
more accessible by transit or other travel
modes.

2. A project applicant shall implement
transportation demand management (TDM) or
physical design measures to reduce VMT
generated by a project prior to issuance of an
occupancy permit.

3. The City shall participate in a CCTA-approved
VMT impact fee program and/or VMT
mitigation exchange/banking program, once it
is completed and published by CCTA. (Note that
CCTA is developing such a program for Contra
Costa County.)
When option 2 (TDM plan) is applied for future land
use development projects facilitated by the 2040
General Plan that do not meet CCTA screening
criteria and thresholds, the City shall require
preparation and implementation of a project-level
TDM plan with the following TDM measures.

Table 3.12-4 TDM Measures
CAPCOA Handbook
Measure Types of Projects
T-7: Commute Trip
Reduction Marketing
Employment-based

generated by the project,
the City shall verify that
1) the project’s
characteristics are
modified to reduce VMT
generated by the project
or 2) A TDM plan is
prepared and approved
by the City
The City shall participate
in a CCTA-approved VMT
impact fee program
and/or VMT mitigation
exchange/banking
program
Once a CCTAapproved VMT impact
fee program and/or
VMT mitigation
exchange/banking
program is established
Once
Services
Division
City of San
Ramon
Planning
Services
Division
City of San
Ramon
Engineering
Services
Division

9.1.f
Packet Pg. 784 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
2040 General Plan
22 Mitigation Measure Action Required Timing
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T-8: Provide Ridesharing
Program
Employment-based *Participation in a TMA with ridematching program *Preferential parking policies for carpools
*Promotions and incentives such as gas
cards at carpool formation
T-9: Implement
Subsidized or Discounted
Transit Program
Residential, School,
Employment-based
*Location within 1/2 mile of major transit
stop or high-quality transit corridor
*Participation in Commuter Benefits
Program
*Easy to sign up for incentives
T-11: Provide Employer
Sponsored Vanpool /
Point-to-Point Shuttles
Employment-based *Coordinate logistics of vanpool program *Cover vanpool fares for riders through
commute benefits program
*Promote and facilitate vanpool creation
T-12: Price Workplace
Parking
Employment-based *Location within 1/2 mile of transit
service
*Priced at least $5 per day
*On-street parking nearby is not readily
available
T-13: Implement
Employee Parking
Cashout
Employment-based *Parking is provided as benefit
*On-street parking nearby is not readily
available
*Participants pledge to not drive to work
T-16: Unbundle
Residential Parking Costs
Residential *On-street parking nearby is not readily
available
*All parking is priced at a rate at least $30
per month
T-23: Community-Based
Travel Planning
Residential, Retail, School *Proactive outreach to all households in service area or project
*Program Coordinator designated as lead
in promoting non-auto transportation
T-10: Provide End-of-Trip
Bicycle Facilities
All Projects *Provision of secure bicycle parking in the form of lockers, a locked storage room, or
an attended storage facility
*(For non-residential): Provision of
lockers, showers, and changing rooms

9.1.f
Packet Pg. 785 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Mitigation Monitoring and Reporting Program
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T-21A: Implement
Carshare Program /
Provide Carshare Parking
All Projects *Dedicate parking for carshare vehicles
*Identify carshare partner
T-15 Reduce Parking
Supply
Residential *On-street parking nearby is not readily
available
T-18: Provide Pedestrian
Network Improvements:

All Projects Completion of one or more projects
identified in the San Ramon Bicycle
Master Plan T-19-A and T-19-B:

Construct or Improve
Bicycle Facility/Bicycle
Boulevard
All Projects
T-20: Expand Bikeway
Network
All Projects
T-26 Increase Transit
Frequency
All Projects in PDAs Increase the frequency of transit service by providing funding for more operators
and vehicles
T-25 Increase Transit
Coverage
All Projects Expand transit service to areas without
access to it, or expand to later/earlier
hours.

T-23: Community-Based
Travel Planning
Residential, Retail, School *Proactive outreach to all households in service area or project
*Program Coordinator designated as lead
in promoting non-auto transportation
T-22:

Bikeshare/Scootershare
All Projects in PDAs Fund and implement program providing e-bikes or scooters available on demand.

Ideally pursue a "dockless" system.

Free E-Bike Program All Projects Provide e-bikes free of charge to households pledging to reduce vehicle
trips
Source: Handbook for Analyzing Greenhouse Gas Emissions Reductions, Assessing Climate Change Vulnerabilities, and Advancing Health and Equity (CAPCOA, December 2021).

Feasible options listed under Table 3.12-4 to reduce
VMT below CCTA thresholds shall be implemented
for individual projects facilitated by the 2040
General Plan. VMT reduction measures shall be
included at project design review and be reviewed
and approved by the City prior to issuance of
construction permits.

9.1.f
Packet Pg. 786 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
2040 General Plan
24 Mitigation Measure Action Required Timing
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Utilities and Service Systems
UTIL-1 Provide Adequate Water Supply and Treatment for Projects To ensure adequate water supply, as well as
consistency with existing utility providers and State
regulations, the City shall implement the following
measures:
 Infrastructure Maintenance.

Collaborate with water providers in their
efforts to maintain wastewater
conveyance, treatment, and disposal
infrastructure in good working
conditions within San Ramon.
 Water Services Requirement. Require
that water services for new
developments do not negatively affect
service to existing uses.
 Water Provider Coordination.

Coordinate with water providers to
ensure that new proposed development
can be adequately served by the water
supply system prior to approving the
development.
 Commercial and Business Water
Conservation. Require new or
remodeled commercial and industrial
development to make changes that
conserve water, to the extent feasible.

This could include utilizing efficient
plumbing fixtures, installing droughttolerant and water-wise landscaping, and harvesting rainwater for irrigation.
 Water Conservation Measures. Reduce
the amount of water used by
development by requiring compliance
with adopted water conservation
measures.

The City shall coordinate
with water providers to
ensure adequate water
supply treatment is
available within the City.

The City shall ensure
adequate water supplies
are available for
development projects
within the City.

Ongoing/Prior to
project approval
Periodically City of San
Ramon
Planning
Services
Division
UTL-2 Provide Adequate Wastewater Infrastructure and Treatment for Projects.

9.1.f
Packet Pg. 787 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Mitigation Monitoring and Reporting Program
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To ensure adequate wastewater infrastructure and
treatment, as well as consistency with existing
utility providers and State regulations, the City shall implement the following measures:
□ Infrastructure Maintenance. Infrastructure
Maintenance. Collaborate with Central San
and Dublin San Ramon Services District in
their efforts to maintain wastewater
conveyance, treatment, and disposal
infrastructure in good working conditions
within San Ramon.
□ New Development. Coordinate the review
of development proposals with Central San
to ensure that new development can be
adequately served.
□ Wastewater Services Requirement.

Require that wastewater services for new
development do not negatively affect
service to existing uses.
□ Capital Improvements Program. When
updating the Capital Improvements
Program, identify and include the
following:
– Projects that could also support green
infrastructure improvements.
– Street improvements consistent with
emergency vehicle access standards.

City-sponsored projects necessary to maintain or
improve levels of performance.

The City shall coordinate
with Central San to
ensure adequate
conveyance, treatment,
and disposal
infrastructure is available
within the City. The City
shall ensure for
development projects
within the City can be
adequately served by
wastewater services.

Ongoing/Prior to
project approval
Periodically City of San
Ramon City
Council

9.1.f
Packet Pg. 788 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public City of San Ramon
2040 General Plan Update
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9.1.f
Packet Pg. 789 Attachment: F. Planning Commission Resolutions No. 13-23 and 14-23 (2023-40 : City Council Public Hearing: Draft General Plan 2040 Update Resolution No. 14-23