City Council and Authorities Concurrent
June 7, 2022

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable
2 -
Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-9
Freedom Circle Focus Area Plan/Greystar General Plan Amendment MMRP Impacts
Significance
Without
Mitigation Mitigation Measures
Mitigation
Responsibility
Significance
With
Mitigation

AESTHETICS
Impact 4-1: Effects on Scenic Vistas—Plan
Area

LS N/A N/A N/A
Impact 4-2: Effects on Scenic Vistas—
Greystar Project

LS N/A N/A N/A
Impact 4-3: Impacts on Existing Visual
Character and Quality—Plan Area. New
development throughout the Plan Area could
include a combination of residential, retail,
office, and open space uses. New uses could
include combinations of, for example,
residential, retail, restaurant, and office uses in
single or mixed-use buildings. The Freedom
Circle Focus Area Plan is, by definition, a
generalized plan. As stated in the General
Plan, a comprehensive planning study is
required for future focus areas, which would
include, among other items, “…appropriate
design guidelines for private development,
public facilities, streetscapes and transitions to
adjacent land uses” (Prerequisite Policy 5.1.1-
P8). Although the Focus Area Plan includes
goals and policies intended to provide direction
for minimizing visual impacts from future
development, these general goals and policies
lack the detail and enforceability that would be
S Mitigation 4-3. As required by the City of Santa
Clara General Plan, the City shall prepare a
future comprehensive planning study for the
Freedom Circle Focus Area Plan (whether a
specific plan or another type of plan) and it shall
include the following performance and design
standards and guidelines that apply to all future
individual development proposals in the Plan
Area to minimize visual impacts by: (a) those
enhancing form and design in the Plan Area; (b)
those incorporating land use densities and
associated changes in intensity consistent with
the General Plan; (c) those encouraging street
trees and landscaping along corridors to beautify
the streetscape; (d) those coordinating signage
color, shape, and graphic styles with the City’s
signage system; (e) those including standards to
ensure compatibility of new development with
nearby existing and planned development; (f)
those establishing standards related to building
form, mass, and scale that enhance the
City LS
_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable
2 -
Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-10
Impacts
Significance
Without
Mitigation Mitigation Measures
Mitigation
Responsibility
Significance
With
Mitigation
included in the comprehensive planning study,
and therefore present potential conflicts with
applicable General Plan policies governing
scenic quality. This represents a potentially
significant impact.
pedestrian realm and provide transitions to
adjacent lower-density development and public
spaces; (g) those including guidelines and
standards for pedestrian amenities; and (h)
those fostering site design so that building height
and massing would not overshadow new parks
and plazas and/or interfere with solar collectors.

Incorporation of such performance and design
standards and guidelines in the required
comprehensive planning study for the Plan Area
would minimize conflicts with General Plan
policies pertaining to visual character.

Therefore, implementation of this mitigation
would reduce this impact to a less-than-
significant level.

Impact 4-4: Impacts on Existing Visual
Character and Quality—Greystar Project

LS N/A N/A N/A
Impact 4-5: Project Light and Glare
Effects—Plan Area

LS N/A N/A N/A
Impact 4-6: Project Light and Glare
Effects—Greystar Project

LS N/A N/A N/A

AIR QUALITY
Impact 5-1: Conflict with 2017 Clean Air
Plan – Freedom Circle Focus Area Plan

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-11

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 5-2: Conflict with 2017 Clean Air
Plan – Greystar General Plan Amendment

LS N/A N/A N/A
Impact 5-3: Result in a Cumulatively
Considerable Net Increase in Criteria
Pollutants for which the Region is Non-
Attainment – Freedom Circle Focus Area
Plan. Implementation of the Freedom Circle
Focus Area Plan could result in growth in the
Plan Area that exceeds the level of growth
accounted for in the City’s General Plan and,
therefore, could generate a cumulatively
considerable net increase in criteria air
pollutants for which the region is in non-
attainment. This represents a potentially
significant impact.

S Mitigation Measure 5-3A: Implement
BAAQMD Basic Construction Mitigation
Measures. The City shall require new
development projects occurring under
implementation of the Freedom Circle Focus
Area Plan to implement the BAAQMD’s Basic
Control Mitigation Measures to address fugitive
dust emissions that would occur during
earthmoving activities associated with project
construction. These measures include:

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

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

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

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

5. All roadways, driveways, and sidewalks
to be paved shall be completed as soon
as possible. Building pads shall be laid
City;
Individual
project
applicants
SU

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-12

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
as soon as possible after grading unless
seeding or soil binders are used.

6. Idling times shall be minimized either by
shutting equipment off when not in use
or reducing the maximum idling time to 5
minutes (as required by the California
airborne toxics control measure Title 13,
Section 2485 of California Code of
Regulations [CCR]). Clear signage shall
be provided for construction workers at
all access points.

7. All construction equipment shall be
maintained and properly tuned in
accordance with manufacturer’s
specifications. All equipment shall be
checked by a certified mechanic and
determined to be running in proper
condition prior to operation.

8. Post a publicly visible sign with the
telephone number and person to contact
at the City regarding dust complaints.

This person shall respond and take
corrective action within 48 hours. The Air
District’s phone number shall also be
visible to ensure compliance with
applicable regulations.

Mitigation Measure 5-3B: Require a Project-
level Construction Assessment for New
Development Proposed Under
Implementation of the Freedom Circle Focus
Area Plan. The City shall require applicants to
City;
Individual
project
applicants
SU

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-13

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
submit a quantitative project-level construction
criteria air pollutant and toxic air contaminant
emissions analysis for future development
proposed under implementation of the Freedom
Circle Focus Area Plan. The estimated
construction criteria air pollutant and toxic air
contaminant emissions shall be compared
against the thresholds of significance maintained
by the Bay Area Air Quality Management District
(BAAQMD) and, if emissions are shown to be
above BAAQMD thresholds, the City shall
require the implementation of mitigation to
reduce emissions below BAAQMD thresholds or
to the maximum extent feasible. Mitigation
measures to reduce emissions could include, but
are not limited to:

 Selection of specific construction equipment
(e.g., specialized pieces of equipment with
smaller engines or equipment that will be
more efficient and reduce engine runtime);
 Requiring equipment to use alternative fuel
sources (e.g., electric-powered and liquefied
or compressed natural gas), meet cleaner
emission standards (e.g., U.S. EPA Tier IV
Final emissions standards for equipment
greater than 50-horsepower), and/or utilizing
added exhaust devices (e.g., Level 3 Diesel
Particular Filter);
 Minimizing the idling time of diesel-powered
construction equipment to two minutes;

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-14

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
 Requiring that all construction equipment,
diesel trucks, and generators be equipped
with Best Available Control Technology for
emission reductions of NOx and PM;
 Requiring all contractors use equipment that
meets CARB’s most recent certification
standard for off-road heavy-duty diesel
engines; and
 Application of Low-VOC paints to interior
and/or exterior surfaces (e.g., paints that
meet SCAQMD Rule 1113 “Low-VOC” or
“Super-Compliant” requirements).

Mitigation Measure 5-3C: Use Low- and
Super Compliant VOC Architectural Coatings
During Operational Activities. The City shall
require the use of Low- and Super-Compliant
VOC Architectural Coatings in maintaining
buildings in Freedom Circle Focus Area Plan
through Covenants Conditions and Restrictions
(CC&Rs) and Ground Lease. Developed parcels
shall require within their CC&Rs and/or ground
leases requirements for all future interior and
exterior spaces to be repainted with architectural
coatings that meet the “Low-VOC” or “Super-
Compliant” requirements. “Low-VOC” refers to
paints that meet the more stringent regulatory
limits of South Coast Air Quality Management
District AQMD Rule 1113. “Super-Compliant”
refers to paints that have been reformulated to
levels well below the “Low-VOC” limits.

City;
Individual
project
applicants
SU

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-15

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Mitigation Measure 5-3D: Implement TDM
Program. Proposed residential and office land
uses within the Freedom Circle Focus Area Plan
shall prepare and implement Transportation
Demand Management (TDM) programs that
achieve a minimum reduction in vehicle miles
traveled (VMT) of 20 percent compared to
baseline conditions (i.e., without internal or
external reductions accounted for, such as
geographic location, land use interconnectivity,
etc.), with at least 10 percent of the reduction
coming through project-specific TDM measures
(e.g., transit subsidies, telecommuting options,
etc.).

Even with implementation of these measures,
this impact would remain significant and
unavoidable.

City;
Individual
project
applicants
SU
Impact 5-4: Result in a Cumulatively
Considerable Net Increase in Criteria
Pollutants for which the Region is Non-
Attainment – Greystar General Plan
Amendment. Implementation of the Greystar
General Plan Amendment / Project could result
in the emission of criteria air pollutants that
have the potential to exceed BAAQMD
thresholds of significance. These activities
represent a potentially significant impact.

S Mitigation Measure 5-4A: See Mitigation
Measure 5-3A.

Mitigation Measure 5-4B: Use Low- and
Super Compliant VOC Architectural Coatings
During Construction. During construction, the
City shall require the Greystar Project use
architectural coatings for exterior applications
that meet “Low-VOC” or “Super-Compliant”
standards, as defined in South Coast Air Quality
Management District AQMD Rule 1113. “Super-
Compliant” refers to paints that have been
reformulated to levels well below the “Low-VOC”
Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-16

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
limits. This impact would be less than
significant with mitigation incorporated.

Impact 5-5: Generate Toxic Air
Contaminant Emissions that Expose
Sensitive Receptors to Substantial Pollutant
Concentrations During Construction –
Freedom Circle Focus Area Plan.

Implementation of the Freedom Circle Focus
Area Plan would result in construction activities
over the next approximately 20 years that
generate toxic air contaminant emissions and
could expose sensitive receptors to substantial
pollutant concentrations. These activities
represent a potentially significant impact.

S Mitigation Measure 5-5: See Mitigation
Measure 5-3B.

Even with implementation of these measures,
this impact would remain significant and
unavoidable.

City;
Individual
project
applicants
SU
Impact 5-6: Expose Sensitive Receptors to
Substantial Operational Pollutant
Concentrations – Freedom Circle Focus
Area Plan

LS N/A N/A N/A
Impact 5-7: Expose Sensitive Receptors to
Substantial Pollutant Concentrations –
Greystar General Plan Amendment

LS N/A N/A N/A
Impact 5-8: Odors – Freedom Circle Focus
Area Plan

LS N/A N/A N/A
Impact 5-9: Odors – Greystar General Plan
Amendment

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-17

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

BIOLOGICAL RESOURCES
Impact 6-1: Impacts on Special-Status
Species, Riparian Habitat, Sensitive Natural
Communities, and Wetlands

LS N/A N/A N/A
Impact 6-2: Potential Impacts on
Threatened and Endangered Species
Habitat. Because biological resources are
mobile and may colonized or relocate, even
within built structures, before project work
begins, the City would evaluate whether each
individual, future project application (with the
exception of the Greystar site [Ground-truthing
of the biological resources on the Greystar
property site on the December 12, 2020 site
visit provided no evidence that further
biological surveys would be required to be in
compliance with this EIR’s mitigation
measures, as the site contained no vegetation,
no aquatic resources, is regularly disked, and
did not contain any small mammal burrows.])
would be required to prepare a biological
resource survey for City review prior to
approval of any development. This is to ensure
that any future project activities within the
Focus Plan Area that have the potential to
degrade the habitat of any threatened or
endangered species are evaluated according
to Policy 5.10.1‐P1 of the Santa Clara General
Plan (see “Regulatory Setting” above).

Disregarding City evaluation of the need for
S Mitigation 6-2. Upon receiving applications for
projects within the project area, the City shall
evaluate the need for a specific biological
resource survey of the project area and adjacent
area that may be indirectly impacted by project
work. If no biological resources are determined
to be at risk for an individual project (i.e.,
potential for bird and bat species, within and
directly adjacent to the project area, to occur
and/or be affected by project activities is
negligible), no further survey shall be required.

However, if the City determines that biological
resources within the proposed project area
require further analysis, the project proponent
shall be required to conduct a biological
resource survey of the habitat and special-status
species that may be impacted by project
activities, either directly or indirectly. A report
shall be provided to the City detailing survey
methods, results, performance standards, and
avoidance and minimization measures required
to protect any special-status species with
potential to be impacted, consistent with the
regulatory agency protocols. Implementation of
this measure would reduce the impact to a less-
than-significant level.

City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-18

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
further biological resource surveys would be in
violation of City policy and is therefore
considered a potentially significant impact.

Impact 6-3: Potential Impacts on Special-
Status Plants. There is a low potential for
Congdon’s tarplant (Centromadia parryi ssp.
congdonii; California Rare Plant Rank 1B.2)
and arcuate bush mallow (Malacothamnus
arcuatus; California Rare Plant Rank 1B.2) to
occur within the project area (with the
exception of the Greystar site, which has been
confirmed not to contain these plant species) ,
especially if the area is left undisturbed for a
long period of time (i.e., a year or longer) and
plants are able to colonize the project site.

Without a proactive mitigation procedure in
place, Plan implementation and any future
projects planned within the Focus Area Plan
could inadvertently result in the removal of
special-status plants. This is considered a
potentially significant impact.

S Mitigation 6-3. Before any project work within
the project area, including the Greystar project
site, a qualified botanist shall conduct site-
specific, focused surveys according to CDFW
guidelines to determine presence or absence of
special-status plant species on the individual
project site and any adjacent potential area of
disturbance. A comprehensive, site-wide survey
should be conducted within May to September
before project work begins, to encompass the
Congdon’s tarplant and arcuate bush mallow’s
blooming periods. Following the completion of
the surveys, a survey results report shall be
prepared and provided to the City. This report
should include, but should not be limited to, the
following: (1) a description of the survey
methodology; (2) a discussion of the survey
results; and (3) a map showing the survey area
and the location of any special-status plants
encountered. If no rare plants are found, then
no further mitigation would be required.

If rare plants are found during the survey, the
number of individuals present shall be
documented, and the limits of population shall
be marked with flagging. The flagged border of
the population shall be avoided by construction
personnel for the duration of the project. If the
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-19

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
species cannot be avoided or may be indirectly
impacted, the applicant shall notify CDFW to
discuss avoidance, minimization, and other
measures as appropriate for each species
population, including measures to be taken and
protocols to be followed if special-status plants
are inadvertently disturbed during construction
activities.

CDFW may require the preparation and
implementation of a mitigation plan that details
avoidance, preservation, and/or compensation
for the loss of individual special-status plant
species. Mitigation may include the purchase of
mitigation bank credits, preserving and
enhancing existing on-site populations, creation
of off-site populations through seed collection
and/or transplantation and monitoring these
populations to ensure their successful
establishment, and/or preserving occupied
habitat off-site in perpetuity. Specific amount and
method of mitigation and/or credits shall be
determined in formal consultation with CDFW
and/or USFWS.

Implementation of this measure would reduce
the impact to a less-than-significant level.

Impact 6-4: Potential Impacts on Nesting
Birds or Roosting Bats. The Federal
Migratory Bird Treaty Act and California Fish
and Game Code sections 3503, 3503.5, 3513,
S Mitigation 6-4. The demolition of any buildings,
disturbance of gravel substrate, and/or removal
of trees, shrubs, or weedy vegetation shall be
avoided during the February 1 through August
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-20

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
3800, and 4150 protect migratory and nesting
birds, as well as roosting bats. Although the
project does not specify which trees or
buildings might be removed under individual
projects facilitated by the Plan, trees (potential
nesting and roosting habitat) or buildings could
be disturbed or removed by Plan
implementation. The possibility of removing
trees and/or buildings that contain nests or
roosting bats is identified here as a potentially
significant impact. Any direct removal of trees
or indirect disturbance by construction or
operational activities during the nesting season
that causes nest abandonment and/or loss of
reproductive effort (killing or abandonment of
eggs or young) is considered a "take."

There is a low potential for burrowing owl
(Athene cunicularia; California species of
special concern), white-tailed kite (Elanus
leucurus; California Fully-Protected Species),
pallid bat (Antrozous pallidus), and
Townsend’s big-eared bat (Corynorhinus
townsendii; California species of special
concern) to utilize the landscaped habitat
within the project area for roosting and/or
nesting, especially if the area is left
undisturbed for a long period of time. In
addition, many common bird species without a
special status, though protected by the MBTA,
MBPA, and California Fish and Game Code
(CFGC), may utilize buildings, gravel
31 bird nesting period to the extent possible. If
no demolition, gravel disturbance, vegetation, or
tree removal is proposed during the nesting
period, no further action is required. If it is not
feasible to avoid the nesting period, the project
applicant shall retain a qualified wildlife biologist
to conduct a survey for nesting birds at most 14
days prior to the start of removal of trees,
shrubs, grassland vegetation, or buildings,
including prior to grading or other construction
activity. If demolition of buildings, disturbance of
gravel substrate, or vegetation removal efforts
do not begin within the 14 days following the
nesting bird survey, another survey shall be
required. The area surveyed shall include all
construction sites, access roads, and staging
areas, as well as reasonably accessible areas
within 150 feet outside the boundaries of the
areas to be cleared or as otherwise determined
by the biologist and dependent on species’ life
history requirements.

If an active nest is discovered in the areas to be
directly physically disturbed, or in other habitats
within the vicinity of construction boundaries and
may be disturbed by construction activities (as
determined by the qualified biologist), clearing
and construction shall be postponed within a
species-specific no-work buffer (to be
determined by the qualified biologist and based
on the species life history and regulatory
requirements) until the biologist has determined

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-21

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
substrates, and the landscaped vegetation
within the project area for nesting, foraging,
and roosting. Common bat species protected
by the CFGC may also rarely utilize vegetation
or roof tiles within the project area for individual
roosting. Without a proactive mitigation
procedure in place, Plan implementation could
inadvertently result in the removal of existing
trees containing nests or eggs of migratory
birds, raptors, or bird species during the
nesting season, or roosting bats, which would
be considered unlawful take under the MBTA
and the CFGC (see Regulatory Setting above).

This is considered a potentially significant
impact.
that the young have fledged (left the nest), the
nest fails, or the nest is otherwise determined to
be inactive by the biologist (i.e., predation).

To avoid impacts to roosting bats that may rarely
utilize the project area vegetation, roof tiles,
and/or vacant buildings for day roosting, the
project applicant shall retain a qualified wildlife
biologist to conduct a survey for roosting bats no
sooner than 14 days prior to the start of
demolition of any vacant buildings left with entry
and egress points accessible to bats or removal
of suitable bat roosting vegetation. If demolition
of buildings or vegetation removal efforts do not
begin within the 14 days following the roosting
bat survey, another survey shall be required. If
roosting bats are detected, the biologist shall
enact a minimum of a 150-foot no-work buffer
and confer with CDFW to determine potential
roost protection or roost eviction practices. After
conferring with CDFW, the protective buffer may
be adjusted based on specific roost needs. Once
bats have been suitably protected by a buffer
and/or safely evicted from roosting sites (as
approved by CDFW, avoiding take as defined by
CESA and the CFGC), construction may resume
outside the buffered area.

A nesting bird and roosting bat survey report of
the methods and results of the pre-project
survey will be submitted to the City for review
and approval prior to commencement of

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-22

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
construction activities for individual projects.

Any additional construction monitoring, as
determined through any necessary
coordination/discretionary approvals with the
resource agencies, will be documented per
requirements set forth in an approved mitigation
monitoring and reporting program for the entirety
of the project.

Implementation of this measure would reduce
the impact to a less-than-significant level.

Impact 6-5: Potential Impacts on Protected
Trees, Plants, and Shrubs

LS N/A N/A N/A

CULTURAL AND HISTORIC RESOURCES
Impact 7-1: Destruction/Degradation of
Historic Resources—Plan Area. There may
be one or more properties or features within
the Focus Area Plan Area, now or in the future,
that meets the CEQA definition of a historic
resource, including properties or features
eligible for listing in a local, State, or Federal
register of historic resources. Future
development projects in the Focus Area Plan
Area, which would be required to be consistent
with the standards and guidelines incorporated
in a subsequent comprehensive planning study
(such as a specific plan) adopted by the City to
guide Plan Area development, may ultimately
cause substantial adverse changes in the
S Mitigation 7-1. For any individual discretionary
project under the subsequent comprehensive
planning study (such as a specific plan) adopted
by the City to guide Plan Area development that
the City determines may involve a property that
contains a potentially significant historic
resource, the resource shall be assessed by a
professional who meets the Secretary of the
Interior's Professional Qualifications Standards
to determine whether the property is a significant
historic resource and whether or not the project
may have a potentially significant adverse effect
on the historic resource. If, based on the
recommendation of the qualified professional,
the City determines that the project may have a
City;
Individual
project
applicants
SU

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-23

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
significance of one or more such historic
resources. Substantial adverse changes that
may occur include physical demolition,
destruction, relocation, or alteration of one or
more historic resources or its immediate
surroundings such that the resource is
"materially impaired." The significance of a
historic resource would be considered
potentially "materially impaired" when and if an
individual future development project proposes
to demolish or materially alter the physical
characteristics that justify the determination of
its significance (CEQA Guidelines section
15064.5[b]). Such adverse changes in the
significance of a CEQA-defined historic
resource would be a significant impact.
potentially significant effect, the City shall require
the applicant to implement the following
mitigation measures:

(a) Adhere to at least one of the following
Secretary of the Interior’s Standards:1

 Secretary of Interior's Standards for the
Treatment of Historic Properties with
Guidelines for Preserving, Rehabilitating,
Restoring, and Reconstructing Historic
Buildings; or

 Secretary of Interior's Standards for
Rehabilitation and Guidelines for
Rehabilitating Historic Buildings.

The qualified professional shall make a
recommendation to the City as to whether the
project fully adheres to the Secretary of the
Interior’s Standards, and any specific
modifications necessary to do so. The final
determination as to a project's adherence to the
Standards shall be made by the City body with
final decision-making authority over the project.

Such a determination of individual project
adherence to the Secretary of the Interior’s
Standards will constitute mitigation of the project

1Under the CEQA Guidelines (section 15064.5[b][3]), a project's adverse impact on a historic resource generally can be mitigated to a less - than-significant level by following either of these standards.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-24

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
historic resource impacts to a less-than-
significant level (CEQA Guidelines section
15064.5).

(b) If the City determines that measure (a) is not
feasible, the historic resource shall be moved to
a new location compatible with the original
character and use of the historic resource, and
its historic features and compatibility in
orientation, setting, and general environment
shall be retained, such that a substantial
adverse change in the significance of the historic
resource is avoided.1 Implementation of
measure (b) would reduce the impact to a less-
than-significant level.

If the City determines that neither measure (a)
nor measure (b) is feasible, to the extent
required by CEQA, additional analysis shall be
conducted in accordance with CEQA Guidelines
Section 15064.5 and 15162, particularly in order
for specific project alternatives to be designed
and evaluated. If the City determines that

1One example of a substantial adverse change would be the loss of eligibility for listing on the California Register. The State Historical Resources Code encourages the retention of historic resources on-site and discourages the non-historic grouping of historic buildings into parks or districts.

However, it is recognized that moving a historic building, structure, or object is sometimes necessary to prevent its destruction. Therefore, a moved building, structure, or object that is otherwise eligible may be listed in the California Register if it was moved to prevent its demolition at its former location and if the new location is compatible with the original character and use of the historic resource. A historic resource should retain its histor ic features and compatibility in orientation, setting, and general environment. (California Office of Historic Preservation, California Register and National Register: A Comparison, Technical Assistance Series 6; Sacramento, CA: California Department of Parks and Recreation, 2001)

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-25

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
neither measure (a) nor (b) is found to be
feasible, then the City shall, as applicable and to
the extent feasible, implement the following
measures in the following order:

(c) Document the historic resource before any
changes that would cause a loss of integrity and
loss of continued eligibility. The documentation
shall adhere to the Secretary of the Interior's
Standards for Architectural and Engineering
Documentation. The level of documentation
shall be proportionate with the level of
significance of the resource. The documentation
shall be made available for inclusion in the
Historic American Building Survey (HABS) or the
Historic American Engineering Record (HAER)
Collections in the Library of Congress, the
California Historical Resources Information
System (CHRIS), and the Bancroft Library, as
well as local libraries and historical societies.

(d) Retain and reuse the historic resource to the
maximum feasible extent and continue to apply
the Secretary of the Interior’s Standards to the
maximum feasible extent in all alterations,
additions, and new construction.

(e) Through careful methods of planned
deconstruction to avoid damage and loss,
salvage character-defining features and
materials for educational and interpretive use on-
site, or for reuse in new construction on the site

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-26

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
in a way that commemorates their original use
and significance.

(f) Interpret the historical significance of the
resource through a permanent exhibit or
program in a publicly accessible location on the
site or elsewhere within the Plan Area.

Implementation of measures (b), (c), (d), (e),
and/or (f) would reduce a significant impact on
historic resources, but not to a less-than-
significant level. Without knowing the
characteristics of the potentially affected historic
resource or of the future individual development
proposal, the City cannot determine with
certainty that measure (a) or (b) above would be
considered feasible. Consequently, this impact
is currently considered significant and
unavoidable.

Impact 7-2: Destruction/Degradation of
Historic Resources—Greystar Project

LS N/A N/A N/A
Impact 7-3: Potential for Disturbance of
Buried Archaeological Resources, Including
Human Remains, and Tribal Cultural
Resources—Plan Area. Development
facilitated by the subsequent comprehensive
planning study (such as a specific plan) could
disturb unrecorded sensitive archaeological
resources or tribal cultural resources in the

S Mitigation 7-3. During the City’s standard
project-specific review process for all future,
discretionary, public improvement and private
development projects under the subsequent
comprehensive planning study (such as a
specific plan) adopted by the City to guide
development in the Plan Area, the City shall
determine the possible presence of, and the

City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-27

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Plan Area. This possibility represents a
potentially significant impact.
potential for new or substantially more severe
impacts of the action on, archaeological
resources and tribal cultural resources. The City
shall require individual project applicants or
environmental consultants to contact the
California Historical Resources Information
System (CHRIS) to determine whether the
particular project is located in a sensitive area.

Future discretionary development projects that
CHRIS determines may be located in a sensitive
area – i.e., on or adjoining an identified
archaeological site – shall proceed only after the
project applicant contracts with an archaeologist
who meets the Secretary of the Interior’s
Professional Qualifications Standards, to
conduct a determination in regard to cultural
values remaining on the site and warranted
mitigation measures, as described directly
below.

In general, to make an adequate determination
in these instances, the archaeologist shall
conduct a preliminary field inspection to (1)
assess the amount and location of visible ground
surface, (2) determine the nature and extent of
previous impacts, and (3) assess the nature and
extent of potential impacts. Such field inspection
may demonstrate the need for some form of
additional subsurface testing (e.g., excavation by
auger, shovel, or backhoe unit) or, alternatively,
the need for on-site monitoring of subsurface
activities (i.e., during grading or trenching).

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-28

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

In addition, the City shall continue to notify the
Native American tribes traditionally and culturally
affiliated with the Plan Area of the discretionary,
public improvement and private development
projects if those proposed improvements or
projects are subject to a CEQA Negative
Declaration (including Mitigated Negative
Declaration) or Environmental Impact Report
(EIR), in accordance with California Assembly
Bill 52, and if a Native American tribe requests
consultation, conduct a good faith consultation.

Following field inspection and completion of all
necessary phases of study as determined by the
archaeologist and the City, damage to any
identified archaeological resources shall be
avoided or mitigated to the maximum extent
possible. Preservation in place to maintain the
relationship between the artifact(s) and the
archaeological context is the preferred manner
of mitigating impacts on an archaeological site.

Preservation may be accomplished by:

 Planning construction to avoid the
archaeological or tribal cultural site;

 Incorporating the site within a park, green
space, or other open space element;

 Covering the site with a layer of chemically
stable soil; or

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-29

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

 Deeding the site into a permanent
conservation easement.

When in-place mitigation is determined by the
City to be infeasible, a data recovery plan, which
makes provisions for adequate recovery of
culturally or historically consequential
information about the site (including artifacts
discovered on the site), subject to review and
approval by the City, shall be prepared and
adopted prior to any excavation being
undertaken. Such studies shall be submitted to
the CHRIS Northwest Information Center. If
Native American artifacts are indicated, the
studies shall also be submitted to the Native
American Heritage Commission (NAHC).

CHRIS and NAHC are recognized as experts in
their respective disciplines.

Identified cultural resources shall be recorded on
form DPR 422 (archaeological sites). Mitigation
measures recommended by these two groups
(CHRIS and NAHC), as reviewed and approved
by the City, shall be undertaken prior to and
during construction activities. Although the
precise details of the mitigation measures would
be specific to the particular project site, the
measures shall be consistent with the avoidance
and mitigation strategies described in this
programmatic mitigation measure.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-30

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
A data recovery plan and data recovery for a
historic resource shall not be required if the City
determines that testing or studies already
completed have adequately recovered the
necessary data, provided that the data have
already been documented in an EIR or are
available for review at the CHRIS Northwest
Information Center (CEQA Guidelines section
15126.4[b]).

Resource identification training procedures shall
be implemented for construction personnel,
conducted by an archaeologist who meets the
Secretary of the Interior’s Professional
Qualifications Standards. In the event that
subsurface cultural resources are otherwise
encountered during approved ground-disturbing
activities for a Plan Area construction activity,
work within 50 feet shall be stopped and a
qualified archaeologist retained to evaluate the
finds following the procedures described above.

Project personnel shall not collect cultural
resources. Although work may continue beyond
50 feet, the archaeologist shall be empowered to
temporarily halt or redirect construction activities
to ensure avoidance of adverse impacts to
archaeological resources.

If human remains are found, the rules set forth in
State Health and Safety Code section 7050.5
and CEQA Guidelines section 15126.4(b) apply
and shall be followed.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-31

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

Implementation of this measure would reduce
the impact to a less-than-significant level.

Impact 7-4: Potential for Disturbance of
Buried Archaeological Resources, Including
Human Remains and Tribal Cultural
Resources—Greystar Project. Development
of the Greystar project could disturb
unrecorded sensitive archaeological resources
or tribal cultural resources on the project site.

This possibility represents a potentially
significant impact.

S Mitigation 7-4. Prior to construction activities,
resource identification training procedures shall
be implemented for construction personnel,
conducted by an archaeologist who meets the
Secretary of the Interior’s Professional
Qualifications Standards. The qualified
professional archaeologist shall be retained by
the applicant and approved by the City and shall
meet U.S. Secretary of the Interior’s Professional
Qualifications and Standards. Training shall
include a written handout and focus on how to
identify cultural/Native American resources that
may be encountered during earth-moving
activities, including the procedures to be
followed in such an event. On-site
archaeological monitor duties and the general
steps a qualified professional archaeologist
would follow in conducting a salvage
investigation shall also be explained, in case
either or both becomes necessary.

During ground-disturbing project construction
activities, if subsurface cultural resources are
encountered, work within 50 feet shall be
stopped and a qualified archaeologist retained to
evaluate the finds following the procedures
described below. Project personnel shall not
collect cultural resources. Although work may
City; Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-32

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
continue beyond 50 feet, the archaeologist shall
be empowered to temporarily halt or redirect
construction activities to ensure avoidance of
adverse impacts to archaeological resources.

All cultural/archaeological resources unearthed
by project construction activities shall be
evaluated by the qualified professional
archaeologist. Should the newly discovered
artifacts be determined to be prehistoric, Native
American Tribes and/or Individuals shall be
contacted and consulted, and Native American
construction monitoring shall be initiated if
requested by the Tribes and/or Individuals. The
City shall coordinate with the archaeologist to
develop an appropriate treatment plan that
avoids or mitigates, to the maximum extent
possible, damage to any identified resources.

Preservation in place to maintain the relationship
between the artifact(s) and the archaeological
context is the preferred manner of mitigating
impacts on an archaeological site. Preservation
may be accomplished by:

 Planning construction to avoid the
archaeological or tribal cultural site;

 Incorporating the site within a park, green
space, or other open space element;

 Covering the site with a layer of chemically
stable soil; or

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-33

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
 Deeding the site into a permanent
conservation easement.

If in-place mitigation is determined by the City to
be infeasible, a data recovery plan, which makes
provisions for adequate recovery of culturally or
historically consequential information about the
site (including artifacts discovered on the site),
subject to review and approval by the City, shall
be prepared and adopted prior to any excavation
being undertaken. The study shall be submitted
to the CHRIS Northwest Information Center, and
if Native American artifacts are indicated, the
study shall also be submitted to the Native
American Heritage Commission (NAHC).

CHRIS and NAHC are recognized as experts in
their respective disciplines.

Identified cultural resources shall be recorded on
form DPR 422 (archaeological sites). Any
additional mitigation measures recommended by
these two groups (CHRIS and NAHC), as
reviewed and approved by the City, shall be
undertaken prior to and during construction
activities. Although the precise details of those
measures would be based on the nature and
extent of the resource(s) uncovered on the site,
the measures shall be consistent with the
avoidance and mitigation strategies described
above in this mitigation measure.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-34

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
In addition, if the qualified archaeologist
determines that construction excavations have
exposed, or have a high probability of exposing,
cultural and/or archaeological artifacts,
construction monitoring for cultural and/or
archaeological resources shall be required. The
City shall retain a qualified archaeological
monitor, who meets the qualifications set forth by
the U.S. Secretary of the Interior’s Professional
Qualifications and Standards, who will work
under the guidance and direction of a
professional archaeologist. The archaeological
monitor shall be present during all construction
excavations (e.g., grading, trenching, or
clearing/grubbing) into non-fill sediments.

Multiple earth-moving construction activities may
require multiple archaeological monitors.

The frequency of monitoring shall be based on
the rate of excavation and grading activities,
proximity to known archaeological resources, the
materials being excavated (native versus
artificial fill soils), the depth of excavation, and if found, the abundance and type of archaeological
resources encountered. Full-time monitoring
can be reduced to part-time inspections if
determined adequate by the project
archaeologist.

If human remains are found, the rules set forth in
State Health and Safety Code section 7050.5
and CEQA Guidelines section 15126.4(b) apply

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-35

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
and shall be followed, in consultation with the
Native American Heritage Commission (as
appropriate).

Implementation of this measure would reduce
the impact to a less-than-significant level.

GEOLOGY AND SOILS
Impact 8-1: Effects of Strong Seismic
Ground Shaking—Plan Area

LS N/A N/A N/A
Impact 8-2: Effects of Strong Seismic
Ground Shaking—Greystar Project

LS N/A N/A N/A
Impact 8-3: Potential Soil Erosion and Loss
of Topsoil—Plan Area

LS N/A N/A N/A
Impact 8-4: Potential Soil Erosion and Loss
of Topsoil—Greystar Project

LS N/A N/A N/A
Impact 8-5: Potential Ground Instability
Impacts—Plan Area. The potential for ground
instability can depend on specific, highly
localized underlying soil conditions.

Determination of differential settlement,
liquefaction, lateral spreading, and subsidence
potential in the Plan Area would require site-
specific geotechnical studies for future
individual development proposals. Possible
ground instability conditions, if not properly
S Mitigation 8-5. Subject to City review and
approval, complete and implement the
geotechnical mitigation recommendations
identified in the required individual project- and
site-specific geotechnical investigations and
engineering studies for site-specific proposals, in
coordination with City grading permit and
building permit performance standards. Such
recommendations could address design- and
construction-level details regarding the type of
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-36

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
engineered for, could result in associated
significant damage to project buildings, other
improvements, and adjacent property, with
direct or indirect risks to life or property,
representing a potentially significant impact.
building foundation, the extent of subsurface
excavation, the details of retaining structures,
any need for subsurface water extraction, and
other engineering issues and solutions.

Incorporation of this mitigation requirement
would reduce this impact to a less-than-
significant level.

Impact 8-6: Potential Ground Instability
Impacts—Greystar Project. The potential for
ground instability would depend on specific,
highly localized underlying soil conditions. As
discussed in section 8.1.4, the Rockridge
geotechnical report concluded that although no
major geotechnical or geological issues would
prevent development of the proposed project
on the site, the following issues would need to
be addressed:

 adequate foundation support for the
structures;

 weaker, more compressible zones of clay
above about 30 feet below ground surface
(bgs);

 moderately to highly expansive near-surface
soil and susceptibility to large volume
changes with moisture changes; and

S Mitigation 8-6. The City shall require the
applicant to provide a final geotechnical report,
prepared by a geotechnical engineer, for City
review and approval. The final geotechnical
report (as discussed in Impact 8-2 above) shall
include a supplemental field investigation that
includes: (1) new borings as necessary to
confirm subsurface conditions; (2) review of final
project plans and specifications with
recommendations based on professional
geotechnical engineering (such as final
foundation design recommendations and
potential need for piles); (3) any other
engineering studies to address design- and
construction-level details related to type of
building foundation, the extent of subsurface
excavation, details of retaining structures or
subsurface water extraction, and other
engineering issues and solutions as may be
determined necessary in consultation with the
City; and (4) observation of site preparation,
foundation installation, shoring installation, and

City; Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-37

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
 liquefaction-induced settlement potential at
one location in the southwestern part of the
site.

Possible ground instability conditions, if not
properly engineered for, could result in
associated significant damage to project
buildings, other improvements, and adjacent
property, with direct or indirect risks to life or
property, representing a potentially
significant impact.
the placement and compaction of fill during
construction by a professional geotechnical
engineer.

The mitigations and recommendations in the
final geotechnical report, subject to review and
approval by the City, shall be complied with and
would provide reasonable, professional
assurances that the project incorporates design
and engineering refinements to reduce the
degree of impacts to less-than-significant levels
by either avoiding identified soil and geologic
impact areas altogether (i.e., basic project
design changes) or by rectifying the impact
through conventional engineering and
construction procedures (e.g., suitable
foundation design and construction).

Incorporation of these measures into project final
plans prior to issuance of permits and City
inspection and verification procedures prior to
project operation is required and would reduce
this impact to a less-than-significant level.

Impact 8-7: Potential for Disturbance of
Paleontological Resources—Plan Area.

Development facilitated by the Freedom Circle
Focus Area Plan could disturb unrecorded
paleontological resources in the Plan Area.

This possibility represents a potentially
significant impact.

S Mitigation 8-7. For all public improvement and
private development projects in the Freedom
Circle Focus Area Plan Area, the following
measures shall be implemented:

(1) Education Program. Project applicants
shall implement a program that includes the
following elements:

City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-38

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
 Resource identification training procedures
for construction personnel, conducted by a
paleontologist who meets the Secretary of
the Interior’s Professional Qualifications
Standards;

 Spot-checks and monitoring by a qualified
paleontologist of all excavations deeper
than seven feet below ground surface; and

 Procedures for reporting discoveries and
their geologic context.

(2) Procedures for Resources Encountered. If
subsurface paleontological resources are
encountered, excavation shall halt within a buffer
area of at least 50 feet around the find, where
construction activities will not be allowed to
continue until the project paleontologist
evaluates the resource and its stratigraphic
context. Work shall be allowed to continue
outside the buffer area; however, the
paleontologist shall be empowered to
temporarily halt or redirect construction activities
to ensure avoidance of adverse impacts to
paleontological resources. During monitoring, if
potentially significant paleontological resources
are found, “standard” samples shall be collected
and processed by a qualified paleontologist to
recover micro vertebrate fossils. If significant
fossils are found and collected, they shall be
prepared to a reasonable point of identification.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-39

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Excess sediment or matrix shall be removed
from the specimens to reduce the bulk and cost
of storage.

Itemized catalogs of material collected and
identified shall be provided to a local museum
repository with the specimens. Significant fossils
collected during this work, along with the
itemized inventory of these specimens, shall be
deposited in a local museum repository for
permanent curatorship and storage. A report
documenting the results of the monitoring and
salvage activities, and the significance of the
fossils, if any, shall be prepared. The report and
inventory, when submitted to the City, shall
signify the completion of the program to mitigate
impacts on paleontological resources.

Implementation of this measure would reduce
the impact to a less-than-significant level.

Impact 8-8: Potential for Disturbance of
Paleontological Resources—Greystar
Project. Similar to Impact 8-7, development of
the Greystar project could disturb unrecorded
paleontological resources in the Plan Area.

This possibility represents a potentially
significant impact.

S Mitigation 8-8. The Greystar project shall be
required, as a condition of project approval, to
implement the following measures:

(1) Education Program. The project applicant
shall implement a program that includes the
following elements:

 Resource identification training procedures
for construction personnel, conducted by a
paleontologist who meets the Secretary of
City; Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-40

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
the Interior’s Professional Qualifications
Standards;

 Spot-checks and monitoring by a qualified
paleontologist of all excavations deeper
than seven feet below ground surface; and

 Procedures for reporting discoveries and
their geologic context.

(2) Procedures for Resources Encountered. If
subsurface paleontological resources are
encountered, excavation shall halt within a buffer
area of at least 50 feet around the find, where
construction activities will not be allowed to
continue until the project paleontologist
evaluates the resource and its stratigraphic
context. Work shall be allowed to continue
outside the buffer area; however, the
paleontologist shall be empowered to
temporarily halt or redirect construction activities
to ensure avoidance of adverse impacts to
paleontological resources. During monitoring, if
potentially significant paleontological resources
are found, “standard” samples shall be collected
and processed by a qualified paleontologist to
recover micro vertebrate fossils. If significant
fossils are found and collected, they shall be
prepared to a reasonable point of identification.

Excess sediment or matrix shall be removed
from the specimens to reduce the bulk and cost
of storage.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-41

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

Itemized catalogs of material collected and
identified shall be provided to a local museum
repository with the specimens. Significant fossils
collected during this work, along with the
itemized inventory of these specimens, shall be
deposited in a local museum repository for
permanent curatorship and storage. A report
documenting the results of the monitoring and
salvage activities, and the significance of the
fossils, if any, shall be prepared. The report and
inventory, when submitted to the City, shall
signify the completion of the program to mitigate
impacts on paleontological resources.

Implementation of this measure would reduce
the impact to a less-than-significant level.

GREENHOUSE GAS EMISSIONS AND
ENERGY

Impact 9-1: GHG Emissions and Plan
Consistency – Freedom Circle Focus Area
Plan. Implementation of the Freedom Circle
Focus Area Plan could generate GHG
emissions that have a significant effect on the
environment and/or conflict with a plan, policy,
or regulation adopted for the purposes of
reducing GHG emissions. This represents a
potentially significant impact.

S Mitigation Measure 9-1A: See Mitigation
Measure 5-3D.

Mitigation Measure 9-1B: Utilize GHG-Free
Electricity. The City shall require new
development projects occurring under
implementation of the Freedom Circle Focus
Area Plan to source 100% of their electricity from
GHG-free sources. GHG-free electricity may
come from on-site renewable electricity
generation (e.g., photovoltaic systems),
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-42

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
enrollment in a GHG-free electricity program
(e.g., Silicon Valley Power’s Santa Clara Green
Power program), or any combination of
measures that ensure electricity consumed by
projects subject to discretionary approval come
entirely from GHG-free sources, as determined
by the City.

This impact would be less than significant with
mitigation incorporated.

Impact 9-2: GHG Emissions and Plan
Consistency – Greystar General Plan
Amendment

LS N/A N/A N/A
Impact 9-3. Wasteful, Inefficient, or
Unnecessary Consumption of Energy
Resources – Freedom Circle Focus Area
Plan

LS N/A N/A N/A
Impact 9-4. Wasteful, Inefficient, or
Unnecessary Consumption of Energy
Resources – Greystar General Plan
Amendment

LS N/A N/A N/A
Impact 9-5. Conflict with or Obstruct a
State or Local Plan for Renewable Energy
or Energy Efficiency – Freedom Circle
Focus Area Plan

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-43

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 9-6. Conflict with or Obstruct a
State or Local Plan for Renewable Energy
or Energy Efficiency – Greystar General
Plan Amendment

LS N/A N/A N/A

HAZARDS AND HAZARDOUS MATERIALS
Impact 10-1: Project-Related Potential
Impacts Due to Hazardous Materials
Transport, Use, Storage, and Disposal—
Plan Area

LS N/A N/A N/A
Impact 10-2: Project-Related Potential
Impacts Due to Hazardous Materials
Transport, Use, Storage, and Disposal—
Greystar Project

LS N/A N/A N/A
Impact 10-3: Potential Exposure to Existing
Hazardous Materials Contamination—Plan
Area

LS N/A N/A N/A
Impact 10-4: Potential Exposure to Existing
Hazardous Materials Contamination—
Greystar Project

LS N/A N/A N/A
Impact 10-5: Project-Related Potential
Asbestos and PCB Exposure—Plan Area

LS N/A N/A N/A
Impact 10-6: Project-Related Potential
Asbestos and PCB Exposure—Greystar
Project

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-44

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 10-7: Project-Related Potential
Lead-Based Paint Exposure—Plan Area

LS N/A N/A N/A
Impact 10-8: Project-Related Potential
Lead-Based Paint Exposure—Greystar
Project

LS N/A N/A N/A
Impact 10-9: Potential for Hazardous
Materials Near Schools—Plan Area

LS N/A N/A N/A
Impact 10-10: Potential for Hazardous
Materials Near Schools—Greystar Project

LS N/A N/A N/A
Impact 10-11: Protocols for Government
Code Section 65962.5 Sites—Plan Area

LS N/A N/A N/A
Impact 10-12: Protocols for Government
Code Section 65962.5 Sites—Greystar
Project

LS N/A N/A N/A
Impact 10-13: Consistency With San Jose
Airport Comprehensive Land Use Plan—
Plan Area

LS N/A N/A N/A
Impact 10-14: Consistency With San Jose
Airport Comprehensive Land Use Plan—
Greystar Project

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-45

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

HYDROLOGY AND WATER QUALITY
Impact 11-1: Construction Period and Post-
Construction Water Quality Impacts—Plan
Area

LS N/A N/A N/A
Impact 11-2: Construction Period and Post-
Construction Water Quality Impacts—
Greystar Project

LS N/A N/A N/A
Impact 11-3: Long-Term Water Quality
Impacts from Project Operation—Plan Area

LS N/A N/A N/A
Impact 11-4: Long-Term Water Quality
Impacts from Project Operation—Greystar
Project

LS N/A N/A N/A
Impact 11-5: Effects on Groundwater
Recharge and Groundwater Management—
Plan Area

LS N/A N/A N/A
Impact 11-6: Effects on Groundwater
Recharge and Groundwater Management—
Greystar Project

LS N/A N/A N/A
Impact 11-7: Drainage Patterns and Risk of
Flooding—Plan Area

LS N/A N/A N/A
Impact 11-8: Drainage Patterns and Risk of
Flooding—Greystar Project

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-46

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

LAND USE AND PLANNING
Impact 12-1: Project Effects on the Physical
Arrangement of the Community—Plan Area

LS N/A N/A N/A
Impact 12-2: Project Effects on the Physical
Arrangement of the Community—Greystar
Project

LS N/A N/A N/A
Impact 12-3: Project Consistency with Land
Use Plans, Policies, and Regulations
Adopted for the Purpose of Avoiding or
Mitigating Environmental Effects—Plan
Area

LS N/A N/A N/A
Impact 12-4: Project Consistency with Land
Use Plans, Policies, and Regulations
Adopted for the Purpose of Avoiding or
Mitigating Environmental Effects—Greystar
Project

LS N/A N/A N/A
NOISE
Impact 13-1: Temporary Construction
Noise Levels – Freedom Circle Focus Area
Plan. The implementation of the Freedom
Circle Focus Area Plan could result in
construction and development activities in the
Plan Area that generate noise levels above
City standards and/or otherwise result in a

S Mitigation 13-1: Reduce Potential Freedom
Circle Focus Area Plan Construction Noise
Levels. To reduce potential noise levels from
Focus Area Plan related construction activities,
the City shall ensure future development projects
within the Plan Area:

City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-47

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
substantial, temporary increase in ambient
noise levels in the vicinity of the Plan Area.

This represents a potentially significant
impact.
1) Notify Residential and Commercial Land
Uses of Planned Construction Activities. This
notice shall be provided at least one week prior
to the start of any construction activities,
describe the noise control measures to be
implemented by the Project, and include the
name and phone number of the designated
contact for the Applicant/project representative
and the City of Santa Clara responsible for
handling construction-related noise complaints
(per Section 8). This notice shall be provided to:

A) The owner/occupants of residential dwelling
units within 500 feet of construction work areas;
and B) The owner/occupants of commercial
buildings (including institutional buildings) within
200 feet of construction work areas or within 400
feet of construction work areas if pile driving
equipment will be used.

2) Notify San Tomas Aquino Creek Trail
Users of Construction Activities. Prior to the start
of construction activities within 500 feet of the
San Tomas Aquino Creek Trail, signs shall be
posted along the trail warning of potential
temporary elevated noise levels during
construction. Signs shall be posted within 250
feet of impacted trail segments (i.e., portions of
the trail within 500 feet of a work area) and shall
remain posted throughout the duration of all
substantial noise generating construction
activities (typically demolition, grading, and initial
foundation installation activities).

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-48

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

3) Restrict Work Hours. All construction-
related work activities, including material
deliveries, shall be subject to the requirements of
City Municipal Code Section 9.10.230.

Construction activities, including deliveries, shall
occur only during the hours of 7:00 AM to 6:00
PM, Monday through Friday, and 9 AM to 6 PM
on Saturday, unless otherwise authorized by City
permit. The applicant/project representative
and/or its contractor shall post a sign at all
entrances to the construction site informing
contractors, subcontractors, construction
workers, etc. of this requirement.

4) Control Construction Traffic and Site
Access. Construction traffic, including soil and
debris hauling, shall follow City-designated truck
routes and shall avoid routes (including local
roads in the Plan Area) that contain residential
dwelling units to the maximum extent feasible
given specific project location and access needs.

5) Construction Equipment Selection, Use,
and Noise Control Measures. The following
measures shall apply to construction equipment
used in the Plan Area: A) To the extent feasible,
contractors shall use the smallest size
equipment capable of safely completing work
activities; B) Construction staging shall occur as
far away from residential and commercial land
uses as possible; C) All stationary noise-

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-49

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
generating equipment such as pumps,
compressors, and welding machines shall be
shielded and located as far from sensitive
receptor locations as practical. Shielding may
consist of existing vacant structures or a three-
or four-sided enclosure provide the structure/
barrier breaks the line of sight between the
equipment and the receptor and provides for
proper ventilation and equipment operations; D)
Heavy equipment engines shall be equipped
with standard noise suppression devices such as
mufflers, engine covers, and engine/mechanical
isolators, mounts, etc. These devices shall be
maintained in accordance with manufacturer’s
recommendations during active construction
activities; E) Pneumatic tools shall include a
noise suppression device on the compressed air
exhaust; F) The applicant/project representative
and/or their contractor shall connect to existing
electrical service at the site to avoid the use of
stationary power generators (if feasible); G) No
radios or other amplified sound devices shall be
audible beyond the property line of the
construction site.

6) Implement Construction Activity Noise
Control Measures: The following measures shall
apply to construction activities in the Plan Area:

A) Demolition: Activities shall be sequenced to
take advantage of existing shielding/noise
reduction provided by existing buildings or parts
of buildings and methods that minimize noise

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-50

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
and vibration, such as sawing concrete blocks,
prohibiting on-site hydraulic breakers, crushing,
or other pulverization activities, shall be
employed to the maximum extent feasible; B)
Demolition Site Preparation, Grading, and
Foundation Work: During all demolition, site
preparation, grading, and structure foundation
work activities within 500 feet of a residential
dwelling unit or 400 feet of a commercial building
(including institutional buildings), a physical
noise barrier capable of achieving the
construction noise level standards set forth in
Section 7 below shall, if required pursuant to
Section 7, be installed and maintained around
the site perimeter to the maximum extent
feasible given site constraints and access
requirements. Potential barrier options capable
of reducing construction noise levels could
include, but are not limited to: i) A concrete,
wood, or other barrier installed at-grade (or
mounted to structures located at-grade, such as
a K-Rail), and consisting of a solid material (i.e.,
free of openings or gaps other than weep holes)
of sufficient height (determined pursuant to
Section 7) that has a minimum rated
transmission loss value of 20 dB; ii)
Commercially available acoustic panels or other
products such as acoustic barrier blankets that
have a minimum sound transmission class
(STC) or transmission loss value of 20 dB; iii)
any combination of noise barriers and
commercial products capable of achieving

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-51

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
required construction noise reductions during
demolition, site preparation, grading, and
structure foundation work activities; iv) The noise
barrier may be removed following the completion
of building foundation work (i.e., it is not
necessary once framing and typical vertical
building construction begins provided no other
grading, foundation, etc. work is still occurring
on-site); and C) Pile Driving: If pile driving
activities are required within 500 feet of a
residential dwelling unit or 400 feet of a
commercial building, the piles shall be pre-drilled
with an auger to minimize pile driving equipment
run times.

7) Prepare Project-Specific Construction
Noise Evaluation. Prior to the start of any
specific construction project lasting 12 months or
more, the City shall review and approve a
project-specific construction noise evaluation
prepared by a qualified acoustical consultant
that: A) Identifies the planned project
construction sequence and equipment usage; B)
Identifies typical hourly average construction
noise levels for project construction equipment;
C) Compares hourly average construction noise
levels to ambient noise levels at residential and
commercial land uses near work areas (ambient
noise levels may be newly measured or
presumed to be consistent with those levels
shown in Table 13-2 and 13-3 of the Freedom
Circle Focus Area Plan/Greystar General Plan

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-52

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Amendment Draft Environmental Impact Report
(EIR); and D) Identifies construction noise
control measures incorporated into the project
that ensure: i) activities do not generate noise
levels that are above 60 dBA Leq at a residential
dwelling unit and exceed the ambient noise
environment by at least 5 dBA Leq for more than
one year; and ii) activities do not generate noise
levels that are above 70 dBA Leq at a
commercial property (including institutional land
uses) and exceed the ambient noise
environment by at least 5 dBA Leq for more than
one year. Such measures may include but are
not limited to: a) The requirements of Sections 4,
5, 6, and 8; b) Additional project and/or
equipment-specific enclosures, barriers,
shrouds, or other noise suppression methods.

The use of noise control blankets on building
facades shall be considered only if noise
complaints are not resolvable with other means
or methods.

8) Prepare a Construction Noise Complaint
Plan. The Construction Noise Complaint Plan
shall: A) Identify the name and/or title and
contact information (including phone number
and email) for a designated project and City
representative responsible for addressing
construction-related noise issues; B) Includes
procedures describing how the designated
project representative will receive, respond, and
resolve construction noise complaints; C) At a

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-53

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
minimum, upon receipt of a noise complaint, the
project representative shall notify the City
contact, identify the noise source generating the
complaint, determine the cause of the complaint,
and take steps to resolve the complaint; D) The
elements of the Construction Noise Complaint
Plan may be included in the project-specific
noise evaluation prepared to satisfy Section 7 or
as a separate document.

9) Owner/Occupant Disclosure: The City shall
require future occupants/tenants in the Plan
Area receive disclosure that properties in the
Plan Area may be subject to elevated
construction noise levels from development in
the Plan Area. This disclosure shall be provided
as part of the mortgage, lease, sub-lease, and/or
other contractual real-estate transaction
associated with the subject property.

With implementation of these measures, this
impact would be less than significant.

Impact 13-2: Temporary Construction
Noise Levels – Greystar General Plan
Amendment. The Greystar project could
result in construction and development
activities in the Plan Area that generate noise
levels above City standards and/or otherwise

S Mitigation 13-2: Reduce Greystar Project
Construction Noise Levels. To reduce
potential noise levels from Greystar Project
construction activities, the City shall ensure the
Applicant:

City; Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-54

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
result in a substantial, temporary increase in
ambient noise levels in the vicinity of the Plan
Area. This represents a potentially
significant impact.
1) Notify Residential and Commercial Land
Uses of Planned Construction Activities. See
Freedom Circle Focus Area Plan/Greystar
General Plan Amendment Draft Environmental
Impact Report (EIR) Mitigation Measure 13-1,
Section 1.

2) Notify San Tomas Aquino Creek Trail
Users of Construction Activities. See Freedom
Circle Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 2.

3) Restrict Work Hours. See Freedom Circle
Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 3.

4) Control Construction Traffic and Site
Access. See Freedom Circle Focus Area
Plan/Greystar General Plan Amendment Draft
EIR Mitigation Measure 13-1, Section 4.

5) Construction Equipment Selection, Use,
and Noise Control Measures. See Freedom
Circle Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 5.

6) Implement Construction Activity Noise
Control Measures: See Freedom Circle Focus
Area Plan/Greystar General Plan Amendment

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-55

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Draft EIR Mitigation Measure 13-1, Section. The
project will not require pile driving and, therefore,
pile driving control measures identified in
Mitigation Measure 13-1, Section 6 C) are not
applicable. See below for noise barrier mitigation
requirements per Mitigation Measure 13-1,
Section 6 B).

7) Prepare Project-Specific Construction
Noise Evaluation. Not applicable. The
construction noise analysis presented in the
Freedom Circle Focus Area Plan/Greystar
General Plan Amendment Draft Environmental
Impact Report constitutes the Project-specific
construction noise evaluation per Mitigation
Measure 13-1, Section 7.

8) Prepare a Construction Noise Complaint
Plan. See Freedom Circle Focus Area
Plan/Greystar General Plan Amendment Draft
EIR Mitigation Measure 13-1, Section 8.

9) Owner/Occupant Disclosure: See Freedom
Circle Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 9.

Per Mitigation Measure 13-1, Section 6 B), the
following noise barriers shall be installed and
maintained around the perimeter of active work
areas: A) For all demolition, site preparation,
grading, and foundation work within 100 feet of

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-56

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
the commercial property (Pedro’s Restaurant
and Cantina) that borders the site’s southwest
perimeter: i) a 6-foot-tall barrier shall be installed
starting at Freedom Circle and extending south
along the property boundary to the site’s
southern property line (approximately 640 linear
feet). B) For all demolition, site preparation,
grading, and foundation work within 150 feet of
commercial properties across Freedom Circle: i)
a 6-foot-tall barrier shall be provided along the
length of the property line that fronts Freedom
Circle, excepting construction access points as
needed (approximately 1,130 linear feet). C)
Noise barriers shall consist of ½” plywood or any
other material weighing 4 pounds per square
foot or more or having a minimum documented
transmission loss value of 20 dBA. The barriers
may be erected on temporary retaining walls or
temporary K-rails or other solid structures (which
shall be considered as part of the total height of
the barrier). Boards shall be staggered one over
two, or joints otherwise fastened and sealed, to
prevent sound transmission through joints. There
shall be no openings or gaps in the barrier. The
barrier shall be regularly inspected (e.g., weekly)
and maintained during construction activities
(e.g., warped or cracked boards shall be
replaced upon discovery). D) The noise barrier
may be removed following the completion of
building foundation work within the distances
specific above (i.e., it is not necessary once
framing and typical vertical building construction

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-57

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
begins provided no other grading, foundation,
etc. work is still occurring on-site).

With implementation of these measures, this
impact would be less than significant.

Impact 13-3: Temporary Construction
Vibration Levels – Freedom Circle Focus
Area Plan. The implementation of the
Freedom Circle Focus Area Plan could result in
construction and development activities in the
Plan Area that generate vibration levels above
City standards and/or otherwise result
excessive ground-borne vibration levels. This
represents a potentially significant impact.

S Mitigation 13-3: Reduce Potential Freedom
Circle Focus Area Plan Construction
Vibration Levels. To reduce potential vibration-
related structural damage and other excessive
vibration levels from Focus Area Plan related
construction activities, the City shall ensure
future development projects within the Plan
Area:

1) Notify Residential and Commercial Land
Uses of Planned Construction Activities. See
Freedom Circle Focus Area Plan/Greystar
General Plan Amendment Draft Environmental
Impact Report (EIR) Mitigation Measure 13-1,
Section 1.

2) Restrict Work Hours. See Freedom Circle
Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 2.

3) Prohibit Vibratory Equipment. The use of
large vibratory rollers, vibratory/impact hammers,
and other potential large vibration-generating
equipment (e.g., hydraulic breakers/hoe rams)
shall be prohibited within 100 feet of any
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-58

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
residential building façade and 50 feet of any
commercial building façade during construction
activities. Plate compactors and compactor
rollers are acceptable, and deep foundation
piers or caissons shall be auger drilled.

4) Prepare Project-Specific Construction
Vibration Evaluation Plan. If it is not feasible to
prohibit vibratory equipment per Section 3) due
to site- or project-specific conditions or design
considerations, the City shall review and
approve a project-specific construction vibration
evaluation that: A) Identifies the project’s
planned vibration-generating construction
activities (e.g., demolition, pile driving, vibratory
compaction); B) Identifies the potential project-
specific vibration levels (given project-specific
equipment and soil conditions, if known) at
specific building locations that may be impacted
by the vibration-generating work activities
(generally buildings within 50 feet of the work
area); C) Identifies the vibration control
measures incorporated into the project that
ensure equipment and work activities would not
damage buildings or result in vibrations that
exceed Caltrans’ strongly perceptible vibration
detection threshold for peak particle velocity
(PPV) of 0.1 inches/second (in/sec). Such
measures may include, but are not limited to: i)
the requirements of Sections 1, 2, and 3; ii) the
use of vibration monitoring to measure actual
vibration levels; iii) the use of photo monitoring

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-59

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
or other records to document building conditions
prior to, during, and after construction activities;
and iv) the use of other measures such as
trenches or wave barriers; D) Identifies the name
(or title) and contact information (including phone
number and email) of the Contractor and City-
representatives responsible for addressing
construction vibration-related issues; and E)
Includes procedures describing how the
construction contractor will receive, respond, and
resolve to construction vibration complaints. At a
minimum, upon receipt of a vibration complaint,
the Contractor and/or City representative
described in the first condition D) above shall
identify the vibration source generating the
complaint, determine the cause of the complaint,
and take steps to resolve the complaint by
reducing ground-borne vibration levels to peak
particle velocity levels that do not exceed
accepted guidance or thresholds for structural
damage that are best applicable to potentially
impacted buildings (e.g., see Freedom Circle
Focus Area Plan/Greystar General Plan
Amendment Draft EIR Table 13-6) and Caltrans’
strongly perceptible vibration detection threshold
(PPV of 0.1 in/sec, see Freedom Circle Focus
Area Plan/Greystar General Plan Amendment
Draft EIR Table 13-7).

With implementation of these measures, this
impact would be less than significant.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-60

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 13-4: Temporary Construction
Vibration Levels – Greystar General Plan
Amendment. The Greystar project could
result in construction and development
activities in the Plan Area that generate
vibration levels above City standards and/or
otherwise result excessive ground-borne
vibration levels. This represents a potentially
significant impact.

S Mitigation 13-4: Reduce Greystar Project
Construction Vibration Levels. To reduce
potential vibration-related structural damage and
other excessive vibration levels from Greystar
project construction activities, the City shall
require the Applicant:

1) Notify Residential and Commercial Land
Uses of Planned Construction Activities. See
Freedom Circle Focus Area Plan/Greystar
General Plan Amendment Draft Environmental
Impact Report (EIR) Mitigation Measure 13-1,
Section 1.

2) Restrict Work Hours. See Freedom Circle
Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 2.

3) Prohibit Vibratory Equipment. See
Freedom Circle Focus Area Plan/Greystar
General Plan Amendment Draft EIR Mitigation
Measure 13-3, Section 3.

4) Prepare Project-Specific Construction
Vibration Evaluation Plan. See Freedom Circle
Focus Area Plan/Greystar General Plan
Amendment Draft EIR Mitigation Measure 13-1,
Section 3. Mitigation Measure 13-3, Section 4 A)
– C) are not applicable because the construction
vibration analysis presented in the Freedom
Circle Focus Area Plan/Greystar General Plan
City; Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-61

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Amendment Draft EIR constitutes the Project-
specific construction vibration evaluation per
Mitigation Measure 13-3, Section 4.

With implementation of these measures, this
impact would be less than significant.

Impact 13-5: On-site Noise Levels from
Focus Area Plan Development. The
implementation of the Freedom Circle Focus
Area Plan could result in new residential, office,
and other land uses that generate noise from
on-site equipment, activities, or other
operations in excess of applicable City
standards. This represents a potentially
significant impact.

S Mitigation 13-5: Control Fixed and Other On-
site Noise-Generating Sources and Activities
in the Freedom Circle Area Plan. To ensure
on-site, operations-related equipment and
activities associated with the Focus Area Plan do
not generate noise levels that exceed City
standards or otherwise result in a substantial
permanent increase in ambient noise levels,
future development projects shall submit a
project-specific operational noise analysis to the
City for review and approval prior to the issuance
of the first building permit for the project, or as
otherwise determined by the City. The noise
analysis shall be prepared by a qualified
acoustical consultant and shall identify all major
fixed machinery and equipment, non-residential
truck docks/dedicated loading zones, waste
collection areas, and above ground parking
garages included in the final project design/site
plan. The noise analysis shall also document
how project noise sources and activities will
comply with the exterior sound limits established
in Municipal Code Section 9.10.040, Schedule A
and the noise compatibility guidelines in General
Plan Table 8.14-1. Fixed machinery and
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-62

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
equipment may include, but is not limited to,
pumps, fans (including air intake or exhaust fans
in parking garages), compressors, air
conditioners, generators, and refrigeration
equipment. The control of noise from such
equipment may be accomplished by selecting
quiet equipment types, siting machinery and
equipment inside buildings, within an enclosure
(e.g., equipment cabinet or mechanical closets,
or behind a parapet wall or other barrier/
shielding. Truck docks/dedicated loading zones
consist of a loading dock or other dedicated area
for the regular loading and unloading of retail,
commercial, or other non-residential goods from
delivery trucks. The control of noise from such
truck docks/loading areas, waste collection
areas, and parking garages may be
accomplished by placing such areas away from
sensitive land uses, restricting activities or
operating hours for certain areas, or other design
means.

With implementation of these measures, this
impact would be less than significant.

Impact 13-6: On-site Noise Levels from
Greystar Project. The implementation of the
Greystar project could result in new residential,
park, and retail land uses that could generate
noise from on-site equipment, activities, or

S Mitigation 13-6: Control Greystar Project
Parking Garage Ventilation System Noise
Levels. To ensure potential parking garage
ventilation systems do not generate noise levels
that exceed City standards or otherwise result in

City; Greystar
project
applicant
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-63

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
other operations in excess of applicable City
standards. This represents a potentially
significant impact.
a substantial permanent increase in ambient
noise levels, the City shall require the Applicant
to prepare an acoustical study that identifies the
final type, location, and sound power level of all
parking garage ventilation systems. The study
shall also document how project noise sources
and activities will comply with the exterior sound
limits established in Municipal Code Section

9.10.040, Schedule A. The control of noise from
ventilation systems may be accomplished by
selecting quiet equipment types, siting
machinery and equipment inside buildings,
within an enclosure (e.g., equipment cabinet or
mechanical closets), the installation of louvres or
baffles, or other design means.

With implementation of these measures, this
impact would be less than significant.

Impact 13-7: Increases in Traffic Noise
Levels – Freedom Circle Focus Area Plan.

The implementation of the Freedom Circle
Focus Area Plan could generate vehicle trips
that substantially increase existing and future
No Project traffic noise levels and/or exceed
City noise and land use compatibility
standards. This represents a potentially
significant impact.

S Mitigation 13-7. No feasible mitigation is
available.

City;
Individual
project
owners
SU
Impact 13-8: Increases in Traffic Noise
Levels – Greystar Project

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-64

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 13-9: Operational Vibrations –
Freedom Circle Focus Area Plan

LS N/A N/A N/A
Impact 13-10: Operational Vibrations –
Greystar Project

LS N/A N/A N/A
Impact 13-11: Exposure to Airport-Related
Noise – Freedom Circle Focus Area Plan
and Greystar Project

LS N/A N/A N/A

POPULATION AND HOUSING
Impact 14-1: Effects on Population
Growth—Plan Area

LS N/A N/A N/A
Impact 14-2: Effects on Population
Growth—Greystar Project

LS N/A N/A N/A
Impact 14-3: Population and Housing
Displacement Effects—Plan Area

LS N/A N/A N/A
Impact 14-4: Population and Housing
Displacement Effects—Greystar Project

LS N/A N/A N/A
Impact 14-5: Temporary Employment
Impacts—Plan Area

LS N/A N/A N/A
Impact 14-6: Temporary Employment
Impacts—Greystar Project

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-65

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation

PUBLIC SERVICES
Impact 15-1: Increase in Fire
Protection/Emergency Medical Service
(EMS) Demands—Plan Area

LS N/A N/A N/A
Impact 15-2: Impacts on Fire
Protection/Emergency Medical Service
(EMS) Demands-- Greystar Project

LS N/A N/A N/A
Impact 15-3: Increase in Police Service
Demands—Plan Area

LS N/A N/A N/A
Impact 15-4: Impacts on Police Service
Demands--Greystar Project

LS N/A N/A N/A
Impact 15-5: Impacts on Public Schools—
Plan Area

LS N/A N/A N/A
Impact 15-6: Impacts on Public Schools--
Greystar Project

LS N/A N/A N/A
Impact 15-7: Impacts on Parks and
Recreational Facilities—Plan Area

LS N/A N/A N/A
Impact 15-8: Impacts on Parks and
Recreational Facilities--Greystar Project

LS N/A N/A N/A
Impact 15-9: Impacts on Other Public
Facilities—Plan Area

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-66

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 15-10: Impacts on Other Public
Facilities—Greystar Project

LS N/A N/A N/A
Impact 15-11: Construction Period
Impacts—Plan Area

LS N/A N/A N/A
Impact 15-12: Construction Period
Impacts—Greystar Project

LS N/A N/A N/A

RECREATION
Impact 16-1: Impacts on Parks and
Recreational Facilities—Plan Area

LS N/A N/A N/A
Impact 16-2: Impacts on Parks and
Recreational Facilities—Greystar Project

LS N/A N/A N/A
Impact 16-3: Construction Period
Impacts—Plan Area

LS N/A N/A N/A
Impact 16-4: Construction Period
Impacts—Greystar Project

LS N/A N/A N/A

TRANSPORTATION
Impact 17-1: Conflict With Adopted
Policies, Plans, or Programs Regarding
Roadways—Plan Area

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-67

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 17-2: Conflict With Adopted
Policies, Plans, or Programs Regarding
Roadways—Greystar Project

LS N/A N/A N/A
Impact 17-3: Impacts on Transit Related to
Conflicts with Adopted Policies, Plans, or
Programs—Plan Area

LS N/A N/A N/A
Impact 17-4: Impacts on Bicycle Facilities—
Plan Area

LS N/A N/A N/A
Impact 17-5: Impacts on Pedestrian
Facilities—Plan Area

LS N/A N/A N/A
Impact 17-6: Impacts on Transit Related to
Conflicts with Adopted Policies, Plans, or
Programs—Greystar Project

LS N/A N/A N/A
Impact 17-7: Impacts on Bicycle Facilities—
Greystar Project

LS N/A N/A N/A
Impact 17-8: Impacts on Pedestrian
Facilities—Greystar Project

LS N/A N/A N/A
Impact 17-9: Impacts Related to Vehicle
Miles Traveled—Plan Area

LS N/A N/A N/A
Impact 17-10: Impacts Related to Vehicle
Miles Traveled—Greystar Project

LS N/A N/A N/A

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-68

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 17-11: Hazards Due to Design
Features or Incompatible Uses—Plan Area

LS N/A N/A N/A
Impact 17-12: Hazards Due to Design
Features or Incompatible Uses—Greystar
Project

LS N/A N/A N/A
Impact 17-13: Emergency Access—Plan
Area

LS N/A N/A N/A
Impact 17-14: Emergency Access—
Greystar Project

LS N/A N/A N/A

UTILITIES AND SERVICE SYSTEMS
Impact 18-1: Focus Area Plan
Inconsistency with General Plan and UWMP
Growth Projections. The WSA prepared for
the proposed Focus Area Plan includes
development in the Plan Area that has not
been identified in the General Plan (i.e.,
exceeds the General Plan land use projections
for 2035, the General Plan horizon year), and
therefore, because the 2015 Urban Water
Management Plan (UWMP) was based on
General Plan buildout projections, this WSA is
inconsistent with General Plan and UWMP
buildout projections. Until the Focus Area Plan
development exceeding General Plan growth
projections is included in the General Plan and
the UWMP (i.e., the 2020 UWMP), the Focus
S Mitigation 18-1. The WSA prepared for the
proposed Focus Area Plan includes
development in the Plan Area that has not been
identified in the General Plan (i.e., exceeds the
General Plan land use projections for 2035, the
General Plan horizon year), and therefore,
because the 2015 Urban Water Management
Plan (UWMP) was based on General Plan
buildout projections, this WSA is inconsistent
with General Plan and UWMP buildout
projections. Until the Focus Area Plan
development exceeding General Plan growth
projections is included in the General Plan and
the UWMP (i.e., the 2020 UWMP), the Focus
Area Plan is inconsistent with the General
Plan/Urban Water Management Plan, and this
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-69

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Area Plan is inconsistent with the General
Plan/Urban Water Management Plan, and this
inconsistency would represent a potentially
significant project and cumulative impact.
inconsistency would represent a potentially
significant project and cumulative impact.

Impact 18-2: Greystar Project
Inconsistency with General Plan and UWMP
Growth Projections

LS N/A N/A N/A
Impact 18-3: Project and Cumulative Need
for Water, Wastewater, and Storm Drainage
System Infrastructure—Plan Area

LS N/A N/A N/A
Impact 18-4: Project and Cumulative Need
for Water, Wastewater, and Storm Drainage
System Infrastructure—Greystar Project

LS N/A N/A N/A
Impact 18-5: Cumulative Wastewater Pump
Station Capacity Impacts—Plan Area. As
noted in the Woodard & Curran technical
memo conducted for the Focus Area Plan (and
discussed above), future wastewater generated
by anticipated development in the Focus Area
Plan Area is projected to exceed the current
combined wastewater capacity of the Northside
and Rabello pump stations (46.1 mgd) by 0.2
mgd (for a total of 46.3 mgd), which represents
a cumulative wastewater impact. Therefore,
the proposed Freedom Circle Focus Area Plan
contribution to cumulative pump station
capacity at the Northside and Rabello pump
S Mitigation 18-5. The City shall require
individual projects implemented under the
Freedom Circle Focus Area Plan (and the future,
required comprehensive planning study – e.g.,
specific plan) to make a fair-share contribution to
the wastewater pump station improvements
necessary to accommodate cumulative
development in Santa Clara. The fair-share
contributions for future projects developed under
the Focus Area Plan and required
comprehensive planning study shall be
determined based on a detailed wastewater
pump station engineering study prepared by the
City and each project’s percent of wastewater
City;
Individual
project
applicants
LS

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-70

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
stations would be a significant cumulative
impact.
contribution to cumulative flow capacity needs
above the current pump capacity. This
mitigation would provide funding for wastewater
pump station upgrades, which would reduce the
Plan’s contribution to the cumulative impact to a
less-than-significant level. The City would be
required to plan and construct the
improvements. Because the timing of these
improvements cannot be guaranteed or
estimated at this time (spring 2021), the
combined wastewater capacity of the two pump
stations could be exceeded by development
proposals already under consideration.

Therefore, the City shall continually monitor
pump station capacity in order to coordinate the
pump station improvements with development
proposals. Until pump station capacity
improvements adequate to accommodate the
incremental increases in wastewater flows are
completed, the City shall delay individual project
building permits. In addition, as a standard
condition of approval, each individual project
would need to provide sanitary sewer
information to the City, and no project would be
approved by the City until the City determines
that sufficient sewer capacity exists.

Implementation of this mitigation measure would
reduce Plan cumulative wastewater pump
capacity impacts to a less-than-significant
level.

_______________________
S = Significant
LS = Less than significant
SU = Significant unavoidable impact See Table 1.1 for definitions.

NA = Not applicable

2 - Summary (19034)_PRD
Freedom Circle Focus Area Plan/Greystar General Plan Amendment Draft EIR City of Santa Clara 2. Summary
November 2, 2021 Page 2-71

Impacts
Significance
Without
Mitigation

Mitigation Measures

Mitigation
Responsibility
Significance
With
Mitigation
Impact 18-6: Cumulative Wastewater Pump
Station Capacity Impacts—Greystar Project

LS N/A N/A N/A
Impact 18-7: Wastewater Treatment
Capacity Impacts—Plan Area

LS N/A N/A N/A
Impact 18-8: Wastewater Treatment
Capacity Impacts—Greystar Project

LS N/A N/A N/A
Impact 18-9: Impacts on Solid Waste
Disposal and Recycling Service—Plan Area

LS N/A N/A N/A
Impact 18-10: Impacts on Solid Waste
Disposal and Recycling Service—Greystar
Project

LS N/A N/A N/A
Impact 18-11: Electricity, Natural Gas, and
Telecommunications Infrastructure—Plan
Area

LS N/A N/A N/A
Impact 18-12: Electricity, Natural Gas, and
Telecommunications Infrastructure—
Greystar Project

LS N/A N/A N/A