Cities Index.
Agenda packet

Santa Cruz City Council
March 11, 2025

Document
Agenda packet
Meeting
March 11, 2025
Body
Santa Cruz City Council
Pages
151
Original file
209.1 MB
Text extracted from the city's file for reading and search. Open the original on ecm.cityofsantacruz.com. That file is the official record.

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Metals (Total)
Flag
Batch - B4I0321
Matrix Spike Dup (B4I0321-MSD1) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30003-06 EPA 6010B
Arsenic 38.0 2.0 mg/kg 39.9 ND 95.1 75-125 0.968 20
Barium 128 2.0 mg/kg 39.9 85.4 106 75-125 2.29 20
Beryllium 4.03 0.40 mg/kg 3.99 0.327 92.6 75-125 0.154 20 Cadmium 3.91 0.40 mg/kg 3.99 ND 98.0 75-125 0.598 20
Chromium MS3 39.6 2.0 mg/kg 20.0 34.7 24.7 75-125 19.5 20 Cobalt 10.5 0.80 mg/kg 7.99 3.08 93.4 75-125 0.0305 20
Copper 21.7 2.0 mg/kg 20.0 2.87 94.3 75-125 3.22 20
Lead 24.9 2.0 mg/kg 20.0 5.61 96.7 75-125 1.26 20
Molybdenum 17.6 2.0 mg/kg 20.0 ND 88.3 75-125 0.814 20
Nickel 38.0 2.0 mg/kg 20.0 21.6 82.1 75-125 5.53 20
Selenium 69.7 5.0 mg/kg 79.9 ND 87.3 75-125 1.41 20
Silver 19.6 2.0 mg/kg 20.0 ND 98.3 75-125 0.144 20
Thallium 74.2 5.0 mg/kg 79.9 ND 92.9 75-125 1.21 20
Vanadium 69.4 2.5 mg/kg 39.9 27.0 106 75-125 1.31 20
Zinc 33.4 2.0 mg/kg 20.0 13.8 98.0 75-125 7.68 20
Matrix Spike (B4I0321-MS2) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30037-01 EPA 6010B
Antimony MS3 4.16 2.0 mg/kg 20.2 ND 20.6 75-125
Arsenic 39.6 2.0 mg/kg 40.4 3.00 90.6 75-125
Barium 68.9 2.0 mg/kg 40.4 34.0 86.5 75-125
Beryllium 3.80 0.40 mg/kg 4.04 0.327 86.1 75-125
Cadmium MS3 2.99 0.40 mg/kg 4.04 ND 74.1 75-125
Chromium 27.3 2.0 mg/kg 20.2 7.85 96.6 75-125
Cobalt 12.5 0.80 mg/kg 8.08 4.29 102 75-125
Copper 21.4 2.0 mg/kg 20.2 1.83 96.7 75-125
Lead 21.2 2.0 mg/kg 20.2 2.93 90.5 75-125
Molybdenum 18.8 2.0 mg/kg 20.2 ND 93.0 75-125
Nickel 24.0 2.0 mg/kg 20.2 4.16 98.4 75-125
Selenium 68.2 5.0 mg/kg 80.8 ND 84.5 75-125
Silver 17.9 2.0 mg/kg 20.2 ND 88.7 75-125
Thallium 71.3 5.0 mg/kg 80.8 ND 88.3 75-125
Vanadium 70.4 2.5 mg/kg 40.4 29.3 102 75-125
Zinc 53.5 2.0 mg/kg 20.2 35.2 91.0 75-125
Matrix Spike Dup (B4I0321-MSD2) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30037-01 EPA 6010B
Antimony MS3 2.86 2.0 mg/kg 20.1 ND 14.2 75-125 37.1 20 Arsenic 39.7 2.0 mg/kg 40.2 3.00 91.2 75-125 0.157 20
Barium 72.6 2.0 mg/kg 40.2 34.0 96.1 75-125 5.20 20
Beryllium 3.77 0.40 mg/kg 4.02 0.327 85.6 75-125 0.980 20 Cadmium MS3 2.73 0.40 mg/kg 4.02 ND 68.0 75-125 9.09 20 Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 124 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Metals (Total)
Flag
Batch - B4I0321
Matrix Spike Dup (B4I0321-MSD2) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30037-01 EPA 6010B
Chromium 27.2 2.0 mg/kg 20.1 7.85 96.3 75-125 0.530 20
Cobalt 12.9 0.80 mg/kg 8.04 4.29 107 75-125 3.04 20
Copper 23.8 2.0 mg/kg 20.1 1.83 109 75-125 10.8 20
Lead 20.7 2.0 mg/kg 20.1 2.93 88.2 75-125 2.68 20
Molybdenum 17.7 2.0 mg/kg 20.1 ND 88.0 75-125 5.96 20
Nickel 23.1 2.0 mg/kg 20.1 4.16 94.3 75-125 3.92 20
Selenium 66.4 5.0 mg/kg 80.4 ND 82.6 75-125 2.74 20
Silver 16.9 2.0 mg/kg 20.1 ND 84.3 75-125 5.51 20
Thallium 69.5 5.0 mg/kg 80.4 ND 86.4 75-125 2.64 20
Vanadium 72.8 2.5 mg/kg 40.2 29.3 108 75-125 3.39 20
Zinc MS2 62.6 2.0 mg/kg 20.1 35.2 137 75-125 15.7 20
Batch - B4I0404
Blank (B4I0404-BLK1) Prepared & Analyzed: 09/09/24
EPA 7471A
Mercury ND 0.040 mg/kg
LCS (B4I0404-BS1) Prepared & Analyzed: 09/09/24
EPA 7471A
Mercury 0.320 0.040 mg/kg 0.333 96.0 80-120
LCS Dup (B4I0404-BSD1) Prepared & Analyzed: 09/09/24
EPA 7471A
Mercury 0.324 0.040 mg/kg 0.333 97.3 80-120 1.37 20
Matrix Spike (B4I0404-MS1) Prepared & Analyzed: 09/09/24 Source: KH28001-01 EPA 7471A
Mercury 0.364 0.040 mg/kg 0.331 0.0713 88.4 70-130
Matrix Spike Dup (B4I0404-MSD1) Prepared & Analyzed: 09/09/24 Source: KH28001-01 EPA 7471A
Mercury 0.362 0.040 mg/kg 0.333 0.0713 87.3 70-130 0.596 20 Matrix Spike (B4I0404-MS2) Prepared & Analyzed: 09/09/24 Source: KH30036-01 EPA 7471A
Mercury 0.322 0.040 mg/kg 0.331 0.0359 86.4 70-130
Matrix Spike Dup (B4I0404-MSD2) Prepared & Analyzed: 09/09/24 Source: KH30036-01 EPA 7471A
Mercury 0.312 0.040 mg/kg 0.333 0.0359 83.1 70-130 2.90 20 Batch - B4I1003
Blank (B4I1003-BLK1) Prepared & Analyzed: 09/16/24
EPA 245.1
Mercury ND 0.20 µg/L
LCS (B4I1003-BS1) Prepared & Analyzed: 09/16/24
EPA 245.1
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 125 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Metals (Total)
Flag
Batch - B4I1003
LCS (B4I1003-BS1) Prepared & Analyzed: 09/16/24
EPA 245.1
Mercury 4.68 0.20 µg/L 5.00 93.5 85-115
LCS Dup (B4I1003-BSD1) Prepared & Analyzed: 09/16/24
EPA 245.1
Mercury 4.71 0.20 µg/L 5.00 94.1 85-115 0.626 20
Matrix Spike (B4I1003-MS1) Prepared & Analyzed: 09/16/24 Source: KH30003-15 EPA 245.1
Mercury 28.5 1.2 µg/L 30.0 ND 95.1 70-130
Matrix Spike Dup (B4I1003-MSD1) Prepared & Analyzed: 09/16/24 Source: KH30003-15 EPA 245.1
Mercury 27.7 1.2 µg/L 30.0 ND 92.2 70-130 3.18 20
Batch - B4I1604
Blank (B4I1604-BLK1) Prepared & Analyzed: 09/16/24
EPA 7471A
Mercury ND 0.040 mg/kg
LCS (B4I1604-BS1) Prepared & Analyzed: 09/16/24
EPA 7471A
Mercury 0.304 0.040 mg/kg 0.333 91.3 80-120
LCS Dup (B4I1604-BSD1) Prepared & Analyzed: 09/16/24
EPA 7471A
Mercury 0.331 0.040 mg/kg 0.333 99.4 80-120 8.50 20
Matrix Spike (B4I1604-MS1) Prepared & Analyzed: 09/16/24 Source: KH30003-16 EPA 7471A
Mercury 0.280 0.040 mg/kg 0.332 0.0186 78.5 70-130
Matrix Spike Dup (B4I1604-MSD1) Prepared & Analyzed: 09/16/24 Source: KH30003-16 EPA 7471A
Mercury 0.254 0.040 mg/kg 0.333 0.0186 70.7 70-130 9.65 20 Batch - B4J1806
Blank (B4J1806-BLK1) Prepared: 10/21/24 Analyzed: 10/22/24 EPA 6010B
Cadmium ND 0.40 mg/kg
Chromium ND 2.0 mg/kg
Thallium ND 5.0 mg/kg
LCS (B4J1806-BS1) Prepared: 10/21/24 Analyzed: 10/22/24 EPA 6010B
Cadmium 4.04 0.40 mg/kg 4.00 101 75-125
Chromium 20.9 2.0 mg/kg 20.0 104 75-125
Thallium 72.8 5.0 mg/kg 80.0 91.0 75-125
LCS Dup (B4J1806-BSD1) Prepared: 10/21/24 Analyzed: 10/22/24 EPA 6010B
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 126 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Metals (Total)
Flag
Batch - B4J1806
LCS Dup (B4J1806-BSD1) Prepared: 10/21/24 Analyzed: 10/22/24 EPA 6010B
Cadmium 3.93 0.40 mg/kg 4.00 98.2 75-125 2.93 20
Chromium 19.9 2.0 mg/kg 20.0 99.7 75-125 4.54 20
Thallium 71.4 5.0 mg/kg 80.0 89.3 75-125 1.87 20
Matrix Spike (B4J1806-MS1) Prepared: 10/21/24 Analyzed: 10/22/24 Source: KJ07036-29 EPA 6010B
Cadmium 3.27 0.40 mg/kg 3.97 ND 82.4 75-125
Chromium 25.4 2.0 mg/kg 19.9 5.67 99.1 75-125
Thallium 68.2 5.0 mg/kg 79.4 ND 85.9 75-125
Matrix Spike Dup (B4J1806-MSD1) Prepared: 10/21/24 Analyzed: 10/22/24 Source: KJ07036-29 EPA 6010B
Cadmium 3.10 0.40 mg/kg 3.96 ND 78.3 75-125 5.52 20
Chromium 26.7 2.0 mg/kg 19.8 5.67 106 75-125 5.29 20
Thallium 72.0 5.0 mg/kg 79.2 ND 91.0 75-125 5.45 20
Matrix Spike (B4J1806-MS2) Prepared: 10/21/24 Analyzed: 10/22/24 Source: KJ17001-01 EPA 6010B
Cadmium 3.49 0.40 mg/kg 3.97 ND 87.8 75-125
Chromium 26.4 2.0 mg/kg 19.9 7.15 96.9 75-125
Thallium 71.9 5.0 mg/kg 79.5 ND 90.4 75-125
Matrix Spike Dup (B4J1806-MSD2) Prepared: 10/21/24 Analyzed: 10/22/24 Source: KJ17001-01 EPA 6010B
Cadmium 3.57 0.40 mg/kg 4.03 ND 88.5 75-125 2.36 20
Chromium 26.9 2.0 mg/kg 20.2 7.15 97.7 75-125 1.74 20
Thallium 73.7 5.0 mg/kg 80.7 ND 91.4 75-125 2.54 20
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 127 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I0303
Blank (B4I0303-BLK1) Prepared: 09/03/24 Analyzed: 09/25/24 EPA 8015B
Surr: o-Terphenyl 14.4 µg/L 20.0 72.2 34-150
Surr: o-Terphenyl 17.8 µg/L 20.0 89.0 0-200
Diesel ND 50 µg/L
Motor Oil J 45.6 100 µg/L
LCS (B4I0303-BS1) Prepared: 09/03/24 Analyzed: 09/25/24 EPA 8015B
Surr: o-Terphenyl 28.6 µg/L 20.0 143 34-150
Diesel 423 50 µg/L 500 84.5 70-130
LCS (B4I0303-BS2) Prepared: 09/03/24 Analyzed: 09/25/24 EPA 8015B
Surr: o-Terphenyl 26.2 µg/L 20.0 131 62-132
Motor Oil 470 100 µg/L 500 94.0 62-132
LCS Dup (B4I0303-BSD1) Prepared: 09/03/24 Analyzed: 09/25/24 EPA 8015B
Surr: o-Terphenyl 29.6 µg/L 20.0 148 34-150
Diesel 424 50 µg/L 500 84.9 70-130 0.421 20
LCS Dup (B4I0303-BSD2) Prepared: 09/03/24 Analyzed: 09/25/24 EPA 8015B
Surr: o-Terphenyl S 32.0 µg/L 20.0 160 62-132
Motor Oil 471 100 µg/L 500 94.1 62-132 0.134 20
Batch - B4I0329
Blank (B4I0329-BLK1) Prepared: 09/04/23 Analyzed: 09/17/24 EPA 8270C
Surr: 2,4,6-Tribromophenol 56.7 µg/L 100 56.7 14-128
Surr: 2-Fluorobiphenyl 14.2 µg/L 50.0 28.4 21-111
Surr: 2-Fluorophenol 25.4 µg/L 100 25.4 5-71
Surr: d14-Terphenyl 38.0 µg/L 50.0 75.9 5-189
Surr: Nitrobenzene-d5 14.3 µg/L 50.0 28.7 22-119
Surr: Phenol-d5 16.6 µg/L 100 16.6 5-52
1,2,4-Trichlorobenzene ND 5.0 µg/L
1,2-Dichlorobenzene ND 5.0 µg/L
1,2-Diphenylhydrazine ND 5.0 µg/L
1,3-Dichlorobenzene ND 5.0 µg/L
1,4-Dichlorobenzene ND 5.0 µg/L
2,3,4,6-Tetrachlorophenol ND 5.0 µg/L
2,4,5-Trichlorophenol ND 5.0 µg/L
2,4,6-Trichlorophenol ND 5.0 µg/L
2,4-Dichlorophenol ND 5.0 µg/L
2,4-Dimethylphenol ND 5.0 µg/L
2,4-Dinitrophenol ND 5.0 µg/L
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 128 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I0329
Blank (B4I0329-BLK1) Prepared: 09/04/23 Analyzed: 09/17/24 EPA 8270C
2,4-Dinitrotoluene ND 5.0 µg/L
2,6-Dichlorophenol ND 5.0 µg/L
2,6-Dinitrotoluene ND 5.0 µg/L
2-Chloronaphthalene ND 5.0 µg/L
2-Chlorophenol ND 5.0 µg/L
2-Methylnaphthalene ND 5.0 µg/L
2-Methylphenol ND 5.0 µg/L
2-Nitroaniline ND 5.0 µg/L
2-Nitrophenol ND 5.0 µg/L
3,3'-Dichlorobenzidine ND 5.0 µg/L
3-Nitroaniline ND 5.0 µg/L
4,6-Dinitro-2-methylphenol ND 5.0 µg/L
4-Bromophenyl phenyl ether ND 5.0 µg/L
4-Chloro-3-methylphenol ND 5.0 µg/L
4-Chloroaniline ND 5.0 µg/L
4-Chlorophenyl phenyl ether ND 5.0 µg/L
4-Methylphenol ND 5.0 µg/L
4-Nitroaniline ND 5.0 µg/L
4-Nitrophenol ND 5.0 µg/L
7,12-Dimethylbenz(a)anthracene ND 5.0 µg/L
Acenaphthene ND 5.0 µg/L
Acenaphthylene ND 5.0 µg/L
Anthracene ND 5.0 µg/L
Benzidine ND 10 µg/L
Benzo (a) anthracene ND 5.0 µg/L
Benzo (a) pyrene ND 5.0 µg/L
Benzo (b) fluoranthene ND 5.0 µg/L
Benzo (k) fluoranthene ND 5.0 µg/L
Benzo(ghi)perylene ND 5.0 µg/L
Benzoic acid ND 5.0 µg/L
Benzyl alcohol ND 5.0 µg/L
Bis(2-chloroethoxy)methane ND 5.0 µg/L
Bis(2-chloroethyl)ether ND 5.0 µg/L
Bis(2-chloroisopropyl)ether ND 5.0 µg/L
Bis(2-ethylhexyl) phthalate ND 5.0 µg/L
Butyl benzyl phthalate ND 5.0 µg/L
Chrysene ND 5.0 µg/L
Dibenzo(a,h)anthracene ND 5.0 µg/L
Dibenzofuran ND 5.0 µg/L
Diethyl phthalate ND 5.0 µg/L
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 129 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I0329
Blank (B4I0329-BLK1) Prepared: 09/04/23 Analyzed: 09/17/24 EPA 8270C
Dimethyl phthalate ND 5.0 µg/L
Di-n-butyl phthalate ND 5.0 µg/L
Di-n-octyl phthalate ND 5.0 µg/L
Fluoranthene ND 5.0 µg/L
Fluorene ND 5.0 µg/L
Hexachlorobenzene ND 5.0 µg/L
Hexachlorobutadiene ND 5.0 µg/L
Hexachlorocyclopentadiene ND 5.0 µg/L
Hexachloroethane ND 5.0 µg/L
Indeno(1,2,3-cd)pyrene ND 5.0 µg/L
Isophorone ND 5.0 µg/L
Naphthalene ND 5.0 µg/L
Nitrobenzene ND 5.0 µg/L
N-Nitrosodimethylamine ND 5.0 µg/L
N-Nitrosodi-n-propylamine ND 5.0 µg/L
N-Nitrosodiphenylamine ND 5.0 µg/L
Pentachlorophenol ND 5.0 µg/L
Phenanthrene ND 5.0 µg/L
Phenol ND 5.0 µg/L
Pyrene ND 5.0 µg/L
LCS (B4I0329-BS1) Prepared: 09/04/23 Analyzed: 09/17/24 EPA 8270C
Surr: 2,4,6-Tribromophenol 63.8 µg/L 100 63.8 33-131
Surr: 2-Fluorobiphenyl 20.7 µg/L 50.0 41.3 32-116
Surr: 2-Fluorophenol 23.4 µg/L 100 23.4 21-72
Surr: d14-Terphenyl 39.8 µg/L 50.0 79.6 36-128
Surr: Nitrobenzene-d5 20.9 µg/L 50.0 41.8 32-120
Surr: Phenol-d5 14.9 µg/L 100 14.9 13-51
1,2,4-Trichlorobenzene *a 6.33 5.0 µg/L 25.0 25.3 44-142 1,4-Dichlorobenzene 9.32 5.0 µg/L 25.0 37.3 20-124
2,4-Dinitrotoluene 14.0 5.0 µg/L 25.0 56.2 39-139
2-Chlorophenol 19.9 5.0 µg/L 50.0 39.8 23-134
4-Chloro-3-methylphenol 19.0 5.0 µg/L 50.0 38.0 22-147
Acenaphthene BS2 10.5 5.0 µg/L 25.0 41.9 47-145
N-Nitrosodi-n-propylamine 12.0 5.0 µg/L 25.0 48.2 5-230 Phenol RPD 7.66 5.0 µg/L 50.0 15.3 5-112
Pyrene 16.4 5.0 µg/L 25.0 65.6 52-115
LCS Dup (B4I0329-BSD1) Prepared: 09/04/23 Analyzed: 09/17/24 EPA 8270C
Surr: 2,4,6-Tribromophenol 65.5 µg/L 100 65.5 33-131
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 130 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I0329
LCS Dup (B4I0329-BSD1) Prepared: 09/04/23 Analyzed: 09/17/24 EPA 8270C
Surr: 2-Fluorobiphenyl 22.5 µg/L 50.0 45.0 32-116
Surr: 2-Fluorophenol 34.0 µg/L 100 34.0 21-72
Surr: d14-Terphenyl 39.4 µg/L 50.0 78.7 36-128
Surr: Nitrobenzene-d5 23.4 µg/L 50.0 46.8 32-120
Surr: Phenol-d5 22.6 µg/L 100 22.6 13-51
1,2,4-Trichlorobenzene *a 6.76 5.0 µg/L 25.0 27.0 44-142 6.57 20 1,4-Dichlorobenzene 10.2 5.0 µg/L 25.0 40.9 20-124 9.22 20 2,4-Dinitrotoluene 15.1 5.0 µg/L 25.0 60.3 39-139 7.03 20 2-Chlorophenol RPD 25.3 5.0 µg/L 50.0 50.6 23-134 23.8 20 4-Chloro-3-methylphenol 21.9 5.0 µg/L 50.0 43.8 22-147 14.2 20 Acenaphthene * 11.7 5.0 µg/L 25.0 46.9 47-145 11.1 20
N-Nitrosodi-n-propylamine 13.8 5.0 µg/L 25.0 55.1 5-230 13.3 20 Phenol RPD 12.0 5.0 µg/L 50.0 24.0 5-112 44.1 20
Pyrene 17.1 5.0 µg/L 25.0 68.3 52-115 4.14 20
Batch - B4I0616
Blank (B4I0616-BLK1) Prepared: 09/09/24 Analyzed: 09/24/24 EPA 8015B
Surr: o-Terphenyl 1.12 mg/kg 2.00 56.0 11.8-130
Diesel ND 10 mg/kg
Blank (B4I0616-BLK2) Prepared: 09/09/24 Analyzed: 09/24/24 EPA 8015B
Surr: o-Terphenyl 1.49 mg/kg 2.00 74.4 11.8-130
Motor Oil ND 10 mg/kg
LCS (B4I0616-BS1) Prepared: 09/09/24 Analyzed: 09/24/24 EPA 8015B
Surr: o-Terphenyl 1.40 mg/kg 2.00 70.1 11.8-130
Diesel 18.5 10 mg/kg 25.0 74.2 48-131
LCS (B4I0616-BS2) Prepared: 09/09/24 Analyzed: 09/24/24 EPA 8015B
Surr: o-Terphenyl 1.44 mg/kg 2.00 72.0 11.8-130
Motor Oil 22.6 10 mg/kg 25.0 90.5 62-132
LCS Dup (B4I0616-BSD1) Prepared: 09/09/24 Analyzed: 09/24/24 EPA 8015B
Surr: o-Terphenyl 1.36 mg/kg 2.00 68.0 11.8-130
Diesel 18.0 10 mg/kg 25.0 71.9 48-131 3.09 20
LCS Dup (B4I0616-BSD2) Prepared: 09/09/24 Analyzed: 09/24/24 EPA 8015B
Surr: o-Terphenyl 1.50 mg/kg 2.00 75.0 11.8-130
Motor Oil 25.8 10 mg/kg 25.0 103 62-132 12.9 20
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 131 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I0616
Matrix Spike (B4I0616-MS1) Prepared: 09/09/24 Analyzed: 09/24/24 Source: KH30003-01 EPA 8015B
Surr: o-Terphenyl 0.842 mg/kg 2.00 42.1 11.8-130
Diesel MS1 10.9 10 mg/kg 25.0 ND 43.5 48-131
Matrix Spike (B4I0616-MS2) Prepared: 09/09/24 Analyzed: 09/25/24 Source: KH30003-01 EPA 8015B
Surr: o-Terphenyl 0.798 mg/kg 2.00 39.9 11.8-130
Motor Oil 22.3 10 mg/kg 25.0 ND 89.0 48-131
Matrix Spike Dup (B4I0616-MSD1) Prepared: 09/09/24 Analyzed: 09/24/24 Source: KH30003-01 EPA 8015B
Surr: o-Terphenyl 0.820 mg/kg 2.00 41.0 11.8-130
Diesel MS1 10.8 10 mg/kg 25.0 ND 43.4 48-131 0.277 20
Matrix Spike Dup (B4I0616-MSD2) Prepared: 09/09/24 Analyzed: 09/25/24 Source: KH30003-01 EPA 8015B
Surr: o-Terphenyl 0.890 mg/kg 2.00 44.5 11.8-130
Motor Oil 26.5 10 mg/kg 25.0 ND 106 48-131 17.6 20
Batch - B4I1111
Blank (B4I1111-BLK1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0402 mg/kg 0.0500 80.4 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S 0.00138 mg/kg 0.0500 2.75 8.5-170 4,4¥-DDD ND 0.0083 mg/kg
4,4¥-DDE ND 0.0083 mg/kg
4,4¥-DDT ND 0.0083 mg/kg
alpha-BHC ND 0.0083 mg/kg
alpha-Chlordane ND 0.0083 mg/kg
beta-BHC ND 0.0083 mg/kg
Chlordane (tech) ND 0.030 mg/kg
delta-BHC ND 0.0083 mg/kg
Dieldrin ND 0.0083 mg/kg
Endosulfan I ND 0.0083 mg/kg
Endosulfan II ND 0.0083 mg/kg
Endosulfan sulfate ND 0.0083 mg/kg
Endrin ND 0.0083 mg/kg
Endrin aldehyde ND 0.0083 mg/kg
Endrin ketone ND 0.0083 mg/kg
gamma-BHC (Lindane) ND 0.0083 mg/kg
gamma-Chlordane ND 0.0083 mg/kg
Heptachlor ND 0.0083 mg/kg
Heptachlor epoxide ND 0.0083 mg/kg
Methoxychlor ND 0.0083 mg/kg
Toxaphene ND 0.017 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 132 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1111
Blank (B4I1111-BLK1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Trifluralin J 0.00606 0.0083 mg/kg
Blank (B4I1111-BLK2) Prepared: 09/11/24 Analyzed: 10/03/24 EPA 8082
Surr: Decachlorobiphenyl (DCB) S03 0.106 mg/kg 0.0500 211 17.2-156 Surr: Tetrachloro-meta-xylene (TMX) S 0.00 mg/kg 0.0500 20.6-119 PCB-1016 ND 0.017 mg/kg
PCB-1221 ND 0.017 mg/kg
PCB-1232 ND 0.017 mg/kg
PCB-1242 ND 0.017 mg/kg
PCB-1248 ND 0.017 mg/kg
PCB-1254 ND 0.017 mg/kg
PCB-1260 ND 0.017 mg/kg
LCS (B4I1111-BS1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0539 mg/kg 0.0500 108 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S 0.00114 mg/kg 0.0500 2.27 8.5-170 4,4¥-DDT 0.0252 0.0083 mg/kg 0.0250 101 25-160
Dieldrin 0.0250 0.0083 mg/kg 0.0250 99.8 36-146
Endrin 0.0265 0.0083 mg/kg 0.0250 106 30-147
gamma-BHC (Lindane) RPD 0.0160 0.0083 mg/kg 0.0250 63.9 19-140 Heptachlor RPD 0.0146 0.0083 mg/kg 0.0250 58.2 34-111
LCS (B4I1111-BS2) Prepared: 09/11/24 Analyzed: 10/03/24 EPA 8082
Surr: Decachlorobiphenyl (DCB) 0.0629 mg/kg 0.0500 126 17.2-156 Surr: Tetrachloro-meta-xylene (TMX) S 0.00 mg/kg 0.0500 20.6-119 PCB-1016 0.169 0.017 mg/kg 0.150 113 45-117
PCB-1260 BS1 0.191 0.017 mg/kg 0.150 127 45-117
LCS Dup (B4I1111-BSD1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0341 mg/kg 0.0500 68.2 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S 0.00139 mg/kg 0.0500 2.79 8.5-170 4,4¥-DDT 0.0213 0.0083 mg/kg 0.0250 85.2 25-160 16.8 20 Dieldrin 0.0218 0.0083 mg/kg 0.0250 87.1 36-146 13.7 20 Endrin 0.0218 0.0083 mg/kg 0.0250 87.2 30-147 19.4 20
gamma-BHC (Lindane) RPD 0.0119 0.0083 mg/kg 0.0250 47.6 19-140 29.2 20 Heptachlor RPD 0.00999 0.0083 mg/kg 0.0250 40.0 34-111 37.2 20 LCS Dup (B4I1111-BSD2) Prepared: 09/11/24 Analyzed: 10/03/24 EPA 8082
Surr: Decachlorobiphenyl (DCB) 0.0673 mg/kg 0.0500 135 17.2-156 Surr: Tetrachloro-meta-xylene (TMX) S 0.00 mg/kg 0.0500 20.6-119 Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 133 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1111
LCS Dup (B4I1111-BSD2) Prepared: 09/11/24 Analyzed: 10/03/24 EPA 8082
PCB-1016 0.144 0.017 mg/kg 0.150 95.9 45-117 16.2 20
PCB-1260 0.171 0.017 mg/kg 0.150 114 45-117 10.9 20
Duplicate (B4I1111-DUP1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Decachlorobiphenyl (DCB) S03 0.0188 mg/kg 0.0250 75.2 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) 0.0153 mg/kg 0.0250 61.1 8.5-170 4,4¥-DDD ND 0.0083 mg/kg ND
4,4¥-DDE ND 0.0083 mg/kg ND
4,4¥-DDT ND 0.0083 mg/kg ND
alpha-BHC ND 0.0083 mg/kg ND
alpha-Chlordane ND 0.0083 mg/kg ND
beta-BHC ND 0.0083 mg/kg ND
Chlordane (tech) ND 0.030 mg/kg ND
delta-BHC ND 0.0083 mg/kg ND
Dieldrin ND 0.0083 mg/kg ND
Endosulfan I ND 0.0083 mg/kg ND
Endosulfan II ND 0.0083 mg/kg ND
Endosulfan sulfate ND 0.0083 mg/kg ND
Endrin ND 0.0083 mg/kg ND
Endrin aldehyde ND 0.0083 mg/kg ND
Endrin ketone ND 0.0083 mg/kg ND
gamma-BHC (Lindane) ND 0.0083 mg/kg ND
gamma-Chlordane ND 0.0083 mg/kg ND
Heptachlor ND 0.0083 mg/kg ND
Heptachlor epoxide ND 0.0083 mg/kg ND
Methoxychlor ND 0.0083 mg/kg ND
Toxaphene ND 0.017 mg/kg ND
Trifluralin ND 0.0083 mg/kg ND
Matrix Spike (B4I1111-MS1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0192 mg/kg 0.0250 76.7 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) 0.0231 mg/kg 0.0250 92.6 8.5-170 4,4¥-DDT 0.00951 0.0083 mg/kg 0.0250 ND 38.0 25-160
Dieldrin 0.0134 0.0083 mg/kg 0.0250 ND 53.6 36-146
Endrin 0.0152 0.0083 mg/kg 0.0250 ND 60.7 30-147
gamma-BHC (Lindane) 0.00973 0.0083 mg/kg 0.0250 ND 38.9 19-140 Heptachlor 0.00929 0.0083 mg/kg 0.0250 ND 37.2 34-111
Matrix Spike (B4I1111-MS2) Prepared: 09/11/24 Analyzed: 10/03/24 Source: KH30003-01 EPA 8082
Surr: Decachlorobiphenyl (DCB) S02 0.0618 mg/kg 0.0250 247 17.2-156 Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 134 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1111
Matrix Spike (B4I1111-MS2) Prepared: 09/11/24 Analyzed: 10/03/24 Source: KH30003-01 EPA 8082
Surr: Tetrachloro-meta-xylene (TMX) 0.0212 mg/kg 0.0250 84.6 20.6-119 PCB-1016 MS1, 0.203 0.017 mg/kg 0.150 ND 135 45-117
RPD3
PCB-1260 MS1, 0.200 0.017 mg/kg 0.150 ND 133 45-117
RPD3
Matrix Spike Dup (B4I1111-MSD1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Decachlorobiphenyl (DCB) S02 0.0342 mg/kg 0.0250 137 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S02 0.0475 mg/kg 0.0250 190 8.5-170 4,4¥-DDT J 0.00790 0.0083 mg/kg 0.0250 ND 31.6 25-160 18.4 20 Dieldrin 0.0123 0.0083 mg/kg 0.0250 ND 49.2 36-146 8.55 20 Endrin 0.0138 0.0083 mg/kg 0.0250 ND 55.1 30-147 9.68 20 gamma-BHC (Lindane) 0.0103 0.0083 mg/kg 0.0250 ND 41.2 19-140 5.74 20 Heptachlor 0.00943 0.0083 mg/kg 0.0250 ND 37.7 34-111 1.41 20 Matrix Spike Dup (B4I1111-MSD2) Prepared: 09/11/24 Analyzed: 10/03/24 Source: KH30003-01 EPA 8082
Surr: Decachlorobiphenyl (DCB) S02 0.0485 mg/kg 0.0250 194 17.2-156 Surr: Tetrachloro-meta-xylene (TMX) 0.00992 mg/kg 0.0250 39.7 20.6-119 PCB-1016 RPD3 0.132 0.017 mg/kg 0.150 ND 88.0 45-117 42.4 20 PCB-1260 RPD3 0.128 0.017 mg/kg 0.150 ND 85.6 45-117 43.7 20 Batch - B4I1115
Blank (B4I1115-BLK1) Prepared: 09/11/24 Analyzed: 09/17/24 EPA 8270C
Surr: 2,4,6-Tribromophenol 2.98 mg/kg 3.33 89.3 13-118
Surr: 2-Fluorobiphenyl 1.21 mg/kg 1.67 72.4 22-112
Surr: 2-Fluorophenol 2.51 mg/kg 3.33 75.2 13-99
Surr: d14-Terphenyl 1.56 mg/kg 1.67 93.7 5-230
Surr: Nitrobenzene-d5 1.32 mg/kg 1.67 79.0 5-189
Surr: Phenol-d5 2.59 mg/kg 3.33 77.8 20-110
1,2,4-Trichlorobenzene ND 0.33 mg/kg
1,2-Diphenylhydrazine ND 0.33 mg/kg
1,3-Dinitrobenzene ND 0.33 mg/kg
1,4-Dichlorobenzene ND 0.33 mg/kg
1,4-Naphthoquinone ND 0.33 mg/kg
1-Naphthylamine ND 0.33 mg/kg
2,3,4,6-Tetrachlorophenol ND 0.33 mg/kg
2,4,5-Trichlorophenol ND 0.33 mg/kg
2,4,6-Trichlorophenol ND 0.33 mg/kg
2,4-Dichlorophenol ND 0.33 mg/kg
2,4-Dimethylphenol ND 0.33 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 135 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1115
Blank (B4I1115-BLK1) Prepared: 09/11/24 Analyzed: 09/17/24 EPA 8270C
2,4-Dinitrophenol ND 0.33 mg/kg
2,4-Dinitrotoluene ND 0.33 mg/kg
2,6-Dichlorophenol ND 0.33 mg/kg
2,6-Dinitrotoluene ND 0.33 mg/kg
2-Acetylaminofluorene ND 0.33 mg/kg
2-Chloronaphthalene ND 0.33 mg/kg
2-Chlorophenol ND 0.33 mg/kg
2-Methylnaphthalene ND 0.33 mg/kg
2-Methylphenol ND 0.33 mg/kg
2-Naphthylamine ND 0.33 mg/kg
2-Nitroaniline ND 0.33 mg/kg
2-Nitrophenol ND 0.33 mg/kg
3,3¥-Dimethylbenzidine ND 0.33 mg/kg
3,3'-Dichlorobenzidine ND 0.33 mg/kg
3-Methylcholanthrene ND 0.33 mg/kg
3-Nitroaniline ND 0.33 mg/kg
4,6-Dinitro-2-methylphenol ND 0.33 mg/kg
4-Aminobiphenyl ND 0.33 mg/kg
4-Bromophenyl phenyl ether ND 0.33 mg/kg
4-Chloro-3-methylphenol ND 0.33 mg/kg
4-Chlorophenyl phenyl ether ND 0.33 mg/kg
4-Methylphenol ND 0.33 mg/kg
4-Nitroaniline ND 0.33 mg/kg
4-Nitrophenol ND 0.33 mg/kg
5-Nitro-o-toluidine ND 0.33 mg/kg
7,12-Dimethylbenz(a)anthracene ND 0.33 mg/kg
Acenaphthene ND 0.33 mg/kg
Acenaphthylene ND 0.33 mg/kg
Acetophenone ND 0.33 mg/kg
Anthracene ND 0.33 mg/kg
Benzidine ND 0.33 mg/kg
Benzo (a) anthracene ND 0.33 mg/kg
Benzo (a) pyrene ND 0.33 mg/kg
Benzo (b) fluoranthene ND 0.33 mg/kg
Benzo (k) fluoranthene ND 0.33 mg/kg
Benzo(ghi)perylene ND 0.33 mg/kg
Benzoic acid ND 0.33 mg/kg
Benzyl alcohol ND 0.33 mg/kg
Bis(2-chloroethoxy)methane ND 0.33 mg/kg
Bis(2-chloroethyl)ether ND 0.33 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 136 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1115
Blank (B4I1115-BLK1) Prepared: 09/11/24 Analyzed: 09/17/24 EPA 8270C
Bis(2-chloroisopropyl)ether ND 0.33 mg/kg
Bis(2-ethylhexyl) phthalate ND 0.33 mg/kg
Butyl benzyl phthalate ND 0.33 mg/kg
Chrysene ND 0.33 mg/kg
Dibenzo(a,h)anthracene ND 0.33 mg/kg
Diethyl phthalate ND 0.33 mg/kg
Dimethyl phthalate ND 0.33 mg/kg
Di-n-butyl phthalate ND 0.33 mg/kg
Di-n-octyl phthalate ND 0.33 mg/kg
Diphenylamine ND 0.33 mg/kg
Ethyl Methanesulfonate ND 0.33 mg/kg
Fluoranthene ND 0.33 mg/kg
Fluorene ND 0.33 mg/kg
Hexachlorobenzene ND 0.33 mg/kg
Hexachlorocyclopentadiene ND 0.33 mg/kg
Hexachloroethane ND 0.33 mg/kg
Indeno(1,2,3-cd)pyrene ND 0.33 mg/kg
Isophorone ND 0.33 mg/kg
Methapyrilene ND 0.33 mg/kg
Methyl Methanesulfonate ND 0.33 mg/kg
Nitrobenzene ND 0.33 mg/kg
N-Nitrosodiethylamine ND 0.33 mg/kg
N-Nitrosodimethylamine ND 0.33 mg/kg
N-Nitrosodi-n-butylamine ND 0.33 mg/kg
N-Nitrosodi-n-propylamine ND 0.33 mg/kg
N-Nitrosodiphenylamine ND 0.33 mg/kg
N-Nitrosomethylethylamine ND 0.33 mg/kg
N-Nitrosopiperidine ND 0.33 mg/kg
N-Nitrosopyrrolidine ND 0.33 mg/kg
O,O,O-Triethyl phosphorothioate ND 0.33 mg/kg
o-Toluidine ND 0.33 mg/kg
p-Dimethylaminoazobenzene ND 0.33 mg/kg
Pentachlorobenzene ND 0.33 mg/kg
Pentachloronitrobenzene ND 0.33 mg/kg
Pentachlorophenol ND 0.33 mg/kg
Phenacetin ND 0.33 mg/kg
Phenanthrene ND 0.33 mg/kg
Phenol ND 0.33 mg/kg
Pronamide ND 0.33 mg/kg
Pyrene ND 0.33 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 137 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1115
Blank (B4I1115-BLK1) Prepared: 09/11/24 Analyzed: 09/17/24 EPA 8270C
Safrole ND 0.33 mg/kg
LCS (B4I1115-BS1) Prepared: 09/11/24 Analyzed: 09/17/24 EPA 8270C
Surr: 2,4,6-Tribromophenol 3.06 mg/kg 3.33 91.8 30-125
Surr: 2-Fluorobiphenyl 1.28 mg/kg 1.67 76.7 32-114
Surr: 2-Fluorophenol 2.49 mg/kg 3.33 74.7 21-105
Surr: d14-Terphenyl 1.48 mg/kg 1.67 88.8 34-123
Surr: Nitrobenzene-d5 1.28 mg/kg 1.67 76.9 20-116
Surr: Phenol-d5 2.68 mg/kg 3.33 80.4 25-116
1,2,4-Trichlorobenzene 0.424 0.33 mg/kg 0.833 50.9 44-142 1,4-Dichlorobenzene 0.623 0.33 mg/kg 0.833 74.8 20-124
2,4-Dinitrotoluene 0.631 0.33 mg/kg 0.833 75.8 39-139
2-Chlorophenol 1.33 0.33 mg/kg 1.67 80.1 23-134
4-Chloro-3-methylphenol 1.05 0.33 mg/kg 1.67 62.8 22-147 Acenaphthene 0.628 0.33 mg/kg 0.833 75.3 47-145
N-Nitrosodi-n-propylamine 0.674 0.33 mg/kg 0.833 80.9 5-230 Phenol 1.36 0.33 mg/kg 1.67 81.4 5-112
Pyrene 0.669 0.33 mg/kg 0.833 80.3 52-115
LCS Dup (B4I1115-BSD1) Prepared: 09/11/24 Analyzed: 09/17/24 EPA 8270C
Surr: 2,4,6-Tribromophenol 3.11 mg/kg 3.33 93.2 30-125
Surr: 2-Fluorobiphenyl 1.33 mg/kg 1.67 80.0 32-114
Surr: 2-Fluorophenol 2.73 mg/kg 3.33 81.9 21-105
Surr: d14-Terphenyl 1.55 mg/kg 1.67 92.9 34-123
Surr: Nitrobenzene-d5 1.41 mg/kg 1.67 84.4 20-116
Surr: Phenol-d5 2.86 mg/kg 3.33 85.8 25-116
1,2,4-Trichlorobenzene 0.454 0.33 mg/kg 0.833 54.5 44-142 6.80 20 1,4-Dichlorobenzene 0.679 0.33 mg/kg 0.833 81.4 20-124 8.53 20 2,4-Dinitrotoluene 0.709 0.33 mg/kg 0.833 85.1 39-139 11.6 20 2-Chlorophenol 1.47 0.33 mg/kg 1.67 88.2 23-134 9.70 20 4-Chloro-3-methylphenol 1.13 0.33 mg/kg 1.67 67.6 22-147 7.29 20 Acenaphthene 0.668 0.33 mg/kg 0.833 80.1 47-145 6.21 20 N-Nitrosodi-n-propylamine 0.720 0.33 mg/kg 0.833 86.4 5-230 6.63 20 Phenol 1.49 0.33 mg/kg 1.67 89.2 5-112 9.16 20
Pyrene 0.719 0.33 mg/kg 0.833 86.3 52-115 7.17 20
Matrix Spike (B4I1115-MS1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KI11001-04 EPA 8270C
Surr: 2,4,6-Tribromophenol 3.00 mg/kg 3.30 90.8 13-118
Surr: 2-Fluorobiphenyl 1.34 mg/kg 1.65 81.4 22-112
Surr: 2-Fluorophenol 2.61 mg/kg 3.30 79.1 13-99
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 138 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1115
Matrix Spike (B4I1115-MS1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KI11001-04 EPA 8270C
Surr: d14-Terphenyl 2.01 mg/kg 1.65 122 5-230
Surr: Nitrobenzene-d5 1.38 mg/kg 1.65 83.8 5-189
Surr: Phenol-d5 2.72 mg/kg 3.30 82.6 20-110
1,2,4-Trichlorobenzene 0.397 0.33 mg/kg 0.825 ND 48.2 44-142 1,4-Dichlorobenzene 0.610 0.33 mg/kg 0.825 ND 74.0 20-124 2,4-Dinitrotoluene 0.658 0.33 mg/kg 0.825 ND 79.8 39-139 2-Chlorophenol 1.30 0.33 mg/kg 1.65 ND 78.6 23-134
4-Chloro-3-methylphenol 1.03 0.33 mg/kg 1.65 ND 62.6 22-147 Acenaphthene 0.616 0.33 mg/kg 0.825 ND 74.6 47-145
N-Nitrosodi-n-propylamine 0.654 0.33 mg/kg 0.825 ND 79.2 5-230 Phenol 1.32 0.33 mg/kg 1.65 ND 80.3 5-112
Pyrene 0.886 0.33 mg/kg 0.825 ND 107 52-115
Matrix Spike Dup (B4I1115-MSD1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KI11001-04 EPA 8270C
Surr: 2,4,6-Tribromophenol 2.47 mg/kg 3.26 75.8 13-118
Surr: 2-Fluorobiphenyl 1.13 mg/kg 1.63 69.5 22-112
Surr: 2-Fluorophenol 2.23 mg/kg 3.26 68.5 13-99
Surr: d14-Terphenyl 1.63 mg/kg 1.63 100 5-230
Surr: Nitrobenzene-d5 1.17 mg/kg 1.63 71.8 5-189
Surr: Phenol-d5 2.35 mg/kg 3.26 72.1 20-110
1,2,4-Trichlorobenzene MS3 0.345 0.33 mg/kg 0.814 ND 42.4 44-142 14.1 20 1,4-Dichlorobenzene 0.528 0.33 mg/kg 0.814 ND 64.8 20-124 14.4 20 2,4-Dinitrotoluene 0.553 0.33 mg/kg 0.814 ND 67.9 39-139 17.4 20 2-Chlorophenol 1.12 0.33 mg/kg 1.63 ND 68.9 23-134 14.5 20 4-Chloro-3-methylphenol 0.899 0.33 mg/kg 1.63 ND 55.2 22-147 13.9 20 Acenaphthene 0.533 0.33 mg/kg 0.814 ND 65.4 47-145 14.4 20 N-Nitrosodi-n-propylamine 0.578 0.33 mg/kg 0.814 ND 71.0 5-230 12.2 20 Phenol 1.15 0.33 mg/kg 1.63 ND 70.9 5-112 13.7 20
Pyrene 0.738 0.33 mg/kg 0.814 ND 90.6 52-115 18.2 20
Batch - B4I1140
Blank (B4I1140-BLK1) Prepared: 09/11/24 Analyzed: 09/21/24 EPA 8015B
Surr: o-Terphenyl 1.67 mg/kg 2.00 83.5 11.8-130
Surr: o-Terphenyl 1.24 mg/kg 2.00 61.9 11.8-130
Diesel ND 10 mg/kg
Motor Oil ND 10 mg/kg
LCS (B4I1140-BS1) Prepared: 09/11/24 Analyzed: 09/21/24 EPA 8015B
Surr: o-Terphenyl 1.30 mg/kg 2.00 65.1 11.8-130
Diesel 18.6 10 mg/kg 25.0 74.3 48-131
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 139 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1140
LCS (B4I1140-BS2) Prepared: 09/11/24 Analyzed: 09/22/24 EPA 8015B
Surr: o-Terphenyl 1.59 mg/kg 2.00 79.3 11.8-130
Motor Oil 21.4 10 mg/kg 25.0 85.6 62-132
LCS Dup (B4I1140-BSD1) Prepared: 09/11/24 Analyzed: 09/21/24 EPA 8015B
Surr: o-Terphenyl 1.47 mg/kg 2.00 73.4 11.8-130
Diesel 22.3 10 mg/kg 25.0 89.2 48-131 18.1 20
LCS Dup (B4I1140-BSD2) Prepared: 09/11/24 Analyzed: 09/22/24 EPA 8015B
Surr: o-Terphenyl 1.58 mg/kg 2.00 79.0 11.8-130
Motor Oil 25.4 10 mg/kg 25.0 102 62-132 17.2 20
Matrix Spike (B4I1140-MS1) Prepared: 09/11/24 Analyzed: 09/22/24 Source: KH30003-14 EPA 8015B
Surr: o-Terphenyl 1.13 mg/kg 2.00 56.4 11.8-130
Diesel 12.4 10 mg/kg 25.0 ND 49.5 48-131
Matrix Spike (B4I1140-MS2) Prepared: 09/11/24 Analyzed: 09/22/24 Source: KH30003-14 EPA 8015B
Surr: o-Terphenyl 1.33 mg/kg 2.00 66.7 11.8-130
Motor Oil 24.3 10 mg/kg 25.0 ND 97.0 48-131
Matrix Spike Dup (B4I1140-MSD1) Prepared: 09/11/24 Analyzed: 09/22/24 Source: KH30003-14 EPA 8015B
Surr: o-Terphenyl 0.889 mg/kg 2.00 44.4 11.8-130
Diesel MS1, J 9.55 10 mg/kg 25.0 ND 38.2 48-131 25.8 20 Matrix Spike Dup (B4I1140-MSD2) Prepared: 09/11/24 Analyzed: 09/22/24 Source: KH30003-14 EPA 8015B
Surr: o-Terphenyl 1.37 mg/kg 2.00 68.3 11.8-130
Motor Oil 24.3 10 mg/kg 25.0 ND 97.2 48-131 0.150 20
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 140 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0304
Blank (B4I0304-BLK1) Prepared & Analyzed: 09/03/24
EPA 8260B
Surr: 4-Bromofluorobenzene 22.6 µg/L 25.0 90.2 70-130
Surr: Dibromofluoromethane 27.5 µg/L 25.0 110 70-130
Surr: Toluene-d8 26.7 µg/L 25.0 107 70-130
1,1,1,2-Tetrachloroethane ND 0.50 µg/L
1,1,1-Trichloroethane (TCA) ND 0.50 µg/L
1,1,2,2-Tetrachloroethane ND 1.0 µg/L
1,1,2-Trichloroethane ND 0.50 µg/L
1,1-Dichloroethane ND 0.50 µg/L
1,1-Dichloroethene ND 0.50 µg/L
1,1-Dichloropropene ND 0.50 µg/L
1,2,3-Trichlorobenzene ND 0.50 µg/L
1,2,3-Trichloropropane (123TCP) ND 0.50 µg/L
1,2,4-Trichlorobenzene ND 1.0 µg/L
1,2,4-Trimethylbenzene ND 1.0 µg/L
1,2-Dibromo-3-chloropropane (DBCP) ND 5.0 µg/L
1,2-Dibromoethane (EDB) ND 0.50 µg/L
1,2-Dichlorobenzene ND 0.50 µg/L
1,2-Dichloroethane (1,2-DCA) ND 0.50 µg/L
1,2-Dichloropropane ND 0.50 µg/L
1,3,5-Trimethylbenzene ND 0.50 µg/L
1,3-Dichlorobenzene ND 0.50 µg/L
1,3-Dichloropropane ND 0.50 µg/L
1,4-Dichlorobenzene ND 0.50 µg/L
2,2-Dichloropropane ND 1.0 µg/L
2-Butanone (MEK) ND 10 µg/L
2-Chloroethylvinyl ether ND 1.0 µg/L
2-Chlorotoluene ND 0.50 µg/L
2-Hexanone ND 1.0 µg/L
4-Chlorotoluene ND 0.50 µg/L
4-Methyl-2-pentanone (MIBK) ND 1.0 µg/L
Acetone ND 10 µg/L
Acetonitrile ND 10 µg/L
Acrolein ND 10 µg/L
Acrylonitrile ND 5.0 µg/L
Benzene ND 0.50 µg/L
Bromobenzene ND 0.50 µg/L
Bromochloromethane ND 0.50 µg/L
Bromodichloromethane ND 0.50 µg/L
Bromoform ND 0.50 µg/L
Bromomethane ND 1.0 µg/L
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 141 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0304
Blank (B4I0304-BLK1) Prepared & Analyzed: 09/03/24
EPA 8260B
Carbon disulfide ND 0.50 µg/L
Carbon tetrachloride ND 0.50 µg/L
Chlorobenzene ND 0.50 µg/L
Chloroethane ND 0.50 µg/L
Chloroform ND 0.50 µg/L
Chloromethane ND 0.50 µg/L
cis-1,2-Dichloroethene ND 0.50 µg/L
cis-1,3-Dichloropropene ND 0.50 µg/L
Dibromochloromethane ND 0.50 µg/L
Dibromomethane ND 0.50 µg/L
Dichlorodifluoromethane (CFC-12) ND 0.50 µg/L
Di-isopropyl ether (DIPE) ND 0.50 µg/L
Ethanol ND 50 µg/L
Ethyl methacrylate ND 1.0 µg/L
Ethyl tert-Butyl Ether (ETBE) ND 1.0 µg/L
Ethylbenzene ND 0.50 µg/L
Hexachlorobutadiene ND 1.0 µg/L
Hexachloroethane ND 1.0 µg/L
Iodomethane ND 5.0 µg/L
Isobutyl alcohol ND 20 µg/L
Isopropylbenzene ND 1.0 µg/L
m,p-Xylene ND 1.0 µg/L
Methacrylonitrile ND 5.0 µg/L
Methyl Methacrylate ND 0.50 µg/L
Methyl tert-Butyl Ether (MTBE) ND 1.0 µg/L
Methylene chloride ND 1.0 µg/L
Naphthalene ND 0.50 µg/L
n-Butylbenzene ND 0.50 µg/L
n-Propylbenzene ND 1.0 µg/L
o-Xylene ND 0.50 µg/L
p-Isopropyltoluene ND 1.0 µg/L
Propionitrile ND 10 µg/L
sec-Butylbenzene ND 0.50 µg/L
Styrene ND 0.50 µg/L
Tert-Amyl Methyl Ether (TAME) ND 1.0 µg/L
tert-Butyl alcohol (TBA) ND 20 µg/L
tert-Butylbenzene ND 1.0 µg/L
Tetrachloroethene (PCE) ND 0.50 µg/L
Toluene ND 0.50 µg/L
trans-1,2-Dichloroethene ND 0.50 µg/L
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 142 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0304
Blank (B4I0304-BLK1) Prepared & Analyzed: 09/03/24
EPA 8260B
trans-1,3-Dichloropropene ND 0.50 µg/L
trans-1,4-Dichloro-2-butene ND 5.0 µg/L
Trichloroethene (TCE) ND 0.50 µg/L
Trichlorofluoromethane (CFC-11) ND 0.50 µg/L
Trichlorotrifluoroethane (CFC-113) ND 1.0 µg/L
Vinyl acetate ND 0.50 µg/L
Vinyl chloride ND 0.50 µg/L
Xylenes ND 2.0 µg/L
LCS (B4I0304-BS1) Prepared & Analyzed: 09/03/24
EPA 8260B
Surr: 4-Bromofluorobenzene 22.9 µg/L 25.0 91.6 70-130
Surr: Dibromofluoromethane 27.8 µg/L 25.0 111 70-130
Surr: Toluene-d8 26.8 µg/L 25.0 107 70-130
1,1-Dichloroethene 18.5 0.50 µg/L 20.0 92.6 70-130
Benzene 18.1 0.50 µg/L 20.0 90.6 70-130
Chlorobenzene 23.6 0.50 µg/L 20.0 118 70-130
Toluene 21.4 0.50 µg/L 20.0 107 70-130
Trichloroethene (TCE) 19.9 0.50 µg/L 20.0 99.3 70-130
LCS Dup (B4I0304-BSD1) Prepared & Analyzed: 09/03/24
EPA 8260B
Surr: 4-Bromofluorobenzene 22.5 µg/L 25.0 89.8 70-130
Surr: Dibromofluoromethane 27.9 µg/L 25.0 112 70-130
Surr: Toluene-d8 26.0 µg/L 25.0 104 70-130
1,1-Dichloroethene 20.1 0.50 µg/L 20.0 101 70-130 8.28 20 Benzene 20.5 0.50 µg/L 20.0 102 70-130 12.2 20
Chlorobenzene 25.6 0.50 µg/L 20.0 128 70-130 8.14 20
Toluene 22.9 0.50 µg/L 20.0 115 70-130 6.58 20
Trichloroethene (TCE) 22.3 0.50 µg/L 20.0 111 70-130 11.5 20 Batch - B4I0305
Blank (B4I0305-BLK1) Prepared & Analyzed: 09/03/24
EPA 8260B
Surr: 4-Bromofluorobenzene 0.0232 mg/kg 0.0250 92.8 70-130 Surr: Dibromofluoromethane 0.0250 mg/kg 0.0250 100 70-130 Surr: Toluene-d8 0.0250 mg/kg 0.0250 100 70-130
1,1,1,2-Tetrachloroethane ND 0.0010 mg/kg
1,1,1-Trichloroethane (TCA) ND 0.0010 mg/kg
1,1,2,2-Tetrachloroethane ND 0.0010 mg/kg
1,1,2-Trichloroethane ND 0.0010 mg/kg
1,1-Dichloroethane ND 0.0010 mg/kg
1,1-Dichloroethene ND 0.0010 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 143 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0305
Blank (B4I0305-BLK1) Prepared & Analyzed: 09/03/24
EPA 8260B
1,1-Dichloropropene ND 0.0010 mg/kg
1,2,3-Trichlorobenzene ND 0.0010 mg/kg
1,2,3-Trichloropropane (123TCP) ND 0.0010 mg/kg
1,2,4-Trichlorobenzene ND 0.0010 mg/kg
1,2,4-Trimethylbenzene ND 0.0010 mg/kg
1,2-Dibromo-3-chloropropane (DBCP) ND 0.0050 mg/kg
1,2-Dibromoethane (EDB) ND 0.0010 mg/kg
1,2-Dichlorobenzene ND 0.0010 mg/kg
1,2-Dichloroethane (1,2-DCA) ND 0.0010 mg/kg
1,2-Dichloropropane ND 0.0010 mg/kg
1,3,5-Trimethylbenzene ND 0.0010 mg/kg
1,3-Dichlorobenzene ND 0.0010 mg/kg
1,3-Dichloropropane ND 0.0010 mg/kg
1,4-Dichlorobenzene ND 0.0010 mg/kg
2,2-Dichloropropane ND 0.0010 mg/kg
2-Butanone (MEK) ND 0.0010 mg/kg
2-Chloroethylvinyl ether ND 0.020 mg/kg
2-Chlorotoluene ND 0.0010 mg/kg
2-Hexanone ND 0.0010 mg/kg
4-Chlorotoluene ND 0.0010 mg/kg
4-Methyl-2-pentanone (MIBK) ND 0.0010 mg/kg
Acetone ND 0.020 mg/kg
Acrolein ND 0.050 mg/kg
Acrylonitrile ND 0.010 mg/kg
Benzene ND 0.0010 mg/kg
Bromobenzene ND 0.0010 mg/kg
Bromochloromethane ND 0.0010 mg/kg
Bromodichloromethane ND 0.0010 mg/kg
Bromoform ND 0.0010 mg/kg
Bromomethane ND 0.0010 mg/kg
Carbon disulfide ND 0.0010 mg/kg
Carbon tetrachloride ND 0.0010 mg/kg
Chlorobenzene ND 0.0010 mg/kg
Chloroethane ND 0.0010 mg/kg
Chloroform ND 0.0010 mg/kg
Chloromethane ND 0.0010 mg/kg
Chloroprene ND 0.0010 mg/kg
cis-1,2-Dichloroethene ND 0.0010 mg/kg
cis-1,3-Dichloropropene ND 0.0010 mg/kg
Dibromochloromethane ND 0.0010 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 144 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0305
Blank (B4I0305-BLK1) Prepared & Analyzed: 09/03/24
EPA 8260B
Dibromomethane ND 0.0010 mg/kg
Dichlorodifluoromethane (CFC-12) ND 0.0010 mg/kg
Di-isopropyl ether (DIPE) ND 0.0010 mg/kg
Ethanol ND 0.050 mg/kg
Ethyl methacrylate ND 0.0010 mg/kg
Ethyl tert-Butyl Ether (ETBE) ND 0.0010 mg/kg
Ethylbenzene ND 0.0010 mg/kg
Hexachlorobutadiene ND 0.0010 mg/kg
Iodomethane ND 0.0010 mg/kg
Isopropylbenzene ND 0.0010 mg/kg
m,p-Xylene ND 0.0010 mg/kg
Methyl Methacrylate ND 0.0010 mg/kg
Methyl tert-Butyl Ether (MTBE) ND 0.0010 mg/kg
Methylene chloride ND 0.0020 mg/kg
Naphthalene ND 0.0010 mg/kg
n-Butylbenzene ND 0.0010 mg/kg
n-Propylbenzene ND 0.0010 mg/kg
o-Xylene ND 0.0010 mg/kg
p-Isopropyltoluene ND 0.0010 mg/kg
sec-Butylbenzene ND 0.0010 mg/kg
Styrene ND 0.0010 mg/kg
Tert-Amyl Methyl Ether (TAME) ND 0.0010 mg/kg
tert-Butyl alcohol (TBA) ND 0.020 mg/kg
tert-Butylbenzene ND 0.0010 mg/kg
Tetrachloroethene (PCE) ND 0.0010 mg/kg
Toluene ND 0.0010 mg/kg
trans-1,2-Dichloroethene ND 0.0010 mg/kg
trans-1,3-Dichloropropene ND 0.0010 mg/kg
trans-1,4-Dichloro-2-butene ND 0.0010 mg/kg
Trichloroethene (TCE) ND 0.0010 mg/kg
Trichlorofluoromethane (CFC-11) ND 0.0010 mg/kg
Trichlorotrifluoroethane (CFC-113) ND 0.0010 mg/kg
Vinyl acetate ND 0.0010 mg/kg
Vinyl chloride ND 0.0010 mg/kg
Xylenes ND 0.0010 mg/kg
LCS (B4I0305-BS1) Prepared & Analyzed: 09/03/24
EPA 8260B
Surr: 4-Bromofluorobenzene 0.0237 mg/kg 0.0250 94.7 70-130 Surr: Dibromofluoromethane 0.0245 mg/kg 0.0250 98.0 70-130 Surr: Toluene-d8 0.0250 mg/kg 0.0250 99.8 70-130
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 145 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0305
LCS (B4I0305-BS1) Prepared & Analyzed: 09/03/24
EPA 8260B
1,1-Dichloroethene 0.0212 0.0010 mg/kg 0.0200 106 70-130 Benzene 0.0192 0.0010 mg/kg 0.0200 96.0 70-130
Chlorobenzene 0.0212 0.0010 mg/kg 0.0200 106 70-130
Toluene 0.0201 0.0010 mg/kg 0.0200 101 70-130
Trichloroethene (TCE) 0.0204 0.0010 mg/kg 0.0200 102 70-130 LCS Dup (B4I0305-BSD1) Prepared & Analyzed: 09/03/24
EPA 8260B
Surr: 4-Bromofluorobenzene 0.0231 mg/kg 0.0250 92.4 70-130 Surr: Dibromofluoromethane 0.0238 mg/kg 0.0250 95.2 70-130 Surr: Toluene-d8 0.0246 mg/kg 0.0250 98.5 70-130
1,1-Dichloroethene 0.0193 0.0010 mg/kg 0.0200 96.6 70-130 9.42 20 Benzene 0.0176 0.0010 mg/kg 0.0200 88.0 70-130 8.75 20
Chlorobenzene 0.0193 0.0010 mg/kg 0.0200 96.7 70-130 8.99 20 Toluene 0.0188 0.0010 mg/kg 0.0200 94.2 70-130 6.67 20
Trichloroethene (TCE) 0.0186 0.0010 mg/kg 0.0200 93.0 70-130 9.09 20 Batch - B4I0310
Blank (B4I0310-BLK1) Prepared & Analyzed: 09/03/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0519 mg/kg 0.0625 83.0 70-130 Gasoline (C6-C10) ND 1.0 mg/kg
LCS (B4I0310-BS1) Prepared & Analyzed: 09/03/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0546 mg/kg 0.0625 87.3 70-130 Gasoline (C6-C10) 2.75 1.0 mg/kg 2.50 110 70-130
LCS Dup (B4I0310-BSD1) Prepared & Analyzed: 09/03/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0535 mg/kg 0.0625 85.6 70-130 Gasoline (C6-C10) 2.94 1.0 mg/kg 2.50 118 70-130 6.68 20 Batch - B4I0412
Blank (B4I0412-BLK1) Prepared & Analyzed: 09/04/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0515 mg/kg 0.0625 82.4 70-130 Gasoline (C6-C10) ND 1.0 mg/kg
LCS (B4I0412-BS1) Prepared & Analyzed: 09/04/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0537 mg/kg 0.0625 85.9 70-130 Gasoline (C6-C10) 2.61 1.0 mg/kg 2.50 104 70-130
LCS Dup (B4I0412-BSD1) Prepared & Analyzed: 09/04/24
EPA 8015B
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 146 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0412
LCS Dup (B4I0412-BSD1) Prepared & Analyzed: 09/04/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0558 mg/kg 0.0625 89.3 70-130 Gasoline (C6-C10) 2.66 1.0 mg/kg 2.50 106 70-130 2.04 20 Batch - B4I0511
Blank (B4I0511-BLK1) Prepared & Analyzed: 09/05/24
EPA 8260B
Surr: 4-Bromofluorobenzene 0.0223 mg/kg 0.0250 89.4 70-130 Surr: Dibromofluoromethane 0.0237 mg/kg 0.0250 94.9 70-130 Surr: Toluene-d8 0.0250 mg/kg 0.0250 100 70-130
1,1,1,2-Tetrachloroethane ND 0.0010 mg/kg
1,1,1-Trichloroethane (TCA) ND 0.0010 mg/kg
1,1,2,2-Tetrachloroethane ND 0.0010 mg/kg
1,1,2-Trichloroethane ND 0.0010 mg/kg
1,1-Dichloroethane ND 0.0010 mg/kg
1,1-Dichloroethene ND 0.0010 mg/kg
1,1-Dichloropropene ND 0.0010 mg/kg
1,2,3-Trichlorobenzene ND 0.0010 mg/kg
1,2,3-Trichloropropane (123TCP) ND 0.0010 mg/kg
1,2,4-Trichlorobenzene ND 0.0010 mg/kg
1,2,4-Trimethylbenzene ND 0.0010 mg/kg
1,2-Dibromo-3-chloropropane (DBCP) ND 0.0050 mg/kg
1,2-Dibromoethane (EDB) ND 0.0010 mg/kg
1,2-Dichlorobenzene ND 0.0010 mg/kg
1,2-Dichloroethane (1,2-DCA) ND 0.0010 mg/kg
1,2-Dichloropropane ND 0.0010 mg/kg
1,3,5-Trimethylbenzene ND 0.0010 mg/kg
1,3-Dichlorobenzene ND 0.0010 mg/kg
1,3-Dichloropropane ND 0.0010 mg/kg
1,4-Dichlorobenzene ND 0.0010 mg/kg
2,2-Dichloropropane ND 0.0010 mg/kg
2-Butanone (MEK) ND 0.0010 mg/kg
2-Chloroethylvinyl ether ND 0.020 mg/kg
2-Chlorotoluene ND 0.0010 mg/kg
2-Hexanone ND 0.0010 mg/kg
4-Chlorotoluene ND 0.0010 mg/kg
4-Methyl-2-pentanone (MIBK) ND 0.0010 mg/kg
Acetone ND 0.020 mg/kg
Acrolein ND 0.050 mg/kg
Acrylonitrile ND 0.010 mg/kg
Benzene ND 0.0010 mg/kg
Bromobenzene ND 0.0010 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 147 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0511
Blank (B4I0511-BLK1) Prepared & Analyzed: 09/05/24
EPA 8260B
Bromochloromethane ND 0.0010 mg/kg
Bromodichloromethane ND 0.0010 mg/kg
Bromoform ND 0.0010 mg/kg
Bromomethane ND 0.0010 mg/kg
Carbon disulfide ND 0.0010 mg/kg
Carbon tetrachloride ND 0.0010 mg/kg
Chlorobenzene ND 0.0010 mg/kg
Chlorodifluoromethane ND 0.0010 mg/kg
Chloroethane ND 0.0010 mg/kg
Chloroform ND 0.0010 mg/kg
Chloromethane ND 0.0010 mg/kg
Chloroprene ND 0.0010 mg/kg
cis-1,2-Dichloroethene ND 0.0010 mg/kg
cis-1,3-Dichloropropene ND 0.0010 mg/kg
Dibromochloromethane ND 0.0010 mg/kg
Dibromomethane ND 0.0010 mg/kg
Dichlorodifluoromethane (CFC-12) ND 0.0010 mg/kg
Dichlorotetrafluoroethane (CFC-114) ND 0.010 mg/kg
Di-isopropyl ether (DIPE) ND 0.0010 mg/kg
Ethanol ND 0.050 mg/kg
Ethyl methacrylate ND 0.0010 mg/kg
Ethyl tert-Butyl Ether (ETBE) ND 0.0010 mg/kg
Ethylbenzene ND 0.0010 mg/kg
Hexachlorobutadiene ND 0.0010 mg/kg
Iodomethane ND 0.0010 mg/kg
Isopropylbenzene ND 0.0010 mg/kg
m,p-Xylene ND 0.0010 mg/kg
Methyl Methacrylate ND 0.0010 mg/kg
Methyl tert-Butyl Ether (MTBE) ND 0.0010 mg/kg
Methylene chloride ND 0.0020 mg/kg
Naphthalene ND 0.0010 mg/kg
n-Butylbenzene ND 0.0010 mg/kg
n-Propylbenzene ND 0.0010 mg/kg
o-Xylene ND 0.0010 mg/kg
p-Isopropyltoluene ND 0.0010 mg/kg
sec-Butylbenzene ND 0.0010 mg/kg
Styrene ND 0.0010 mg/kg
Tert-Amyl Methyl Ether (TAME) ND 0.0010 mg/kg
tert-Butyl alcohol (TBA) ND 0.020 mg/kg
tert-Butylbenzene ND 0.0010 mg/kg
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 148 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0511
Blank (B4I0511-BLK1) Prepared & Analyzed: 09/05/24
EPA 8260B
Tetrachloroethene (PCE) ND 0.0010 mg/kg
Toluene ND 0.0010 mg/kg
trans-1,2-Dichloroethene ND 0.0010 mg/kg
trans-1,3-Dichloropropene ND 0.0010 mg/kg
trans-1,4-Dichloro-2-butene ND 0.0010 mg/kg
Trichloroethene (TCE) ND 0.0010 mg/kg
Trichlorofluoromethane (CFC-11) ND 0.0010 mg/kg
Trichlorotrifluoroethane (CFC-113) ND 0.0010 mg/kg
Vinyl acetate ND 0.0010 mg/kg
Vinyl chloride ND 0.0010 mg/kg
Xylenes ND 0.0010 mg/kg
LCS (B4I0511-BS1) Prepared & Analyzed: 09/05/24
EPA 8260B
Surr: 4-Bromofluorobenzene 0.0228 mg/kg 0.0250 91.2 70-130 Surr: Dibromofluoromethane 0.0238 mg/kg 0.0250 95.0 70-130 Surr: Toluene-d8 0.0251 mg/kg 0.0250 100 70-130
1,1-Dichloroethene 0.0198 0.0010 mg/kg 0.0200 99.0 70-130 Benzene 0.0183 0.0010 mg/kg 0.0200 91.6 70-130
Chlorobenzene 0.0198 0.0010 mg/kg 0.0200 99.3 70-130
Toluene 0.0191 0.0010 mg/kg 0.0200 95.6 70-130
Trichloroethene (TCE) 0.0190 0.0010 mg/kg 0.0200 94.8 70-130 LCS Dup (B4I0511-BSD1) Prepared & Analyzed: 09/05/24
EPA 8260B
Surr: 4-Bromofluorobenzene 0.0228 mg/kg 0.0250 91.4 70-130 Surr: Dibromofluoromethane 0.0248 mg/kg 0.0250 99.1 70-130 Surr: Toluene-d8 0.0247 mg/kg 0.0250 98.8 70-130
1,1-Dichloroethene 0.0199 0.0010 mg/kg 0.0200 99.6 70-130 0.605 20 Benzene 0.0186 0.0010 mg/kg 0.0200 93.0 70-130 1.52 20
Chlorobenzene 0.0194 0.0010 mg/kg 0.0200 96.8 70-130 2.50 20 Toluene 0.0184 0.0010 mg/kg 0.0200 91.8 70-130 4.06 20
Trichloroethene (TCE) 0.0184 0.0010 mg/kg 0.0200 92.0 70-130 3.00 20 Batch - B4I0514
Blank (B4I0514-BLK1) Prepared & Analyzed: 09/05/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0492 mg/kg 0.0625 78.7 70-130 Gasoline (C6-C10) ND 1.0 mg/kg
LCS (B4I0514-BS1) Prepared & Analyzed: 09/05/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0570 mg/kg 0.0625 91.1 70-130 Gasoline (C6-C10) 2.77 1.0 mg/kg 2.50 111 70-130
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 149 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Volatile Organics
Flag
Batch - B4I0514
LCS Dup (B4I0514-BSD1) Prepared & Analyzed: 09/05/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0589 mg/kg 0.0625 94.3 70-130 Gasoline (C6-C10) 2.82 1.0 mg/kg 2.50 113 70-130 1.62 20 Batch - B4I0610
Blank (B4I0610-BLK1) Prepared & Analyzed: 09/06/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 19.0 µg/L 25.0 75.8 70-130 Gasoline (C6-C10) ND 50 µg/L
LCS (B4I0610-BS1) Prepared & Analyzed: 09/06/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 25.4 µg/L 25.0 102 70-130 Gasoline (C6-C10) 1100 50 µg/L 1000 110 70-130
LCS Dup (B4I0610-BSD1) Prepared & Analyzed: 09/06/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 25.4 µg/L 25.0 101 70-130 Gasoline (C6-C10) 1170 50 µg/L 1000 117 70-130 6.21 20
Batch - B4I0906
Blank (B4I0906-BLK1) Prepared & Analyzed: 09/09/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0494 mg/kg 0.0625 79.1 70-130 Gasoline (C6-C10) ND 1.0 mg/kg
LCS (B4I0906-BS1) Prepared & Analyzed: 09/09/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0604 mg/kg 0.0625 96.6 70-130 Gasoline (C6-C10) 2.62 1.0 mg/kg 2.50 105 70-130
LCS Dup (B4I0906-BSD1) Prepared & Analyzed: 09/09/24
EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0640 mg/kg 0.0625 102 70-130 Gasoline (C6-C10) 2.58 1.0 mg/kg 2.50 103 70-130 1.60 20 Matrix Spike (B4I0906-MS1) Prepared & Analyzed: 09/09/24 Source: KH30036-01 EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0444 mg/kg 0.0619 71.8 70-130 Gasoline (C6-C10) 2.19 1.0 mg/kg 2.48 ND 88.5 70-130
Matrix Spike Dup (B4I0906-MSD1) Prepared & Analyzed: 09/09/24 Source: KH30036-01 EPA 8015B
Surr: 4-Bromofluorobenzene (FID) 0.0498 mg/kg 0.0619 80.5 70-130 Gasoline (C6-C10) 2.37 1.0 mg/kg 2.48 ND 95.8 70-130 7.92 20 Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 150 of 157 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/23/2024
California ELAP Certificate #1371
Reported:

Notes and Definitions
* 47%
*a BS/BSD failed low. Sample results biased low, estimate only.

AJ Heavier hydrocarbon than diesel
BS1 Blank Spike Recovery for this analyte was biased high. Results were accepted based on Blank Spike duplicate result.

BS2 Blank Spike Recovery for this analyte was biased low. Results were accepted based on Blank Spike duplicate result.

CC Analyte did not meet calibration curve criteria, however the average RSD across all analytes was within acceptance criteria.

IS Internal standard recovered low due to possible matrix interference. The result is suspect.

J Detected but below the Reporting Limit; therefore, result is an estimated concentration ( CLP J-Flag). Same as DNQ - Detected, but Not Quantified.

MS1 Recovery for this analyte was affected by matrix.

MS2 Matrix Spike Recovery for this analyte was biased high; associated blank spike recovery is within range.

MS3 Matrix Spike Recovery for this analyte was biased low; associated blank spike recovery is within range.

RPD The RPD result exceeded the QC control limits. However, both percent recoveries were acceptable.

RPD3 The RPD is out of range for this spike and its duplicate due to a low or high bias of one of the two spikes.

S The surrogate recovery for this sample is outside of established control limits.

S02 Surrogate recovery was affected by the matrix.

S03 Surrogate recovery was biased high for this sample; sample results are ND.

RPD Relative Percent Difference
µg/L micrograms per liter (parts per billion concentration units) ND Analyte NOT DETECTED at or above the reporting limit mg/L milligrams per liter (parts per million concentration units) mg/kg milligrams per kilogram (parts per million concentration units) Analysis of pH, filtration, and residual chlorine is to take place immediately after sampling in the field.

If the test was performed in the laboratory, the hold time was exceeded. (for aqueous matrices only) Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 151 of 157 ends

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2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
October 09, 2024
California ELAP Certificate #1371

SARA BLOOM
MTA Environmental Division
RE: SCCS Work Force Housing
Fresno, CA 93721
2527 Fresno Street
Work Order #: KH30037
Enclosed are the analytical results for samples received by our laboratory on 08/30/24 . For your reference, these analyses have been assigned laboratory work order number KH30037.

All analyses have been performed according to our laboratory's quality assurance program. All results are intended to be considered in their entirety, Moore Twining Associates, Inc. (MTA) is not responsible for use of less than complete reports. Results apply only to samples analyzed.

If you have any questions, please feel free to contact us at the number listed above.

Sincerely,
Moore Twining Associates, Inc.

Lauren Cox
Client Services Representative

22.1523 Page 1 of 9
Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/09/2024
California ELAP Certificate #1371
Reported:

Analytical Report for the Following Samples
Sample ID Notes Laboratory ID Matrix Date Sampled Date Received B11- 0.5' KH30037-01 Soil 08/30/24 10:57 08/30/24 16:00 Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 2 of 9 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/09/2024
California ELAP Certificate #1371
Reported:

Sampled: 08/30/24 10:57
B11- 0.5'
KH30037-01 (Soil)
Analyte Flag Result MDL Units Dilution Batch Analyst Prepared Analyzed Method Reporting Limit
Metals (Total)
Arsenic 3.0 2.0 0.85 mg/kg 1 B4I0321 VAM 09/10/24 8:52 09/11/24 18:25 EPA 6010B Semi-Volatile Organics
8081A Twining
4,4¥-DDD ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A 4,4¥-DDE ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A 4,4¥-DDT ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A alpha-BHC ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A alpha-Chlordane ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A beta-BHC ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Chlordane (tech) ND 0.030 0.013 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A delta-BHC ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Dieldrin ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Endosulfan I ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Endosulfan II ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Endosulfan sulfate ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Endrin ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Endrin aldehyde ND 0.0083 0.0013 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Endrin ketone ND 0.0083 0.0060 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A gamma-BHC (Lindane) ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A gamma-Chlordane ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Heptachlor ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Heptachlor epoxide ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Methoxychlor ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Toxaphene ND 0.017 0.0060 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Trifluralin ND 0.0083 0.0030 mg/kg 1 B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Surr: Decachlorobiphenyl (DCB) S 174% Recovery Limits: 11.4% - 122% B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Surr: Tetrachloro-meta-xylene (TMX) 134% Recovery Limits: 8.5% - 170% B4I1111 JQV 09/11/24 16:46 09/18/24 23:00 EPA 8081A Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 3 of 9 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/09/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Metals (Total)
Flag
Batch - B4I0321
Blank (B4I0321-BLK1) Prepared: 09/10/24 Analyzed: 09/11/24 EPA 6010B
Arsenic ND 2.0 mg/kg
LCS (B4I0321-BS1) Prepared: 09/10/24 Analyzed: 09/11/24 EPA 6010B
Arsenic 39.5 2.0 mg/kg 40.0 98.9 75-125
LCS Dup (B4I0321-BSD1) Prepared: 09/10/24 Analyzed: 09/11/24 EPA 6010B
Arsenic 38.9 2.0 mg/kg 40.0 97.1 75-125 1.77 20
Matrix Spike (B4I0321-MS1) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30003-06 EPA 6010B
Arsenic 37.6 2.0 mg/kg 39.7 ND 94.7 75-125
Matrix Spike Dup (B4I0321-MSD1) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30003-06 EPA 6010B
Arsenic 38.0 2.0 mg/kg 39.9 ND 95.1 75-125 0.968 20
Matrix Spike (B4I0321-MS2) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30037-01 EPA 6010B
Arsenic 39.6 2.0 mg/kg 40.4 3.00 90.6 75-125
Matrix Spike Dup (B4I0321-MSD2) Prepared: 09/10/24 Analyzed: 09/11/24 Source: KH30037-01 EPA 6010B
Arsenic 39.7 2.0 mg/kg 40.2 3.00 91.2 75-125 0.157 20
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 4 of 9 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/09/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1111
Blank (B4I1111-BLK1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0402 mg/kg 0.0500 80.4 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S 0.00138 mg/kg 0.0500 2.75 8.5-170 4,4¥-DDD ND 0.0083 mg/kg
4,4¥-DDE ND 0.0083 mg/kg
4,4¥-DDT ND 0.0083 mg/kg
alpha-BHC ND 0.0083 mg/kg
alpha-Chlordane ND 0.0083 mg/kg
beta-BHC ND 0.0083 mg/kg
Chlordane (tech) ND 0.030 mg/kg
delta-BHC ND 0.0083 mg/kg
Dieldrin ND 0.0083 mg/kg
Endosulfan I ND 0.0083 mg/kg
Endosulfan II ND 0.0083 mg/kg
Endosulfan sulfate ND 0.0083 mg/kg
Endrin ND 0.0083 mg/kg
Endrin aldehyde ND 0.0083 mg/kg
Endrin ketone ND 0.0083 mg/kg
gamma-BHC (Lindane) ND 0.0083 mg/kg
gamma-Chlordane ND 0.0083 mg/kg
Heptachlor ND 0.0083 mg/kg
Heptachlor epoxide ND 0.0083 mg/kg
Methoxychlor ND 0.0083 mg/kg
Toxaphene ND 0.017 mg/kg
Trifluralin J 0.00606 0.0083 mg/kg
LCS (B4I1111-BS1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0539 mg/kg 0.0500 108 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S 0.00114 mg/kg 0.0500 2.27 8.5-170 4,4¥-DDT 0.0252 0.0083 mg/kg 0.0250 101 25-160
Dieldrin 0.0250 0.0083 mg/kg 0.0250 99.8 36-146
Endrin 0.0265 0.0083 mg/kg 0.0250 106 30-147
gamma-BHC (Lindane) RPD 0.0160 0.0083 mg/kg 0.0250 63.9 19-140 Heptachlor RPD 0.0146 0.0083 mg/kg 0.0250 58.2 34-111
LCS Dup (B4I1111-BSD1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0341 mg/kg 0.0500 68.2 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) S 0.00139 mg/kg 0.0500 2.79 8.5-170 4,4¥-DDT 0.0213 0.0083 mg/kg 0.0250 85.2 25-160 16.8 20 Dieldrin 0.0218 0.0083 mg/kg 0.0250 87.1 36-146 13.7 20 Endrin 0.0218 0.0083 mg/kg 0.0250 87.2 30-147 19.4 20
Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 5 of 9 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/09/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1111
LCS Dup (B4I1111-BSD1) Prepared: 09/11/24 Analyzed: 09/18/24 EPA 8081A
gamma-BHC (Lindane) RPD 0.0119 0.0083 mg/kg 0.0250 47.6 19-140 29.2 20 Heptachlor RPD 0.00999 0.0083 mg/kg 0.0250 40.0 34-111 37.2 20 Duplicate (B4I1111-DUP1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Decachlorobiphenyl (DCB) S03 0.0188 mg/kg 0.0250 75.2 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) 0.0153 mg/kg 0.0250 61.1 8.5-170 4,4¥-DDD ND 0.0083 mg/kg ND
4,4¥-DDE ND 0.0083 mg/kg ND
4,4¥-DDT ND 0.0083 mg/kg ND
alpha-BHC ND 0.0083 mg/kg ND
alpha-Chlordane ND 0.0083 mg/kg ND
beta-BHC ND 0.0083 mg/kg ND
Chlordane (tech) ND 0.030 mg/kg ND
delta-BHC ND 0.0083 mg/kg ND
Dieldrin ND 0.0083 mg/kg ND
Endosulfan I ND 0.0083 mg/kg ND
Endosulfan II ND 0.0083 mg/kg ND
Endosulfan sulfate ND 0.0083 mg/kg ND
Endrin ND 0.0083 mg/kg ND
Endrin aldehyde ND 0.0083 mg/kg ND
Endrin ketone ND 0.0083 mg/kg ND
gamma-BHC (Lindane) ND 0.0083 mg/kg ND
gamma-Chlordane ND 0.0083 mg/kg ND
Heptachlor ND 0.0083 mg/kg ND
Heptachlor epoxide ND 0.0083 mg/kg ND
Methoxychlor ND 0.0083 mg/kg ND
Toxaphene ND 0.017 mg/kg ND
Trifluralin ND 0.0083 mg/kg ND
Matrix Spike (B4I1111-MS1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Decachlorobiphenyl (DCB) 0.0192 mg/kg 0.0250 76.7 11.4-122 Surr: Tetrachloro-meta-xylene (TMX) 0.0231 mg/kg 0.0250 92.6 8.5-170 4,4¥-DDT 0.00951 0.0083 mg/kg 0.0250 ND 38.0 25-160
Dieldrin 0.0134 0.0083 mg/kg 0.0250 ND 53.6 36-146
Endrin 0.0152 0.0083 mg/kg 0.0250 ND 60.7 30-147
gamma-BHC (Lindane) 0.00973 0.0083 mg/kg 0.0250 ND 38.9 19-140 Heptachlor 0.00929 0.0083 mg/kg 0.0250 ND 37.2 34-111
Matrix Spike Dup (B4I1111-MSD1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Decachlorobiphenyl (DCB) S02 0.0342 mg/kg 0.0250 137 11.4-122 Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 6 of 9 ends

Project:

Project Number:

Project Manager:

MTA Environmental Division
2527 Fresno Street E95815.03

SARA BLOOM
SCCS Work Force Housing
Fresno CA, 93721
2527 Fresno Street
Fresno, CA 93721
(559) 268-7021 Phone
(559) 268-0740 Fax
10/09/2024
California ELAP Certificate #1371
Reported:

Result Reporting
Limit
Units Spike
Level
Source
Result
%REC %REC
Limits

RPD RPD
Limits
Analyte
Quality Control Sample Results - Semi-Volatile Organics Flag
Batch - B4I1111
Matrix Spike Dup (B4I1111-MSD1) Prepared: 09/11/24 Analyzed: 09/18/24 Source: KH30003-01 EPA 8081A
Surr: Tetrachloro-meta-xylene (TMX) S02 0.0475 mg/kg 0.0250 190 8.5-170 4,4¥-DDT J 0.00790 0.0083 mg/kg 0.0250 ND 31.6 25-160 18.4 20 Dieldrin 0.0123 0.0083 mg/kg 0.0250 ND 49.2 36-146 8.55 20 Endrin 0.0138 0.0083 mg/kg 0.0250 ND 55.1 30-147 9.68 20 gamma-BHC (Lindane) 0.0103 0.0083 mg/kg 0.0250 ND 41.2 19-140 5.74 20 Heptachlor 0.00943 0.0083 mg/kg 0.0250 ND 37.7 34-111 1.41 20 Notes and Definitions
J Detected but below the Reporting Limit; therefore, result is an estimated concentration ( CLP J-Flag). Same as DNQ - Detected, but Not Quantified.

RPD The RPD result exceeded the QC control limits. However, both percent recoveries were acceptable.

S The surrogate recovery for this sample is outside of established control limits.

S02 Surrogate recovery was affected by the matrix.

S03 Surrogate recovery was biased high for this sample; sample results are ND.

RPD Relative Percent Difference
µg/L micrograms per liter (parts per billion concentration units) ND Analyte NOT DETECTED at or above the reporting limit mg/L milligrams per liter (parts per million concentration units) mg/kg milligrams per kilogram (parts per million concentration units) Analysis of pH, filtration, and residual chlorine is to take place immediately after sampling in the field.

If the test was performed in the laboratory, the hold time was exceeded. (for aqueous matrices only) Moore Twining Associates, Inc. The results in this report apply to the samples analyzed in accordance with the chain of custody document. This analytical report must be reproduced in its entirety.

Danielle Abrames, Director of Analytical Chemistry

Page 7 of 9 ends

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22.1560
60 South Market Street | Suite 700 | San José, CA 95113 | (408) 278-1700 | Fax (408) 278-1717 www.fehrandpeers.com
Memorandum
Date: October 25, 2024
To: Trevor Miller, Santa Cruz City Schools
From: Alex Huang, Daniel Rubins, and Matt Haynes, Fehr & Peers Subject: Project Trip Generation Analysis for an Educator Housing Development at 313 Swift Street, Santa Cruz, California
SJ24-2284
This memorandum documents the project trip generation analysis for the proposed development at 313 Swift Street in Santa Cruz, California.

Summary
A transportation study is not needed for this project, because the project will generate fewer than 50 net new evening peak hour vehicle trips and add fewer than 25 new morning or evening peak hour project trips to a critical intersection (refer to the Transportation Study Requirements for Development, City of Santa Cruz, August 2021).

Project Description
The project is in Santa Cruz, California. The project site is bounded by industrial land use along Delaware Avenue to the north, Swift Street to the east, a charter school to the south, and industrial and park land uses to the west. The project proposes to construct approximately 100 residential units for educators with a maximum parking supply of 119 parking spaces, reuse an existing building (currently a 3,308 square foot daycare center) as storage space for residents, and an existing office building (2,077 square feet) would remain office. The residential unit mix includes 11 studio units, 28 one-bedroom units, 50 two-bedroom units, and 11 three-bedroom units. The project will connect Swift Street and Delaware Avenue (via an easement through the neighboring industrial land use is under negotiations). Figure 1 and Figure 2 show the project location and the project site, respectively.

22.1561
Delaware Ave
High Rd
Elizabeth St
S
wift St
John St
Heath St
Panetta Ave
Low
Rd
Chace St
Woodland Way
Coalinga Way
Getchell St
\\fpgisdevapp01\DevGISLibrary\ServiceMXDs\SJ\2024_Projects\SJ24_2284\SJ24_2284\SJ24_2284.aprx Figure 1

0.1 Miles
Proposed Project Location
Project Site Location
Proposed Easement

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Figure 2
N:\Projects\_SJ24_Projects\SJ24_2284_Santa_Cruz_City_Schools_Parking_Swift_Street\Graphics\ADOBE\Fig02_SitePlan.ai Data: Schematic Grading and Drainage Plan C1.0 August 28, 2024

22.1563
Trevor Miller
October 25, 2024

Page 4 of 8 ends

Introduction
The City of Santa Cruz adheres to the Transportation Study Requirements for Development (TS Requirements), which provides a clear and consistent technical approach for analyzing projects that could affect the City’s transportation system and services. The TS Requirements outline the City’s approach for determining the need for a transportation analysis, preparing its content, and identifying acceptable transportation improvements for land use and transportation projects proposed within the City of Santa Cruz. The TS Requirements also provide guidance for analyzing and determining environmental impacts under the California Environmental Quality Act (CEQA).

The amount of detail required in a transportation study is based on the project’s expected level of daily and/or peak hour vehicle trip generation. Projects with fewer than 50 net new evening peak hour trips will not require a Transportation Study. Additionally, projects with fewer than 25 net new morning or evening peak hour trips at a critical intersection (the nearest critical intersection to this site is at Mission Street and Swift Street) do not need to conduct off-site intersection analysis.

Vehicle Trip Generation Estimates
This section summarizes the vehicle trip generation of the existing and future land use for the project site.

Trip Credits for Existing Uses
The estimate of new trips generated by the proposed development project includes a credit for trips associated with existing uses on the site. Uses are considered existing if they are actively present on the project site at the time of the transportation analysis or could be easily re-occupied. The project sponsor for this development (Santa Cruz City School) has control and continuous ownership of the project site and on-site occupancy was paused due to this redevelopment activity. In other words, the project sponsor could re-occupy the site if it chooses to, and a trip credit is based on the most recent use of the site—a 3,308 square foot preschool/daycare center. The 2,077 square foot existing office building is not changing use, and neither a trip credit nor trip generation estimate is provided for this analysis.

The existing preschool/daycare center trips were estimated using vehicle-trip rates from the Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition (ITE Land Use Code 565). The existing trip credit is 157 daily vehicle trips, 36 AM peak hour trips (19 inbound and 17 outbound), and 37 PM peak hour (17 inbound and 20 outbound).

22.1564
Trevor Miller
October 25, 2024

Page 5 of 8 ends

Trip Estimates for Proposed Uses
The proposed project most closely fits the description of ITE land use code 220 (Suburban, Lowrise Residential Multifamily Housing). No transit trip reductions or other location-based trip reductions were applied to the proposed uses. The proposed project would generate 716 daily vehicle trips, 54 AM peak hour trips (13 inbound and 41 outbound), and 64 PM peak hour trips (40 inbound and 24 outbound).

Net New Project Estimates
Table 1 summarizes trip generation estimates based on the methods outlined above. Considering the trip credit for the existing on-site establishment, the project would generate fewer trips; specifically, 559 more daily trips, 18 more AM peak hour trips, and 27 more PM peak hour trips than the existing number of calculated trips. As shown in Table 1, the proposed project is expected to generate fewer than 50 net new trips during the AM and PM peak hours; therefore, according to the City of Santa Cruz Transportation Study Requirements for Development (2021), no transportation study is necessary.

Table 1: Trip Generation Using ITE Trip Generation Method ITE# Land Use Type Method Size Type Weekday
Trips
AM Peak Hour Trips PM Peak Hour Trips
In Out Total In Out Total
Proposed Development
2201 Multifamily
Housing (Low-Rise) Fit Curve 100 Dwelling Units 716 13 41 54 40 24 64 Existing (To-Be-Reused as an Amenity) Development Credit 565 Daycare/
Preschool Facility
Average
Rate 3.3 1,000 SF
GFA
157 19 17 36 17 20 37
Net New Project Trips 559 -6 24 18 23 4 27
The project will generate fewer than 50 net new evening peak hour vehicle trips? Yes Notes:

ITE Trip Generation Manual (11th Edition) provides an average rate and a best fit curve equation for trip generation estimates. The equation used for the projects is from ITE Land Use 220: Multifamily Housing (Low-Rise) – Not Close to Rail Transit:

Daily: T=6.41(X) + 75.31;
AM Peak Hour: T=0.31(X) + 22.85 (24% in, 76% out);
PM Peak Hour: T=0.43(X) + 20.55 (63% in, 37% out).
where T is the number of trips generated and X is the number of dwelling units.

Average rate for weekday and peak periods were used for the estimating trips contributed by the existing daycare facility is from ITE Land Use 565: Daycare/Preschool Facility:

Daily Split between entering and exiting traffic – 50% in, 50% out; AM Peak Hour Split between entering and exiting traffic - 53% in, 47% out; PM Peak Hour Split between entering and exiting traffic - 47% in, 53% out.

Source: Fehr & Peers, 2024.

22.1565
Trevor Miller
October 25, 2024

Page 6 of 8 ends

Study Intersections
This section shows that fewer than 25 net new AM or PM peak hour project trips are added to the nearby intersections of Delaware Avenue and Swift Street.

Trip Distribution
The directions of approach and departure of project trips were based on the locations of complementary land uses as well as existing travel patterns in the area. Figure 3 shows the trip distribution for each relevant segment in the roadway network.

Trip Assignment
The project trips were assigned to the roadway system based on the directions of approach and departure discussed above. Figure 4 shows the project trips assigned to each turning movement by intersection.

Critical Intersection Evaluation
Figure 4 shows that 5 net new AM peak hour, and 13 net new PM peak hour project trips are added to the nearby intersection of Delaware Avenue and Swift Street. If the proposed easement is not built, the morning and evening peak hour traffic would be 13 net new AM peak hour, and 23 net new PM peak hour project trips are added to the nearby intersection of Delaware Avenue and Swift Street. Thus, an off-site intersection analysis is not needed because the project would add fewer than 25 new morning or evening peak hour project trips to the nearest intersection and even less to a critical intersection. The assignment also shows 5 net new AM peak hour trips are subtracted and 4 net new PM peak hour project trips are added to the other nearby intersection of Chace Street and Swift Street.

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Delaware Ave
High Rd
Elizabeth St
S
wift
St
John St
Heath St
Panetta
Ave
Low
Rd
Chace St
Woodland Way
Coalinga Way
Getchell St
N:\Projects\_SJ24_Projects\SJ24_2284_Santa_Cruz_City_Schools_Parking_Swift_Street\Graphics\ADOBE\FIg03_TripDistribution_V2.ai Trip Distribution
25%
15%
45%
15%
Figure 3

0.1 Miles
Proposed Project Location
Easement
XX% Trip Distribution

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E lizabeth S t
LowRd
Getchell S t
N:\Projects\_SJ24_Projects\SJ24_2284_Santa_Cruz_City_Schools_Parking_Swift_Street\Graphics\ADOBE\FIg04_TripAssignment_V13.ai Trip Assignment
Nearby Intersection
Swift St/ Delaware Ave
Nearby Intersection
Swift St/ Chace St
Figure 4
Proposed Project Location
Study Intersection
Proposed Easement
#
1 Existing Development Trip Credit Proposed Development Trips Net New Project Trips D
D
D
D
D
D
D
D
D
D
D
D
Delaware Avenue
Swift Street
Delaware Avenue Swift Street
Delaware Avenue Swift Street
E2 (6) 0 (0)
B7 (3)
0 (0)
G0 (0)
0 (0)
Proposed Development Trips
E0 (4) 0 (0)
B5 (0) 0 (0)
G0 (0)
0 (0)
Net New Project Trips
Chace St
Swift Street
Chace St
Swift Street
E-2 (-2) 0 (0)
B-2 (-3) 0 ( 0 )
G0 (0)
0 (0)
Existing Development Trip Credit
Chace St
Swift Street
-3 (-3)
-4 (-5)-8 (-9)
0 (0)
0 (0)
-3 (-3)0 (0) -5 (-4)
0 (0)
0 (0)
0 (0)
-9 (-8)
0 (0)9 (5)
15 (9)
1 (1)
3 (2)
0 (0)0 (1) 3 (9)
0 (0)
0 (0)
1 (3)
5 (15)
-3 (-3)
5 (0)
7 (0)
1 (1)
3 (2)
-3 (-3)0 (1) -2 (5)
0 (0)
0 (0)
1 (3)
-4 (7)
Delaware Ave
John St

0.1 Miles
S
wift
St
Chace St

22.1568
SCCS Educator Housing Initial Study -1- December 2024
City of Santa Cruz

ENVIRONMENTAL CHECKLIST FORM / INITIAL STUDY
I. Background

1. Application No: CP24-0104

2. Project Title: Santa Cruz City Schools (SCCS) Educator Housing

3. Lead Agency Name and Address:

City of Santa Cruz Planning and Community Development Department 809 Center Street, Room 101
Santa Cruz, CA 95060

4. Contact Person and Phone Number:

Timothy Maier, Senior Planner
City of Santa Cruz Planning and Community Development Department (831) 420-5129 | [email protected]

5. Project Location: 313 Swift Street (APN 003-16-132) in the City of Santa Cruz; see Figure 1.

6. Project Applicant’s/Sponsor’s Name and Address:

Trevor Miller
Santa Cruz City Schools
133 Mission Street, Suite 100
Santa Cruz, CA 95060

7. General Plan Designation: Community Facilities

8. Zoning: PF (Public Facilities) / CZ-O Coastal Zone Overlay)

9. Description of the Project: The proposed project consists of a Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit for demolition of select existing features and proposed construction of a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project, encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of five heritage trees.

Residential Building. The proposed residential apartment building would span three distinct wings connected by exterior bridges. The 100 units include 11 studio, 28 one-bedroom, 50 two-bedroom, and 11 three-bedroom apartment units, resulting in a dwelling unit density of 24 dwelling units per acre (du/acre). These units would be reserved for SCCS employees, and the new building and property would be wholly owned by SCCS. The project site plan is shown on Figure 2.

22.1569
SCCS Educator Housing Initial Study -2- December 2024
The new buildings would be located behind two existing buildings on the site that front Swift Street. The existing onsite buildings will be retained and include a one-story, 2,077 squarefoot administrative building and a one-story, 3,308 square-foot educational building, which will be used for property management offices and resident storage space, respectively. Two existing one-story portable, modular classroom buildings would be removed.

Project entitlements include, among others, a Planned Development Permit to allow for consideration, at the subject site, of a land use not enumerated in the General Plan for the Community Facilities (CF) land use designation nor specified in the Municipal Code as a land use within the list of uses identified as principally or conditionally permitted in the Municipal Code for the P-F zone district. The General Plan CF land use designation envisions sites for existing and potential community facilities, including schools, government offices, community buildings such as the Civic Auditorium, sewer and water facilities, and the City landfill, but does not specifically identify residential uses. The City’s 2023-2031 Housing Element, however, does support employee housing (Policy 3.7) and references state legislation to help school districts create housing for employees. Objective 3.7b. supports efforts of the Santa Cruz City School District to provide workforce housing for its employees. City of Santa Cruz Municipal Code Section 24.08.720 states, “A planned development permit provides variation on district regulation, where appropriate", for, among other items, “uses.” The project’s application for Planned Development Permit therefore provides a mechanism for consideration of the proposed project on a site with a General Plan land use designation of CF and with a Zoning classification of P-F.

It is also noted that the applicant has requested, through CP24-0120, development pursuant to State Senate Bill 330 (Housing Crisis Act) for vesting of the application to local regulations in place at the time of SB330 Preapplication completeness and to accommodate a residential density consistent with the General Plan Land Use designation of CF (Community Facilities), in which development intensity is limited to a Floor Area Ratio (FAR) of 2.5. Affordable housing will be provided through a request for Alternative Compliance pursuant to City of Santa Cruz Municipal Code Section 24.16.030(10), with residential lease rates expected to be approximately 50- to 60-percent of market rate. The project will be funded through two local bond measures.

Existing Structures and Proposed Demolition. The eastern portion of the site is currently occupied by two existing single-story office buildings and two portable, modular classroom buildings. As indicated above, one office building would be converted to storage use and the other would house residential support spaces such as property management offices. The trailers would be removed from the project site. Storage containers, concrete pads, and interior fencing located along the western portion of the project site also would be removed.

All existing surface parking, which is located along the northeastern and central portions of the project site, would be removed. The existing sidewalk along Swift Street would be replaced with a new, eight-foot-wide sidewalk.

Access and Parking. The project would provide two vehicular access points, including one from Swift Street to the east and one from Delaware Avenue, through an adjacent property to the north. Entry to the project site would be controlled through automatic sliding vehicular

22.1570
SCCS Educator Housing Initial Study -3- December 2024
gates. Each entry point would accommodate inbound and outbound vehicles. A private access easement would cover the northern entry point to allow access through the adjacent property. Turnaround areas for emergency vehicles are proposed at the northwestern and southeastern portions of the project site.

Resident parking would be located behind a resident-only gate, with the remainder of proposed vehicular parking intended to be used by guests and employees occupying the administrative offices. The project proposes 40 standard, 58 compact, 15 Electric Vehicle Supply Equipment (EVSE), 3 ADA-Standard, and 3 ADA-van spaces for a total of 119 spaces.

The project would provide 129 bicycle parking spaces as well as 2 bicycle “fix-it" stations.

A new pedestrian path would be built connecting Swift Street to/from Sergeant Derby Park, which borders the project site to the west, through the southern portion of the project site.

New pedestrian paths would also be built throughout the project site connecting the building wings to outdoor gathering spaces, parking areas, and administrative buildings.

Landscaping. The project would include 1,800 square feet of private open space and 51,200 square feet of common open space. The proposed project includes removal of 12 trees, five of which are considered heritage trees as defined by the City’s Heritage Tree Ordinance, and 10 existing trees on the project site would be retained. Project landscaping would be designed to include shared outdoor gathering spaces for residents. It would include features such as boulders, logs, and stumps as well as natural materials such as wood and decomposed granite. The project would be landscaped with a total of 122 new trees and 65,000 square feet of new planting and groundcover. The project would be subject to provisions of the City’s Water Efficient Landscape Ordinance (WELO), per Chapter 16.16 of the City’s Municipal Code.

Stormwater and Utilities. The project site is currently partially developed with impervious surface area associated with the office buildings and surface parking. Stormwater would be controlled through a new, 6,300-square-foot bioretention planting area and associated storm drains along the northern border of the project site and along the proposed pedestrian pathway to Sergeant Derby Park. These drainage areas would flow to a Swift Street public storm drain inlet. Furthermore,several Low Impact Development (LID) methods are proposed in the project’s Stormwater Control Plan.

The project would be serviced by public sewer and water mains from Swift Street. Electricity would be provided by Pacific Gas & Electric (PG&E).

Construction Schedule and Earthwork. Construction would be expected to occur over approximately two years. During grading and earthwork activities, approximately 1,000 cubic yards (cy) of earth material would be cut and approximately 6,000 cy of earth material would be filled. Therefore, there would be a net volume of 5,000 cy of earth material imported to the project site.

10. Other public agencies whose approval is required: None known.

22.1571
SCCS Educator Housing Initial Study -4- December 2024

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? Yes
II. Environmental Setting and Surrounding Land Uses
The 4.08-acre project site is located on the west side of Swift Street in the southwestern portion of the City of Santa Cruz in the Lower Westside neighborhood of the City as defined in the City’s General Plan (SOURCE V1.a). The site is located south of Delaware Avenue and is bordered by commercial and industrial uses to the north, Swift Street and single-family residential uses to the east, Natural Bridges Children’s Center and Gateway School to the south, and industrial and commercial uses, as well as Sergeant Derby Park including tennis courts, to the west. The project site is located within the Coastal Zone, approximately one-third mile north of the Pacific Ocean.

The project site is approximately 52 feet above mean sea level (amsl) and generally slopes toward the south-southeast. The majority of the property is developed with two existing buildings, two portable, modular classroom buildings, surface parking, and an uncovered storage yard. The area of proposed development is located behind the existing buildings and includes paved areas and formerly landscaped, grass areas. A 2,077 square-foot, one-story administrative building currently is used by the Santa Cruz Education Foundation, and a 3,308 square-foot, one-story educational building is used by the Westside Parent Education Nursery School. The modular classroom buildings are used by the Santa Cruz Office of Education Transition program.

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SCCS Educator Housing Initial Study -5- December 2024
FIGURE 1: Vicinity Location
SOURCE: EHDD Architecture

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SCCS Educator Housing Initial Study -6- December 2024
FIGURE 2: Project Site Plan

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SCCS Educator Housing Initial Study -7- December 2024
III. Environmental Checklist
Environmental Factors Potentially Affected by the Project: The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages.  Aesthetics Agricultural and Forestry
Resources
 Air Quality
 Biological Resources Cultural Resources Energy
 Geology / Soils  Greenhouse Gas Emissions 
Hazards and Hazardous
Materials
 Hydrology / Water Quality Land Use / Planning Mineral Resources  Noise Population / Housing Public Services
Recreation Transportation Tribal Cultural Resources
 Utilities / Service Systems Wildfire Mandatory Findings of Significance
A. Instructions to Environmental Checklist

1. A brief explanation is required (see Section VI, Explanation of Environmental Checklist Responses) for all answers except “No Impact” answers that are adequately supported by the information sources a lead agency cites in the parentheses following each question (see Section V, References and Data Source List, attached). A “No Impact” answer is adequately supported if the referenced information sources show that the impact simply does not apply to projects like the one involved (e.g., the project falls outside a fault rupture zone). A “No Impact” answer should be explained where it is based on project-specific factors as well as general standards (e.g., the project will not expose sensitive receptors to pollutants, based on a project-specific screening analysis).

2. All answers must take account of the whole action involved, including off-site as well as on-site, cumulative as well as project-level, indirect as well as direct, and construction as well as operational impacts.

3. Once the lead agency has determined that a particular physical impact may occur, then the checklist answers must indicate whether the impact is potentially significant, less than significant with mitigation, or less than significant. “Potentially Significant Impact” is appropriate if there is substantial evidence that any effect may be significant. If there are one or more “Potentially Significant Impact” entries when the determination is made, an EIR is required.

4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less-than-significant level.

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SCCS Educator Housing Initial Study -8- December 2024

5. Earlier Analysis may be used where, pursuant to the tiering, program EIR, or other CEQA process, one or more effects have been adequately analyzed in an earlier EIR or negative declaration.

Section 15063(c)(3)(D). In this case a discussion should identify the following on attached sheets:
a) Earlier Analysis used. Identify earlier analyses and state where they are available for review. b) Impacts adequately addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis.
c) Mitigation measures. For effects that are “Less than Significant with Mitigation Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

6. Lead agencies are encouraged to incorporate into the checklist references to information sources for potential impacts (e.g., general plans, zoning ordinances). Reference to a previously prepared or outside document should, where appropriate, include a reference to the page or pages where the statement is substantiated.

7. Supporting Information Sources: A source list should be attached, and other sources used or individuals contacted should be cited in the discussion.

8. The explanation of each issue should identify:
a) The significance criteria or threshold, if any, used to evaluation each question; and b) The mitigation measure identified, if any, to reduce the impact to less than significance.

B. Use of Earlier Analyses
In analyzing the proposed project, the City may consider whether existing environmental documents already provide an adequate analysis of potential environmental impacts. An earlier analysis may be used where, pursuant to the tiering, program EIR, or other California Environmental Quality Act (CEQA) provisions, if it can be determined that one or more effects have been adequately analyzed in an earlier EIR or negative declaration (State CEQA Guidelines Section 15063(c)(3)(D)).

The preparation of this Initial Study has drawn from analyses contained in the City of Santa Cruz General Plan 2030 EIR (April 2012), which includes the Draft EIR volume (September 2011) and the Final EIR volume (April 2012). The Santa Cruz City Council certified the EIR and adopted the General Plan 2030 on June 26, 2012. The General Plan EIR is a “program” EIR prepared pursuant to State CEQA Guidelines section 15168, which reviewed environmental impacts associated with future development and buildout within the City’s planning area that would be accommodated by the General Plan. A program EIR can be used for subsequent projects implemented within the scope of the program/plan and where the project is consistent with the general plan and zoning of the city or county in which the project is located. Typically, site-specific impacts or new impacts that were not addressed in the program EIR would be evaluated in an Initial Study, leading to preparation of a Negative Declaration, Mitigated Negative Declaration or EIR. Site-specific mitigation measures included in the General Plan EIR also would be a part of future development projects, and

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SCCS Educator Housing Initial Study -9- December 2024
supplemented, as may be necessary, with site-specific mitigation measures identified in the subsequent environmental review process. The General Plan EIR reviewed all of the topics included on the Appendix G environmental checklist in the State CEQA Guidelines. In accordance with CEQA and the State CEQA Guidelines, this Initial Study is being “tiered” from the General Plan 2030 EIR. “Tiering” refers to using analyses of general matters contained in an EIR for a plan with later environmental analyses for development projects, concentrating solely on the issues specific to the later project. This approach is in accordance with State CEQA Guidelines section 15152, which encourages lead agencies to use an EIR prepared for a general plan or other program or ordinance, when the later project is pursuant to or consistent with the program or plan. The Initial Study tiers from the General Plan 2030 EIR for the following topics; relevant information is summarized under each subsection.
▪ Aesthetics – Light and Glare
▪ Geology and Soils
▪ Hydrology and Water Quality – Groundwater
▪ Noise
The General Plan 2030 EIR is on file at the City’s Planning and Community Development Department, 809 Center Street, Room 101, Santa Cruz, California and available for review from 7:30 to 11:30 AM, Monday through Thursday. The document also is available for review on the City of Santa Cruz Planning Department’s website at: https://www.cityofsantacruz.com/government/citydepartments/planning-and-community-development/long-range-policy-planning/general-plan.

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SCCS Educator Housing Initial Study -10- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

1. AESTHETICS. Except as provided in Public Resources Code Section 21099, would the project:
a) Have a substantial adverse effect on a scenic
vista?

b) Substantially damage scenic resources,
including but not limited to trees, rock
outcroppings, and historic buildings within a
state scenic highway?

c) In non-urbanized areas, substantially degrade
the existing visual character or quality of public
views of the site and its surroundings? (Public
views are those that are experienced from
publicly accessible vantage point.) If the project
is in an urbanized area, would the project
conflict with applicable zoning and other
regulations governing scenic quality?

d) Create a new source of substantial light or glare
which would adversely affect day or nighttime
views in the area?

2. AGRICULTURE AND FORESTRY RESOURCES. In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement Methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland),
as shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of
the California Resources Agency, to nonagricultural use? (V.1b-DEIR volume) 
b) Conflict with existing zoning for agricultural use,
or a Williamson Act contract?

c) Conflict with existing zoning for, or cause
rezoning of, forest land (as defined in Public
Resources Code section 12220(g)), timberland
(as defined by Public Resources Code section
4526), or timberland zoned Timberland
Production (as defined by Government Code
section 51104(g))?

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SCCS Educator Housing Initial Study -11- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Result in the loss of forest land or conversion of
forest land to non-forest use?

e) Involve other changes in the existing
environment which, due to their location or
nature, could result in conversion of Farmland
to non-agricultural use or conversion of forest
land to non-forest use?

3. AIR QUALITY. Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the
applicable air quality plan?

b) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is non-attainment under an
applicable federal or state ambient air quality
standard?

c) Expose sensitive receptors to substantial
pollutant concentrations?

d) Result in other emissions (such as those leading
to odors adversely affecting a substantial
number of people?

4. BIOLOGICAL RESOURCES. Would the project:
a) Have a substantial adverse effect, either directly
or through habitat modifications, on any species
identified as a candidate, sensitive, or specialstatus species in local or regional plans, policies, or regulations, or by the California Department
of Fish and Wildlife or U.S. Fish and Wildlife
Service?

b) Have a substantial adverse effect on any
riparian habitat or other sensitive natural
community identified in local or regional plans,
policies, regulations or by the California
Department of Fish and Wildlife or U.S. Fish and
Wildlife Service?

c) Have a substantial adverse effect on state or
federally protected wetlands (including, but not
limited to, marsh, vernal pool, coastal, etc.)
through direct removal, filling, hydrological
interruption, or other means?

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SCCS Educator Housing Initial Study -12- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Interfere substantially with the movement of
any native resident or migratory fish or wildlife
species or with established native resident or
migratory wildlife corridors, or impede the use
of native wildlife nursery sites?

e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?

f) Conflict with the provisions of an adopted
Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local,
regional, or state habitat conservation plan?

5. CULTURAL RESOURCES. Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
in Section 15064.5?

b) Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to Section 15064.5?

c) Disturb any human remains, including those
interred outside of formal cemeteries?

6. ENERGY. Would the project:
a) Result in potentially significant environmental
impact due to wasteful, inefficient, or
unnecessary consumption of energy resources,
during project construction or operation?

b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?

7. GEOLOGY AND SOILS. Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury,
or death involving:
i. Rupture of a known earthquake fault, as
delineated on the most recent AlquistPriolo Earthquake Fault Zoning Map issued by the State Geologist for the area
or based on other substantial evidence of
a known fault? Refer to Division of Mines
and Geology Special Publication 42.

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SCCS Educator Housing Initial Study -13- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
ii. Strong seismic ground shaking?
iii. Seismic-related ground failure, including
liquefaction?
iv. Landslides?

b) Result in substantial soil erosion or the loss of
topsoil?

c) Be located on a geologic unit or soil that is
unstable, or that would become unstable as a
result of the project, and potentially result in
on- or off-site landslide, lateral spreading,
subsidence, liquefaction or collapse?

d) Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994),
creating substantial direct or indirect risks to life
or property?

e) Have soils incapable of adequately supporting
the use of septic tanks or alternative
wastewater disposal systems where sewers are
not available for the disposal of wastewater?

f) Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature?

8. GREENHOUSE GAS EMISSIONS. Would the project:
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?

b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing
the emissions of greenhouse gases?

9. HAZARDS AND HAZARDOUS MATERIALS. Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport,
use, or disposal of hazardous materials?

b) Create a significant hazard to the public or the
environment through reasonably foreseeable
upset and accident conditions involving the
release of hazardous materials into the
environment?

c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within ¼ miles of an existing or proposed
school?

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SCCS Educator Housing Initial Study -14- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a
result, would it create a significant hazard to the
public or the environment?

e) For a project located within an airport land use
plan or, where such a plan has not been
adopted, within two miles of a public airport or
public use airport, would the project result in a
safety hazard for people residing or working in
the project area?

f) Impair implementation of or physically interfere
with an adopted emergency response plan or
emergency evacuation plan?

g) Expose people or structures to a significant risk
of loss, injury or death involving wildland fires,
including where wildlands are adjacent to
urbanized areas or where residences are
intermixed with wildlands?

10. HYDROLOGY AND WATER QUALITY. Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise
substantially degrade surface or ground water
quality?

b) Substantially decrease groundwater supplies or
interfere substantially with groundwater
recharge such that the project may impede
sustainable groundwater management of the
basin?

c) Substantially alter the existing drainage pattern
of the site or area, including through the
alteration of the course of a stream or river or
through the addition of impervious surfaces, in
a manner which would:
i) Result in substantial erosion or siltation
on- or off-site; 
ii) Substantially increase the rate or amount
of surface runoff in a manner which would
result in flooding on- or off-site;

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SCCS Educator Housing Initial Study -15- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
iii) Create or contribute runoff water which
would exceed the capacity of existing or
planned storm water drainage systems or
provide substantial additional sources of
polluted runoff; or

iv) impede or redirect flood flows? 
d) In flood hazard, tsunami or seiche zones, risk
release of pollutants due to project inundation?

e) Conflict with or obstruct implementation of a
water quality control plan or sustainable
groundwater management plan?

11. LAND USE AND PLANNING. Would the project:
a) Physically divide an established community? 
b) Cause a significant environmental impact due to
a conflict with any land use plan, policy, or
regulation adopted for the purpose of avoiding
or mitigating an environmental effect?

12. MINERAL RESOURCES. Would the project:
a) Result in the loss of availability of a known
mineral resource that would be of value to the
region and the residents of the state?

b) Result in the loss of availability of a locallyimportant mineral resource recovery site delineated on a local general plan, specific plan,
or other land use plan?

13. NOISE: Would the project:
a) Generation of a substantial temporary or
permanent increase in ambient noise levels in
the vicinity of the project in excess of standards
established in the local general plan or noise
ordinance or applicable standards of other
agencies?

b) Result in exposure of persons to or generation
of excessive ground borne vibration or ground
borne noise levels?

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SCCS Educator Housing Initial Study -16- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
c) For a project located within the vicinity of a
private airstrip or an airport land use plan or,
where such a plan has not been adopted, within
two miles of a public airport or public use
airport, would the project expose people
residing or working in the project area to
excessive noise levels?

14. POPULATION AND HOUSING. Would the project:
a) Induce substantial unplanned population
growth in an area, either directly (for example,
by proposing new homes and businesses) or
indirectly (for example, through extension of
roads or other infrastructure)?

b) Displace substantial numbers of existing people
or housing, necessitating the construction of
replacement housing elsewhere?

15. PUBLIC SERVICES.
a) Would the project result in substantial adverse
physical impacts associated with the provision
of new or physically altered governmental
facilities or need for new or physical altered
governmental facilities, the construction of
which could cause significant environmental
impacts, in order to maintain acceptable service
ratios, response times, or other performance
objectives for any of the public services:
a) Fire protection? 
b) Police protection? 
c) Schools? 
d) Parks? 
e) Other public facilities? 

16. RECREATION. Would the project:
a) Increase the use of existing neighborhood and
regional parks or other recreational facilities
such that substantial physical deterioration of
the facility would occur or be accelerated?

b) Include recreational facilities or require the
construction or expansion of recreational
facilities which might have an adverse physical
effect on the environment?

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SCCS Educator Housing Initial Study -17- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

17. TRANSPORTATION. Would the project:
a) Conflict with a program plan, ordinance or
policy addressing the circulation system,
including transit, roadway, bicycle and
pedestrian facilities?

b) Would the project conflict or be inconsistent
with CEQA Guidelines section 15064.3,
subdivision (b)?

c) Substantially increase hazards due to a design
feature (for example, sharp curves or dangerous
intersections) or incompatible uses (for
example, farm equipment)?

d) Result in inadequate emergency access? 

18. TRIBAL CULTURAL RESOURCES. Would the project:

Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code section
21074 as either a site, feature, place, cultural
landscape that is geographically defined in terms of
the size and scope of the landscape, sacred place, or
object with cultural value to a California Native
American tribe, and that is:
a) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code section 5020.1(k), or

b) A resource determined by the lead agency, in its
discretion and supported by substantial
evidence, to be significant pursuant to criteria
set forth in subdivision (c) of Public Resources
Code Section 5024.1. In applying the criteria set
forth in subdivision (c) of Public Resources Code
Section 5024.1, the lead agency shall consider
the significance of the resource to a California
Native American tribe.

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SCCS Educator Housing Initial Study -18- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact

19. UTILITIES AND SERVICE SYSTEMS. Would the project:
a) Require or result in the relocation or
construction of new or expanded water, or
wastewater treatment or storm water drainage,
electric power, natural gas, or
telecommunications facilities, the construction
or which could cause significant environmental
effects?

b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple
dry years?

c) Result in a determination by the wastewater
treatment provider which serves or may serve
the project that it has adequate capacity to
serve the project’s projected demand in
addition to the provider’s existing
commitments?

d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the
attainment of solid waste reduction goals?

e) Comply with federal, state, and local
management and reduction statutes and
regulations related to solid waste?

20. WILDFIRE. If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response land or emergency evacuation?

b) Due to slope, prevailing winds, and other
factors, exacerbate wildfire risks, and thereby
expose project occupants to, pollutant
concentrations from a wildfire or the
uncontrolled spread of a wildfire?

c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel
breaks, emergency water sources, power lines
or other utilities) that may exacerbate fire risk
or that may result in temporary or ongoing
impacts to the environment?

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SCCS Educator Housing Initial Study -19- December 2024

ENVIRONMENTAL IMPACTS
Issues (and Supporting Information Sources)
Potentially
Significant
Impact
Potentially
Significant
Unless
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?

21. MANDATORY FINDINGS OF SIGNIFICANCE. Would the project:
a) Have the potential to substantially degrade the
quality of the environment, substantially reduce
the habitat of a fish or wildlife species, cause a
fish or wildlife population to drop below selfsustaining levels, threaten to eliminate a plant or animal community, substantially reduce the
number or restrict the range of a rare or
endangered plant or animal or eliminate
important examples of the major periods of
California history or prehistory?

b) Have impacts that are individually limited, but
cumulatively considerable? (“Cumulatively
considerable” means that the incremental
effects of a project are considerable when
viewed in connection with the effects of the
past projects, the effects of other current
projects, and the effects of probable future
projects.)

c) Have environmental effects which will cause
substantial adverse effects on human beings,
either directly or indirectly?

Discussion of Environmental Checklist
See Section VI, Explanation of Environmental Checklist Responses, for discussion.

22.1587

22.1588
SCCS Educator Housing Initial Study -21- December 2024
V. References and Data Source List
City Plans and Studies

1. City of Santa Cruz General Plan and EIR.
a. Adopted June 26, 2012. General Plan 2030. Available online at:
http://www.cityofsantacruz.com/home/showdocument?id=71130. b. April 2012. City of Santa Cruz General Plan 2030 Final EIR. [SCH#2009032007] Certified June 26, 2012. Includes Draft EIR document, dated September 2011. Available online at:
http://www.cityofsantacruz.com/Home/Components/BusinessDirectory/BusinessDirect ory/102/1775.
c. July 2018. “Cultural Resources Background Report Update with Policies, Programs, and Maps, City of Santa Cruz, Santa Cruz County, California.” Prepared by Dudek. d. Adopted December 12, 2023. City of Santa Cruz 2023-2031 Housing Element-Prohousing.

Prepared by Kimley-Horn.

2. Other City of Santa Cruz Adopted Plans and Studies.
a. 2024. 908 Ocean Street Mixed-Use Development Draft Environmental Impact Report.

Prepared by Kimley-Horn. October 2024. Available online at:
https://www.cityofsantacruz.com/government/city-departments/planning-and-communitydevelopment/environmental-review-ceqa. b. 2024. Water Supply Evaluation for the Downtown Plan Expansion Project. Prepared by the City of Santa Cruz Water Department. October 2024.
c. 2022. City of Santa Cruz 2030 Climate Action Plan Update, Resilient Together. Adopted September 2022.
d. Adopted June 14, 2022. SB 743 Implementation Guidelines, City of Santa Cruz. May 12, 2022. e. Adopted November 2021. 2020 Urban Water Management Plan. Prepared by the City of Santa Cruz, Water Department. Available online at:
https://www.cityofsantacruz.com/government/city-departments/water/urban-watermanagement-plan-2020. f. August 2020. City of Santa Cruz Parks Master Plan 2030. Prepared by the City of Santa Cruz Parks and Recreation Department and Royston Hanamoto Alley and Abey. Available online at:
https://www.cityofsantacruz.com/home/showpublisheddocument/82608/63744319732297 0000.
g. June 2020. Resolution of the City Council of the City of Santa Cruz Adopting the Use of Vehicle Miles Traveled as the New Transportation Measure of Environmental Impacts. June 9, 2020 with Draft SB 743 Implementation Guidelines (May 27, 2020). h. 2018. City of Santa Cruz Climate Adaptation Plan Update 2018-2023. Available online at:
https://www.cityofsantacruz.com/home/showpublisheddocument/95350/6382725227 24800000.
i. October 25, 1994 as amended. The City of Santa Cruz General Plan and Local Coastal Program 1990-2005. [Local Coastal Program portion] Available online at:
http://www.cityofsantacruz.com/government/about-us/general-plan.

22.1589
SCCS Educator Housing Initial Study -22- December 2024
Other Agency Plans and Studies

3. AMBAG.
a. Adopted June 15, 2022. “2022 Regional Growth Forecast.” b. Adopted June 2022. Monterey Bay 2045 Moving Forward, 2045 Metropolitan Transportation Plan / Sustainable Communities Strategy.
c. Adopted June 11, 2014. “2014 Regional Growth Forecast”.

4. California Air Resources Board (CARB).
a. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. November 2022. Available online at: https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf. b. 2022. California Air Resources Board 2022 Scoping Plan—Appendix D, Local Actions.

November 2022. Available online at: https://ww2.arb.ca.gov/sites/default/files/2022- 11/2022-sp-appendix-d-local-actions.pdf.

5. California Department of Finance. 2024. Population and Housing Estimates for Cities, Counties, and the State — January 1, 2023, and 2024. Available online at:
https://dof.ca.gov/forecasting/demographics/estimates-e1/.

6. Monterey Bay Air Resources District.
a. Adopted March 15, 2017. 2012-2015 Air Quality Management Plan. Adopted March 15, 2017. Available online at:
http://www.co.monterey.ca.us/home/showdocument?id=62318. b. Revised February 2016, adopted April 1996. “Guidelines for Implementing the California Environmental Quality Act.” Available online at:
https://www.mbard.org/files/50d38962a/Attachment_Guidelines-for-ImplementingCEQA.pdf. c. February 2008. “CEQA Air Quality Guidelines.” Available online at:
https://www.mbard.org/files/f665829d1/CEQA_full+%281%29.pdf.

7. Schoolworks, Inc. March 2024. 2024 Developer Fee Justification Study for the Santa Cruz School Districts. Available online at: https://www.sccs.net/developer-fees.

8. U.S. Energy Information Administration. 2024. “California State Energy Profile.” Available online at:
https://www.eia.gov/state/print.php?sid=CA.

Applicant Studies

9. Albion Environmental, Incorporated. May 2023. Phase I Cultural Resource Inventory for the Educator Housing Project, Santa Cruz, Santa Cruz County, California.

10. Nigel Belton Consulting Arborist. June 2023. Tree Resource Analysis and Arborist Report – The Santa Cruz City Schools Workforce Housing Project – 313 Swift Street, California.

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11. Fehr and Peers.
a. May 2024. Memorandum. Parking Supply Rates for an Educator Housing Development at 3013 Swift Street, Santa Cruz, California.
b. October 2024. Memorandum. Project Trip Generation Analysis for an Educator Housing Development at 313 Swift Street, Santa Cruz, California.

12. Ifland Engineers. 2024. Preliminary Stormwater Control Plan For Santa Cruz Educator Housing 313 Swift Street Santa Cruz, California. April 2024.

13. Moore Twining Associates, Incorporated.
a. October 2024. Phase II Environmental Site Assessment for Proposed Santa Cruz City Schools Workforce Housing 313 Swift Street, Santa Cruz, California. b. June 2024. Phase I Environmental Site Assessment Addendum- Santa Cruz City Schools Workforce Housing Project, 313 Swift Street, Santa Cruz, California. c. June 2023. Draft Geotechnical Engineering and Geohazard Investigation for Proposed Teacher Workforce Housing Project. Santa Cruz City Schools, 313 Swift Street, Santa Cruz, California 95060.
d. June 2023. Phase I Environmental Site Assessment. Santa Cruz City Schools, 313 Swift Street, Santa Cruz, California 95060.

14. Patricia Paramoure Archaeological Consulting. April 2023. Phase 1A Archaeological Assessment of Property at 313 Swift Street, Santa Cruz, Santa Cruz County, California (APN 003-161-32).

Initial Study Preparation: City of Santa Cruz Planning and Community Development Department in association with Dudek.

VI. Explanation of Environmental Checklist Responses

1. Aesthetics
(a) Scenic Views. The project site is located in the southwestern portion of the City in an area characterized by a mix of residential, commercial, light industrial uses, park, and public facility uses. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located within any mapped panoramic view areas or in proximity to visual landmarks (SOURCE V.1b-DEIR Figure 4.3 1). The nearest panoramic view is located along West Cliff Drive, approximately 0.3 miles south of the project site. However, the project site is not visible from the coast. A panoramic view near Arroyo Seco, approximately 0.70-mile north of the project site, is identified in the General Plan 2030 EIR. However, the project site is screened from view of this panoramic view area due to existing topography and vegetation, as well asintervening development, elevation changes and distance. In addition, the project is not within an area visible from a mapped viewpoint/panorama as identified in in the City’s Local Coastal Program (LCP) maps (SOURCE V.1b-DEIR Map CD-3: Scenic Views); mapped scenic viewpoints from West Cliff Drive are oriented toward the ocean. Thus, the proposed residential development and associated improvements would not be within or have an adverse effect on a scenic view. Therefore, the project would have no impact on scenic views.

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(b) Scenic Resources. There are no designated state scenic highways or roads within the City.

The project site is not located near a state scenic highway. Therefore, no impact to scenic resources within a state scenic highway would occur. To accommodate development of the proposed project, 12 trees would be removed, 5 of which are considered heritage trees, as defined by City regulations. Although some of these trees are larger and are visible from adjacent properties and partially visible from Swift Street, the trees are not visible from a wideranging, publicly-viewed area, are not visually prominent or distinctive, and are not considered scenic resources. The project site does not contain other physical features that would be considered scenic resources. Therefore, the project would have no impact on scenic resources. (c) Visual Character. The project site is partially developed with two, one-story public facility buildings; two mobile portable classroom trailers; and surface parking lots.

The General Plan 2030 EIR concluded that most of the future development accommodated by the General Plan would not substantially degrade the visual character of surrounding areas with implementation of General Plan policies and actions to develop design guidelines and review development to protect “distinctive design characteristics” and landmarks of neighborhoods (CD2.1, CD2.3) in combination with continued application of design review as part of Design Permit approvals.

Impact Analysis. The proposed project consists of a new residential apartment building that would span three distinct wings connected by exterior bridges. The massing of each wing is defined by longer side-by-side bars and shed roof-style which is inspired by industrial building typologies and a rectangular volume that is more commonly found on mid-sized residential buildings. The building would be four stories tall with a maximum of height 50 feet. This height would be greater than other buildings in the neighborhood, which are generally between one to three stories in height. However, the proposed heights are consistent with heights permitted in the PF zone and adjacent industrial (IG) zone.

The project will be reviewed through the Design Permit process. Per section 24.08.400 of the Municipal Code, the purpose of the City’s Design Permit review is to “promote the public health, safety and general welfare through the review of architectural and site development proposals and through application of recognized principles of design, planning and aesthetics and qualities typifying the Santa Cruz community.” The City must make the required findings to approve the Design Permit for the project, and with approval, the project would be consistent with Design Permit regulations that serve to reduce potential visual character impacts.

The City of Santa Cruz is an “urbanized area” under the definition of the term in CEQA Guidelines section 15387. Per the CEQA Guidelines Environmental Checklist (Appendix G), the City need not specifically consider existing visual character or the quality of the existing views and the project’s potential effect on them. In an urbanized area, a project that conflicts with applicable zoning and other regulations governing scenic quality could be considered to result in a significant impact regarding scenic quality.

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One of the findings set forth in section 24.08.430 of the City’s zoning ordinance for approval of a Design Permit is that the site plan shall be situated and designed to protect views along the ocean and of scenic coastal areas. As discussed in Impact AES-1, the proposed project would not result in impacts to existing scenic views and would not affect coastal views along West Cliff Drive. Section 24.08.250 of the City’s Municipal Code also requires a finding with approval of a coastal permit that a development will maintain views between the sea and the first public roadway parallel to the sea. The proposed project would not be located between a road and the ocean and would not affect coastal views.

There are no other applicable zoning and other regulations governing scenic quality. The project does not conflict with applicable zoning and other applicable regulations governing scenic quality. Therefore, the project and would have a less-than-significant impact on the visual character of public views.

This conclusion also is consistent with CEQA (Public Resources Code section 21099), which provides that aesthetic impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment, although design review would still be required pursuant to local City requirements and regulations. “Infill site” means a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins, or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses. “Transit priority area” means an area within one-half mile of a major transit stop that is existing or planned. The project qualifies as a residential project on an infill site in a transit priority area (approximately 2,000 feet south of Mission Street); see also discussion in section VI.17(b). (d) Light and Glare. Light and glare refers to exterior lighting associated with surface parking, walkways, and lighting on buildings. There are no existing significant sources of excessive light or glare in the project area.

Impact Analysis. The project would not result in introduction of a major new source of light or glare. Although there would be exterior lighting on the proposed multi-family building, this would be typical of residential areas. This would not be expected to create significant visual impacts on the surrounding area as lighting would not be directed to off-site adjacent properties. Additionally, section 24.14.266 of the City’s Municipal Code prohibits direct or sky-reflected glare. Exterior building lighting also would be further reviewed as part of the Design Permit review process, and the project would be conditioned to install lighting such that it is directed downward and does not create light spillover onto adjacent properties.

The General Plan 2030 EIR concluded that new infill development accommodated by the plan could result in potential sources of light and glare but would not result in creation of “substantial” new sources of light and glare or result in a significant impact. The EIR indicated that infill buildings would have standard window and exterior lighting treatments but would not be expected to result in new sources of substantial light or glare as future development projects would largely replace or redevelop existing urban uses. (The General Plan 2030 EIR analyses are included on pages 4.3-19 to 4.3-20 of the Draft EIR volume.)

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Thus, the project would not be expected to create a new substantial source of light and glare and would not impact adjacent properties and the surrounding area. The following standard condition of approval will be included in the Project Conditions of Approval.

Therefore, the project would result in a less-than-significant impact related to creation of a new source of substantial light or glare.

STANDARD CONDITION OF APPROVAL: Plans submitted for building permit issuance shall show all exterior site lighting locations and fixture details. All exterior building lighting shall be shielded and contained in a downward direction. No exterior lighting shall produce off-site glare.

2. Agriculture and Forestry Resources
The project site does not contain farmland or grazing land as mapped on the Santa Cruz Important Farmland Map by the California Department of Conservation Farmland Mapping and Monitoring Program (SOURCE V.1b-DEIR Figure 4.15-1). The project site is designated as “Urban and Built-Up Land.” Surrounding lands are designated as “Other Land” and “Urban and BuiltUp Land.” Neither the site nor adjacent lands are designated for agricultural uses in the City’s General Plan. The project site is not zoned Timberland Production. Therefore, the project would not result in the conversion of agricultural or forest lands to other uses, and no impact would occur.

3. Air Quality
(a) Conflict with Air Quality Management Plan. In 1991, the Monterey Bay Air Resources District (MBARD) adopted the Air Quality Management Plan (AQMP) for the Monterey Bay Region in response to the California Clean Air Act of 1988, which established specific planning requirements to meet the ozone standards. The California Clean Air Act requires that AQMPs be updated every three years. The MBARD has updated the AQMP seven times. The most recent update, the 2012-2015 Air Quality Management Plan (2016 AQMP), was adopted in 2017. The 2016 AQMP relies on a multilevel partnership of federal, state, regional, and local governmental agencies. The 2016 AQMP documents the MBARD’s progress toward attaining the state 8-hour ozone standard, which is more stringent than the state 1-hour ozone standard. The 2016 AQMP builds on information developed in past AQMPs and updates the 2012 AQMP. The primary elements from the 2012 AQMP that were updated in the 2016 revision include the air quality trends analysis, emission inventory, and mobile source programs (SOURCE V.6a).

For population-related projects, the MBARD developed a procedure that compares existing, under-construction, and approved residential dwelling units with AMBAG’s housing unit forecast for a jurisdiction, as dwelling units are closely related to population and can be tracked within local jurisdictions; therefore, the number of dwelling units is used as the method for determining consistency with the AQMP. Consistency of indirect emissions associated with commercial, industrial, or institutional projects intended to meet the needs of the population as forecast in the AQMP is determined by comparing the estimated current population of the county in which the project is to be located with the applicable population forecast in the AQMP. If the estimated current population does not exceed the forecasts, indirect emissions

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associated with the project are deemed to be consistent with the AQMP. Projects which are consistent with AMBAG’s regional forecasts have been accommodated in the AQMP and are therefore consistent with the AQMP (SOURCE V.6a and 6c). The MBARD’s mostrecent 2015 AQMP utilized AMBAG’s 2014 Regional Growth Forecast.

The City had 24,506 existing dwelling units as of January 1, 2024 (California Department of Finance, 2024), and approximately 2,100 residential units are under construction or have been approved throughout the City, including residential development at the University of California Santa Cruz (UCSC)1. With the addition of these units, the City’s housing units would total approximately 26,610 dwelling units. The City’s total number of housing units would increase to 27,710 dwelling units with the addition of the project’s 100 residential apartment units. The resulting total is below the AMBAG Regional Growth Forecast of 28,297 dwelling units for the year 2030 that were factored into the AQMP. Therefore, the proposed project would be consistent with the AQMP, would not conflict with or obstruct implementation of the AQMP and would result in no impact.
(b) Project Criteria Pollutant Emissions. The U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) have established ambient air quality standards that are the maximum levels of ambient (background) air pollutants considered safe, with an adequate margin of safety to protect public health and welfare. Criteria pollutants include ozone (O3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), inhalable particulates (PM10), fine particulates (PM2.5), and lead. High O3 levels are caused by the cumulative emissions of reactive organic gases (ROG) and nitrogen oxides (NOx), which react under certain meteorological conditions to form O3. In California, sulfates, vinyl chloride, hydrogen sulfide, and visibility-reducing particles are also regulated as criteria air pollutants.

An area is designated as “in attainment” when it is in compliance with the federal and/or state standards, as further discussed below.

The project site is located within the North Central Coast Air Basin (NCCAB), which is under the jurisdiction of the MBARD and includes Santa Cruz, Monterey, and San Benito Counties. The NCCAB is designated attainment for the federal PM10 and SO2 standards, and is designated attainment/unclassified for the other federal standards. The NCCAB is designated attainment for the state PM2.5, NO2, SO2, and lead standards, and is designated unclassified for CO in Santa Cruz County. The NCCAB has nonattainment designations for state O3 and PM10 standards.

The MBARD 2012-2015 AQMP, adopted March 15, 2017, identifies a continued trend of declining O3 emissions in the NCCAB primarily related to lower vehicle miles traveled (VMT), 1 Residential projects at UCSC are primarily student housing projects, and there is one approved employee housing project and the first phase of the Student Housing West (Hagar Development). In general, part-year student housing is considered group quarters and year-round faculty / student family housing is counted as housing units (SOURCE V.3a). For the 2014 forecast used in the AQMP, University population and housing projections were completed separately from jurisdiction population projections (SOURCE V.3c). For the purpose of this review and in accordance with current AMBAG guidance, approved employee housing is considered as housing units, and student housing is considered group quarters and is not included as housing units, but the population accommodated by new student housing is included in the population estimates.

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showing that the region is continuing to make progress toward meeting the state O3 standard during the three-year period reviewed (SOURCE V.6a).

The General Plan 2030 EIR concluded that future development accommodated by the Plan could result in air pollutant emissions, but overall future emissions of ozone precursor pollutants are projected to decrease or remain nearly unchanged over the next 20 years, and thus, project-level emissions would not contribute to existing or potential future violations of air quality standards related to O3. The General Plan EIR further concluded that, while PM10 emissions would increase, compliance with MBARD significance criteria at a project level would ensure that emissions would not exceed daily standards. It was also found that vehicular emission rates are anticipated to lessen in future years due to continuing improvements in automobile and fuel efficiency and new regulations and programs adopted by the State of California that are scheduled to be phased in over the life of the proposed General Plan, and such reductions are factored into the air quality models used to estimate emissions.

Furthermore, the General Plan 2030 includes goals, policies and actions that set forth measures to avoid and minimize adverse impacts on air quality, including environmental review to address project-level emissions, requiring project-level mitigation measures, and reduction of vehicle trips and emissions. General Plan policies and actions LU1.2, LU1.2.1 and HZ2.2.1 (as modified by the General Plan EIR) are intended to ensure that new development does not result in creation of air pollution and implements measures set forth by the MBARD as part of future project-level review. Specifically, Action HZ2.2.1 requires future development projects to implement applicable MBARD control measures and/ or air quality mitigation in the design of new projects as set forth in the District’s “CEQA Guidelines.” General Plan Action HZ2.2.2 permits major indirect sources of air pollution only if transportation measures are provided to reduce impacts to a less-than-significant level, consistent with applicable MBARDrecommended mitigation and control measures as set forth in the District’s CEQA Guidelines.

The policies and actions require future project-level review and implementation of mitigation measures, if warranted, consistent with the adopted standards in the MBARD’s CEQA Guidelines. The General Plan EIR concluded that with implementation of the General Plan policies and actions, compliance with MBARD requirements and air quality control measures, and adherence to MBARD permit requirements, contributions to air pollutant emissions and air quality impacts would be less than significant.

Impact Analysis. The proposed project would result in construction of a 100-unit residential apartment project. The project would indirectly generate air pollutant emissions through new regional vehicle trips. The MBARD CEQA Guidelines provide several land use types with corresponding screening threshold levels to assess ozone impacts. The proposed project size is substantially below the MBARD’s screening levels for apartments (1,080 dwelling units), which is used to determine potential significant ozone impacts as set forth in the MBARD’s CEQA Air Quality Guidelines (SOURCE V.6c). Therefore, project emissions typically would not be considered substantial or result in an air quality violation, although air emissions as a result of the project were modeled as further described below.

Project construction could result in generation of dust and PM10 emissions as a result of site excavation and grading. According to MBARD’s CEQA Air Quality Guidelines (SOURCE

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V.6c), construction activity on 8.1 acres per day with minimal earthmoving or 2.2 acres per day with grading and excavation are assumed to be below the MBARD’s PM10 significance threshold of 82 pounds per day. The area of proposed development is approximately 4.08 acres in size.

Because the project site exceeds 2.2 acres, air emissions were modeled for project construction and operations using the California Emissions Estimator Model (CalEEMod) Version. The results are summarized in Tables 1 and 2, and as shown, neither project construction nor operational emissions would exceed MBARD thresholds for criteria pollutant air emissions. Therefore, the project-level review required by the General Plan 2030, finds that potential emissions would not exceed MBARD’s adopted CEQA significance thresholds, and the project would not violate current air quality standards.

Table 1. Estimated Maximum Daily Construction Criteria Air Pollutant Emissions Year
ROG NOx CO SOx PM10 PM2.5
pounds per day
Summer
2026 6.68 51.67 47.79 0.12 4.52 2.28
2027 0.39 1.08 4.08 <0.01 0.58 0.15
2028 -- -- -- -- -- --
Winter
2026 1.28 11.41 11.89 0.03 2.31 1.18
2027 11.48 7.00 15.26 0.01 1.44 0.50
2028 11.39 6.96 14.84 0.02 1.41 0.47
Maximum Daily
Emissions 11.48 51.67 47.79 0.12 4.52 2.28
MBARD Threshold N/A N/A N/A N/A 82 N/A
Threshold
Exceeded? N/A N/A N/A N/A No N/A
Source: Dudek
Notes: CO = carbon monoxide; MBARD = Monterey Bay Air Resources District; N/A = not applicable; NOx = oxides of nitrogen; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; ROG = reactive organic gases; SOx = sulfur oxides. The values shown are the maximum summer or winter daily emissions results from CalEEMod and include watering of exposed areas two times per day, per the City’s Standard Construction Practices.

Construction would not occur during Summer of 2028.

Technical calculations are on file with the City of Santa Cruz Planning and Community Development Department.

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Table 2. Estimated Maximum Daily Operational Criteria Air Pollutant Emissions Emission Source ROG NOx CO SOx PM10 PM2.5
pounds per day
Summer
Mobile 2.59 1.43 13.82 0.02 2.24 0.58
Area 3.34 0.05 5.68 <0.01 <0.01 <0.01
Energy 0.00 0.00 0.00 0.00 0.00 0.00
Total Summer
Emissions 5.93 1.49 19.50 0.02 2.24 0.58
Winter
Mobile 2.57 1.67 14.99 0.02 2.24 0.58
Area 2.84 0.00 0.00 0.00 0.00 0.00
Energy 0.00 0.00 0.00 0.00 0.00 0.00
Total Winter
Emissions 5.41 1.67 14.99 0.02 2.24 0.58
Maximum Daily
Emissions 5.93 1.67 19.50 0.02 2.24 0.58
MBARD Threshold 137 137 550 150 82 N/A
Threshold Exceeded? No No No No No N/A
Source: Dudek
Notes: CO = carbon monoxide; MBARD = Monterey Bay Air Resources District; N/A = not applicable; NOx = oxides of nitrogen; PM10 = coarse particulate matter; PM2.5 = fine particulate matter; ROG = reactive organic gases; SOx = sulfur oxides. The values shown are the maximum summer or winter daily emissions results from CalEEMod.

Technical calculations are on file with the City of Santa Cruz Planning and Community Development Department. *Includes all-electric development
General Plan Action HZ2.2.1 establishes a procedure for project-level reviews and requires site-specific mitigation measures if significant impacts are identified. These measures include applicable MBARD control measure and/ or air quality mitigation. The proposed project has complied with this requirement; no significant impacts were identified. Thus, impacts of criteria air pollutant from construction and operation of the project would be less than significant.

In addition, according to the MBARD CEQA Air Quality Guidelines, projects that are consistent with the AQMP would not result in cumulative impacts as regional emissions have been factored into the AQMP. The MBARD prepares air quality plans which address attainment of the state and federal emission standards and incorporate growth forecasts developed by AMBAG. As indicated in subsection 3(a) above, the proposed project would not conflict with, or obstruct the implementation of, the AQMP, which takes into account cumulative development within the City. Therefore, the proposed project would not result in a cumulatively considerable criteria pollutant increase. (c) Sensitive Receptors. For CEQA purposes, a sensitive receptor is defined as any residence, including private homes, condominiums, apartments, and living quarters; education resources such as preschools and kindergarten through grade 12 schools; daycare centers; and healthcare facilities such as hospitals or retirement and nursing homes. A sensitive receptor includes longterm care hospitals, hospices, prisons, and dormitories or similar live-in housing (SOURCE V.6c).

The project site is located within a developed -residential neighborhood, and existing

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residences, which are considered sensitive receptors, are located to the east and west of the project site. The Gateway School and Natural Bridges Children’s Center to the south of the project site are also considered sensitive receptors. The proposed residential project would not introduce a new source of stationary emissions, and thus, would not expose sensitive receptors to substantial pollutant concentrations.

Diesel Particulate Emissions. Diesel particulate matter was identified as a toxic air contaminant (TAC) by the State of California in 1998. The General Plan 2030 EIR discusses constructionrelated impacts in which diesel particulate matter could be emitted from construction equipment. The impact was found to be less than significant due to the California Air Resources Board’s ongoing adoption of regulations for in-use, off-road diesel vehicles that would significantly reduce particulate matter emissions by requiring fleet owners to accelerate turnover to cleaner engines and install exhaust retrofits. The EIR also noted that the California Code of Regulations, Title 13, section 2486(c)(1) prohibits idling of a diesel engine for more than five minutes in any location, thereby further limiting particulate matter emissions. Additionally, emissions during construction are of a short-term duration in comparison to life-long exposure and health risks. Construction-related diesel emissions at the project site would be of limited duration (i.e., primarily during grading) and temporary. Thus, the construction of the proposed residential apartment project would not expose sensitive receptors to diesel emissions.

Subsequent to certification of the General Plan 2030 EIR, changes were made to California guidelines regarding review of health risks associated with exposure to TACs. The most recent guidance from the Office of Environmental Health Hazard Assessment (2015 Risk Assessment Guidelines Manual2) updated some cancer risk parameters, such as age-sensitivity factors, daily breathing rates, exposure period, fraction of time at home, and cancer potency factors. Diesel particulate emissions from heavy construction equipment and vehicles during construction could result in a health risk to proximate sensitive receptors, particularly to children and pregnant women. However, use of heavy-duty construction equipment is subject to a CARB Airborne Toxics Control Measure for in-use diesel construction equipment to reduce diesel particulate emissions and use of diesel trucks is also subject to an Airborne Toxics Control Measure, which serve to reduce emissions. Additionally, construction equipment that includes CARB-compliant emissions control equipment or diesel particulate filters can substantially reduce emissions and associated potential health risks to a level that would not be considered a significant impact.

General Plan 2030 Policy and Program HZ2.2 and HZ2.2.1 require review of air quality issues and mitigation of air quality impacts, and use of best available equipment controls are standard measures to control or reduce diesel emissions. The City’s Climate Action Plan (CAP) (SOURCE 2.a) includes measures to work toward reduction/elimination of off-road gasoline- and dieselpowered equipment, including construction equipment (Actions T6.1 through T6.5), and best available equipment technology is identified as typical controls for TAC emissions from diesel equipment (SOURCE 2a-Appenix A). Additionally, the City’s Water Department has identified Standard Construction Practices to be implemented by the City and/or its contractors during 2 Office of Environmental Health Hazard Assessment. February 2015. Risk Assessment Guidelines Guidance Manual for Preparation of Health Risk Assessments.

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construction, which includes a requirement to use specified CARB-compliant equipment and/or diesel-particulate filters to substantially reduce diesel emissions.

A standard project condition of approval requires use of specified CARB-compliant equipment and/or filters (e.g., requiring use of Tier 4 emission control technology), which would mitigate potential impacts associated with exposure to diesel emissions to a less-than-significant level, consistent with General Plan Program HZ2.2.1, Climate Action Plan measures and Standard Construction Practices implemented in the City. The following standard condition of approval will be included in the Project Conditions of Approval. Therefore, the project would not expose sensitive receptors to substantial pollutant concentrations, and potential exposure of sensitive receptors to diesel particulate matter and associated risks would be considered less than significant.

STANDARD CONDITION OF APPROVAL: All diesel-fueled off-road construction equipment greater than 75 horsepower shall be zero-emissions or equipped with California Air Resources Board (CARB) Tier 4 Final or Interim compliant engines.

Alternatively, CARB Tier 2 or 3 compliant engines may be used if CARB Level 3 Verified Diesel Emissions Control Strategy (VDECS) filters are added to each piece of off-road diesel-fueled equipment.
(d) Odors. According to the Air District’s CEQA Air Quality Guidelines (SOURCE V.6c), land uses associated with odor complaints typically include landfills, agricultural uses, wastewater treatment plants, food processing plants, chemical plants, and refineries. The proposed residential project does not include any uses associated with odors and would not create objectionable odors. Thus, no impact would occur.

4. Biological Resources
(a-c) Special-Status Species and Sensitive Habitat. The project site is primarily developed with two single-story buildings, two mobile portable classroom trailers, concrete pads and paved surface parking. The project site also includes areas of non-native grassland and 26 planted trees on or immediately adjacent to the project site. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is not located within, or adjacent to, a sensitive habitat area (SOURCE V.1b-DEIR Figure 4.8-3). No areas of riparian and wetland habitat are located on or adjacent to the project site. The infill project site is surrounded by urban residential, light industrial, commercial, and public facility uses to the north, south, east, and west and recreational park space to the southwest. The project site does not contain sensitive habitat or habitat for special-status species. For these reasons, no specialstatus plant or wildlife species or sensitive are expected to be present on the project site.

Therefore, the project would have no impact on special-status species or sensitive habitat. (d) Wildlife Movement/Breeding. The primary wildlife movement corridors within the City are located along major watercourses and within City-owned open space lands, which would be protected from future development impacts. As noted above, the project is not mapped within or adjacent to sensitive habitat areas and is not adjacent to a watercourse. The site does not contain habitat nor does it connect to other habitat areas. The General Plan 2030 EIR concluded

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primary wildlife movement corridors in the City are located along major watercourses and within City-owned open space lands. The proposed project is not located adjacent to, or within proximity to, a watercourse or City-owned open space lands.

The project site is partially developed and located within a developed urban area. The site does not contain habitat, nor does it connect to other habitat areas and is not within or adjacent to a creek, riparian area, or wildlife dispersal area. The project is not located adjacent to or within proximity to a watercourse. Thus, the project would have no effect on wildlife movement and would not interfere with native fish or wildlife movement, and therefore the project would result in no impact related to wildlife movement.

Impact Analysis. The project would result in removal of 12 trees on the project site. These trees could provide potential nesting habitat for migratory birds which are protected by the Migratory Bird Treaty Act (MBTA) and the California Fish and Game Code (CFGC). Tree removal during the breeding season (generally February 15 to August 31) has the potential to destroy bird nests, eggs or chicks if any are present during the removal. Compliance with the MBTA would require that either a pre-construction nesting survey be conducted to confirm that no nesting birds protected under the MBTA are present if trees or removed during the nesting season or to remove trees outside of the nesting season. Compliance with required regulations would not result in a significant impact. Furthermore, General Plan Action NCR2.4.1 and Table 1 establish biological survey protocols, including preconstruction nesting bird surveys with establishment of appropriate construction buffers if needed, if tree removal and/or construction were to commence during the nesting season.

A standard project condition of approval requires implementation of a pre-construction nesting survey, and the following standard condition of approval will be included in the Project Conditions of Approval. Because the project would be required to comply with the MBTA and General Plan Action NCR2.4.1, and a standard condition of approval will be imposed by the City that requires a pre-construction survey during the construction period with protection of nesting birds if any are found, the potential impact to nesting birds is considered less than significant.

STANDARD CONDITION OF APPROVAL: If project site work occurs anytime between February 1 and August 31, the applicant shall submit documentation of a preconstruction ne000sting bird survey by a qualified biologist prior to the start of work.

The survey shall be described in the biotic report, if such a report was prepared, and shall be completed no more than seven days before the start of any project construction activities on the site (including tree removal, clearing, and excavation) and shall include observations of any nesting activities on the site. Site work may commence once the Planning Department has accepted the report and confirmed that there are no nesting birds on the site or that an appropriate buffer zone around any active nests has been recommended by the biologist and physically established on the site. (e) Conflicts with Local Plans. An arborist review (SOURCE V.10) was conducted to review existing trees on the project site. The project would result in removal of five heritage trees as defined by the City’s Heritage Tree Ordinance in Chapter 9.56 of the City’s Municipal Code. Generally, trees with a 14-inch or larger diameter are heritage trees.

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Chapter 9.56 of the City Municipal Code defines heritage trees, establishes permit requirements for the removal of a heritage tree, and sets forth mitigation requirements as adopted by resolution by the City Council. Resolution NS-23, 710 adopted by the City Council in April 1998 establishes the criteria for permitting removal of a heritage tree and indicates that one or more of the following findings must be made by the Director of Parks and Recreation:
1) The heritage tree or heritage shrub has, or is likely to have, an adverse effect upon the structural integrity of a building, utility, or public or private right of way; 2) The physical condition or health of the tree or shrub, such as disease or infestation, warrants alteration or removal; or
3) A construction project design cannot be altered to accommodate existing heritage trees or heritage shrubs.

Resolution NS-21, 436 sets forth the tree replacement/mitigation requirements for approved removal of a heritage tree to include replanting three, 15-gallon or one, 24-inch-size specimen or payment of the current retail value, which shall be determined by the Director of Parks and Recreation. Removal would be permitted if found in accordance with the above criteria and requirements. Approval of a tree removal permit automatically requires replacement trees as set forth above. Removal of heritage trees consistent with City regulations and requirements is not considered a significant impact.

Removal of 5 heritage trees would require planting of 15, 15-gallon trees or five, 24-inch-size trees to replace the removed heritage trees. Because the project site is located in the coastal zone, LCP Policy CD 6.1.2 requires a two-to-one replacement for tree removal relevant to new construction. Therefore, the project would be required to plant at least 10 new replacement trees.

Approval of a heritage tree removal permit automatically requires replacement trees or payment of an in-lieu fee. Removal of a heritage tree that is consistent with the criteria, provisions, and requirements set forth in City regulations would not result in a conflict with a local ordinance. The project’s proposed landscape plan includes a total of 122 new trees that would exceed the replacement tree size requirements established in City regulations and LCP.

The project proposes to plant 57 small canopy trees, 39 large canopy trees, 20 parking lot trees, and 6 street trees of various species. The proposed tree replanting would exceed the City’s replanting minimum requirements. Therefore, the project would replace removed heritage trees in accordance with City requirements and would result in a less than significant impact related to potential conflicts with City regulations protecting trees. The project arborist report includes recommendations for protection of retained trees during construction, which would be included as a project condition of approval.
(f) Habitat Conservation Plans. There are no adopted Habitat Conservation or Natural Community Conservation Plans in the project vicinity. The City’s recently approved Operations and Maintenance Habitat Conservation Plan (O&M HCP) is not applicable to the proposed project or project site as it was developed for improvements or projects related to City facilities with the potential to take federally listed species and other non-listed special-status species.

Therefore, the project would have no impact with regards to Habitat Conservation Plans.

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5. Cultural Resources
(a) Historical Resources. The project site is not located within a designated historic district (SOURCE V.1b-DEIR Figure 4.94). The existing buildings on the project site are not listed in the Santa Cruz Historic Building Survey. The existing buildings were developed as part of the Natural Bridges School in 1964. Although the existing buildings are more than 45 years old and could potentially qualify as historical resources under CEQA, the buildings would be retained as part of the project, and no alterations to existing buildings are proposed. Therefore, the project would result in no impact to historical resources.
(b-c) Archaeological Resources. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is located within an area that is sensitive for archaeological resources (SOURCE V.1b-DEIR Figure 4.9-1). The site is not located within an area that is sensitive for historic archaeological resources (SOURCE V.1b-DEIR Figure 4.9-3).

Two archaeological investigations of the site were conducted in 2023, which included a records search of the California Historical Resources Information System (CHRIS) at the Northwest Information Center (NWIC) at Sonoma State University and field reconnaissance. The records search identified one archaeological resource and two recorded historical resources within a ½- mile radius of the project site (SOURCE V.14). No evidence of surface or subsurface precontact archaeological deposits was observed during the field reconnaissance of the property (SOURCE V.14). The investigation did not recommend subsurface testing as no recorded or potentially significant precontact or historical archaeological resources have been identified within or adjacent to the project parcel (SOURCE V.14). A subsequent cultural resource inventory conducted for the project also indicated that no archaeological resources have been previously identified within the project area or within a 1/4-mile radius of the project site, and visual inspection of the site revealed no evidence of precolonial or historic-era artifacts or archaeological deposits (SOURCE V.9).

Impact Analysis. The project site is located within an area considered to have low potential for archaeological sensitivity or archaeological resources, and construction is unlikely to disturb unknown resources. A project cultural resources assessment did not find evidence of cultural resources and potentially significant precolonial and historic-era archaeological materials are not located in the project area (SOURCE V.9 and V.14). In the event an unknown cultural resource is discovered during soil disturbing construction activities, compliance with local and state regulations would be required. Section 24.12.430 of the City’s Municipal Code sets forth the procedure to follow in the event that prehistoric or cultural features are accidentally discovered during construction. Under provisions of this Code section, work shall be halted within 50 meters (150 feet) of the find until it can be evaluated by a qualified professional archaeologist. If the find is determined to be significant, the Planning Director shall be immediately notified, and appropriate mitigation measures shall be formulated and implemented. Additionally, the County Coroner shall be notified in accordance with provisions of Public Resources Code 5097.98-99 in the event human remains are found and the Native American Heritage Commission shall be notified in accordance with the provisions of Public Resources Code section 5097 if the remains are

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determined to be Native American. Therefore, the project would result in a less-thansignificant impact to archaeological resources.

6. Energy
Pacific Gas and Electric Company (PG&E) provides electricity and natural gas service to the City.

Central Coast Community Energy (3CE), formerly Monterey Bay Community Power (MBCP), was formed in March 2017 as a joint powers authority to provide locally controlled, 100% carbonfree electricity to residents and businesses in Monterey, San Benito and Santa Cruz Counties through the Community Choice Energy (CCE) model established by the State of California. The CCE model enables communities to choose clean-source power at a cost equivalent to PG&E while retaining PG&E’s role in maintaining power lines and providing customer service. 3CE started supplying electricity to customers in spring 2018 with existing customers automatically enrolled. 3CE supplies electricity generated from hydropower, solar and wind, which are renewable resources.

The state of California’s per capita electrical use has been the lowest or one of lowest of any state in the United States. California is among the top states in the nation in net electricity generation from renewable resources. The state leads the nation in net electricity generation from solar, geothermal, and biomass (SOURCE V.8).

In 2007, Santa Cruz became one of the first municipalities in the nation to require new construction to include the adoption of environmentally superior building materials and designs. Builders in Santa Cruz now use best practices for their construction projects that enhance building energy efficiency and water conservation. The City encourages energy conservation strategies, for example, through its green building program, and has seen an increase in solar energy system installations. The City is in the process of expanding an existing building decarbonization and electrification program to improve energy efficiency in existing buildings, to remove natural gas, and to replace the natural gas with energy-efficient electric appliances such as heat pumps (SOURCE V.1d).
(a) Energy Use. Construction of the project would require consumption of nonrenewable energy resources, primarily in the form of fossil fuels (including fuel oil, natural gas, and gasoline) for automobiles and construction equipment, and other resources including, but not limited to, lumber, sand, gravel, asphalt, metals, and water. Construction would include energy used by construction equipment and other activities at the project site (e.g., building construction, grading, paving), in addition to the energy used to manufacture the equipment, materials, and supplies and transport them to the project site. It is expected that nonrenewable energy resources would be used efficiently during future construction of residential units accommodated by the project. Therefore, the amount and rate of consumption of such resources during construction and maintenance activities would not result in the unnecessary, inefficient, or wasteful use of energy resources.

The proposed project avoids or reduces inefficient, wasteful, and unnecessary consumption of energy. The project would be subject to approval of building permits that meet the California Building Code and City Green Building Code requirements, as well as compliance with City

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requirements for water conservation fixtures and features, including drought-resistant landscaping. The project applicant proposes to construct the project with all electric utilities.

Additionally, Santa Cruz residents can enroll in 3CE, which supplies electricity generated from renewable resources. The project also includes 15 EVSE parking spaces that would be available for residents.

Overall, the future consumption of electrical and natural gas resources would not represent unnecessary, inefficient, or wasteful use of resources given the ongoing implementation of the City’s Climate Action Plan and General Plan 2030 policies that address lighting and energy conservation measures. In addition, new structures will be required to be constructed in accordance with specifications contained in Title 24 of the California Code of Regulations and the City’s Green Building Regulations. Such measures have been factored into California energy forecasts which predict an overall reduction in per capita use of electricity due to energy efficiency standards and conservation. Therefore, the proposed project would not result in wasteful or inefficient energy use during construction or operation and would result in a lessthan-significant impact. (b) Conflicts with Plans. Construction and operation of the project would not conflict with or obstruct implementation of a state or local plan for renewable energy. Therefore, the project would result in no impact.

7. Geology and Soils
(a.i) Fault Rupture. The project site is located in a seismically active region of California and the region is considered to be subject to very intense shaking during a seismic event. The project site is located in a seismically active region of California and the region is considered to be subject to very intense shaking during a seismic event. The City of Santa Cruz is situated between two major active faults: the San Andreas, approximately 11.2 miles to the northeast and the San Gregorio, approximately 9.9 miles to the southwest. According to the Geotechnical Engineering and Geohazard Investigation report performed for the project, the nearby active San Andreas, San Gregorio and Monterey Bay-Tularcitos (Seaside-Monterey segment) faults are the predominant contributing sources of seismic activity for the project site (SOURCE V.13c).

There are no active fault zones or risk of fault rupture within the City (SOURCE V.1b-DEIR volume).

The project site is not located within a State-designated Alquist Priolo Earthquake Fault Zone.

The nearest known “active” fault to the project site is the Monterey Bay - Tularcitos Fault Zone, is located approximately 4.75 miles southwest of the project site, and the potential for surface fault rupture at the project site due to a known “active” fault is considered low (SOURCE V.13c).

Therefore, the project would result in no impact related to fault rupture. (a.ii-iv). Seismically induced hazards include ground shaking, surface rupture, ground failure, settlement, landslides, and water waves (SOURCE V.1a). As indicated above, the project site is located in a seismically active region of California, which has the potential to be subject to intense shaking during a seismic event. According to maps developed for the City’s General Plan 2030 and included in the General Plan 2030 EIR, the project site is not located in an area susceptible to liquefaction (SOURCE V.1b-DEIR Figure 4.10-4) or within a mapped landslide area

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(SOURCE V.1b-DEIR Figure 4.10-3). A geotechnical investigation was prepared for the project site that included soils borings and testing (SOURCE V.13c).

The project site is relatively flat, and according to a review of mapping done for project-specific geotechnical report, the project area is not within the landslide hazard areas or areas with slopes greater than 50 percent. The City’s General Plan mapping also shows the site and surrounding area as being located outside any definitive, probable or questionable landslides.

Consequently, the potential impacts to the site from active landsliding is considered low (SOURCE V.13c).

Impact Analysis. The proposed structures would be subject to seismic shaking from an earthquake on regional faults, but with implementation the geotechnical investigation recommendations, exposure to seismic hazards would be considered a less-than-significant impact.

The City is in relative proximity to historically active faults; as such, there is potential for development to be subject to strong seismic ground shaking. While the potential for seismic ground shaking cannot be eliminated, the project would be required to comply with the 2022 California Building Standards Code (California Code of Regulations, Title 24), which includes requirements for geotechnical investigations that establish seismic design parameters. Compliance with recommendations in the project geotechnical report and with the California Building Standards Code would reduce risks associated with strong seismic ground shaking at the project site. Therefore, the project would have a less-than-significant impact with regard to strong seismic ground shaking.

According to the Geotechnical Engineering and Geohazard Investigation report performed for the project, based on geotechnical testing, the project site has a moderate potential for liquefaction and seismic settlement; this is due to the granular nature of many of the project site soils within the upper 10 feet below site grade (BSG) as well as the presence of shallow groundwater (SOURCE V.13c). The findings of the liquefaction analyses indicate that numerous layers of granular soils, with thicknesses ranging from less than a foot to about 3 feet thick within the upper about 10 to 15 feet of soils, are susceptible to liquefaction as a result of potential seismic shaking. The results of the seismic settlement analyses indicated a total seismic settlement of about 3 to 4 inches due to liquefaction. Based on the analysis, the liquefiable soils are within the zone of influence of the proposed building foundations.

To address liquefaction, the geotechnical report recommends specialty deep ground improvement methods or deep foundation systems to mitigate potential for failure due to liquefaction.

Other than liquefaction, which can be addressed through geotechnical engineering methods, the geotechnical report did not identify other geologic or seismic hazards that pose significant potential impacts. The project would be designed to accommodate sitespecific geologic conditions in accordance with recommendations of the project sitespecific geotechnical report, and, as applicable, would adhere to the provisions of the California Building Code (CBC) to address geologic hazards and include appropriate design measures.

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The General Plan 2030 EIR concluded that adherence to existing regulations and standards, including the California Building Code (CBC) and various policies and actions established in the General Plan 2030 would minimize harm to people and structures from adverse seismic hazards. General Plan Action HZ6.3.1 requires that all new construction conform with the latest edition of the CBC, and Municipal Code section 18.040.030 adopts State of California building codes as part of the City’s Building Code. General Plan Action HZ6.3.6 requires sitespecific geologic investigation(s) by qualified professionals for proposed development in potential liquefaction areas and requires developments to incorporate the design and other mitigation measures recommended by the investigation. In addition, Municipal Code section 24.14.070 requires preparation of a geotechnical report and implementation of recommendations for residential projects with more than four units that are located within potential liquefaction areas, which has been completed for the project. Thus, buildings must be designed in accordance with the latest edition of the CBC, which sets forth structural design parameters for buildings to withstand seismic shaking without substantial structural damage. Conformance to the CBC as required by state law and the City would ensure the maximum practicable protection available for structures and their associated trenches, excavations and foundations. (The General Plan 2030 EIR analyses are included on pages

4.10-21 to 4.10-23 of the Draft EIR volume.)
The General Plan 2030 EIR concluded that with adherence to existing regulations and standards, including preparation of a project-specific geotechnical report and adherence to the CBC, as incorporated into the City’s Municipal Code, and various policies and actions established in the General Plan, harm to people and structures from adverse seismic events would be minimized (SOURCE V.1b-DEIR volume).

The project geotechnical report includes recommended design measures to ensure the project would not cause substantial adverse effects, including the risk of loss, injury, or death due to potential existing geologic hazards. Demonstration of project design adherence to geotechnical report recommendations will be required at the time of building permit application that demonstrates that the proposed buildings are designed to current seismic design standards. Compliance with recommendations in the project geotechnical report and with the California Building Standards Code would reduce risks associated with strong seismic ground shaking, liquefaction, and lateral spreading at the project site.

Therefore, impacts to seismic hazards would be less than significant. Although mitigation measures are not required as a significant impact has not been identified, the following measure is recommended as a condition of project approval.

RECOMMENDED CONDITION OF APPROVAL: Require implementation of recommendations set forth in the geotechnical investigation prepared for the project as may be updated (Moore Twining Associates 2023), including, but not limited to recommendations regarding: site preparation and grading; excavation; engineered fill requirements; drainage; structural seismic design parameters; structural foundation deign; ground improvement; and all other recommendations. (b) Erosion. According to maps developed as part of the City’s General Plan 2030 and included in the General Plan EIR, the project site consists of Watsonville loam thick surface soils, with 0

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to 2 percent slopes (SOURCE V.1b-DEIR Figure 4.10-6). As described in the General Plan EIR, erosion potential for this soil profile is not considered high (SOURCE V.1b-DEIR volume).

Impact Analysis. The project would result in the excavation of approximately 32,200 cubic yards (cy) of soil and approximately 5,700 cy of fill, resulting in a net removal of 26, 500 cy.

See section VI.10(a) below regarding potential water quality impacts due to grading and earthwork.

Project earthwork would include grading, trenching, and removal of trees and other vegetation. Construction of the proposed project would result in grading and excavation of approximately 1,000 cy of earth material, which would be cut from the site, and approximately 6,000 cy of earth material, which would be filled. Therefore, there would be net import of approximately 5,000 cy of earth material on site. These construction activities would include ground disturbance, which would potentially result in short-term soil erosion. To address potential erosion of on-site soils, building permit project plans will be required to include an erosion control plan that would be implemented during construction.

Erosion control measures required on the building permit plan include, but are not limited to: implementation of construction best management practices (BMPs) in accordance with City regulations; installation and inspection of erosion and sediment control BMPs, such as hay bales, filter berms, silt fencing, fiber rolls, and/or other measures; daily checks and sweeping as needed of sidewalk and street; proper storage of construction materials; protection of soil stockpiles from stormwater runoff; installation and maintenance of additional sediment control measures during rainy season (October 15 through April 15); and storm drain inlet/catch basin protection.

The General Plan 2030 EIR concluded that future development accommodated by the Plan could result in erosion during construction but could be mitigated with adherence to local regulations that require implementation of erosion control plans, and thus, potential erosion during construction would be minimized, resulting in a less-than-significant impact.

The project will be required to implement erosion control plans and erosion control standards and requirements set forth in the City’s Municipal Code Chapter 18.45. (The General Plan 2030 EIR analyses are included on pages 4.10-25 to 4.10-26 of the Draft EIR volume.) Thus, implementation of project erosion control plans would prevent excessive erosion during construction.

In addition, because the proposed project footprint is greater than 1 acre, it would be subject to the National Pollutant Discharge Elimination System (NPDES) permit requirements for construction site stormwater discharges and would comply with those requirements. A Storm Water Pollution Prevention Plan (SWPPP) is required to be prepared and implemented under these requirements, which includes appropriate erosion-control and water-quality-control measures during site preparation, grading, construction, and post-construction. Implementation of the SWPPP for the proposed project would minimize short-term erosion impacts.

Future development of the project would result in limited disturbance within identified building envelops and new driveway and walkway areas; development of these areas would

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result in 87,015 square feet of new/replaced impervious surface covering soils. Long-term impacts of the proposed project would not result in substantial erosion, as the soils would be covered by buildings, pavement, vegetation, and landscaping. See subsection 10(a) below regarding potential water quality impacts due to grading and earthwork.

Implementation of required erosion control plans and erosion control standards described above and requirements set forth in the City’s Municipal Code Chapter 18.45 would address potential soil erosion impacts. For these reasons, the project result in less-than-significant soil erosion impact.
c) Geologic Hazards. Non-seismically induced hazards include slope instability, cliff retreat, and non-seismic settlement and landslides (SOURCE V.1a). The project site is relatively level and is not in an area susceptible to landslides (SOURCE V.1b-DEIR Figure 4.10-3). The project site is not located in an area of steep slopes (SOURCE V.1b-DEIR Figure 4.10-5). As described in the geotechnical report, there are no non-seismically induced geologic hazards present on or near the project site. (SOURCE V.13c). Therefore, the project would result in no impact related to nonseismic geologic hazards. (d) Expansive Soils. The geotechnical report prepared for the project included exploratory borings and laboratory testing. Fill soils were encountered generally consisting of very loose to loose silty sands, loose silty clayey sands with gravel, and medium stiff to stiff sandy lean clays.

The undocumented fill soils typically contained gravel and/or debris such as brick and concrete debris. The undocumented fill soils were underlain by native soils consisting of various interbedded, discontinuous layers of very soft to hard sandy lean clays, medium dense clayey sands, medium dense poorly graded sands with silt, very loose to medium dense silty sands, loose poorly graded sand, and medium stiff sandy fat clays which extended to depths of approximately 10 to 15 feet BSG where the siltstone rock was generally encountered. The near surface soils consisted of either very loose silty clayey sands or very soft to medium stiff sandy lean clays. These near surface soils were underlain by various interbedded, discontinuous layers of dense clayey sands with gravel and very stiff to hard sandy lean clays over siltstone. Where encountered, the native soils were underlain by Santa Cruz mudstone that generally consisted of slightly friable, moderately weathered and thinly bedded hard siltstone which extended to the maximum depth explored (SOURCE V.13c).

The near surface soils tested exhibited a very low expansion potential, moderate compressibility characteristics, and fair support characteristics for pavements when compacted as engineered fill. In order to reduce the potential for excessive static settlement of surface improvements which are sensitive to settlement, the geotechnical report recommends overexcavation of the existing undocumented fill soils to support new surface improvements on compacted engineered fill soils. Furthermore, due to the shallow groundwater conditions encountered during the geotechnical investigation, the report recommends that contractors should anticipate dewatering and control and management of groundwater will be required for construction of the project. The report also recommends that contractors should anticipate that the onsite soils will be overly moist and will require drying prior to being used as engineered fill. Also, it should be anticipated that the base of excavations will require stabilization due to wet, unstable soil conditions (SOURCE V.13c).

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As described above, implementation of recommendations set forth in the project geotechnical report is required by the CBC and City regulations and policies, which would ensure that potential exposure to geotechnical hazards associated with potentially expansive soils would be reduced to a less-than-significant level.
(e) Septic Systems. The project would be connected to an existing 8-inch sanitary sewer in Swift Street and would not use septic systems. A septic system would not be used for the proposed project. Therefore, no impact would occur.
(f) Paleontological Resources. According to maps developed for the City’s General Plan 2030 and included in the General Plan EIR, the project site is within an area mapped as Late Pleistocene alluvium formations (SOURCE V.1b-DEIR Figure 4.9-5). Late Pleistocene alluvium is one of the four geologic units in the General Plan area known to contain paleontological resources (SOURCE V.1b-DEIR volume).

Impact Analysis. While the project site does not contain known paleontological resources, construction activities could potentially destroy unknown paleontological resources.

General Plan Action HA1.2.3 requires the City to notify applicants within paleontologically sensitive areas of the potential for encountering such resources during construction and condition approvals that work will be halted and resources examined in the event of encountering paleontological resources during construction. If the find is significant, the City would require treatment of the find in accordance with the recommendations of the evaluating paleontologist. Treatment may include, but is not limited to, specimen recovery and curation or thorough documentation. The City includes this requirement as a standard condition of approval, and therefore the impact potential impact to paleontological resources would be considered less than significant.

STANDARD CONDITION OF APPROVAL: In the event that paleontological resources are encountered during construction, work shall be halted in the vicinity of the find until it can be evaluated by a professional paleontologist. If a find is determined to be significant, treatment of the find in accordance with the recommendations of the evaluating paleontologist shall be required. Treatment may include, but is not limited to, specimen recovery and curation or thorough documentation.

8. Greenhouse Gas Emissions
(a) Greenhouse Gas Emissions. Climate change refers to any significant change in measures of climate, such as average temperature, precipitation, or wind patterns over a period of time.

Climate change may result from natural factors, natural processes, and human activities that change the composition of the atmosphere and alter the surface and features of the land.

Significant changes in global climate patterns have recently been associated with global warming, an average increase in the temperature of the atmosphere near the Earth’s surface, attributed to accumulation of greenhouse gas (GHG) emissions in the atmosphere. Greenhouse gases trap heat in the atmosphere, which in turn heats the surface of the Earth. Some GHGs occur naturally and are emitted to the atmosphere through natural processes, while others are created and emitted solely through human activities. Climate change models predict changes

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in temperature, precipitation patterns, water availability, and rising sea levels, and these altered conditions can have impacts on natural and human systems in California that can affect California’s public health, habitats, ocean and coastal resources, water supplies, agriculture, forestry, and energy use (SOURCE V.1b-DEIR volume).

The most common GHG that results from human activity is carbon dioxide, followed by methane and nitrous oxide. The primary contributors to GHG emissions in California are transportation (about 37 percent), electric power production (24 percent), industry (20 percent), agriculture and forestry (6 percent), and other sources, including commercial and residential uses (13 percent). Approximately 81 percent of California’s emissions are carbon dioxide produced from fossil fuel combustion (SOURCE V.1b-DEIR volume).

In 2006, the California Legislature passed the Global Warming Solutions Act of 2006 (AB 32), which sought to reduce GHG emissions generated by California to 1990 emissions levels by the year 2020. AB 32 defines GHGs to include carbon dioxide, methane, nitrous oxide, hydrocarbons, perfluorocarbons and sulfur hexafluoride. In 2016, the Legislature followed up with SB 32, which requires California, by 2030, to reduce its statewide GHG emissions so that they are 40 percent below those that occurred in 1990.

In enacting both AB 32 (2006) and SB 32 (2016), the Legislature codified some of the ambitious GHG reduction targets included within certain Executive Orders issued by Governors Schwarzenegger and Brown. The 2020 statewide GHG reduction target in AB 32 was consistent with the second of three statewide emissions reduction targets set forth in former Governor Schwarzenegger’s 2005 Executive Order known as S-3-05, which is expressly mentioned in AB

32. (See Health & Safety Code section 38501, subd. (i)). That Executive Branch document included the following GHG emission reduction targets: by 2010, reduce GHG emissions to 2000 levels; by 2020, reduce GHG emissions to 1990 levels; by 2050, reduce GHG emissions to 80 percent below 1990 levels. To meet the targets, the Governor directed several State agencies to cooperate in the development of a climate action plan. The Secretary of Cal-EPA leads the Climate Action Team, whose goal is to implement global warming emission reduction programs identified in the Climate Action Plan and to report on the progress made toward meeting the emission reduction targets established in the executive order.

In 2015, Governor Brown issued Executive Order, B-30-15, which created a “new interim statewide GHG emission reduction target to reduce GHG emissions to 40 percent below 1990 levels by 2030 in order to ensure California meets its target of reducing GHG emissions to 80 percent below 1990 levels by 2050.” SB 32 codified this target.

In 2018, Governor Brown issued Executive Order B-55-18, which established a statewide goal to “achieve carbon neutrality as soon as possible, and no later than 2045, and maintain and achieve negative emissions thereafter.” The order directs the California Air Resources Board (CARB) to work with other State agencies to identify and recommend measures to achieve those goals.

CARB is the lead agency for implementing AB 32 and SB 32. In accordance with these statutes, CARB conducts an annual statewide GHG Emission Inventory that provides estimates of the

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amount of GHGs emitted to the atmosphere by human activities within California. In accordance with requirements of AB 32, CARB adopted an Initial Scoping Plan in 2008 and is required to update the scoping plan at least every five years. The First Update to the Scoping Plan, approved in 2014, established a 2030 emissions target of 40 percent below 1990 levels.

The 2017 Scoping Plan identified a balanced mix of strategies to meet the State’s 2030 GHG limit.

The current 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) was approved by CARB on December 15, 2022. The 2022 Scoping Plan lays out a path not just to carbon neutrality by 2045, but also to meet the 2030 GHG emissions reduction target. The 2022 Scoping Plan analyzed four scenarios, with the objective of informing the most viable path to remain on track to achieve the 2030 GHG reduction target. The scenario modeling indicates that, if the plan described in the Proposed Scenario is fully implemented, and done so on schedule, the State would cut GHG emissions by 85 percent below 1990 levels, resulting in a 71 percent reduction in smog-forming air pollution, reduce fossil fuel consumption by 94 percent, and create 4 million new jobs, among other benefits (SOURCE V.4a).

The 2022 Scoping Plan details “Local Actions” in Appendix D, which includes recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and approval of new land use development projects, including through environmental review under CEQA. The recommendations provided in Appendix D are nonbinding and should not be interpreted as a directive to local governments, but rather as evidence-based analytical tools to assist local governments with their role as essential partners in achieving California’s climate goals. Appendix D recognizes consistency with a CEQA-qualified GHG reduction plan such as a Climate Action Plan as a preferred option for evaluating potential GHG emission impacts under CEQA (SOURCE V.4b).

The City’s General Plan 2030 includes goals, policies, and actions on climate change, including reducing communitywide GHG emissions 30 percent by 2020, reducing communitywide GHG emissions 80 percent by 2050 (compared to 1990 levels), and for all new buildings to be emissions neutral by 2030.

In September 2022, the City adopted the 2030 Climate Action Plan (CAP) that updates the previous 2020 CAP that was adopted in 2012 and outlines measures and actions that are intended to reduce GHG emissions, per capita, by approximately 40 percent below 1990 levels by 2030, meeting the SB 32 target for 2030 to reduce total GHG emissions 40 percent below 1990 levels. The CAP also seeks to achieve a carbon neutrality goal by the year 2035 prior to the State’s target carbon neutrality goal by 2045 (SOURCE V.2c).

The CAP includes 31 measures with 152 associated individual actions, intended to reduce GHG emissions throughout the City. The measures include those related to building energy use and reduction, transportation, public infrastructure, and other climate restoration and sustainable government measures. Through implementation of its measures and actions, the CAP aims to reduce building energy consumption, vehicle miles traveled, solid waste generation, and increase carbon sequestration (SOURCE V.2c).

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Impact Analysis. The proposed project would result in direct and indirect GHG emissions during construction and operation. The State CEQA Guidelines do not prescribe specific methodologies for performing a GHG emissions assessment, establish specific thresholds of significance, or mandate specific mitigation measures. Rather, the CEQA Guidelines emphasize the lead agency’s discretion to determine the appropriate methodologies and thresholds of significance that are consistent with the manner in which other impact areas are handled in CEQA. Global climate change is a cumulative impact; a project’s potential impact results through its incremental contribution combined with the cumulative increase of all other sources of GHGs (CEQA Guidelines sections 15064.4 and 15183.5). There are currently no established thresholds for assessing whether the GHG emissions of the proposed project would be considered a cumulatively considerable contribution to global climate change. The MBARD does not have an adopted GHG emissions threshold, except it does have an adopted guideline for stationary source projects in which a project would not have a significant GHG emissions impact if the project emits less than 10,000 metric tons of CO2e per year or complies with regulations or requirements adopted to implement a statewide, regional or local plan for the reduction or mitigation of GHG emissions (SOURCE V.6b). As indicated above, while the City’s CAP has a per capita emissions target, it is not a threshold for the purpose of CEQA analyses.

However, the City’s adopted CAP provides a quantification of emissions reductions that would reduce GHG emissions over time throughout the City, through implementation of the measures and actions included in the CAP. For the purposes of CEQA, the City’s 2030 CAP serves as a “Qualified Climate Action Plan” under which the City can streamline the environmental review process of future projects. Pursuant to CEQA Guidelines Section 15064.4(b)(2), a lead agency may consider a project’s consistency with an adopted emissions reduction plan in determining significance of a project’s GHG emissions. To determine consistency, the City adopted a “Project Review Checklist” as part of the CAP to determine consistency with the CAP on a project-by-project basis. Pursuant to CEQA Guidelines Section 15183.5, a lead agency may determine that a project's incremental contribution to a cumulative effect is not cumulatively considerable if the project complies with the requirements in a previously adopted plan or mitigation program under specified circumstances. In order for the CAP to be considered a qualified GHG reduction strategy and provide for CEQA streamlining of GHG emissions analyses for future development, the CAP must identify those measures that are applicable to new development. The CAP includes measures that are applicable to existing developments, municipal government operations, as well as voluntary and mandatory measures to be applied to new development for public and private projects. Mandatory GHG reduction programs that are applicable to new development are summarized in the CAP Project Review Checklist. The CAP Project Review Checklist identifies applicable regulations, applicability, requirements, and monitoring and reporting required by regulations. A development project that demonstrates incorporation of the measures in the CAP Project Review Checklist would be considered consistent with the CAP.

The project applicant completed and submitted the Project Review Checklist, which shows incorporation of measures that would reduce the project’s incremental contribution to GHG emissions and climate change, consistent with the City’s adopted CAP. Thus, the project

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was determined to be consistent with the City’s CAP. Therefore, the project would have a less than significant impact on GHG emissions.
(b) Conflicts with Applicable Plans. The project would not conflict with state plans adopted for the purpose of reducing GHG emissions. As described above, the Santa Cruz City Council adopted a CAP that addresses citywide greenhouse emissions and reduction strategies. The CAP incorporates a variety of measures and actions that focus on continued efforts to reduce GHG emissions. The CAP provides City emissions inventories, identifies emissions reduction targets for the year 2030 and beyond, and includes measures and actions that are categorized into the following sections with corresponding measures and actions: building energy; transportation; water, waste, and wastewater; climate restoration; climate economy; and sustainable municipal government. These measures address and cover topics related to building energy consumption, solar programs, building electrification, active/public transportation programs, including: ridesharing, electric vehicles, remote work policy and infrastructure, water consumption, solid waste reduction, wastewater treatment, urban forestry, green jobs, and municipal facilities. Each measure has supporting actions, states the GHG reduction potential, lists which City department is responsible for implementation, and explains the advantages and benefits of the specific action. The CAP also includes an Implementation chapter that outlines funding, implementation accountability, and monitoring / reporting procedures for the measures and actions. The proposed project includes features that further reduce GHG emissions, consistent with measures included in the 2030 CAP as described above. The project incorporates GHG reduction measures identified by the City in the CAP Project Review Checklist, and, as explained above, the project was found consistent with the City’s CAP. Thus, the project would not conflict with provisions of the CAP, and no impact would occur.

9. Hazards and Hazardous Materials
(a,c) Hazardous Material Use, Sites and Emissions. The proposed project consists of new residential uses, which would not involve the routine transport, use, or disposal of hazardous materials or wastes, except for typical household and commercial cleaning supplies, and would not result in the creation of a public health hazard. The project site is located adjacent to and to the north of Gateway School. However, the project consists of residential uses and would not involve emissions of hazardous materials. Thus, the project would not result in the creation of a significant public health hazard and would result in no impact. (b,d) Exposure to Hazardous Materials. According to a Phase I Environmental Site Assessment (ESA) prepared for the project site, the site previously had been identified on numerous databases, and a ‘No Further Action’ cleanup case was identified on the California Department of Toxic Substance Control (DTSC) EnviroStor website. A Phase I ESA conducted on the project site in 2000 identified one recognized environmental condition (REC) associated with the past uses of the project site. The project site was historically used by the National Guard Armory, and vehicle and tank maintenance were conducted on the site. A limited soil and groundwater assessment was recommended. In May 2002, a Preliminary Endangerment Assessment (PEA) was conducted to address the concerns associated with the former National Guard Armory activities. Elevated concentrations of some constituents of concern (COCs) were identified

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above their respective screening levels at that time, but concentrations were deemed to be typical of those found in ‘urban environments’ and no further action was recommended. DTSC agreed and approved the PEA in July 2002 (SOURCE V.13d).

A Phase I investigation was conducted in 2023 as part of the project studies conducted for the proposed project. Findings from this assessment and a concurrent geotechnical engineering subsurface investigation found groundwater to be at depths ranging from 3 to 6 feet below ground surface, and olfactory observations of petroleum hydrocarbon contamination were observed in the central portion of the project site. Additionally, a review of historical documents for the nearby Santa Cruz Industries facility, located at 411 Swift Street, indicate that monitoring well MW-18, which is located on the Subject Property, has historically had elevated concentrations of TCE above the CalEPA RSLs. Based on these findings, further soil, groundwater and soil vapor assessment was recommended (SOURCE V.13d).

Impact Analysis. Project construction could result in release of and/or exposure to hazardous materials, resulting in a potentially significant impact.

Additional investigation was recommended in the Phase I ESA to evaluate the current subsurface environmental conditions. A Phase II ESA was subsequently conducted to collect soil, groundwater, and soil vapor samples for COCs associated with the former presence of a National Guard Armory on the project site. A total of 10 soil borings were drilled to maximum depths of 14 feet BSG across the project site, and foursoil gas wells were installed to assess vapor intrusion risk for the proposed school development (SOURCE V.13a).

Soil Sample analytical results revealed detectable diesel and motor oil range hydrocarbons (TPHd and TPHmo), which were detected at multiple locations, but only one soil sample at a depth of 2.5 feet BGS was reported above the residential screening levels for diesel of 260 mg/kg, at a concentration of 5,900 mg/kg. The Phase II ESA determined that additional investigation and/or removal action of the elevated TPHd in near surface soil in the vicinity of boring B10 appears to be warranted. The motor oil range hydrocarbons detected did not exceed the residential or industrial RSL values of 12,000 mg/kg and 180,000 mg/kg, respectively and are therefore considered a low threat to human health and the environment. Toluene and trichloroethylene (TCE) were detected slightly above the laboratory detection limit, but concentrations were below the residential and commercial screening levels. No TPHg, OCPs, SVOCs, or PCBs were detected from the soil samples and are therefore considered a low threat to human health and the environment (SOURCE V.13a).

The arsenic concentration found in near surface soils (2.5 feet) in one boring exceeded the reported naturally occurring background concentrations and the DTSC school program screening level. The Phase II ESA indicated that additional investigation and/or removal action of arsenic in near surface soil in the vicinity of boring B4 appears warranted. The remaining arsenic detected in the site soils appears to be slightly above or below the USGS reported naturally occurring concentrations of 3.5 to 5.7. No remaining heavy metal concentration exceeded their respective residential or industrial human health screening levels and are therefore considered a low threat to human health and the environment. No heavy metal analyzed exceeded total threshold limit concentration (TTLC). Chromium

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concentrations in one boring at 2.5 feet bgs, equaled 10 times the soluble threshold limit concentration (STLC trigger concentration) for hazardous waste soil classification (for disposal purposes) (SOURCE V.13a).

Soil gas sample analytical results showed detectable concentrations of seven VOCs, two of which had concentrations slightly exceeding residential screening levels (benzene and chloroform) at well locations SG-1 (chloroform), SG-3 (benzene) and SG-4 (benzene). No VOCs were detected above their commercial soil gas screening levels. Benzene and chloroform were not detected in the soil and groundwater samples analyzed at the site, thus the source of the detected benzene and chloroform in soil gas is unknown. The Phase II ESA indicates that additional soil gas sampling should be conducted to confirm if the detected concentrations of benzene and chloroform are present in soil gas at the site that may cause an excessive vapor intrusion risk to the proposed project (benzene and chloroform concentrations are slightly above published residential screening level values, which are used for proposed school sites). In lieu of additional soil gas sampling, a chemical resistant vapor barrier can be installed below the proposed onsite buildings to mitigate the potential vapor intrusion concern (SOURCE V.13a).

Groundwater sample analytical results showed detectable concentrations of TPHd above its respective tap water RSL. TPHmo was detected, however no RSLs have been established for this constituent. The source of TPHd and TPHmo detected in groundwater is likely from elevated concentrations of TPHd and TPHmo present in near surface soil (upper 3 to 4 feet) in the vicinity of the former concrete ramp used for vehicle/tank maintenance/repairs (near boring B10). As such, removing the near surface soil (upper 3 to 4 feet) in the vicinity of the former concrete ramp (near boring B10) would likely reduce the TPHd and TPHmo concentrations presence in the groundwater. Concentrations of TCE were detected in several borings at concentrations ranging from 0.56 µg/L at boring B4 to 3.7 µg/L at boring B5, which all exceed the tap water RSL of 0.49 µg/L, but are below the published California Maximum Contaminant Level (MCL) for drinking water of 5.0 µg/l. Additionally, soil and soil gas samples collected at the Subject Property did not indicate TCE as an onsite source for the groundwater detection. As such, the source of TCE detected in groundwater is likely associated with the nearby Santa Cruz Industries case (GEOTRACKER ID#: SLT3S0011280) that is located about 400 feet north (upgradient) of the project site (SOURCE V.13a).

Mercury was detected in groundwater at estimated concentrations ranging from 37 µg/L to 48 µg/L, above the California drinking water MCL value of 2.0. The remaining heavy metals were below their respective tap water RSL values or were not detected. No SVOCs nor PCBs were detected in the groundwater samples (SOURCE V.13a).

Based on the findings of this Phase II ESA, additional environmental assessment and/or soil removal action is recommended. Implementation of Mitigation Measures 1, 2 and 3 would reduce the impact to a less-than-significant level.

MITIGATION MEASURE HAZ-1: Prepare and implement a soil removal action plan for additional investigation and/or removal of the elevated TPHd in near surface soil (upper 3 to 4 feet) in the vicinity of boring B10 (near the former concrete ramp used

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for vehicle/tank maintenance/repairs) and elevated arsenic in near surface soil (upper 3 to 4) in the vicinity of boring B4.

MITIGATION MEASURE HAZ-2: Conduct additional soil gas sampling to confirm if the detected concentrations of benzene and chloroform are present in soil gas at the site that may cause an excessive vapor intrusion risk to the proposed school development (benzene and chloroform concentrations were detected slightly above published residential screening level values which are used for proposed school sites). In lieu of additional soil gas sampling, a chemical resistant vapor barrier can be installed below the proposed onsite buildings during future development to mitigate the potential vapor intrusion concern.

MITIGATION MEASURE HAZ-3: Prepare and implement a soil and groundwater management plan to address handling and management of impacted soil and/or groundwater that could be potentially encountered during construction activities The detected concentrations of TPHd, TPHmo, TCE, arsenic, and chromium in soil and/or groundwater may require special handling/testing and increase construction cost if soil/groundwater is required to be exported/disposed of offsite. (e) Location Near Airports. The project site is not located within two miles of a public airport or private airstrip. Therefore, the project would result in no impact. (f) Emergency Response. Existing and proposed access to the project site is from Swift Street.

The project would not include any changes to existing public roadways that provide emergency access to the site. Therefore, the project would have no impact related to interference with adopted emergency response or evacuation plans.
(g) Wildland Fire Hazard. The General Plan 2030 EIR indicated that future growth could result in an indirect increased risk of wildfires in the urban-rural interface and adjacent to the City’s greenbelt areas. The EIR indicates that areas targeted as “likely” to have a wildland fire include the Arroyo Seco/Meder Canyon, DeLaveaga, Pogonip, Moore Creek area and Arana Gulch, and future growth in these areas could result in an indirect increased risk of wildfires in the urbanrural interface and adjacent to the City’s greenbelt areas.

According to maps developed for the City’s General Plan 2030 and included in the General Plan 2030 EIR, the project site is not located within a high fire hazard area (SOURCE V.1b-DEIR Figure

4.6-1). The project is located in an urban area and does not contain significant sources of flammable materials (e.g., timber land). The project would meet all City requirements for access, and the building would be required to install fire sprinkler systems in accordance with City regulations. Therefore, the project would not expose people or structures to a significant risk of loss, injury or death involving wildland fires, resulting in no impact. See also section IV.20 below. See also section VI.20 below.

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10. Hydrology and Water Quality
(a) Water Quality/Discharges. The proposed project does not involve any discharges that would violate any water quality standards or waste discharge requirements.

Within urbanized areas such as the City, pollutants frequently associated with stormwater include sediment, nutrients, oil and grease, heavy metals, and litter. The primary sources of stormwater pollution in urban areas include automobiles, parking lots, landscape maintenance, construction, illegal connections to the stormwater system, accidental spills, and illegal dumping.

Urban runoff and other “non-point source” discharges are regulated by the 1972 Federal Clean Water Act (CWA), through the National Pollutant Discharge Elimination System (NPDES) permit program that has been implemented in two phases through the California Regional Water Quality Control Boards (RWQCB). Phase I regulations, effective since 1990, require NPDES permits for storm water discharges for certain specific industrial facilities and construction activities, and for municipalities with a population size greater than 100,000. Phase II regulations expand the NPDES program to include all municipalities with urbanized areas and municipalities with a population size greater than 10,000 and a population density greater than 1,000 persons per square mile (SOURCE V.1b-DEIR volume).

The City has developed a Storm Water Management Program (SWMP) in order to fulfill the requirements of the Phase II NPDES General Permit for Discharges of Storm Water from Small Municipal Separate Storm Sewer Systems (MS4) (General Permit) and to reduce the amount of pollutants discharged in urban runoff. In compliance with the Phase II regulations, the City’s comprehensive SWMP is designed to reduce the discharge of pollutants to the Maximum Extent Practicable (MEP) and to protect water quality (SOURCE V.1b-DEIR volume). The City also adopted an ordinance for “Storm Water and Urban Runoff Pollution Control” (Chapter 16.19 of the City’s Municipal Code), as part of its Storm Water Management Plan in accordance with the RWQCB’s requirements. The ordinance identifies prohibited discharges and required BMPs for construction and new development. City regulations (Municipal Code section 16.19.140) requires that any construction project, including those undertaken under any permit or approval granted pursuant to Titles 15 (Streets and Sidewalks), 18 (Buildings and Construction), and 24 (Zoning) of the Municipal Code, shall implement BMPs including the City’s mandatory BMPs as detailed in the latest BMP manual published by the City’s Public Works Department.

BMPs shall be maintained in full force and effect during the duration of the project. The City’s BMP manual requires a development project to include structural or treatment control BMPs, or a combination of BMPs, to reduce potential pollutant loadings in storm water runoff to the maximum extent practicable.

Impact Analysis. The project could result in water quality degradation due to stormwater runoff and potential erosion during construction. However, the project is consistent with the City’s stormwater management requirements, and potential erosion will be controlled with implementation of an erosion control plan as explained above in section VI.7(b), resulting in a less-than-significant impact.

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The City’s mandatory BMPs, as detailed in the latest BMP manual published by the City’s Public Works Department, must be implemented to protect water quality into the municipal storm drain system. The project would also be subject to the Central Coast PostConstruction Requirements (PCRs) that were enacted by the Central Coast RWQCB in July 2013. The PCRs are for projects that create and/or replace ≥2,500 square feet of impervious surfaces. Based on the amount of new/replaced impervious surface area created by the project (approximately 87,015 square feet), the project would be required to comply with Tiers 1 through 4 (Site Design, Water Quality Treatment, Runoff Retention, and Peak Management).

The project has claimed technical infeasibility for Tier 3 Runoff Retention therefore per the (PCRs); on-site retention of the full retention volume is not required, and the project is required to dedicate no less than ten percent of the regulated project’s equivalent impervious surface area (EISA) to retention-based measures. The project is also exempt from Tier 4 Peak Management due to the following (PCRs) special circumstances condition:

Project runoff discharges to a continuous underground storm drain system that discharges to marine near-shore waters.

The project site is currently partially developed, and its impervious surface area would increase with the development of the proposed project. New impervious surfaces could increase the delivery of urban pollutants to vicinity storm drains or water courses, but none exist on or adjacent to the project site. A schematic stormwater control plan has been prepared for the project that details drainage features to collect and treat stormwater runoff. The plans note that stormwater would be controlled through new biofiltration rain garden areas, pervious walkways and associated storm drains, along the perimeter of the project site and along the proposed pedestrian pathway to Sergeant Derby Park. These drainage areas would flow to a Swift Street public storm drain inlet. Incorporation of these measures to treat stormwater runoff would be consistent with City stormwater management requirements.

Project construction would include grading that could result in short-term soil erosion. As indicated in subsection 7(b) above, an erosion control plan would be required to be implemented during construction, in accordance with City regulations, including implementation of construction BMPs. In addition, construction activity on projects that disturb one or more acres of soil, which includes the proposed project, must obtain coverage under the State’s General Permit for Discharges of Storm Water Associated with Construction Activity (Construction General Permit, 99-08-DWQ). Construction activity subject to this permit includes clearing, grading, and disturbances to the ground such as stockpiling or excavation. The Construction General Permit requires the development and implementation of a SWPPP. The SWPPP must list best BMPs that the discharger will use to protect stormwater runoff and the placement of those BMPs. A Notice of Intent (NOI) and SWPPP must be prepared prior to commencement of construction. Implementation of the SWPPP would further minimize short-term erosion impacts.

In addition, the project would be required to implement the City’s regulatory requirements and BMPs, as detailed in the “Stormwater Best Management Practices Manual” published

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by the City’s Public Works Department. Part of these requirements include incorporating pollution source control measures for various pollution sources (i.e. trash storage areas, parking areas, etc.). Site-specific pollution source controls are included in the project’s stormwater control plan.

Compliance with regulations contained in the City’s Municipal Code regarding design of stormwater drainage systems to meet water quality standards (section 24.14.050 of the City’s Municipal) and implementation of stormwater BMPs, grading requirements and implementation of erosion control plans (Chapters 16.19 and 18.45 and section 24.14.060), as well as preparation and implementation of a SWPPP as may be required during construction, would mitigate potential storm runoff water quality and erosion impacts resulting from increased stormwater and construction activities. Project stormwater drainage improvements will be designed in accordance with City standards and Public Works requirements in order to meet water quality standards. Therefore, the project would result in a less-than-significant impact related to water quality. The project would not result in waste discharge that would violate any water quality standards, resulting in no impact. (b) Groundwater. The City is primarily developed, and no groundwater recharge areas are identified or mapped in the City’s General Plan 2030 or General Plan 2030 EIR; groundwater resources utilized as part of the City’s water supply are obtained from aquifers outside of the City (SOURCE V.1b-DEIR volume). The General Plan 2030 EIR concluded that development accommodated by the General Plan would not be located within groundwater recharge areas and would have no effect on recharge capabilities, and therefore, would not deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table. (The General Plan 2030 EIR analyses are included on pages 4.5-40 to 4.5-42 of the Draft EIR volume.) Development within groundwater mapped recharge areas also is regulated in Municipal Code section 24.14.090 in order to minimize adverse environmental impacts.

The project site is located within a developed urban area with a mix of residential, light industrial, and public facility uses in the immediate vicinity. The project would be connected to the City’s public water system and does not include the use of a groundwater well. Therefore, the project would not affect groundwater supplies or recharge or impede sustainable groundwater management of the basin and would result in no impact regarding groundwater. (c[i-iii]) Drainage. The project site is located within a developed urban area. The site is partially developed and also contains non-native vegetation. The site currently drains to a storm drain inlet, storm manhole and storm drain pipe in Swift Street.

Impact Analysis. Project development would result in a net increase of impervious surfaces.

On-site stormwater retention and filtration is planned through engineered control measures detailed in the project’s stormwater control plans. These plans are designed so that the project would not generate a flow of stormwater that would exceed the capacity of storm water facilities, or result in substantial erosion.

A project’s stormwater would be required to be maintained at pre-development runoff levels in accordance with General Plan and City requirements. The project is exempt from

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peak management (Tier 4) requirements and pre-development run-off levels under the following (PCRs) special circumstances condition: Project runoff discharges to a continuous underground storm drain system that discharges to marine near-shore waters. The project proposes to discharge to continuous underground storm drainage pipeline from Swift Street fronting the site to an ocean outfall at the end of Merced Avenue.

The project would not alter existing drainage patterns. The project would be compliant with Section 24.14.050 of the City’s Municipal Code that requires preparation of a drainage plan and improvements that would be required to be designed in accordance with City standards and Public Works requirements in order to meet water quality standards. For these reasons, the proposed project would not result in significant drainage impacts. Therefore, the project would result in a less-than-significant impact related drainage. (c [iv], d) Flood and Tsunami Zones. The project site is not located within a Federal Emergency Management Agency (FEMA) flood hazard area (SOURCE V.1b-DEIR Figure 4.7-1). The project site is not in a tsunami inundation zone (SOURCE V.1b-DEIR Figure 4.7-2). Therefore, the project would result in no impact related to release of pollutants in flood or tsunami zones.

Sea Level Rise. The General Plan 2030 EIR reported that sea level rise, storms of increasing intensity, and an alternating series of floods and droughts threaten the City of Santa Cruz in the coming decades. The City prepared a “Climate Adaptation Plan” with funding from FEMA.

The objectives of this Plan are to identify and evaluate the potential impacts of climate change on the City of Santa Cruz, analyze the severity of the hazards that the City faces, and develop potential adaptation responses to reduce the risk and exposure of the City to these hazards.

The potential risks were identified in a “Vulnerability Study” that identified potential facilities vulnerable to risks of sea level rise, including beaches, the City’s wastewater treatment facility, and the Santa Cruz Harbor (SOURCE V.1b, DEIR volume). The Climate Adaptation Plan Update 2018-2023, adopted by the City Council in October 2018, further addresses sea level rise.

The project site is not located within an area identified as being subject to potential effects of coastal storm hazards or sea level rise (SOURCE V.2h). The project site also doesn’t contain any critical facilities, listed in the Climate Adaptation Plan, which provide essential services and protect life and property within the City. Thus, there would be no impact related to sea level rise.
(e) Conflict with Plans. The project site is not located adjacent to a water course or water body. The proposed project would not result in new discharges or conflict with provisions in the Central Coast Basin Plan as stormwater would be treated as described above that include flow-through planters, self-treating biofiltration areas, and underground chambers for retention, which would prevent water quality degradation in accordance with the City’s stormwater requirements. A sustainable groundwater management plan for the area in which the project is located has not yet been prepared. Therefore, the project would not conflict with or obstruct implementation of an adopted water quality or groundwater plans; the project would result in no impact.

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11. Land Use and Planning
(a) Physical Division of Community. . The project site is located within a developed urban area of the City. The project would not physically divide an established community and would result in no impact.
(b) Consistency with Local Policies/Plans. Based on the analyses contained in this Environmental Checklist and City staff review of the General Plan 2030, the proposed project would not result in a conflict with any policies or regulations adopted for the purpose of avoiding or mitigating an environmental impact and would result in no impact.

12. Mineral Resources
There are no mines or areas of known mineral resources within the City (SOURCE V.1b-DEIR).

Therefore, the project would have no impact on mineral resources.

13. Noise
(a) Noise Increases. The project area is located in the Lower Westside neighborhood. The noise assessment conducted for the General Plan 2030 EIR indicates that Swift Street south of Delaware Avenue does not fall within a mapped existing noise contour. (SOURCE V.1b-DEIR Figures

4.13-1 and 4.13-2). Ambient noise levels are characterized by vehicular traffic and activities along Swift Street and adjoining streets. The nearest sensitive noise receptors are Gateway School to the south of the project site and residential uses located across Swift Street, approximately 55 feet east of the project site.

For multi‐family residential uses, normally acceptable exterior noise levels are 65 dB and conditionally acceptable levels are identified as 60‐70 dB (SOURCE V.1b‐DEIR volume). An interior CNEL of 45 dBA is mandated by the State of California Noise Insulation Standards (California Code of Regulations, Title 24, Part 6, Section T25 28) for multiple‐family dwellings and hotel and motel rooms. Since normal noise attenuation within residential structures with closed windows is about 20 dBA, an exterior noise exposure of 65 dBA Ldn allows the interior standard to be met without any specialized structural attenuation (e.g., dual paned windows) (Ibid.). For typical residential construction (i.e., light frame construction with ordinary sash windows), the minimum amount of exterior to interior noise reduction is at least 20 dBA with exterior doors and windows closed and approximately 15 dBA with windows partially open for ventilation.

Buildings constructed of stucco or masonry with dual‐glazed windows and solid core exterior doors can be expected to achieve an exterior to interior noise reduction of approximately 25‐ 30 dBA (Ibid.).

At the end of 2018, amendments to the State CEQA Guidelines were adopted by the State of California that included changes to the Appendix G environmental checklist, including elimination of questions related to exposure to noise. The questions focus on the potential temporary and permanent noise generated by a project.

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Impact Analysis. the proposed project would result in varying increases in temporary and permanent noise levels as discussed below. The nearest sensitive noise receptors are residential uses located across Swift Street, approximately 55 feet east of the project site.

Temporary Noise Increases. There would be a temporary increase in existing noise levels during demolition, earthwork, and construction of the project, which is anticipated to occur over a period of approximately two years and three months . Construction noise levels would depend on the noise generated by various pieces of construction equipment, the timing and duration of noise-generating activities, and the distance between construction noise sources and noise-sensitive receptors, as well as existing ambient noise levels. The highest noise levels would be generated during demolition and grading, with lower noise levels occurring during building construction and paving. As explained in the General Plan 2030 EIR, construction sound levels would be intermittent and varied through a single day as well as throughout the duration of project construction. In addition, as indicated in the General Plan EIR, the noise levels would decrease with distance from the construction site at a rate of approximately 6 dBA per doubling of distance.

The General Plan 2030 includes goals, policies, and actions that set forth measures to avoid and minimize adverse impacts of increased noise resulting from construction or operation of development projects (HZ3.1.1, HZ3.1.2, HZ3.1.3, and HZ3.1.5). The General Plan 2030 EIR concluded that with implementation of General Plan policies and adherence to City regulations, temporary noise impacts from future development would be less than significant. The General Plan EIR concluded that development accommodated by the plan would result in construction of varying sound levels and duration, but with implementation of General Plan policies and actions that set forth measures to minimize exposure to construction noise levels, the increase in temporary noise levels from construction-related activities would be considered less than significant.

General Plan policies seek to minimize and monitor construction noise (HZ3.1.3, HZ3.1.5).

In particular, the General Plan seeks to ensure that construction activities are managed to minimize overall noise impacts on surrounding land uses (HZ3.1.3). (The General Plan 2030 EIR analyses are included on pages 4.13-20 to 4.13-22 of the Draft EIR volume.) Development projects are reviewed on a case-by-case basis, and typical conditions of approval include limiting the day and times of day during which construction and/or heavy construction can be conducted, provision of notification to neighbors regarding construction schedules, and implementation of a process to receive and respond to noise complaints. These are some of the types of measures that may be required by the City to manage and minimize construction noise impacts of development projects per proposed General Plan Actions HZ3.1.3 and HZ3.1.5 (SOURCE V.1b-DEIR volume).

Construction of the proposed project would result in temporary increases in noise levels that would be variable throughout the construction period. Sensitive noise receptors in the vicinity would experience a temporary increase in noise levels. However, construction sound levels would be intermittent and varied through a single day as well as throughout the duration of project construction, and construction noise levels would decrease with

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distance from the construction site. Overall, construction noise levels would be temporary and short-term, and would fluctuate throughout the construction period with the construction activities producing higher noise levels occurring earlier in the construction phase. Therefore, construction noise would not result in substantial increases in temporary noise levels, and the project would result in a less-than-significant impact regarding temporary noise increases.

Permanent Noise Increases. The project would result in new residential development, which is not a land use that is typically associated with activities that would generate substantial permanent increases in ambient noise levels. Operational noise from the project would include exterior mechanical equipment. The project parking area would be a surface parking lot along the northern portion of the project site. The parking lot would be surrounded by exterior walls along the northern project perimeter which would create a shield to vehicular noise.

The project mechanical equipment would largely be limited to the roof. Mechanical equipment would be enclosed and/or screened in order to attenuate sound from this source and to comply with City regulations. Section 24.14.260 prohibits five dB (dBA) increases of sound levels above the local ambient noise level on a residential property. In addition, Municipal Code section 24.14.220 indicates that no land or building in any district shall be used or occupied in any manner so as to create noise or vibration in such a manner or in an amount as to adversely affect the surrounding area or adjoining premises. Municipal Code section 9.36.010 prohibits offensive noise between the hours of 10 PM and 8 AM, and section 9.36.020 prohibits unreasonably disturbing noises. These regulations are intended to prevent increases in ambient noise levels. The following standard condition of approval will be included in the Project Conditions of Approval.

STANDARD CONDITION OF APPROVAL: All new mechanical equipment and appurtenances, including gas and water meters, electrical boxes, roof vents, air conditioners, antennas, etc. visible from the public way and from adjacent properties, shall be screened with material compatible with the materials of the building and shall be subject to the approval of the Zoning Administrator. Prior to issuance of a building permit, the applicant shall provide documentation confirming that all heat pumps comply with the City’s noise standards.

Net traffic increases resulting from the project would contribute to incremental increases in noise, but would not be of the magnitude to result in a significant impact. The proposed project would result in a net increase of approximately 18 AM peak hour trips and 27 PM peak hour trips, which, when added to existing traffic volumes, would result in a minor increase noise levels by less than 0.5 dB, which is less than the 3-dB increase identified for significant impacts in the General Plan 2030 EIR. Thus, the project would not result in a significant increase in noise levels due to increase vehicle trips.

Therefore, the project would not result in generation of a significant temporary or permanent increase in ambient noise levels, and impacts are considered less-thansignificant impact.

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(b) Vibration. Vibration is an oscillatory motion through a solid medium, in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. Typically, groundborne vibration generated by heavy equipment or traffic on rough roads attenuates rapidly with distance from the source of the vibration so that potential impact areas are confined to short distances. Groundborne vibration generated by construction equipment spreads through the ground and diminishes in magnitude with increases in distance. The effect on buildings located in the vicinity of the construction site often varies depending on soil type, ground strata, and construction characteristics of the receiver building(s). The results from vibration can range from no perceptible effects at the lowest vibration levels, to low rumbling sounds and perceptible vibration at moderate levels, to slight damage at the highest levels.

Construction-related ground vibration is normally associated with impact equipment such as pile drivers, jackhammers, and the operation of some heavy-duty construction equipment, such as dozers and trucks. Vibration decreases rapidly with distance.

Impact Analysis. The project would not result in generation of or exposure to vibration as the proposed residential uses are not known to be sources of vibration. The General Plan 2030 EIR indicates that there were no planned land uses that would be expected to result in generation of groundborne vibration, and that the potential for vibration is mostly associated with construction-related impacts.

Standard construction equipment typically does not generate substantial levels of vibration.

The project geotechnical investigation (SOURCE V.13c) recommends use of deep ground modification, such as rigid inclusions or deep cement soil mixing, or a deep foundation system method, cush as auger cast piles, to provide foundation support due to liquefaction conditions at the site. However, neither of these methods would result in significant vibration levels that might otherwise occur with activities such as pile-driving.

In conclusion, project construction or future residential uses would not result in activities or use of equipment that would create excessive vibration or expose people to excessive vibration and impacts would be less than significant.
(c) Location Near Airport. The closest public airport is the Watsonville Municipal Airport located more than 10 miles south in the City of Watsonville. The Bonny Doon Airport, a private airstrip, is located approximately 9.1 miles north of the project site. The project is not located near a public airport or private airstrip, and therefore would result in no impact.

14. Population and Housing
(a) Population Growth. The City had a population of 62,776 people as of January 1, 2024 (SOURCE V.5). The project‘s proposed 100 residential units would result in an increased population of approximately 224 residents based on the City’s existing average household size of 2.24. With the addition of the project’s residents, the City’s population would total 63,000. This is within the adopted regional population forecast of 72,218 for the City of Santa Cruz for the year 2030 (SOURCE V.3a). Thus, the proposed project is consistent with current regional forecasts and would not substantially induce unplanned population growth. Therefore, this increase in

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population would be within planned growth, and the project would result in a less-thansignificant impact related to population growth. (b) Displacement of People or Housing. No housing units exist on the project site. Therefore, the project would not result in the displacement of people or housing. The project would result in future construction of 100 new residential apartment units, thus creating more housing opportunities in the City. Therefore, the project would result in no impact.

15. Public Services
(a-b, e) Fire, Police and Other Public Services. The project would be served by existing public services. The proposed project would result in an incremental demand for police and fire protection services and other public services provided by the City of Santa Cruz. A recent review of cumulative impacts on City fire and police protection services was conducted as part of an EIR prepared for another proposed residential project located with the City (SOURCE V.2a). The review included the proposed project and cumulative development projects as part of the review and concluded that future police services demand would not lead to the need for new or expanded City Police Department facilities (SOURCE V.2a).

The review found that the City’s Fire Department currently has inadequate space and equipment to meet existing needs, which would be further impacted by cumulative development. Potential expanded or new fire facilities would be located at the existing eastside location of Station 2 and possibly near UCSC. Expansion or new construction would be considered infill development at this site, which is surrounded by development. While existing and cumulative development may require new or physically altered fire protection facilities, locations for expansion or construction are expected to be located within developed areas and were not expected to result in significant physical impacts (SOURCE V.2a).

Thus, the proposed project would have no measurable effect on existing public services in that the incremental increase in demand would not require expansion of any facilities to serve the project. New development would be required to install automatic fire sprinklers and alarms in accordance with City requirements and comply with other Fire Department recommendations regarding access. Therefore, the project’s impact to fire, police and other public services would be less than significant.
(c) Schools. Schools and educational services are provided to City residents by the Santa Cruz City Schools District (SCCS), as well as a number of private schools, for grades K through 12.

There are five elementary schools, and the secondary district includes two middle schools, three comprehensive high schools, a continuation school, an independent studies program and a home school program with a combined existing student population of approximately 6,134 students (SOURCE V.7). According to the District’s updated 2024 Developer Fee Justification Study for the Santa Cruz School Districts, District facilities have the capacity to accommodate 6,262 students (SOURCE V.7).

Impact Analysis. The project would result in future construction of 100 residential units. The proposed residential units would be served by the SCSD. Development of the project would

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result in an estimated student enrollment increase of approximately 21 students throughout all grades.3 Schools serving the project site (Bay View Elementary School, Mission Hill Middle School, and Santa Cruz High School) have adequate capacity to serve the project based on current enrollments4 and school capacities identified in the General Plan 2030 EIR (SOURCE V.1b-DEIR volume). Expansion of existing facilities would not be required to serve the project, and therefore, the project would result in a less-thansignificant impact related to school facilities.

In accordance with Section 65995(h) of the California Government Code, the project would be required to pay school impact fees to the SCSD at the time of the building permit issuance. These fees are used to mitigate impacts associated with long-term operation and maintenance of school facilities. The project applicant’s fees would be determined at the time of the building permit issuance and would reflect the most current fee amount established by the SCSD. School fees from residential and commercial uses would help fund necessary school service and facilities improvements to accommodate anticipated population and school enrollment growth within the SCSD service area and would allow for the SCSD to allocate these funds as deemed necessary. Pursuant to Government Code Section 65995, payment of development fees is “full and complete mitigation” for impacts on schools. Therefore, the project would result in a less-than-significant impact on public schools.
(d) Parks. The City manages, maintains and operates more than 1,700 acres of parks and open space lands, including various community/recreational facilities The City has responsibility for management, maintenance, and operation of over 1,700 acres of parks and open space lands, and various community/recreational facilities, and oversees development of new parks and improvements within City-owned parks, open space, and community facilities. The nearest recreational facilities to the project site include: 1) Sergeant Derby Park, located adjacent to the western perimeter of the project site, 2) Natural Bridges State Beach, located south of Delaware Avenue adjacent to Swanton Boulevard, 3) Garfield Park, located south of Pendegast Avenue between Almar Avenue and Seaside Street, and 4) West Cliff Drive and beaches a few blocks south of the project site.

The General Plan 2030 established per capita goals for neighborhood and community parks to ensure adequate parks throughout the City. The City’s standard is to provide neighborhood parks at a ratio of 2.0 acres per 1,000 people with a service radius of ½ mile. The City’s goal for community parks is 2.5 acres per 1,000 people with a service radius of 1.5 miles. According to the Parks Master Plan 2030, the City is currently underserved for neighborhood and community park space. To meet existing goals, a total of 67 acres of parks would need to be created to meet the forecasted population growth associated with the City of Santa Cruz General Plan 2030 growth estimates (SOURCE V.2f).
3 Based on an average generation rate of .2132 students per household per the SCSDs 2024 Developer Fee Justification Study for the Santa Cruz School Districts, Schoolworks Inc., June 2022, page 5. 4 California Department of Education. 2024. California School Directory-School Profiles. Available online at https://www.cde.ca.gov/SchoolDirectory/.

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The Parks Master Plan does not specify locations for new parks or recreational facilities, but some of the Plan’s policies and actions support new and expanded recreational uses and/or facilities. For many recommended new or expanded uses, specific site locations are not identified in the Master Plan, and, in some cases, additional study is recommended in order to identify suitable locations. The Parks Master Plan supports consideration of recreational facilities, identified below, after additional studies are conducted in the future to further evaluate potential uses and site locations. In addition, new, expanded or renovated facilities or structures are recommended in the Parks Master Plan at a variety of existing parks throughout the City, including San Lorenzo and DeLaveaga Parks (SOURCE V.2f).

Impact Analysis. The project would result in future construction of 100 residential units with an estimated population of approximately 224 new residents based on city-wide average household size. Project residents would use a range of neighborhood and regional parks in the vicinity and surrounding area. The increased population resulting from the Project would not, in and of itself, trigger the need for a new park as it does not meet the City’s standard for a new neighborhood park, and existing nearby parks would be adequate to serve the Project’s residents.

While the City’s Parks Master Plan 2030 identifies an existing deficit of 67 acres of park land throughout the City, this is an existing condition that cannot be corrected by any one individual development project, especially given limited availability of land for new parks.

The City’s 2030 Parks Master Plan identifies park needs and improvements to existing parks and recreational facilities but does not propose creating additional park land. The Master Plan includes improvements to existing facilities, and no new parks or facilities are specifically identified. The projects and recommendations in the Parks Master Plan are intended to support the City’s resident and visitor population. Furthermore, the Parks Master Plan identifies potential new facilities and uses that could be developed throughout the City after further study and also recommends a broad range of improvements and upgrades for existing facilities and potential new facilities, which would be in support of the Plans goals and policies to provide adequate parks and recreational facilities throughout the City for its population.

Thus, the proposed project and associated residential demand for parks would not be of a level that would require new or physically altered parks, and the project’s impact regarding parks and new for new or expanded facilities is less-than-significant.

16. Recreation
(a) Use of Existing Parks and Recreational Facilities. As indicated above, the proposed project would result in an increase in residential population with an incremental increased demand for, and use of, public parks and recreational facilities, and there are several nearby parks that could serve project residents. The incremental increased use of public parks resulting from the project would be spread throughout a number of parks and facilities throughout the day. The level of use by future project residents would not be considered substantial in that it is not expected that park or recreational facility use as a result of the project would lead to substantial

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deterioration of any one park facility. Therefore, impacts on existing parks and recreational facilities would be less than significant.

Furthermore, the City imposes a “Parks and Recreation Facilities Tax” (pursuant to Chapter 5.72 of the Municipal Code) on new residential development within the City, payable at the time of issuance of a building permit. The collected taxes are placed into a special fund, and “shall be used and expended solely for the acquisition, improvement and expansion of public park, playground and recreational facilities in the City” (Municipal Code section 5.72.100). (b) New Recreational Facilities. The project does not include public recreational facilities.

Therefore, the project would result in no impact related to potential significant impacts resulting from provision of new park or recreational facilities.

17. Transportation/Traffic
(a) Conflict with Circulation Plan, Policy, or Ordinance. The project site is located on Swift Street between Delaware Avenue and Modesto Avenue. Project access will be provided via an existing driveway on Delaware Avenue. The project will also be accessed through a new easement through the neighboring industrial land use to the north, connecting Swift Street and Delaware Avenue. A total of 119 parking spaces are proposed for the development on a new surface parking lot. Additionally, the project applicant is proposing improvements in the Swift Street public right-of-way and frontage, including construction of a sidewalk per City standards.

The local roadway network serving the project site includes Highway 1 (State Route 1), Mission Street, Swift Street, and Delaware Avenue. The Santa Cruz Metro Transit District (METRO) has bus route service along Delaware Street, Mission Street, and Swift Street. Local METRO bus stops are located at the intersection of Delaware Avenue and Swift Street, approximately 200 feet north of the project site (Route 20) and along the intersection of Mission Street and Swift Street (Routes 18 and 40), approximately 0.38 mile north of the project site. Pedestrian and bicycle facilities are located in the area, including the multi-use path along the Santa Cruz Coastal Rail Trail. The project includes 129 bicycle parking spaces and 2 bicycle “fix-it” stations for residents and visitors. Swift Street is developed with Class II bike lanes, and the project vicinity has multi-use paths, transit stops, and City-sponsored bike share program.

The General Plan 2030 includes goals, policies and actions that set forth comprehensive measures to reduce vehicle trips, increase vehicle occupancy, encourage use of alternative transportation modes, and promote alternative-sustainable land use patterns, all of which would help reduce vehicle trips, avoid and minimize adverse impacts related to traffic. In particular, several policies and actions that call for implementation of road, pedestrian, bicycle and transit improvements through the City’s Capital Improvement Program and other sources (M2.1.3, M2.3.2, M3.2.2). The proposed project is an infill, mixed-use development project that is encouraged in the General Plan and is located in area designated for higher density that is proximity to transit, bicycle and pedestrian facilities. Thus, the project is consistent with City policies that promote sustainable land use patterns, mixed-use development, and consolidation of parcels along transit corridors to encourage use of other transportation modes (LU4.2, 1, LU4.2.1, LU3.7, LU3.8, CD3.3, and M1.1.

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The City’s General Plan strives to maintain the established “level of service” D or better at signalized intersections (M3.1.3). “Level of service” (LOS) is typically used to evaluate traffic operations, in which operating conditions range from LOS “A” (free-flowing) to LOS “F” (forcedflow). Caltrans endeavors to maintain a target LOS at the transition between LOS C and D on State highway facilities. The City’s General Plan also accepts a lower level of service and higher congestion at major regional intersections if necessary improvements would be prohibitively costly or result in significant, unacceptable environmental impacts (M3.1.4).

According to a project-specific Trip Generation Analysis, the project would result in a net increase of 559 daily weekday trips, including an increase of 18 AM peak hour trips and 27 PM peak hour trips. These increases would not result in substantial changes in roadway operations or LOS due to the minimal volume spread out over the day and hour and at different intersections. The proposed project is located in proximity to bus, bicycle, and pedestrian facilities and close to neighborhood businesses and activity centers on the westside, such that alternative transportation modes like would be used for some of the project’s daily trips, and the project amenities supports use of other transportation modes.

The project would not conflict with any policies, programs or regulations addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities. The project is located in a developed area near transit, services, and recreation with a sidewalk and bike lane network. The project provides onsite bicycle parking facilities in accordance with City requirements. The project location is in proximity to transit, bicycle, and pedestrian facilities, which would facilitate use of alternative modes of transportation, consistent with General Plan transportation policies and goals. Therefore, the project would not conflict with plans or policies regarding the City’s circulation system. Additionally, the project would be required to pay the City’s traffic impact fee at the time of building permit issuance. These fees are used to address needed traffic improvements at key intersections for circulation and also for alternative transportation improvements; 15 percent of the collected traffic impact fees are allocated to alternative transportation improvements. Therefore, the project would result in no impact with regards to potential conflicts with circulation policies. (b) Conflicts with State CEQA Guidelines. CEQA Guidelines section 15064.3, subdivision (b) codifies the switch from LOS to vehicle miles traveled (VMT) as the metric for transportation analysis pursuant to state legislation adopted in 2013. In September 2013 Governor Brown signed Senate Bill 743 which made significant changes to how transportation impacts are to be evaluated under CEQA. SB 743 directs the Governor’s Office of Planning and Research (OPR) to develop a new metric to replace LOS as a measure of impact significance and suggests vehicle miles travelled as that metric. According to the legislation, upon certification of the guidelines, automobile delay, as described solely by LOS shall not be considered a significant impact (Section 21009(a)(2)). SB 743 also creates a new CEQA exemption for certain projects that are consistent with the regional Sustainable Communities Strategy.

CEQA Guidelines section 15064.3(b) indicates that development projects that exceed an applicable VMT threshold of significance may indicate a significant impact. Generally, projects within one-half mile of either an existing major transit stop or a stop along an existing high22.1630 SCCS Educator Housing Initial Study -63- December 2024
quality transit corridor should be presumed to cause a less-than-significant transportation impact. Projects that decrease vehicle miles traveled in the project area compared to existing conditions should be presumed to have a less than significant transportation impact.

In accordance with the amended CEQA Guidelines, the City has transitioned from intersection LOS formerly used for traffic impact analyses to VMT as the metric for determining potentially significant impacts. The City adopted a VMT transportation threshold on June 9, 2020 in accordance with CEQA and state requirements, as well as VMT Implementation Guidelines that are consistent with the State’s SB 743 Guidelines. The threshold generally establishes that a project exceeding a level of 15 percent below the County-wide average VMT may result in a significant transportation impact. The City’s adopted SB 743 (VMT) Implementation Guidelines include potential Transportation Demand Management (TDM) measures to help achieve VMT reduction. Updates to the City’s Guidelines were adopted on June 14, 2022.

The City’s guidelines to determine whether a land use project is within the VMT threshold includes a screening process in which situations are identified under which projects are determined to not have a significant impact and further VMT analysis is not required. The guidelines require that each distinct land use for a mixed-use project be analyzed separately unless they are determined to be insignificant to the total VMT. The guidelines also state that housing projects are expected to cause a less-than-significant impact on VMT if a high percentage of the project is affordable, as determined by the City. Furthermore, projects, or portions of a project, that meet the screening criteria do not require a CEQA transportation analysis, and such projects, or portions of a project, will have a non-significant CEQA transportation impact based on their project location and characteristics. According to the City’s guidelines, projects that would not be expected to result in a significant VMT impact and that are screened out from further transportation impact review include:
• Small projects that generate fewer than 110 trips per day; • Projects near high quality transit: within a ½ mile of a major transit stop or a high quality transit corridor with a combined service interval frequency of 15 minutes or less during the AM and PM peak hours;
• Local-serving retail if a single store is less than 50,000 square feet or project is a localserving project as determined by the City; • Affordable housing projects that provide a high percentage of affordable housing as determined by the City;
• Local essential service, including day care center, public K-12 schools, police or fire facility, medical/dental office building, government offices, and supportive housing types (assisted living, permanent supportive housing, memory care, etc.); • Map based screening; and
• Redevelopment projects that do not result in a net increase in VMT (SOURCE V.2d).

Impact Analysis. City staff reviewed the project in accordance with the City’s adopted guidelines. The proposed project meets the screening criteria because it is located in a VMT Efficient Area based on the Santa Cruz County Residential Screening Map, and, therefore,

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the project is located in an area that produces VMT per capita that is at least 15-percent below the Countywide average.

In addition, the project is within a ½ mile of an existing major transit stop a bus line, located on Mission Street, with service interval frequency of 15 minutes or less during both morning and afternoon peak periods. Under existing conditions, transit service on Mission Street is provided by Santa Cruz METRO with Route 18. The service internal frequency during morning and afternoon peak periods is 15 minutes for this route. According to State VMT guidelines, projects would not qualify for this screening threshold if they include more parking for use by residential, customers, or employees than required by the jurisdiction.

The proposed project would provide 119 parking spaces, which is less than the City’s code requirement of 177 parking spaces. This amount of proposed parking spaces is allowed by AB 2097 which prohibits public agencies from imposing parking minimums within ½ mile of major transit stops. For these reasons, the project qualifies as a ‘Project Near High Quality Transit’ and would not result in a significant impact related to VMT based on the City’s adopted threshold and guidelines.

As a result of the above, according to the City’s guidelines, the project would not result in a significant impact related to VMT based on the City’s adopted threshold and guidelines and is screened out from further VMT impact review. Therefore, the project would result in a less-than-significant impact related to VMT and would not conflict or be inconsistent with CEQA Guidelines section 15064.3.
(c, d) Design-Safety and Emergency Access. The project has been designed in accordance with standard City requirements, and there are no access designs that would substantially increase hazards. The project would provide three vehicular access points: two from Swift Street to the east and one from Delaware Avenue, through an adjacent property and new easement to the north. Entry to the project site would be controlled through automatic sliding vehicular gates.

Each entry point would accommodate inbound and outbound vehicles. Turnaround areas for emergency vehicles are proposed at the northwestern and southeastern portions of the project site. The project was reviewed by the City’s transportation engineering staff of the Public Works Department. Furthermore, the project would be designed in accordance with City police and fire department requirements and would provide for adequate emergency access. For these reasons, the project would not result in increased hazards related to project design, would not provide inadequate emergency access, and would result in no impact related to project design that could result in substantial increases in hazards.

18. Tribal Cultural Resources
(a-b) Tribal Cultural Resources and Consultation. The California Public Resources Code section 21084.2 establishes that “[a] project with an effect that may cause a substantial adverse change in the significance of a tribal cultural resource is a project that may have a significant effect on the environment.” Assembly Bill (AB) 52 requires that California lead agencies consult with a California Native American tribe that is traditionally and culturally affiliated with the geographic area of a proposed project, if so requested by the tribe. AB 52 also specifies that a project with an effect that may cause a substantial adverse change in the significance of a tribal cultural

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resource (TCR) is a project that may have a significant effect on the environment. Defined in Section 21074(a) of the Public Resources Code, a TCR is a site feature, place, cultural landscape, sacred place, or object, which is of cultural value to a California Native American tribe and is either listed in or eligible for listing in the California Register of Historical Resources or a local historic register, or the lead agency, at its discretion, chooses to treat the resource as a TCR.

The City of Santa Cruz received formal requests for notification on proposed projects pursuant to Public Resources Code (PRC) section 21080.3.1 from two Native American tribes traditionally and culturally affiliated with the City. The City received the requests from the Amah Mutsun Tribe in April 2022 and from the Costanoan Rumsen Carmel Tribe in May 2024. Both of these tribes requested notification of development projects within the City pursuant to AB 52 requirements codified in Public Resources Code section 21080.3.1.

Pursuant to PRC section 21080.3.1, the City provided notification of the Project to the Amah Mutsun Tribal Band and the Costanoan Rumsen Carmel Tribe on November 8, 2024 (email) and on November 11, 2024 (mailed letters), which was within 14 days of determining the Project application was complete. No Native American tribe has contacted the City of Santa Cruz and requested consultation. As described in Section VI.6 above, an archaeological investigation of the site was conducted and the project would not result in impacts to known resources.

Although the project is located within an area considered to have low potential for archaeological sensitivity or archaeological resources, there is the potential for the discovery of unknown pre-contact archaeological resources or historic archaeological resources during soildisturbing construction. While no known TCRs are located on the project site, it is possible that ground-disturbing activities would have the potential to encounter unknown subsurface resources, the discovery of which would be subject to procedures outlined in City regulations as described in section VI.6. Therefore, the proposed project would result in no impact to tribal cultural resources.

19. Utilities and Service Systems
(a) Relocation or Construction of Utilities. The project would be served by existing utilities. The project would not require the relocation or construction of new utilities, other than extension of utility lines to serve the project, and, there would be no impact. (b) Water Supply. The project site is located within the service area of the City of Santa Cruz Water Department, which serves an approximate 20-square-mile area. The service area includes the entire City of Santa Cruz, adjoining unincorporated areas of Santa Cruz County, a small part of the City of Capitola, the University of California at Santa Cruz campus that is within City limits and coastal agricultural lands north of the City. Water is treated at the City’s Graham Hill Water Treatment Plant (GHWTP), except for groundwater, which is treated as part of the Beltz well system.

Water Supplies. The City’s water system relies predominantly on local surface water supplies, which include the North Coast sources (Liddell Spring and Laguna, Majors, and Reggiardo Creeks), the San Lorenzo River (Felton Diversion, Tait Diversion, and Tait Wells), and Loch Lomond Reservoir. Together, these surface water sources represent approximately 95% of the

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City’s total annual water production. The balance of the City’s supply comes from groundwater, all of which is extracted from the Beltz Well system the Santa Cruz in the Santa Cruz Mid-County Groundwater Basin (SOURCE V.2e). During the past ten years, the North Coast sources represented 20 percent of the total water supply, the San Lorenzo River represented 58 percent, Loch Lomond Reservoir (Newell Creek) represented 16 percent, and Beltz Well system contributed the remaining 6 percent. (SOURCE V.2b).

Water Supply Augmentation Strategies. Since 2015, the City of Santa Cruz has been pursuing its Water Supply Augmentation Strategy (WSAS) developed by the Water Supply Advisory Committee (WSAC) as described in the 2020 UWMP. The overarching goal of the WSAS is to provide significant improvement in the sufficiency and reliability of the City water supply. The WSAS portfolio elements include the following:
▪ Element 0: Demand Management. Additional water conservation with a goal of achieving an additional 200 to 250 MGY of demand reduction by 2035 by expanding water conservation programs.
▪ Element 1: Transfers and Exchanges. Passive recharge of regional aquifers by working to develop agreements for delivering surface water to the Soquel Creek Water District and/or the Scotts Valley Water District so they can rest their groundwater wells, help the aquifers recover, and potentially store water for use by the City in dry periods. ▪ Element 2: Aquifer Storage and Recovery (ASR). Active recharge of regional aquifers by using existing infrastructure and potential new infrastructure in the Purisima aquifer in the Soquel-Aptos Basin (now referred to as the Santa Cruz Mid-County Groundwater Basin), in the Santa Margarita/Lompico/Butano aquifers (now referred to as the Santa Margarita Groundwater Basin) in the Scotts Valley area, or in both to store water that can be available for use by the City in dry periods.
▪ Element 3: Recycled Water or Desalination. A potable water supply using advancedtreated recycled water as its source as a supplemental or replacement supply in the event the groundwater storage strategies described in Element 1 and Element 2 prove insufficient to meet the goals of cost-effectiveness, timeliness, or yield. In the event advanced-treated recycled water does not meet the City’s needs, desalination would become Element 3.

The Santa Cruz Water Department has been actively pursuing these recommendations since 2015 and continues to make steady progress. Additionally, in collaboration with the Soquel Creek Water District (District), the City is currently working on the Santa Cruz Mid-County Regional Water Resources Optimization Study. The primary purpose of the Optimization Study is for the District and City to collaboratively identify and evaluate potential opportunities to optimize select projects and management actions (PMA) identified in the Basin’s Groundwater Sustainability Plan to most effectively achieve/maintain groundwater basin sustainability.

Additionally, the Study is evaluating the PMAs for their ability to improve regional water supply reliability. Projects that are the focus of the Optimization Study include:
▪ Water transfers/exchanges between the District and the City ▪ City’s ASR Project
▪ District’s Pure Water Soquel Project (SOURCE V.2b).

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In 2022, the Water Department worked extensively with the Water Commission to complete a comparison of the water supply augmentation strategies identified in the WSAS, to develop a water supply augmentation policy, Securing Our Water Future (SOWF), since adopted by City Council, and to initiate the Water Supply Augmentation Implementation Plan (WSAIP) as part of the final phase of implementing the WSAS. The SOWF policy provides a comprehensive framework to guide selection and incremental implementation of necessary water supply augmentation projects. It defines how water supply projects will be selected and provides estimated high-level yield and costs associated with water supply augmentation projects. The policy direction includes a provision that the volume of water needed to meet the reliability goal be reviewed and potentially revised no less frequently than every five years based on ongoing research and monitoring of the impacts of climate change on local water conditions.

This “adaptive management” approach is critically important to support appropriate timing of implementation of water supply augmentation projects (SOURCE V.2b).

The City also has embarked on an ambitious capital investment program, the Santa Cruz Water Program, to secure the City’s future water supply portfolio, to improve reliability and resiliency in the face of climate change, and to address aged infrastructure. Major investments are planned in the coming years to meet these goals. Some elements of the program will help contribute to the WSAS and support water supply reliability such as improvements to the Graham Hill Water Treatment Plant, raw water pipeline improvements, and Tait diversion as reported in a recent City evaluation (SOURCE V.2b).

Existing and Future Water Demand. The City’s 2020 UWMP reports that until the early 2000s, the general trend in the City of Santa Cruz water system use was one in which water use rose roughly in parallel with account and population growth over time, except during two major drought periods in the late 1970s and the early 1990s. Around 2000, this pattern changed and system demand began a long period of decline, accelerated by rate increases, drought, economic downturn, and other factors.

In 2015, after two years of water rationing, annual water use fell to a level of about 2.5 billion gallons, similar to the level experienced during the 1970s drought. In 2023, demand was still at a similar level as 2015, about 2.5 billion gallons, despite several years of above long-term average rainfall from 2016 and 2023. While demand did rebound following droughts in the 1970s and 1980s, demand has not rebounded to pre-drought conditions following 2014, contrary to previous projections. Today, even with 30 percent population growth since the 1980s, the City is using less water than in the 1980s due to conservation efforts including plumbing code changes and water efficient appliances and landscapes. In 2023, water demand in the service area was slightly below 2,500 MGY (SOURCE V.2b).

In September 2024, the Water Department updated its demand projections to reflect known cumulative development projects and anticipated growth within the Water Department’s service area, including the proposed Project. The results indicate that demand could reach 2,800 MGY by the year 2035 and reach approximately 3,000 MGY year by 2045, which is about

8.6 percent higher than forecast in the 2020 UWMP due to higher projected levels of housing development, particularly with respect to multi-family and accessory dwelling unit (ADU)

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residential development. For reference, the estimated projected demand in 2045, 3,000 MGY, is approximately equal to the City’s water use in 1968 (SOURCE V.2b).

Water Supply Availability. The water supply reliability and drought risk assessments included in 2020 UWMP found water supply to be adequate in normal and single dry years, but show a potential lack of adequate supplies during near-term multiple consecutive dry years. Santa Cruz has had periodic water shortages for the last several decades, driven by droughts. Yet, even with 30 percent population growth since the 1980s, the City is using less water now as it was then (SOURCE V.2b).

The City’s supply problem has been caused by cyclical shortfalls in rain, exacerbated by a longterm lack of ability to capture and store rainfall – features of the emerging climate change phenomenon of “weather whiplash” that results in so-called “normal” rainfall years becoming a thing of the past. Because of climate change, the City’s water supply problem must be solved regardless of whether or not the City grows. To address supply vulnerability, the City is implementing its WSAS developed and recommended by the WSAC, in addition to ongoing water conservation, including the development of ASR facilities, transfers and/or exchanges with neighboring water districts, and increased use of recycled water (SOURCE V.2b).

The City updated its water supply analysis with the updated 2024 demand projections. The data, methods, and basis for assumed water shortage conditions are consistent with those in the City’s 2020 UWMP (SOURCE V.2b). The City utilized the Confluence® model to analyze the variability of water supplies to determine potential water supply shortages, which the City has used to support water supply planning activities since 2003; this model was also used to generate the results for the 2010, 2015, and 2020 UWMP. The model accounts for the variation in demand both within and between years, the availability of water from various sources, and the capacity of infrastructure to pump and treat the water. The City is in the process of transitioning to a new water system model developed by University of Massachusetts’ Hydrosystem Research Group. Before the Confluence® model was retired from use by the City, model runs for the current scenario were completed under projected demands of up to 2,900 MGY which form the basis for this analysis (SOURCE V.2b).

The City is safeguarding against future water shortages by actively implementing future water projects as described above. Consistent with the WSAS and 2020 UWMP, the following assumptions about future water projects were used in the updated water supply analysis:
▪ In 2025, the City will have implemented proposed water rights modifications, including implementation of the Agreed Flows which are protective of local anadromous fisheries, as described in the Santa Cruz Water Rights Project Final EIR ▪ In 2030, the City will have implemented the following components of the WSAS and planned infrastructure projects:
o ASR in the Santa Cruz Mid-County Groundwater Basin and/or the Santa Margarita Groundwater Basin, sized for up to 4.5 million gallons per day (MGD) injection and

8.0 MGD extraction as described in the Santa Cruz Water Rights Project Final EIR, o Improvements to the Tait Diversion on the San Lorenzo River as described in the Santa Cruz Water Rights Project Final EIR and as included in the Santa Cruz Water Program,

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SCCS Educator Housing Initial Study -69- December 2024
o Facility improvements at the Graham Hill Water Treatment Plan that will allow treatment of more turbid water as included in the Santa Cruz Water Program, and o Replacement of major transmission pipelines on the North Coast and the NCP as included in the Santa Cruz Water Program.

Water supply was modeled for an average/normal year, single dry year and a consecutive fiveyear dry period over a 20-year period. The results indicate that in the near term (2025) with proposed water rights modifications assumed but before implementation of ASR and planned infrastructure projects, City projects having sufficient water supply available in normal years and single dry years. Under near-term multi-year drought conditions, with proposed water rights modifications assumed but before implementation of the ASR and planned infrastructure projects, available supplies would meet projected demand in years one through three of the multi-year drought scenario, but would fall short of demand by four percent in year four, and 23 percent in year five (SOURCE V.2b).

In the 2030 – 2040 analysis period, assuming implementation of the City’s proposed water rights modifications, ASR and planned infrastructure improvements, the City projects having sufficient water supply available in normal years, single dry years, and multiple dry years to serve anticipated demand (SOURCE V.2b).

In 2045, the analysis shows a three percent deficit across all year types. A three percent shortage is considered a negligible amount in the scale of this twenty-year supply and demand analysis. Furthermore, although the demand projected for 2045 is 3,000 MG, the maximum demand modeled in the Confluence® model before it was retired from use by the City was 2,900 MG. While this results in an apparent three percent shortage in all 2045 year-type scenarios, it is anticipated that the modeled shortages would have been smaller or absent if Confluence® model runs had been completed using 3,000 MG as the maximum demand. That is, if the model had been instructed to keep supplying water up to 3,000 MG, rather than stopping when the modeled demand of 2,900 MG was satisfied, the system would likely have had additional water available which the model did not supply since the set demand of 2,900 MG was already met.

Moreover, implementation of the City’s SOWF Policy and its adaptive management approach would ensure that future water supply projects would be fine-tuned to eliminate any minor projected future shortages (SOURCE V.2b).

The City also modeled water supply under a climate change scenario, which indicated that in the near term (2025) in this climate change scenario with proposed water rights modifications but before implementation of ASR and planned infrastructure projects, the City projects having sufficient water supplies available in normal years. In a near-term single dry year in this climate scenario, a four percent shortage would result. In the multi-year drought scenario, available supplies would meet projected demand in years one through three, but would fall short of demand by 19 percent in year four and 15 percent in year five (SOURCE V.2b).

In the 2030 – 2040 analysis period, with implementation of ASR and planned infrastructure projects, available supplies would meet projected demand in normal and single dry years. In the multi-year drought scenario, available supplies would meet projected demand in years one

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SCCS Educator Housing Initial Study -70- December 2024
through four of the multi-year drought scenario, but would fall short of demand in year five by four percent (2030, 2035) to seven percent (2040) (SOURCE V.2b).

In 2045, the analysis shows a three percent deficit across a normal year, single dry year, and years one through four of the multi-year dry sequence, increasing to ten percent in year five.

Although the demand projected for 2045 is 3,000 MG, the maximum demand modeled in the Confluence® model before it was retired from use by the City was 2,900 MG. While this results in an apparent three to ten percent shortage in the 2045 scenarios, it is anticipated that the modeled shortages would have been smaller or absent if Confluence® model runs had been completed using 3,000 MG as the maximum demand. That is, if the model had been instructed to keep supplying water up to 3,000 MG, rather than stopping when the modeled demand of 2,900 MG was satisfied, the system would likely have had additional water available which the model did not supply since the set demand of 2,900 MG was already met (SOURCE V.2b).

While a shortage is projected under these scenarios with implementation of the ASR and planned infrastructure projects, the City is currently planning for water supply augmentation through its SOWF Policy and WSAIP that would meet projected supply under plausible worstcase conditions. Moreover, implementation of the adaptive management approach from SOWF Policy would ensure that future water supply projects would be fine-tuned to eliminate any projected future shortages (SOURCE V.2b).

The SOWF was structured to incorporate changing demands and climate projections over time and includes a reliability goal based on adequate supply to meet all customer demand. As noted in the SOWF, expected increases in demand in the water service area are not expected to drive the size or timing of needed water supply augmentation projects. Longer dry periods under climate change conditions are understood to be the primary challenge driving the need to augment the City’s water supply (SOURCE V.2b).

Impact Analysis. The proposed project would result in increased potable water demand, which would not be substantial and could be served by existing City water supplies, which would be adequate to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years. Therefore, the impact is less than significant.

The proposed project would result in development of 100 new multi-family residential units that could result in a water demand of approximately 3.2 MGY based on multi-family residential (MFR) water demand rates used in the 2020 UWMP. The project water demand represents a negligible amount (approximately 0.01 percent) of the total existing and 2,800 MGY of future water demand projected for the year 2030 with the 2024 demand projections.

The proposed project and other development projects that are under construction, approved, or have pending development applications were considered in the 2024 water demand projections and updated water supply evaluation. Thus, the Project and other foreseeable development water demand is within the water demand accounted for in this update.

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SCCS Educator Housing Initial Study -71- December 2024
As indicated above, the 2024 updated water demand projections and water supply evaluation indicate that in the near term (2025), the City projects having sufficient water supply available in normal years and single dry years. Under near-term multi-year drought conditions, available supplies would meet projected demand in years one through three of the multi-year drought scenario but would fall short of demand by four percent in year four, and 23 percent in year five. In the 2030-2040 analysis period, the City would have sufficient water supply available in normal years, single dry years, and multiple dry years to serve anticipated demand. In 2045, the analysis shows a negligible three percent deficit across all year types (SOURCE V.2b).

Under the climate change scenario in the near term (2025), the City projects having sufficient water supplies available in normal years. In a near-term single dry year in the climate scenario, a four percent shortage would result. In the multi-year drought scenario, available supplies would meet projected demand in years one through three, but would fall short of demand by 19 percent in year four and 15 percent in year five (SOURCE V.2b).

Under the climate change scenario in the 2030-2040 analysis period, available supplies would meet projected demand in normal and single dry years. In the multi-year drought scenario, available supplies would meet projected demand in years one through four of the multi-year drought scenario, but would fall short of demand in year five by four percent (2030, 2035) to seven percent (2040). Under the climate change scenario in 2045, the analysis shows a three percent deficit across a normal year, single dry year, and years one through four of the multi-year dry sequence, increasing to ten percent in year five. Although the demand projected for 2045 is 3,000 MG, the maximum demand modeled in the Confluence® model before it was retired from use by the City was 2,900 MG. While this results in an apparent three to ten percent shortage in the 2045 scenarios, it is anticipated that the modeled shortages would have been smaller or absent if Confluence® model runs had been completed using 3,000 MG as the maximum demand (SOURCE V.2b).

In the near-term, the projected shortfall would require aggressive reduction savings according to the City’s Water Shortage Contingency Plan (2021a). As required by California Water Code and to manage risks due to water supply shortages that can be expected in the future, the 2020 UWMP includes a Water Shortage Contingency Plan that addresses how the City’s water system would be managed during a water shortage emergency that arises as a result of drought, which could result in required customer water use reductions when shortfalls occur. With implementation of planned water augmentation projects and strategies and after the year 2030, potential shortfalls are projected to be a negligible four percent (SOURCE V.2b).

During periods of dry years and drought, water customers could be subject to water curtailment as enacted by the City. A multiple-dry year scenario could require substantial curtailment by all water customers until a number of planned water supply projects and strategies are expected to be implemented by 2030. The Project is expected to be constructed and occupied in 2028, which would be within the period of projected nearterm water shortages during the fifth year of a drought. However, the Project’s estimated water demand is very minimal compared to the total projected water demand in 2030

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SCCS Educator Housing Initial Study -72- December 2024
(approximately 0.04 percent of the total demand). If a shortage and subsequent curtailment were to occur, the Project’s demand when spread out among all users would not be a substantial increase as to cause further curtailment than would already be required throughout the service area. Therefore, the impact of increased water demand on water supplies due to the Project is considered less than significant as there are sufficient supplies from existing sources to serve the project during normal and single-year dry periods, and the Project’s minimal demand during multiple-year droughts would not be substantial in comparison to total demand (SOURCE V.2b).

Project users would be required to comply with required curtailment orders if imposed as would all of the service area customers. In addition, the Project would be subject to City development standards and requirements that include requirements for installation of water conservation fixtures and landscaping for new construction. In addition, the project would pay the required “System Development Charge” for the required new service connection. This charge as set forth in Chapter 16.14 of the City’s Municipal Code is intended to mitigate the water supply impacts caused by new development in the City of Santa Cruz water service area, and the funds are used for construction of public water system improvements and conservation programs.

The City also considered availability of water supplies to serve the project and other “reasonably foreseeable future development,” which the City determined to be projects that are under construction or have been approved. The 2024 updated water demand projections and water supply analysis considered all cumulative development projects, including pending permit applications as well as approved projects and projects under construction. Thus, based on results of the 2024 demand projections and analysis explained above, the demand from the Project and reasonably foreseeable development would not result in more stringent contingency measures than already anticipated for a multiple dry year period.

Therefore, water supplies with implementation of planned augmentation projects are sufficient to serve the project and reasonably foreseeable development, and the impact regarding water supply availability is less-than-significant. (c) Wastewater Treatment Capacity. The project would be served by the City’s wastewater treatment facility. The proposed project would result in an increase in wastewater flows of approximately 0.006 million gallons per day based on average water use. This would not be considered substantial in that the City’s existing remaining wastewater treatment capacity available to the City’s service area is approximately 4.0 million gallons per day, which is more than adequate to serve the project. Thus, increased wastewater generated by the project would result in a less-than-significant impact on wastewater treatment capacity. (d-e) Solid Waste Disposal. Solid waste collection and disposal services, including recycling services, are provided to City residents, businesses, and institutions within the City’s boundaries by the City of Santa Cruz. The City’s Resource Recovery Facility (RRF) is located approximately 3miles west of the City off Highway 1 at 605 Dimeo Lane. The site covers 100 acres with 67 acres available for disposal use. The RRF only accepts municipal solid waste and serves as a

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SCCS Educator Housing Initial Study -73- December 2024
sorting facility to remove any recyclable or composting materials. The recycling center accepts a variety of recyclable materials.

The RRF is permitted to receive a total of 10,484,325 cubic yards (cy) of solid waste, including wood waste, tires, sludge (biosolids), mixed municipal wastes, metals, inert wastes, industrial wastes, green materials, dead animals, and construction/demolition wastes. As of July 31, 2021, the landfill had a remaining capacity of approximately 5.3 million cy (approximately 51%) and is anticipated to reach maximum final capacity in the year 2054. In 2023, 65,687 tons of solid waste were disposed of at the RRF, which is an average of approximately 180 tons per day (approximately 34% of daily capacity) (SOURCE V.2a).

Impact Analysis. The proposed project would result in development of 100 residential units. based on estimated solid waste generation rates provided by CalRecycle of 3.6 pounds per unit per day to 8.6 pounds per multi-family residential unit per day (SOURCE V.2a), the proposed project could generate approximately 360-860 pounds of waste per day or less than one ton per day. the City’s RRF has a remaining capacity of approximately 51% or approximately 5.3 million cy of solid waste. Daily throughput in 2023 averaged 34% of the RRF’s permitted daily capacity of 535 tons (SOURCE V.2a). Thus, adequate landfill capacity is available during the timeframe of the proposed project and beyond to serve development accommodated by the project. Given this, the City’s RRF would have adequate capacity to accommodate the net increase in solid waste generated by the project, and the impact would be less-than-significant.

20. Wildfire
(a) Emergency Plans. Existing and proposed access to the project site is from Swift Street. The project includes construction of 100 new residential apartment units and a new driveway for access to the project site but would not include any changes to existing public roadways that provide emergency access to the site. Therefore, the project would not substantially impair an adopted emergency response or evacuation plan and would result in no impact. (b, d) Exacerbate Wildfire Impacts. The projectsite is not located in or near a state responsibility area nor a high fire hazard area as identified in the City’s General Plan 2030 (SOURCE V.1b-DEIR Figure 4.6-1). The project site is located in a developed urban area and would not significantly increase exposure to wildland fire hazards or exacerbate wildfire risks as the site is not located adjacent to or in proximity to a wildfire hazard area. Therefore, the project would result in no impact.
(c) Installation of Infrastructure. Infrastructure such as roads, fuel breaks, emergency water sources, power lines or other utilities may exacerbate fire risk or may result in temporary or ongoing impacts to the environment. The project would not require installation of infrastructure that would exacerbate fire risks. Utility connections to the project site would be underground within an existing developed urban area. Therefore, the project would not expose people or structures to a significant risk related to wildfires, and there would be no impact. See also section VI.9(g) above.

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SCCS Educator Housing Initial Study -74- December 2024

21. Mandatory Findings of Significance
(a) Quality of the Environment. The proposed project would have no significant effect on cultural resources or result in elimination of important examples of major period of California history or prehistory with implementation of mitigation measures. The project would not result in impacts to biological resources with imposition of the City’s standard conditions of approval for pre-construction nesting bird surveys. The project would not degrade the quality of the environmental or otherwise substantially adversely affect fish and wildlife habitats or threaten to eliminate a plant or animal community.
(b) Cumulative Impacts. Cumulative development with the proposed project would result in a net increase of approximately 3,630 new residential units, including the proposed project, a net decrease of approximately 40,000 square feet of commercial uses, a net increase of approximately 46,500 square feet of industrial uses, a decrease in office space and an increase of approximately 400 hotel rooms based on a cumulative analysis included in an EIR for another proposed residential project within the City (SOURCE V.2a). The analysis identified a potentially significant cumulative impact regarding water supply, but no other significant cumulative impacts to which the proposed project would contribute were identified (SOURCE V.2a).

Cumulative development, including the proposed project, was included in the 2024 updated water demand projections, which also included updated projections within the City’s water service area. Total water demand within the City’s water service area would increase from a current demand of approximately 2,600 MGY to a forecasted demand of 3,000 MGY in 2045 based on the 2024 updated demand projections. Without augmented water supplies, cumulative development and associated water demand during dry periods would result in a potentially significant cumulative impact on water supplies. Water demand resulting from cumulative development projects, would lead to potential near-term shortfalls (2025-2030) depending on the level of development construction, and also negligible shortfalls (approximately four percent) in the fifth year of a multi-year drought under climate change forecasts to the year 2040 and in normal, single dry year and multiple dry years by the year 2045, with a slightly higher shortfall in the fifth year of a multi-year drought. This is considered a significant cumulative impact without implementation of the City’s water supply augmentation projects and strategies. The City is currently planning for water supply augmentation through its SOWF Policy and Water Supply Augmentation Implementation Plan, which the City anticipates would meet projected supply under worst-case conditions (SOURCE V.2b). Furthermore, projected increases in water demand within the service area are not expected to drive the size or timing of needed water supply augmentation projects. Longer dry periods under the climate change scenario is the primary factor driving the need to augment the City’s water supply (SOURCE V.2b).

The proposed project would contribute to significant cumulative impacts related to water supply availability. However, the project would be subject to City requirements for installation of water-conserving fixtures and landscaping in accordance with current Municipal Code and building requirements. Under multi-year drought conditions, the Project, like other City customers, could be subject to water use restrictions. The increase in water demand due to the Project would not substantially exacerbate water supply reliability in the future or during a

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SCCS Educator Housing Initial Study -75- December 2024
drought because the amount of additional demand when spread across all service area customers would not result in any noticeable increase in the timing or extent of curtailment in customer use that would otherwise be implemented during drought conditions.

In addition, the Project would pay the required “System Development Charge” that is required for a new or upgraded service connection or where a project adds new residential uses. This charge, as set forth in Chapter 16.14 of the Municipal Code, funds public water system improvements, and is assessed so projects pay the proportional share of the costs of new and existing water facilities necessary to meet the demand resulting from new or enlarged water services. This charge is intended to mitigate the water supply impacts caused by new development in the City’s water service area, and the funds are used for construction of public water system improvements and conservation programs. Payment of the System Development Charge and implementation of other water conservation measures would mitigate the Project’s contribution to cumulative water supply impacts. Therefore, the project’s incremental contribution to a significant cumulative water supply impact would not be cumulatively considerable.
(c) Substantial Adverse Effects on Human Beings. No environmental effects have been identified that would have direct or indirect adverse effects on human beings.

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SCCS Educator Housing Initial Study -76- December 2024

INTENTIONALLY LEFT BLANK

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CITY OF SANTA CRUZ
Mitigated Negative Declaration
The Administrator of Environmental Quality of the City of Santa Cruz has prepared this Mitigated Negative Declaration for the following described project:

Project: Santa Cruz City Schools Educator Housing Application No.: CP 24-0104 Project Location: 313 Swift Street (APN 003-16-132) in the City of Santa Cruz, California Project Description: The proposed project consists of a Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit for demolition of select existing features and proposed construction of a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project, encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of five heritage trees.

Applicant: Santa Cruz City Schools
Applicant Address: 133 Mission Street, Suite 100, Santa Cruz, CA 95060 The City of Santa Cruz Department of Planning and Community Development has reviewed the proposed project and has determined that the project, based on the Initial Study attached hereto, will not have a significant effect on the environment. An Environmental Impact Report is not required pursuant to the California Environmental Quality Act of 1970. This environmental review process and Mitigated Negative Declaration is done in accordance with the State CEQA Guidelines and the local City of Santa Cruz CEQA Guidelines and Procedures.

The following mitigation measures will be incorporated into the project design or as conditions of approval, to ensure that any potential environmental impacts will not be significant.

Impact
Hazardous Materials. Project
construction could result in release of
and/or exposure to hazardous
materials.

FRM ENV-07
Mitigation
MITIGATION MEASURE HAZ-1 : Prepare and
implement a soil removal action plan for additional
investigation and/or removal of the elevated TPHd in
near surface soil (upper 3 to 4 feet) in the vicinity of boring B10 (near the former concrete ramp used for
vehicle/tank maintenance/repairs) and elevated arsenic
in near surface soil (upper 3 to 4) in the vicinity of
boring B4.

MITIGATION MEASURE HAZ-2: Conduct additional
soil gas sampling to confirm if the detected
concentrations of benzene and chloroform are present
in soil gas at the site that may cause an excessive
vapor intrusion risk to the proposed school
development (benzene and chloroform concentrations
were detected slightly above published residential
screening level values which are used for proposed
school sites). In lieu of additional soil gas sampling, a chemical resistant vapor barrier can be installed below 1 (Rev. 3/26)

22.1645
the proposed onsite buildings during future
development to mitigate the potential vapor intrusion
concern.

MITIGATION MEASURE HAZ-3: Prepare and
implement a soil and groundwater management plan to
address handling and management of impacted soil
and/or groundwater that could be potentially
encountered during construction activities The detected concentrations of TPHd, TPHmo, TCE, arsenic, and
chromium in soil and/or groundwater may require
special handling/testing and increase construction cost if soil/groundwater is required to be exported/disposed of offsite.
~~=---==-===~ ;,2/20/2r:

Lee Butler Date I I
Administrator of Environmental Quality
City of Santa Cruz, California
FRM ENV-07 2 (Rev. 3/26)

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FRM ENV-20 (Rev. 2-12)

MITIGATION MONITORING AND REPORTING PROGRAM
Application #: CP24-0104
Address: Santa Cruz City Schools (SCCS) Educator Housing Applicant: Santa Cruz City Schools
This Mitigation Monitoring and Reporting Program (MMRP) for Application No. CP24-0104, located at 313 Swift Street, has been prepared pursuant to the California Environmental Quality Act (CEQA – Public Resources Code, Section 21000 et seq.), the CEQA Guidelines (Cal. Code Regs., Title 14, Chapter 3, Sections 15074 and 15097). A master copy of this MMRP shall be kept in the office of the Zoning Administrator and shall be available for viewing upon request.

Project Description: The proposed project consists of a Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit for demolition of select existing features and proposed construction of a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project, encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of five heritage trees.

This MMRP includes mitigation measures in the Mitigation Monitoring and Reporting Matrix on the following pages that correspond to the final Mitigated Negative Declaration (MND) for the project. The matrix lists each mitigation measure or series of mitigation measures by environmental topic. For each mitigation measure, the frequency of monitoring and the responsible monitoring entity is identified. Mitigation measures may be shown in submittals and may be checked only once, or they may require monitoring periodically during and/or after construction. Once a mitigation measure is complete, the responsible monitoring entity shall date and initial the corresponding cell, and indicate how effective the mitigation measure was.

If any mitigation measures are not being implemented, the City may pursue corrective action.

Penalties that may be applied include, but are not limited to, the following: (1) a written notification and request for compliance; (2) withholding of permits; (3) administrative fines; (4) a stop-work order; (5) forfeiture of security bonds or other guarantees; (6) revocation of permits or other entitlements.

Monitoring Program Cost:

I HEREBY AGREE TO PAY THE CITY MONITORING FEES, AND IMPLEMENT THESE

MITIGATION MEASURES, AT A MINIMUM, IN THE DESIGN, CONSTRUCTION, AND MAINTENANCE OF THE PROJECT.

Applicant’s signature Date
1/24/25

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313 Swift Street-Santa Cruz City Schools Educator Housing Mitigation Monitoring and Reporting Program January 2025 Page 1
Mitigation Measure Implementation
Actions Responsibility Timing Requirements
Reporting
Requirements
Verification of
Compliance
Hazardous Materials
MITIGATION MEASURE HAZ-1: Prepare and implement a soil
removal action plan for additional investigation and/or removal of the elevated TPHd in near surface soil (upper 3 to 4 feet) in the vicinity of boring B10 (near the former concrete ramp used for vehicle/tank maintenance/repairs) and elevated arsenic in near surface soil (upper 3 to 4) in the vicinity of boring B4. • Include measure as
Condition of
Approval.
• Implementation
actions are specified
in the mitigation
measure.
• Applicant is
responsible for hiring
qualified consultant
for additional
investigation and soil
removal action plan if
needed and providing
results to City
Planning and
Community
Development
Department for
review.
• Applicant responsible
for including any soil
removal requirements
in construction
specifications.

Prior to issuance of
building permit and
site excavation to
complete additional
investigation and/or
soil removal action
plan and during
construction for any
soil removal activities.

Report on
findings of
additional
investigation.

MITIGATION MEASURE HAZ-2: Conduct additional soil gas
sampling to confirm if the detected concentrations of benzene and chloroform are present in soil gas at the site that may cause an excessive vapor intrusion risk to the proposed school development (benzene and chloroform concentrations were detected slightly above published residential screening level values which are used for proposed school sites). In lieu of additional soil gas sampling, a chemical resistant vapor barrier can be installed below the proposed onsite buildings during future development to mitigate the potential vapor intrusion concern.
• Include measure as
Condition of
Approval.
• Implementation
actions are specified
in the mitigation
measure.

Applicant is responsible
for conducting additional
sampling or including
barrier as specified in
building plans and
providing results to City
Planning and Community
Development
Department for review.

Prior to issuance of
building permit and
site excavation.

Report on
findings of
additional
sampling.

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313 Swift Street-Santa Cruz City Schools Educator Housing Mitigation Monitoring and Reporting Program January 2025 Page 2
Mitigation Measure Implementation
Actions Responsibility Timing Requirements
Reporting
Requirements
Verification of
Compliance
MITIGATION MEASURE HAZ-3: Prepare and implement a soil and groundwater management plan to address handling and
management of impacted soil and/or groundwater that could be potentially encountered during construction activities The detected concentrations of TPHd, TPHmo, TCE, arsenic, and chromium in soil and/or groundwater may require special handling/testing and increase construction cost if soil/groundwater is required to be exported/disposed of offsite.
• Include measure as
Condition of
Approval.
• Implementation
actions are specified
in the mitigation
measure.
• Applicant is
responsible for hiring
qualified consultant
for additional
investigation and soil
removal action plan if
needed and providing
results to City
Planning and
Community
Development
Department for
review.
• Applicant responsible
for including any soil
removal requirements
in construction
specifications.

Prior to issuance of
building permit and
site excavation to
complete additional
investigation and/or
soil removal action
plan and during
construction for any
soil removal activities.

Report on
findings of
additional
investigation.

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Compliance with Objective Design Standards for Multifamily Housing - Proposed Educator Workforce Housing Project, 313 Swift Street (CP24-0104) Municipal Code Section Design Category Municipal Code Provision Project Proposal and Code Consistency Complies? Objective
Standard
Variation
Requested?
Walkability
SCMC 24.12.185(4)(a)
i. In all areas of the city, where a project site includes an existing public street, alley, path, paseo, trail, or other public pedestrian connection, this public connection will be maintained or relocated within the project site.

The project proposes a new formal pedestrian/bicycle trail to replace the informal pathway connecting Swift Street to Sergeant Derby Park. They new path will occur in approximately the same location as the existing path.

Yes No
ii. Existing frontage improvements including any bike lanes or sidewalks will be maintained, repaired, or upgraded as dictated by any applicable area plan, or, in the case where no area plan applies, the requirements of subsection (13), Ground Floor Design, or the requirements for sidewalk widths as defined in Chapter 15.20. Where any inconsistency between regulatory documents is present, the widest applicable sidewalk requirement shall apply.

The project frontage includes a new sidewalk of eight feet in width to replace the existing sidewalk.

Yes No
iv. All new pedestrian or bicycle connections not including required street-side improvements such as sidewalks and on-street bike lanes shall be at least ten feet wide and a minimum of eighty percent open to the sky. Standards for public or private streets shall be met as required by department of public works design guidelines.

The new pedestrian/bicycle path connecting Swift Street with Sergeant Derby Park is proposed as five feet in width per requirements of the City's Public Works Department.

Yes No
v. Development or redevelopment proposals on properties with street frontage shall be required to install new or improve existing sidewalks in accordance with the requirements of any area plan, the requirements of subsection (13), Ground Floor Design, and the requirements for sidewalk widths as defined in Chapter 15.20, as applicable. Where any inconsistency between standards exists, the wider sidewalk standard shall apply.

The project frontage includes a new sidewalk of eight feet in width to replace the existing sidewalk.

Yes No
Public Frontages
SCMC 24.12.185(5)
a. Where a common residential lobby is provided, the lobby shall be accessed from a public frontage.

The proposed residential lobby is accessible via pathways connecting to Swift Street. Yes No c. Regardless of the street frontage length of a project, properties abutting a public street, alley, path, paseo, trail, or other public connection on a side or rear property line shall incorporate a connection between the parcel street frontage and that existing public connection with any new development or redevelopment proposal.

These connections shall allow clear passage during daylight or business hours as applicable, whichever is longer. This standard shall not apply to corner lots.

The project proposes a new formal pedestrian/bicycle trail to replace the informal pathway connecting Swift Street to Sergeant Derby Park. They new path will occur in approximately the same location as the existing path.

Yes No
d. All new pedestrian or bicycle connections not including required street-side improvements such as sidewalks and on-street bike lanes shall be at least 10 feet wide and a minimum of 80 percent open to the sky. Standards for public or private streets shall be met as required by Department of Public Works design guidelines.

The new pedestrian/bicycle path connecting Swift Street with Sergeant Derby Park is proposed as five feet in width per requirements of the City's Public Works Department and widens to 10 feet in width at its connection to the improved sidewalk.

Yes No
d. Uses for active frontage shall be subject to the following standards: Yes No ii. Mechanical rooms shall not be placed along the public frontage. Mechanical rooms shall be located adjacent to a driveway or parking area.

Yes No
g. Ground floor residential units that face a public frontage shall provide an entry facing toward the public frontage that provides access into an entry area, living area, kitchen, or hallway (not a bathroom or bedroom, with the exception of studios).

The proposed floor plan provides ground-floor entryways oriented toward the property frontage; portions of the building oriented perpendicular to Swift Street provide ground-floor access facing the right-hand side property line, directly accessed from a pedestrian pathway accessible from Swift Street. All ground-floor building entries allow direct access into a foyer/entry area in each residentail unit.

Yes No
h. Entries facing a public frontage shall include a minimum of 48 square feet of flat, unenclosed, covered area, which may be a projection, or inset, or a combination of the two. (See Planning Code Section 24.12.120 for allowed projections into setback areas.)
Ground-floor patio areas each measure approximately 90 square feet in area. Yes No Parking Location and
Screening

22.1650
Municipal Code Section Design Category Municipal Code Provision Project Proposal and Code Consistency Complies? Objective
Standard
Variation
Requested?
SCMC 24.12.185(6)
a. Off street parking and loading facilities, including bike parking requirements, shall be provided as required in Section 24.12.200 et seq
The project proposes bicycle parking including 100 Class I (long-term) bicycle parking spaces and 25 Class II (short-term) bicycle parking stalls, consistent with Municipal Code requirements.

Yes No
b. For projects including five or more dwelling units, parking shall not be located in the area between the front lot line and a line extended horizontally from the plane of the predominant building face to the edges of the lot. See Figure 5.

Vehicular parking proposed replaces existing vehicular parking in approximately the same locations. Although vehicular parking is located between the predominant building face and the adjacent public right-of-way, screening of such parking is provided by the presence of existing buildings to be retained. The majority of parking would be situated parallel to the right-hand side property line, situated parallel to, and, in part, behind the predominant building face.

Yes No
d. The entire perimeter of a surface parking area that fronts onto a side or rear yard, except the width of the access, shall be screened by buildings, evergreen buffer landscaping to a minimum depth of 3 feet, or fences that are at least 75 percent opaque. Fences or hedges shall not be greater than, nor allowed to exceed 8 feet in height on an interior side yard or rear yard, or 3.5 feet in height in a front or exterior side yard. (Also see Section 24.12.280.)
New perimeter landscaping, minimally 3' in depth, surrounds all parking; existing buildings additionally provide screening from surrounding properties and public rights-of-way.

Yes No
f. Driveways and approaches shall comply with the standards set forth in Municipal Code Sections 15.20 and 24.12.280 and the driveway approach standard detail included with the public works standards in effect at the time of design review and shall be designed in accordance with AASHTO Green Book sight distance standards.

Ingress/egress to driveway approaches may be limited based on the results of a Transportation Study.

Conditions of Approval require compliance with the referenced objective standard. Yes No c. Refuse/Recycling Storage Facility: Enclosures for refuse bins or dumpsters are required of all new multi-family and mixed-use residential projects with three or more housing units or any commercial development as set forth in the City of Santa Cruz Department of Public Works Refuse Container Storage Facility Standard Design Policy
The project provides refuse/recycling enclosures reviewed by the City's Public Works Department for consistency with relevant standards.

Yes No
Roof Form
SCMC 24.12.185(10)
a. Buildings shall be designed with variation in roof form. The number of required roof forms shall be calculated at a ratio of at least one roof form for every thirty feet of frontage and shall be located within fifteen feet of the predominant building face on all building frontages. On corner lots or double-frontage lots, standards for variation in roof form will apply to all frontages. See Figure 8.

The building design conforms to the referenced objective standard. The most easterly façade consists of two distinct sections, neither of which exceeds 30 feet in length. The easterly elevation of the middle section ("bar") of the building provides ten roof forms for a linear distance of approx. 180 feet.

Yes No
ii. A change in roof form must be combined with a change in height of at least 3 feet, a horizontal change in plane of at least 4 feet, or a change in roof pitch. See Figure 10 for examples. Changes in roof form shall not exceed allowed building heights, as defined by the underlying zone district.

The building design conforms to the referenced objective standard. The building includes four stories. Changes in parapet height of the most easterly facade and easterly elevation of the middle section of the building provide variations in parapet height of 3 feet each.

Yes No
v. For the purposes of calculating the number of required roof forms on a building, each increment of 30 feet of building frontage requires an additional roof form, counted by rounding up to the next whole number. For example, a frontage of 31 feet would be required to provide two roof forms. However, there is no maximum dimension for any one roof form, nor are roofs required to be designed in 30-foot increments.

The building design conforms to the referenced objective standard. The most easterly façade consists of two distinct sections, neither of which exceeds 30 feet in length. The easterly elevation of the middle section ("bar") of the building provides ten roof forms for a linear distance of approx. 180 feet.

Yes No
v. For flat roofs and flat roofs with decorative parapets, changes in roofline must be accompanied by a minimum 2-foot change in height relative to the adjacent roof form. For buildings that are three stories or taller, the minimum change in height shall be 3 feet. This change in height shall be measured to the top of the parapet, where present. Changes in roof form shall not exceed allowed building heights, as defined by the underlying zone district. Figure 10: Combining and Counting Roof Forms- seems to apply; roof plan must be provided to demonstrate compliance The building design conforms to the referenced objective standard. The building includes four stories. Changes in parapet height of the most easterly facade and easterly elevation of the middle section of the building provide variations in parapet height of 3 feet each.

Yes No

22.1651
Municipal Code Section Design Category Municipal Code Provision Project Proposal and Code Consistency Complies? Objective
Standard
Variation
Requested?
a. Where no other modulation controls apply (e.g., an Area Plan), building faces that are longer than 30 feet wide shall be articulated in one of the following three ways.

Yes No
i. Provide a horizontal change in plane for every 30 feet building face, rounded up to the next whole number (e.g., a frontage of 31 feet would be required to provide two changes in plane). As shown in Figure 11, the change in plane must be at least 4 feet deep and 6 feet wide, and must be open to the sky; seems to apply; site plan must be provided to demonstrate compliance
The project design demonstrates compliance with this objective standard. The most easterly façade includes distinct elements, one of which is 30 feet or less in width, while the other is articulated with a projecting stairwell. The easterly elevation of the middle section of the building includes 7 changes in plane for span of approximately 123 feet.

Yes No
ii. Provide a horizontal change in plane for every 30 feet of building face, rounded up to the nearest whole number (e.g., a building face of 31 feet would be required to provide two changes in plane). As shown in Figure 12, the change in plane must be at least 2 feet deep and 6 feet wide, and be combined with a change in material; The project design demonstrates compliance with this objective standard. The most easterly façade includes distinct elements, one of which is 30 feet or less in width, while the other is articulated with a projecting stairwell. The easterly elevation of the middle section of the building includes 7 changes in plane for span of approximately 123 feet. Each change in plane measures greater than 6 feet in width and over 3 feet in depth.

Yes No
iii. Provide a horizontal change in plane at an interval of 50 feet or less. As shown in Figure 13, the change in plane must be at least 6 feet deep and 12 feet wide, and be combined with a change in material. When implemented as building notches, such notches may contain balconies, as long as the railing is at least 70 percent seethrough or transparent.

Project design demonstrates compliance with this objective standard as detailed above. Yes No Building Modulation
SCMC 24.12.185(11)
b. Building faces that are less than 30 feet wide are not required to have a change in plane incorporated into their design.

Project design demonstrates compliance with this objective standard as detailed above. The most easterly façade measures approximately 30 feet in width.

Yes No
c. Projections from the building face including balconies, awnings, signs, and decorative elements are not considered to be changes in plane.

Yes No
a. 24.12.185.15 Architectural Detail Goal: To highlight the prominence of corner buildings along Corridors, ensure that buildings have an appropriate level of detailing, and ensure that building facades convey the qualities of substantiality and depth.

Yes No
Architectural Detail
SCMC 24.12.185(14)
a. Buildings that are mixed-use and/or three stories in height or greater shall visually differentiate the ground floor from the floors above by one or more of the following:

Yes No
i. a change in material; and/or Yes No
ii. a change in plane; and/or e
Project design demonstrates compliance. Ground floor is recessed compared to floors above. Yes No iii. a cornice line, belly band, or similar horizontal element. Yes No SCMC 24.12.185(15)
Building Materials
a. Building materials shall be selected according to the following criteria: Yes No i. The following materials are acceptable for use on building faces: tile, brick, glass, metal (except as prohibited below), painted or sealed wood, concrete, stucco, plaster, adobe, and stone (engineered or natural), and living walls (as defined).

Project demonstrates compliance. Building facades include painted stucco and horizontal lapped fiber cement with visible texture.

Yes No
ii. Unarticulated or flat panelized materials (such as metal, cement board, or GFRC panels) are prohibited on public frontages but may be incorporated on other building faces. Panels for modular and pre-fabricated construction are allowed (including sandwich panels).

Project demonstrates compliance. Fiber cement composite board includes visible texturing. Yes No

22.1652
Municipal Code Section Design Category Municipal Code Provision Project Proposal and Code Consistency Complies? Objective
Standard
Variation
Requested?
b. Buildings shall incorporate two or more of the accepted materials listed above or as approved in the design of each building face. No single material may make up more than 85 percent of any building face. This can include materials for building decoration (e.g., awnings, louvers, balconies, cornice lines, or windowsills), but does not include fenestration (glass, frames, or other elements of windows and doors). - applies; applicant must demonstrate compliance
Yes No
c. Vinyl windows are prohibited in the following circumstances: Yes No i. Any mixed-use or residential buildings more than three stories in height. - applies; plans must be revised to demonstrate compliance
Project demonstrates compliance. All windows to be aluminum. Yes No ii. On a building face oriented toward a public street other than an alley of a mixed use or residential building three stories in height or less.

Project demonstrates compliance. All windows to be aluminum. Yes No d. At building corners, except for living walls, all materials shall wrap around the corner to a depth of at least 4 inches. This includes corners of insets, reveals, or changes in plane that are 4 inches or greater in depth, as with a balcony, ground floor entry, or change in plane. See examples shown in Figure 19.

Project demonstrates compliance; no corner material wraps less than 4 inches as included in submitted elevations and project note.

Yes No
Lighting

24.12.185.17
Goal: To ensure that public areas of buildings are lit for wayfinding and safety, while minimizing impacts of glare, light trespass, and light pollution in order to help make new development Dark Sky friendly.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
a. Individual exterior luminaires shall be shielded to direct light downward and shall not exceed 1,260 lumens. Exterior light fixtures shall utilize light sources with a color temperature that does not exceed 3000 Kelvin.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
i. A luminaire is considered to be fully shielded if it is constructed and installed in such a manner that all light emitted by the luminaire, either directly from the lamp or a diffusing element, or indirectly by reflection or refraction from any part of the luminaire, is projected below the horizontal plane through the luminaire's lowest light-emitting part.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
b. Outdoor lights shall not blink, flash, flicker, or change intensity (excluding motiondetecting lights).

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
c. Lighting shall be provided at parking lots, pedestrian paths, outdoor gathering spaces, building entries, and any other pedestrian-accessible areas.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
d. Lighting of outdoor service, loading, and storage areas shall not be visible from the street or adjacent properties.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
e. Rooftop lighting shall be set back at least 12 feet from the edge of any building face that is oriented towards any R-district.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
f. The height of luminaires shall not exceed 15 feet above grade for all luminaires other than those in parking areas or decorative sconces as allowed under F. 3.

Architectural Detail.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No
g. Building faces shall be illuminated such that surfaces located at least 10 horizontal feet away from building entries shall have at least 66 percent less luminance than surfaces within 10 horizontal feet of building entries. Compliance shall be demonstrated with a lighting plan.

Project demonstrates compliance as required per Conditions of Approval added. Yes, as conditioned
No

22.1653

PLANNING COMMISSION

AGENDA REPORT
DATE: January 31, 2025
AGENDA OF: February 6, 2025
ITEM NO: CP24-0104 313 Swift Street
RECOMMENDATION: That the Planning Commission recommend to the City Council acknowledgment of the environmental determination and approval of a Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to allow a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of six (6) Heritage trees, on a site located in the PF/CZ-O (Public Facilities/Coastal Zone Overlay) zone district, based on the findings listed below and Conditions of Approval listed in Exhibit “A.”
PROJECT DATA:

Property Owner: Santa Cruz City School District APN: 003-161-32 Applicant: Bogard Construction with EHDD and Studio Vara Application Type: Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to allow a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of six(6) Heritage trees, on a site located in the P-F/CZ-O (Public Facilities/Coastal Zone Overlay) zone district.

Zoning: P-F/CZ-O (Public Facilities/Coastal Zone Overlay) zone district Project Consistency: Consistent with approval of permits General Plan: CF (Community Facilities)
Project Consistency: Consistent with General Plan designation with approval of permits

22.1654

AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 2
Land Use: - existing: School district property, including existing, approximately 3,308 square-foot preschool/day care center, 2,077 square-foot office building, two modular (temporary/portable) buildings, and shipping containers - proposed: Multifamily educator workforce housing project encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modification
- in area: Industrial buildings (north), Gateway School (south), residential uses (east), and Sergeant Derby Park (west)
Lot Area: Gross lot area: Approximately 4.08 acres
Environmental Review: Initial Study/Mitigated Negative Declaration Planning Staff: Timothy Maier, Senior Planner

SITE DESCRIPTION/BACKGROUND
Site and proposed project
The subject site comprises a flat, generally rectangular lot of approximately 4.08 gross acres, surrounded by industrial buildings to the north, Gateway School to the south, single-family residences to the east, and varied uses, including industrial buildings and Sergeant Derby Park, to the west. The property lies approximately 0.25 mile east of Natural Bridges State Beach and approximately 0.3 mile north of the Pacific Ocean. Access to the site currently occurs via a drive aisle and pedestrian pathways from its easterly frontage along Swift Street, as visible in the below aerial photograph.

On February 6, 2024, staff of the Planning Department and personnel of Santa Cruz City Schools (SCCS) convened to discuss the proposed project, including the scope of work and conceptual design, as well as potential entitlement pathways. Staff later met with the project architects on February 27, 2024 to further review a more refined project design and have engaged in ongoing correspondence since.

Project Site
Figure 1: Site and Vicinity Map

22.1655

AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 3
On April 10, 2024, the Planning Department received a Preapplication (CP24-0073) for review of a proposed project encompassing removal of the existing modular buildings and demolition of current site features and for the proposed construction of a multifamily workforce housing project including a new, three-story building containing approximately 80 residential units intended to house school district personnel, with modifications to the site, including installation of approximately 127 parking spaces, new landscaping, and associated site improvements. Following submittal of the Preapplication, the project scope of work was revised to encompass a fourth story and an additional 20 apartment units (for a total of 100 residential units), and, on May 30, 2024, the Preapplication was deemed complete.

On June 27, 2024, the applicant submitted a formal application (CP24-0104) for the project as currently proposed. Following several resubmittals in response to staff comments, the formal application was deemed complete on October 31, 2024. A Preapplication (CP24-0120) pursuant to California State Senate Bill 330 (SB330), originally submitted on July 22, 2024, merited completeness on December 2, 2024. Overall plan review incorporates an evaluation of the submitted design relative to the City’s Objective Design Standards for Multifamily Development.

RESOURCES AND CONSTRAINTS
 Archaeology: An Archaeological Assessment, prepared by Patricia Paramoure Archaeological Consulting dated April 18, 2023, includes an assessment of the impact of the proposed project to archaeological resources potentially located at the subject site. A second archaeological investigation voluntarily submitted, a Phase 1 Cultural Resource Inventory prepared by Albion Environmental, Inc., dated May 2023, presented similar findings. Results of both investigations reveal no evidence of precolonial or historic-era artifacts and no occurrence of archaeological deposits on the subject site, and both studies predict low potential for discovery of unknown archaeological resources during planned project construction.  Arborist Report: An arborist report prepared by Nigel Belton, Consulting Arborist, dated May 24, 2023, inventoried the 17 Heritage trees in the project area; the arborist report recommends preservation of 11 trees and removal of six. Conditions of approval require mitigation replanting in a ratio of 2 trees, minimally 24-inch box-size each, for each tree removed.  Noise Evaluation: A noise evaluation, prepared by Smith, Fause, and McDonald, Inc. (undated) was submitted for the proposed project to evaluate potential noise impacts associated with the proposed scope of work and design. A condition of approval has been added, requiring consistency with the submitted noise evaluation including the use of sound rated walls, windows, and floor/ceiling assemblies.
 Geotechnical Report: A site-specific geotechnical and groundwater field exploration and evaluation report, prepared by Moore Twining Associates, Inc. February 14, 2024, declares that the project site holds a moderate potential for liquefaction, including seismic settlement of approximately 3 to 4 inches in earthquakes and similar events when water-saturated soil or sediment temporarily loses strength and behaves in a manner similar to a fluid. Conditions of approval require compliance with the reports’ recommendations and submittal of an update to correspond with the project scope of work as currently proposed.  Parking: The property is located within one-half mile of a major transit stop, and vehicular parking is therefore no longer required to be provided on-site. A discussion of proposed modifications to existing parking capacity follows.
 Coastal Zone: The subject site falls within the Coastal Overlay zone, Exclusion Area A. As a project undertaken by a public agency (school district), per City of Santa Cruz Municipal Code Section 24.08.230.2, the project does not satisfy the criteria qualifying for exclusion from attainment of a Coastal Permit, which therefore must be obtained.

22.1656

AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 4
 Phase I Environmental Site Assessment: A Phase I Environmental Site Assessment (ESA), prepared by Moore Twining dated June 21, 2023, describes the results of field investigation including olfactory observations of petroleum hydrocarbon contamination in the central portion of the project site. The Phase I ESA recommended completion of further soil, groundwater, and soil vapor assessment.
 Phase II Environmental Site Assessment: Pursuant to the recommendations of the Phase I ESA, a Phase II Environmental Site Assessment, prepared by Moore Twining and dated October 22, 2024, was prepared. That study recommends the completion of additional soil gas sampling to assess whether concentrations of benzene and chloroform present in soil gas at the site may cause an excessive vapor intrusion risk to the proposed project, or, in lieu of additional soil gas sampling, installation of a chemical resistant vapor barrier below the proposed buildings would alternatively serve to mitigate the potential vapor intrusion concern. Conditions of approval require compliance with such recommendations.
 Trip Generation Memorandum: A Trip Generation Memorandum dated May 29, 2024, and a subsequent memorandum dated October 25, 2024, prepared by Fehr and Peers transportation consultants, provide transportation analyses related to the proposed project. The transportation analysis predicts the scope of work to generate fewer than 50 net new trips during the AM and PM peak hours and, in keeping with the City of Santa Cruz Transportation Study Requirements for Development (2021), the project does not warrant the preparation of an additional Transportation Impact Study (TIS).
 Parking: No vehicular parking capacity is required to be provided at the subject site per Assembly Bill (AB) 2097 and section 24.12.220 of the Zoning Ordinance, as the entire property falls within a half-mile of a major transit facility. Nevertheless, the proposed project includes 119 parking spaces in order to satisfy the realistically-anticipated vehicular parking demand of, on average, 1.2 spaces per residential unit as predicted by the submitted Trip Generation Memorandum referenced above.
 Bird-Safe Development Standards: Approximately one-half the project site, enveloping its westerly portion, falls on land in which the City’s Bird-Safe Development Design Standards pertain. A condition of approval has been added requiring the project to comply with said standards.
 Biotic Resources: The subject site falls outside areas mapped for sensitive biological resources per General Plan 2030; however, the northeasterly corner of the site occurs with an area mapped as habitat potentially supportive of monarch butterfly habitat per General Plan 2005, with which the project must demonstrate compliance. Biotic consulting firm Ecosystems West has conducted a review, deeming potential impacts to monarch butterfly habitat and overwintering as negligible.

Conditions of approval require submittal of a formal biotic report to document such findings and ensure compliance with the consultant’s recommendations, including use of vegetation with the capacity to support monarch butterfly populations.

Public Outreach Meeting
Pursuant to the City’s Public Outreach Policy for Planning Projects, a community engagement meeting (hosted via Internet video conference) was held on May 6, 2024. Approximately 43 members of the community attended, including the property owner/applicant, project architects, owners and occupants of units surrounding the project site, and residents from surrounding neighborhoods throughout the City.

Participants offered diverse feedback, ranging from concerns regarding impacts of the project to loss of available on-street parking capacity and expectation for worsened neighborhood traffic, to remarks related to provision of affordable housing, queries regarding tenant selection criteria and ongoing housing

22.1657

AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 5
opportunities prospective future tenants of the development, and similar topics. Overall, attendee reactions ranged from mild concern to outright support.

Entitlements Required
The proposed project requires a number of entitlements, including the following, which necessitate a recommendation from the Planning Commission prior to final action by the City Council:
a. Planned Development Permit – required for consideration of the proposed land use; the General Plan Land Use designation of CF (Community Facilities) envisions land identified with this classification as, “existing and potential community facilities, including schools, government offices, community buildings such as the Civic Auditorium, sewer and water facilities, and the City landfill. Also applies to land used by State highways.” Residential use is not included among the categories of land uses encompassed by the CF General Plan Land Use designation; however, provision of multifamily residential use to accommodate housing of school district personnel for long-term retention of employees clearly supports the school district’s mission of educating students. The P-F (Public Facilities) zoning district specifies categories of uses principallypermitted and conditionally-permitted. Per City of Santa Cruz Municipal Code Section 24.10.1770, “government facilities; local, state, and federal” and “school, public” constitute classes of land use allowing for consideration via discretionary review, again, without residential use listed among them. A Planned Development Permit “provides variation on district regulation, where appropriate, in the following areas”, including “uses”, thus serving as a mechanism for consideration of multifamily workforce housing project as proposed at the subject site. b. Coastal Permit – required for review “as a project undertaken by a public agency” (school district) per City of Santa Cruz Municipal Code Section 24.08.230. The subject site falls within Coastal Overlay, Exclusion Area A, and a Coastal Permit must be obtained for the proposed scope of work, which fails to satisfy the criteria qualifying the project for exclusion from the requirement for attainment of a Coastal Permit.
c. Design Permit – required for review of site and building design per City of Santa Cruz Municipal Code (SCMC) 24.08.410 as a public project within the Coastal Zone and as a project which requires a Planned Development Permit.
d. Heritage Tree Removal Permit– required for review of proposed removal of approximately six (6) Heritage trees at the subject site per City of Santa Cruz Municipal Code Section 9.56.060.

APPLICABLE STATE LAWS
 Government Code 65915: The project does not seek approval of a Density Bonus.  Government Code 65589.5: The Housing Accountability Act limits a local government’s ability to deny, reduce the density of, or make infeasible housing development projects, emergency shelters, or farmworker housing that are consistent with objective local development standards and contribute to meeting housing need. This project proposes approval of a Planned Development Permit to allow for variations to objective standards, specifically, the use of site for residential purposes, therefore, the city’s discretion is not limited under this section of the state law. However, the project is vested to the standards in place at the time of Preapplication completeness.

ANALYSIS
Site Plan and Project Design

22.1658

AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 6
The project site can be characterized as an approximately 4.08-acre, flat, approximately rectangular site situated southwest of the intersection of Delaware Avenue and Swift Street, having approximately 270 linear feet of frontage along Swift Street, bearing a General Plan Land Use designation of CF (Community Facilities) and located within the P-F (Public Facilities) zone district. The parcel falls outside areas mapped for potentially sensitive habitat or resources (except the northwesterly corner of the subject site, identified as potential monarch butterfly habitat/overwintering site in the 2005 General Plan, as described above), while the westerly approximate half of the project site falls within land in which the City’s Bird-Safe Development standards apply.

The proposal includes 1) removal of the two existing modular buildings and shipping containers and demolition of existing site features, including asphalt pavement and on-site landscaping and 2) construction of a four-story, approximately 120,604 square-foot multifamily educator workforce housing project encompassing 100 residential units, 119 parking spaces, new landscaping, and associated site modifications, including removal of six (6) Heritage trees. The 100 units comprise 11 studio, 28 onebedroom, 50 two-bedroom, and 11 three-bedroom apartment units, resulting in a dwelling unit density of 24 dwelling units per acre (du/acre). The proposed scope of work includes retention of the existing onestory, approximately 2,077 square-foot administrative building most recently occupied by the Santa Cruz Education Foundation and the one-story, approximately 3,308 square-foot educational building formerly occupied by the Westside Parent Education Nursery School (WPENS), in addition to removal of the two existing modular buildings. The existing tenants of the administrative and educational buildings vacated the site before the end of calendar year 2024, while the occupant of the modular buildings will exit the site by June 2025. As proposed, the project scope of work includes conversion of the educational building to residential storage use ancillary to the proposed workforce housing, with programming of the second permanent building remains undetermined, although currently anticipated for occupancy by a property management use supporting the proposed project.

Planned Development Permit
Housing within the Santa Cruz region consistently ranks among the most expensive in the United States, with the rental market particularly intensely impacted. Local school districts have, for years, experienced difficulty in attracting and retaining personnel due to the relatively low salaries of educators and support staff, particularly in light of the high cost of housing within the area.

As aforementioned, neither the Community Facilities General Plan Land Use designation nor the Public Facilities zone designation envision residential use at the subject site. However, as the use proposed comprises a multifamily educator workforce housing project intended to attract and retain employees of Santa Cruz City Schools, including teachers and support staff (i.e., certificated and classified staff), the proposed use can be considered via a Planned Development Permit as a use of the land supportive of, and contributory and complementary to, the school district’s mission as a public agency tasked with educating the residents it serves.

Role of the Planning Commission
A Planned Development Permit constitutes a discretionary permit application providing quasi-judicial review of the requested land use at the subject site, additionally accommodating consideration of the submitted scope of work and project design. The Planning Commission is requested to make a recommendation to the City Council regarding the acceptability of the proposed multifamily residential use of the subject site to accommodate educator workforce housing, as well as support for the proposed scope of work and project design.

22.1659

AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 7
Per SCMC 24.08.700, the purpose of a Planned Development includes the following:

1. Provide an administrative technique to foster development plans for eligible lands which serve public objectives more fully than development plans permitted under conventional zoning regulations;

2. Establish criteria for identifying those parcels of land in the city which are eligible for the special procedures available to applicants proposing creative development plans requiring special review and approval procedures.

Further, SCMC 24.08.710, Intent, states the following:

1. Planned development permits will be issued only where the subject parcel is large enough to make innovative and creative site planning possible;

2. Applicants for planned development permits have the professional capability to produce a creative plan;

3. The public’s interest in achieving goals stated in the General Plan will be served more fully through the planned development process than through application of conventional zoning regulations;

4. The advantages to landowners afforded by the planned development process will be balanced by public benefits;

5. Natural or man-made features and resources of the site such as topography, trees, watercourses, and the like are preserved.

The applicant reports that the project intends to achieve the following:
 The project aims to address the housing affordability crisis facing public educators, specifically those employed by SCCS, serving the public objective of retaining critical public educator staff and addressing housing affordability as set forth in the City’s General Plan, fulfilling the purpose of SCMC

24.08.700(a)(1).
 The development of the parcel in question aims to establish a novel and judicious path for California school districts to achieve the highest and best use of their underutilized properties, providing a case study for others to follow as they seek to address the housing affordability crisis facing public educators, meeting the purpose of SCMC 24.08.700(a)(1).

As a contiguous site exceeding 4 acres in size and of approximately rectangular dimensions, the subject lot provides adequate size and an appropriate shape to accommodate “innovative and creative site planning”, while a team of two professional architecture firms with experience in design of educational facilities have spearheaded the proposed design and layout. The provision of affordable housing for educators serves a clear and demonstrable benefit to the public. Existing site topography will remain largely unchanged, while on-site natural features will remain intact to the extent practicable.

As the subject parcel remains largely unused, development of the site for educator workforce housing facilitates appropriate infill development while retaining ample open space for future potential structures and site features, while offering ample opportunity for active and passive recreation. Further, by repurposing an existing site, the school district will avoid incurring additional costs associated with property acquisition while maintaining wise stewardship and effective utilization of its existing assets.

Zoning and General Plan Consistency

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The project site occurs on land contained in the PF (Public Facilities) zone district and has a General Plan land use designation of CF (Community Facilities).

The project upholds consistency with the purpose of the General Plan Land Use designation of CF, described in the General Plan 2030 as below:
“Designates existing and potential community facilities, including schools, government offices, community buildings such as the Civic Auditorium, sewer and water facilities, and the City landfill.

Also applies to land used by State highways.”
The proposed project conforms to, and fosters the attainment of, many goals and policies of the General Plan, including the following:

Goal LU1 Sustainable Land Uses
 Policy LU1.1: Relate residential, commercial and industrial land use intensities to the capability and location of the land while ensuring optimum utilization of infill parcels.  Policy LU3.7: Encourage higher-intensity residential uses and maximum densities in accordance with the general plan land use designations.

Goal LU3 A complementary balance of diverse land uses
 Policy LU3.1: Foster land use patterns that balance economic, housing, community, and environmental needs, and promote social diversity.

Goal CC2 Comprehensive community facilities and services  Policy CC2.1 Provide community services and facilities in keeping with the needs of a growing and diverse population
Goal CC8 Excellent educational opportunities and resources  Policy CC8.1: Cooperate with public and private institutions seeking to meet their educational objectives.

Goal CD1 A built environment in harmony with its natural setting  Policy CD1.2: Ensure that the scale, bulk, and setbacks of new development preserve important public scenic views and vistas.
 Policy CD1.3. Ensure that development is designed to be in harmony with natural topography and vegetation.

Goal M1 Land use patterns, street design, parking, and access solutions that facilitate multiple transportation alternatives
 Policy M1.6: Design parking areas and parking garages that are safe, pleasant and easy to use.

Goal M4 A citywide interconnected system of safe, inviting, and accessible pedestrian ways and bikeways  Policy M4.1: Enable and encourage walking in Santa Cruz Goal NRC5 An enhanced and sustainable urban forest
 Policy NRC5.1: Protect and manage tree resources in the urban environment, with emphasis on significant and heritage trees.

Goal PR1 Ample, accessible, safe, and well-maintained parks, open space, and active recreational facilities

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 PR1.7: Require developers to mitigate the impacts of their property improvements on city parks, recreation facilities and open space areas.

Goal ED4 A skilled, educated, and diverse local workforce Policy ED4.2 Retain and expand the existing base of medium and large employers in Santa Cruz  ED4.1 Promote the education and training of the workforce to meet the needs of emerging economies.

Because the California Coastal Commission has not yet adopted the City’s General Plan 2030, and the subject site occurs on land within the Coastal Zone, the proposed project is additionally evaluated for consistency with the City’s 1990-2005 General Plan (“2005 General Plan”).

The subject site held a Land Use Designation of “Community Facilities” pursuant to the 2005 General Plan, The project upholds consistency with the purpose of the General Plan Land Use designation of CF, described in the 2005 General Plan as below:
“Community facilities designations identify existing and potential community facilities to acknowledge their location and to ensure that suitable area will be set aside to accommodate the need for these facilities, including schools, government offices, post offices, sewer and water facilities, the Civic Auditorium, and the landfill”
The proposed project advances applicable goals of the 2005 General Plan, including the following:

GOAL L 1: Develop a sustainable community in terms of environmental protection, land-use distribution and densities, housing types and styles, economic development and job opportunities, and opportunities for social and cultural expression and recreation.

GOAL L 2: Provide for a variety and balance of residential, commercial, and industrial land uses while protecting environmental resources and responding to changing community needs, interests and development constraints.

GOAL CD 3: Maintain and enhance the City's unique built character and emphasize a human/pedestrian scale to development.

GOAL CD 4: Enhance neighborhood diversity and reinforce the desirable elements of neighborhood character or quality.

GOAL CD 6: Enhance the landscaped quality of the City and ensure an emphasis on landscape practices, management and plant species that are climate-appropriate to Santa Cruz.

GOAL C 2: Develop and promote pedestrian travel as a viable transportation mode by developing and maintaining a safe, comprehensive, convenient, accessible and aesthetically pleasing pedestrian system.

GOAL H 3: Strive to provide an increased number of affordable housing units to meet the needs of verylow, low and moderate-income households in the City, in particular smaller-sized rental units, in order to approximate as closely as possible the actual income distribution of the City's population.

GOAL ED 1: Foster economic development programs that provides diverse opportunities for stable, meaningful work at livable pay, meets retail and service needs of residents and visitors, creates a strong

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municipal tax base, preserves environmental quality, and enhances the character and quality of community life.

GOAL PR 1: Provide for an adequate and well-balanced supply of parks and recreational lands to meet the needs of Santa Cruz residents.

GOAL PR 2: Ensure that adequate types, numbers and distribution of recreational facilities are available to residents of Santa Cruz.

The proposed project offers affordable housing for educators of the City while maximizing provision of off- street parking, preservation of open space, connectivity to surrounding land uses, and compatibility with the built environment in the vicinity of the subject site. Removal of multiple trees will be necessary as part of the project; however, standard tree replacement measures will be incorporated, as included in the conditions of approval.

Parking and Circulation
The project’s scope of work incorporates a range of site improvements. As proposed, all existing surface parking would be removed, and the driveway currently providing ingress/egress from Swift Street would be relocated for access to new parking spaces and future buildings. Alterations would encompass installation of a new drive aisle flanked by parking stalls arranged parallel to the site’s northerly property line and spanning the easterly lot line to approximately the site’s westerly limit. Parking capacity comprising 119 parking spaces would be provided, including 40 standard-sized stalls and 58 compact parking spaces, in addition to 3 standard accessible stalls and 3 van accessible spaces.

Proposed Easement and Review of Project Circulation
The applicant has engaged in ongoing conversations with the property owner of the adjacent property to the north of the subject site regarding arrangement for provision of a vehicular access easement over that property and expects to acquire an easement over the adjacent lot in the near future. Such easement will provide a second point of ingress and egress directly to Delaware Avenue, as encouraged by the City’s Fire Department.

Staff of the City’s Public Works Department, Traffic Engineering Division has reviewed the submitted application and had provided comments regarding necessary off-site improvements. Staff of the City’s Police Department has also considered the proposed project plans and have conducted site visits, concluding that the project design, as proposed, provides sufficient means for security. Fire Department staff have expressed acceptance of the project design, even without acquisition of an access easement across the adjacent property as referenced above.

Recommended conditions of approval require that the project applicant fulfill the recommendations of staff of reviewing City departments, including the Public Works, Police, and Fire Departments. A further Condition of Approval has been added, requiring supply of requisite bicycle parking capacity and submittal of details of proposed bicycle parking facilities, including identification of vendor and specification of dimensions and arrangement of interior layout with spacing for all bicycle parking proposed.

Design Permit

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The proposed project requires approval of a Design Permit per Municipal Code (SCMC) Section 24.08.410 as a public project within the Coastal Zone and as a project which requires a Planned Development Permit, as well as “for multiple dwellings and dwelling groups containing three or more dwelling units”, with the Design Permit intended to promote high quality of project design consistent with the standards for aesthetics typifying the Santa Cruz community. While the project seeks approval of a discretionary Planned Development permit, staff have focused the Design Review on compliance with the City’s Objective Design Standards for Multifamily Development (Municipal Code Section 24.12.185) as attached, and has included below the applicant’s intent for building design and siting.

The proposed design places a four-story, residential stacked-flat building within the westerly approximate two-thirds of the subject property. As stated by the project architect, the building design aims to respond to the site's urban context and unique circumstances as a zone of transition between three disparate conditions of the surrounding built environment.

The design team relays that the proposed project intends to articulate the separate residential units and character of the proposed structure within the overall development pattern. As specified by the applicant, the proposed design achieves such an objective in the following ways:
 The building forms three distinct masses, or wings, connected by exterior bridges, which mimic the scale of surrounding industrial buildings while reinforcing internal cohesiveness and avoiding a scale otherwise potentially impacting neighboring land uses and structures (through loss of visibility to surroundings, casting of shade/shadows, inducing potential privacy-related impacts, etc.)
 The massing of each wing includes long, side-by-side bars featuring a shed roof design inspired by large-scale industrial building typologies, and a rectangular volume with facades incorporating planar offsets commonly characteristic of mid-size residential buildings  The proposed configuration of wings offers to residents and visitors varied experiences with the project, ranging from a "front yard" at the northeast, adjacent to the building lobby and community room; a more private "back yard" at the northwest; and a communal interior courtyard preserving a view corridor to the ocean
 The articulation, modulation of planes, diversity of facades, and expression of roof forms advances the intent and letter of the Multifamily Objective Design Standards, creating harmony with both the industrial and residential surroundings while expressing individuality of the proposed units The project proposes a building height of 50’, as measured to the midpoint of sloped roofs, in keeping with the height limit specified in SCMC 24.10.190(1) for Commercial/Industrial uses, with a site layout which strives to maximize density within a minimal building footprint as a means of preserving large portions of the site for placement of landscaping and open space. The proposed landscape design aims to foster a sense of community through shared outdoor gathering spaces in a park-like setting. Through pursuit of a vertically-oriented configuration (rather than a large-footprint, low-profile site plan), the project retains substantial land dedicated to a surface parking lot providing off-street parking for residents and employees.

The project additionally introduces a formal pedestrian footpath from Swift Street to Sergeant Derby Park, replacing the current, longstanding informal access path, thereby offering a further public benefit to the site.

The applicant has made a number of revisions to the design compared to that included in the Preapplication, incorporating, among other modifications, revisions to the site plan and proposed architect for enhanced consistency with the City’s Objective Design Standards. Changes made from project inception to the design currently presented include a greater diversity of roof forms, variation in height of roof elements, and

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additional changes in façade planes, as well as integration of increased setbacks. Such revisions collectively offer greater visual interest and accommodate enhanced vehicular parking and pedestrian connectivity in compliance with SCMC 24.12.185.

As currently proposed, the project presents high quality of architecture and site design, satisfying the stated rationale of the requirement for Design Permit as identified in the Municipal Code and ensuring consistency with the standards of the City’s Multifamily Objective Design Standards.

Site Development Standards
The table below summarizes the project’s compliance with the relevant requirements of the P-F zone district and of the City’s Objective Design Standards, SCMC 24.12.185:

Table 1
Standard Allowed/Required Proposed Complies? (Yes/No)
Residential Density None specified in P-F zone
district; density required by
FAR limitation.
25 du/ac. N/A
Floor Area Ratio (FAR) 2.5 Approx. 0.68 Yes
Lot Coverage N/A N/A N/A
Building Height 50’ max. (in
commercial/industrial areas)*
50’ Yes*
Setbacks
Front 20’ min. (adjacent to R-1-5
district)
241’ – 3” Yes
Rear 0’ min. (adjacent to IG/PER2 district)20’ - 8” Yes Left Side 0’ min. (adjacent to IG/PER2 district)17’ – 7” Yes Right Side 0’ min. (adjacent to IG/PER2 district)70’ – 11” Yes Vehicular Parking 0 (per 24.12.220) 119 total spaces Yes Electric Vehicle
Charging Stalls
14 15 Yes
Bicycle Parking
125 total
Class 1: 100
Class 2: 25
129 total
Class 1: 103
Class 2: 26
Yes
Common Open space Unspecified in PF zone 51,200 sq. ft. total Yes Private Open Space Unspecified in PF zone 1,800 sq. ft. (for 22 total ground-floor residential
units)
Yes
*The maximum allowable height allowable in “commercial or industrial areas” applies to the subject application.

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Affordable Housing
The City’s Municipal Code, Section 24.16.020, requires that residential developments creating five or more new residential dwelling units provide 20% of their dwelling units as inclusionary (affordable) units, which shall be made available for lease to low-income households at an affordable rent. Inclusionary units are restricted in perpetuity to households earning 80% or less of the Area Median Income (AMI).

As an alternative, SCMC 24.16.030(10)(b) offers the following means of compliance, applicable only to school-district employer-sponsored housing:
 School district employer sponsored housing projects conforming to the requirements of the Teacher Housing Act of 2016 (Health and Safety Code Section 53570 et seq. or successor provisions) will be deemed to satisfy the inclusionary housing requirements of this chapter. For any such projects, an agreement must be executed to formalize that the project has met this alternate means of compliance, and annual compliance reports must be submitted to confirm compliance with the affordability provisions of the Teacher Housing Act of 2016.

The applicant has invoked the above provision, stating the intent to pursue provision of all 100 residential units at approximately 60% to 65% of market rate, roughly equivalent to affordability at the Low/Moderate Income level, to serve the target population. A condition of approval requires that the project provide full conformance with the Teacher Housing Act of 2016, which legislation requires the majority of units remain restricted to rents affordable to low or moderate income persons or families as defined in Health and Safety Code 50093. A further condition of approval requires submittal of an affordable housing agreement acceptable to the City prior to issuance of any Building Permit related to the project, as well as submittal of annual reports demonstrating compliance with applicable State law.

Staff have confirmed with the City Attorney’s Office that a statue passed subsequent to the Teacher Housing Act of 2016, namely Assembly Bill (AB) 2295, which contains prescriptive criteria for provision of affordable housing, does not serve as a successor statute, with compliance of terms contained therein not required by the proposed project.

Health in all Policies (HiAP)
HiAP is a collaborative approach to improving the health of all people by incorporating health considerations into decision-making across sectors and policy areas. HiAP rests on three pillars: equity, public health, and sustainability. HiAP serves to ensure that all decision-makers remain informed about the health, equity, and sustainability impacts of various policy options during the policy development process.

The project supports the pillar of equity by providing rental units on an infill site in a developed urban area improved with sidewalks and street trees and offering direct access to public transportation, commercial goods and services, and recreational areas, including ample opportunities for recreation and respite provided by virtue of the site’s proximity to the Pacific Ocean. The proposed project provides housing for educators and school district personnel, offering stability in staffing which benefits both students and the broader community through preparation of the local populace for successful entry into, and contribution to, the area’s economy via provision of a well-trained local workforce. Additionally, the development of residences on the existing low-performing, underutilized site encourages a sustainable and healthy lifestyle

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by promoting alternative forms of transportation. Through the incorporation of additional bicycle parking and site landscaping, the redevelopment encourages a sustainable and healthy lifestyle by promoting alternative modes of transportation in a resource-rich environment encouraging outdoor recreation. As such, the project fortifies the three pillars of the HiAP and demonstrates efficient and judicious use of the subject property.

ENVIRONMENTAL REVIEW
The proposed project requires approval of a Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit. All such entitlements represent discretionary actions, and the proposed redevelopment qualifies as a “project” under CEQA.

The California Environmental Quality Act (CEQA) establishes several “categorical exemptions” applicable to classes of projects and varieties of activities which generally avoid inducing risk of significant impacts to the environment. Review of the submitted application and coordination with the City’s CEQA consultant, City Attorney’s Office, and consultant attorney specializing in CEQA matters, has determined that the proposed project would not fully qualify for implementation of Article 19 of the California Environmental Quality Act (CEQA) Guidelines, Section 15332 (that is, the Class 32, infill categorical exemption), as the Class 32 Categorical Exemption requires that a project “is consistent with the applicable general plan designation and all applicable general plan policies as well as with applicable zoning designation and regulations.” The subject application proposes a multifamily residential use on a site with a General Plan Designation of CF (Community Facilities), which the General Plan states Designates existing and potential community facilities, including schools, government offices, community buildings such as the Civic Auditorium, sewer and water facilities, and the City landfill.

Also applies to land used by State highways
Because the proposed project would not provide for full consistency with the General Plan Land Use designation of CF, for assessment of the proposed project’s likelihood for impact to the environment, an Initial Study of Environmental Impact (Initial Study) dated December 2024 was prepared by consulting firm Dudek; that Initial Study indicated that the project holds the potential to generate significant environmental impacts, but which can be mitigated to levels below established thresholds of significance through the implementation of appropriate mitigation measures. Consequently, a Mitigated Negative Declaration (MND) has been prepared in accordance with the procedures directed in CEQA, to assess, disclose, and mitigate the potentially significant environmental impacts of the entire scope of the proposed project, providing the opportunity for review and comment by the public. The Draft MND identifies potentially significant environmental impacts related to hazardous materials associated with the site’s past use by the US Army Reserve, as described in the attached IS/MND. The analysis contained in the IS/MND determines that the proposed project will not have a significant impact on the environment with mitigation measures implemented. All mitigation measures included in the MND have been included as conditions of approval for recommendation by the Planning Commission to the City Council.

A Notice of Intent to adopt a Mitigated Negative Declaration (NOI) was prepared and filed with the Santa Cruz County Clerk and submitted to the State Department of Land Use and Climate (formerly Governor’s Office of Policy and Research) Clearinghouse on December 16, 2024, initiating a 30-day period of circulation allowing for public comment through January 15, 2025.

Several letters of correspondence, attached, were submitted in response to the Initial Study and Mitigated Negative Declaration, including comments from two (2) external agencies and one (1) private party. Letters

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were received from the California Department of Conservation, dated January 10, 2025; California Department of Fish and Wildlife dated January 10, 2025, and Stephen Svete, dated January 15, 2025. None of the correspondence raised concerns regarding the project’s potential to induce environmental impacts not already addressed in the Initial Study and Mitigated Negative Declaration.

The Planning Commission has been requested to make a recommendation to the City Council regarding acknowledgment of environmental determination associated with the project. A final decision related to requested entitlements, including adoption of the IS/MND, will be made by the City Council. With adoption and incorporation of the recommended mitigation measures into the final project, the CEQA Findings will conclude that the proposal will minimize significant adverse impacts to the environment. The Planning Commission’s recommendation for approval of project entitlements would become effective only upon adoption of the MND and project Findings of Fact under CEQA by the City Council.

SUMMARY
The proposed project seeks to pursue the development of an underutilized parcel owned by a public agency, Santa Cruz City Schools, providing housing for educators and educational support staff compatible with, and supportive of, the mission of the school district to provide education for the youth and young adults of the City. While a strict reading of the Municipal Code does not accommodate consideration of workforce housing at the project site, the Planned Development Permit offers a mechanism for pursuit of the proposed land use advancing the venerable goal of accommodating educator housing, thereby reducing the stress on employees for pursuit of suitable accommodations, allowing for greater focus on educating Santa Cruz residents and offering stability in staffing of schools, and contributing to the cultivation of a vital student population and future local workforce.

Set back significantly from the adjacent street and surrounding properties, the building avoids the impression of an imposing edifice through its siting on the subject property as well as via integration of articulated wall planes, diversity of materials and colors, and a varied roofline. Placement of new landscaping throughout softens the appearance of the development. Implementation of a drought-tolerant, water-efficient plant palette affords visible contrast to the building, minimizing ecological impact while enlivening the existing site. Integration of outdoor open space provides visual interest and durable functionality, offering opportunities for usability of outdoor area for active and passive recreation. Through provision of a new bicycle/pedestrian path and widening of adjacent sidewalks, the project expands connectivity to surrounding public rights-of-way and the adjacent park and ocean.

Situated on a school district site currently underutilized and underperforming within a developed, urbanized setting supported by existing transit service, the project complements surrounding residential dwelling units by offering ready access to recreational and commercial destinations by virtue of the subject parcel’s location. The development conforms to the existing site topography and will enrich the subject lot and surrounding neighborhood through removal of dated, underutilized structures of substandard development intensity, replacing them with a high-density housing project offering new amenities while simultaneously remediating the subject lot. The project provides consistency with applicable provisions of the Municipal Code while fostering a significant, substantive development offering an attractive, context-suitable site plan with project architecture, landscaping, and site planning sympathetic to surrounding development and conforming to the City’s’ Objective Design Standards. The project will maximize dwelling-unit density while introducing new residences tailored to the needs of educators and classified staff while contributing to expansion of the City’s overall affordable housing stock. As conditioned, the proposed project satisfies the requirements of the Zoning Ordinance and provides a development in character with its vicinity by virtue of its use, scale, and architecture.

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Staff recommend that the Planning Commission acknowledge the environmental determination and recommend to the City Council approval of the Planned Development Permit, Coastal Permit, Design and Heritage Tree Removal Permit based on the Findings below and the Conditions of Approval in Exhibit A.

FINDINGS
Planned Development Permit, Section 24.08.770

1. Is consistent with the General Plan, the Local Coastal Land Use Plan, and adopted area plans.

The subject parcel has a General Plan land use designation of CF (Community Facilities), which envisions land identified with this classification serving as, “existing and potential community facilities, including schools, government offices, community buildings such as the Civic Auditorium, sewer and water facilities, and the City landfill. Also applies to land used by State highways.” Residential use is not included among the categories of land uses encompassed by the CF General Plan Land Use designation; however, provision of multifamily residential use to accommodate housing of school district personnel for long-term retention of employees supports the school district’s mission of educating students.

The proposed project is consistent with the policies of the General Plan, including the following:

Goal LU1 Sustainable Land Uses
 Policy LU1.1: Relate residential, commercial and industrial land use intensities to the capability and location of the land while ensuring optimum utilization of infill parcels.  Policy LU3.7: Encourage higher-intensity residential uses and maximum densities in accordance with the general plan land use designations.

Goal LU3 A complementary balance of diverse land uses
 Policy LU3.1: Foster land use patterns that balance economic, housing, community, and environmental needs, and promote social diversity.

Goal CC2 Comprehensive community facilities and services  Policy CC2.1 Provide community services and facilities in keeping with the needs of a growing and diverse population
Goal CC8 Excellent educational opportunities and resources  Policy CC8.1: Cooperate with public and private institutions seeking to meet their educational objectives.

Goal CD1 A built environment in harmony with its natural setting  Policy CD1.2: Ensure that the scale, bulk, and setbacks of new development preserve important public scenic views and vistas.
 Policy CD1.3. Ensure that development is designed to be in harmony with natural topography and vegetation.

Goal M1 Land use patterns, street design, parking, and access solutions that facilitate multiple transportation alternatives
 Policy M1.6: Design parking areas and parking garages that are safe, pleasant and easy to use.

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Goal M4 A citywide interconnected system of safe, inviting, and accessible pedestrian ways and bikeways  Policy M4.1: Enable and encourage walking in Santa Cruz Goal NRC5 An enhanced and sustainable urban forest
 Policy NRC5.1: Protect and manage tree resources in the urban environment, with emphasis on significant and heritage trees.

Goal PR1 Ample, accessible, safe, and well-maintained parks, open space, and active recreational facilities  PR1.7: Require developers to mitigate the impacts of their property improvements on city parks, recreation facilities and open space areas.

Goal ED4 A skilled, educated, and diverse local workforce  Policy ED4.2 Retain and expand the existing base of medium and large employers in Santa Cruz  Policy ED4.1 Promote the education and training of the workforce to meet the needs of emerging economies.

The proposed project advances the above goals and policies of the General Plan and conforms to the purpose of the P-F (Public Facilities) zone district, “to designate public buildings and facilities and to ensure that there is a compatible relationship between such uses and the surrounding area”. No area plan applies to the project site.

2. Is consistent with the purpose of this chapter and other applicable sections of this title.

The P-F (Public Facilities) zoning district specifies categories of uses principally-permitted and conditionally-permitted. Per City of Santa Cruz Municipal Code Section 24.10.1770, “government facilities; local, state, and federal” and “school, public” appear among the classes of land use accommodate by the district via discretionary review, without residential uses listed among them. A Planned Development Permit “provides variation on district regulation, where appropriate, in the following areas”, including “uses”, thus providing a mechanism for consideration of multifamily workforce housing project as proposed at the subject site.

As prescribed by the Municipal Code, “the land area subject to planned development permit shall comprise at least twenty thousand square feet”. With a lot size in excess of four acres, the project fulfills the criterion for minimum land area. Further, the Planned Development Permit requires that “the applicant owns or controls the land subject to the planned development permit application”. As Santa Cruz City Schools holds the subject lot in fee-simple ownership, the school district will retain control of project entitlement, construction, and long-term operation and management, satisfying the above finding.

3. Includes planned variations to underlying district regulations which serve public purposes to an equivalent or higher degree than would underlying district regulations.

As an approximately 4.08-acre, generally rectangular, contiguous site, the subject lot provides adequate size to accommodate a creative and innovative design, while a team of two professional architecture firms with experience in designing educational facilities have devised the proposed site configuration, building forms, and architecture. The provision of affordable housing for educators provides a clear and demonstrable benefit to the public. Existing site topography will remain largely unchanged, while on-site natural features will remain intact to the extent practicable.

The inclusion of 119 off-street, surface parking spaces for residents and employees of the new residential building, will offset increased demand for on-street parking in the surrounding residential neighborhoods.

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Provision of ample open space and landscape areas on the site for the enjoyment and benefit of the building’s inhabitants and their guests offers a visual benefit to neighboring properties, both enhancing the local environment and offering greater access to neighboring Sergeant Derby Park.

The proposed project introduces an infill residential development of high density within a minimal building footprint in the context of a site plan integrating generous vehicular and bicycle parking providing connectivity to surrounding destinations in a location well-served by public transit, while offering affordable residences to educators and support staff, thereby reducing school staffing turnover due to high housing costs.

4. Can be coordinated with existing and proposed development of surrounding areas.

The proposed project will maintain a balance of scale, form and proportion to both the existing site and neighboring properties in a variety of ways. Through removal of dated, underutilized, low-density, underperforming buildings, the project will allow for better use of a constrained property while continuing the residential character of the site and maintaining cohesiveness to surrounding uses. Minor regrading of the project area and setting of new surface material will combine for improved circulation and site access conducive to a high-density commercial/ residential use. New rooftop mechanical equipment and all ground-mounted equipment and utility installations will be required to be fully screened from view from surrounding properties and public rights-of-way.

Santa Cruz City Schools retains ownership of the parcel immediately to the south of the subject parcel, which contains an existing school; future plans for the adjacent lot envision retention of the existing school facilities. Additionally, no application for development of the properties to the north of the subject lot been received by the City, and reasonably foreseeable future conditions include retention of the existing industrial uses on parcels adjoining the project site. Surrounding residential neighborhoods will very likely continue such existing land uses for decades into the future. The proposed development therefore demonstrates coordination with existing and proposed development of land within the vicinity of the subject site.

5. Overall, the amenity level of the development and the amount of open space shall be greater than what would have been permitted by the underlying district regulations.

SCMC 24.10.1790 does not specify open space requirements in the district regulations for the P-F district, and, therefore, pursuant to the Municipal Code, no minimum open space requirement pertains. Through provision of 51,200 square feet of common open space and 1,800 square feet of private open space dedicated to ground-floor units, the project provides, on average, 5,300 square feet of open space per residential unit, offering generous opportunities for respite and access by residents and visitors to both active and passive recreation opportunities. Including a direct connection to Sergeant Derby Park, and by virtue of the site’s proximity to the Pacific Ocean, access to natural amenities remains intrinsic to the project’s location. With a proposal for planting of the number of trees as proposed, the project additionally enhances the site and surroundings through integration of features offering visual beauty and connection to nature.

Coastal Permit, Section 24.08.250

6. Maintain views between the sea and the first public roadway parallel to the sea;

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Situated at the southwest corner of Delaware Avenue and Swift Street, surrounded by established industrial and residential uses, approximately a third-mile north of the Pacific Ocean, the proposed project will not impact views between the sea and the first public roadway parallel to the sea.

7. Protect vegetation, natural habitats and natural resources consistent with the Local Coastal Land Use Plan;
The subject site falls outside areas mapped for sensitive biological resources per General Plan 2030; however, the northeasterly corner of the site occurs with an area mapped as habitat potentially supportive of monarch butterfly habitat per General Plan 2005, with which the project must demonstrate compliance.

Biotic consulting firm Ecosystems West has deemed that the project would induce no potential impact to potential monarch butterfly habitat or overwintering capacity. Conditions of approval require submittal of a formal biotic report to document such findings and ongoing compliance with the consultant’s recommendations.

The proposed project falls within an urbanized area, with a number of properties separating the subject site from surrounding sensitive habitat and identified waterways. The site carries no General Plan 2030 designation identifying it as a location potentially containing valuable or rare habitat, nor does it connect directly to other areas of natural habitat. The project will additionally have no effect on wildlife movement.

8. Be consistent with any applicable design plans and/or area plans incorporated into the Local Coastal Land Use Plan;
No design or area plan pertains to the subject site; therefore, the above finding remains inapplicable.

9. Maintain public access to the coast along any coastline as set forth in the Local Coastal Land Use Plan;
The project is set approximately a third mile from the coast and will not impair public access to the shore; rather, through development of 100 new residential units, the project will locate additional population proximate to the shore, thereby improving access to coastal resources. The project would maintain and not disrupt, but, rather, enhance, existing circulation patterns due to incorporation of a new, widened sidewalk, new drive aisle, and multiple pedestrian pathways, including a formalized pathway continuing access from Swift Street to Sergeant Derby Park, thus introducing augmented internal and external connectivity. The project site is additionally positioned within an urbanized area in close proximity to employment, commercial goods and services, and recreational resources, facilitating the use of alternative modes of transportation.

10. Be consistent with the Local Coastal Land Use Plan goal of providing visitor-serving needs as appropriate;
The project includes 100 new affordable housing units , consistent with the allowances of the Municipal Code, including the City’s Multifamily Objective Design Standards, providing enhanced residential capacity in close proximity to surrounding retail, employment, and other services. The project site will likely draw some visitors; however, the project objectives do not directly relate to visitor-serving development.

11. Be consistent with the Local Coastal Land Use Plan goal of encouraging coastal development uses as appropriate.

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AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 20
The project affords consistency with the goal of encouraging coastal development uses, in that the proposed development will enhance access to the seashore by expanding the population in an area within walking and biking distance to the coast. No coastal resources will experience adverse effect, as the project will avoid impact to any coastal scenic viewsheds, the development is located a significant distance from designated sensitive environments, and the proposed design minimizes removal of Heritage trees, thus minimizing detrimental consequences to local ecology, the subject site, and its vicinity. The proposed building will additionally remain sympathetic to surrounding development with regard to mass and height.

Design Permit, Section 24.08.430

12. The site plan and building design are consistent with design and development policies, limited to those policies that constitute objective standards therein when required by state law, of the General Plan, any element of the General Plan, and any area plan, specific plan, or other city policy for physical development. If located in the Coastal Zone, the site plan and building design are also consistent with policies of the Local Coastal Program.

The project complies with all applicable objective standards. The subject site falls within the P-F (Public Facilities) zone district, governed by sparse development standards as identified in the Municipal Code; however, SCMC 24.12.185 contains a variety of objective criteria pertinent to project design. The proposed development achieves compliance with all such objective standards.

The project would replace aging features and fixtures with upgraded facilities at a site bounded on all sides by existing buildings of similar scale and range of land uses. Removal of assorted modular buildings and replacement with a new development boasting modern architecture and extensive amenities will maintain the existing land use and retain compatibility with the nature of surrounding uses of residential character, while avoiding spillover effects inducing detrimental effects to surrounding land uses. The project layout will allow for improved use of the site for public facilities use and maintain compatibility in design and utility of neighboring properties. Building color and texture will complement adjacent topography to blend into the natural environment to the extent possible, in conformance to the appearance of the surroundings to achieve a design aesthetic in keeping with the high standards of the Santa Cruz visual environment and community expectations.

The project site plan demonstrates consistency with, and will facilitate achievement of, the goals, policies, and actions of General Plan 2005 and General Plan 2030, both of whose Land Use Maps designate the land including the subject parcel as “Community Facilities.” Construction of new, modern, amenity-rich residential units to replace existing on-site trailers, and reconfiguration of on-site parking, will provide improved utility of the site and provide for a more uniform, cohesive exterior appearance consistent with the bulk, mass, and architecture of existing, surrounding uses. As proposed, the project will, therefore, 1) attain General Plan Goal CD-1 by promoting “a building environment in harmony with its natural setting;” 2) advance Policy CC2.1 to “provide community services and facilities in keeping with the needs of a growing and diverse population; and 3) support Policy CC2.1.1 to “update and replace facilities consistent with the General Plan Policy”. Consistency with the General Plan and other applicable regulations is further articulated in the project plans, staff reports, website materials for the project, public hearing presentations, and conditions of approval, and elsewhere in these findings.

13. The site plan and building design are in full conformance with the design standards of Section

24.12.185.

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AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 21
The proposed site plan and building design demonstrate consistency with the City’s Objective Design Standards for Multifamily Development as promulgated in Section 24.12.185 of the Municipal Code. The subject site occurs on land within the P-F (Public Facilities) zone district, and the project design complies with all applicable criteria of SCMC 24.12.185. In particular, revisions to the project design as initially submitted have been made to effect full compliance with the Objective Design Standards for Multifamily Development, as follows:

SCMC 24.12.185.4.d.: The project provides a new bicycle/pedestrian pathway through the subject site, 5 feet in width per minimum standards of the Public Works Department, thereby formalizing a longstanding access through the property from Swift Street to Sergeant Derby Park.

SCMC 24.12.185.4.e.: The sidewalk adjacent to Swift Street will measure minimally 8 feet in width as required, with dedication of land, or recordation of an easement to effectuate such widening.

SCMC 24.12.185.7: The submitted plan provides enclosures for refuse bins as set forth in the City of Santa Cruz Department of Public Works Refuse Container Storage Facility Standard Design Policy SCMC 24.12.185.10: The easterly elevation of the east wing has been modified to incorporate six roof forms along the predominant building face, and the southeasterly elevation of the west wing has been updated to incorporate seven roof forms along the predominant building face per SCMC

24.12.185(10)(a).

The proposed roof form has additionally been revised to include a difference in height of at least three feet per roof form per SCMC 24.12.185(10)(b)(v).

SCMC 24.12.185.12: The form of the building has been revised to provide modulation of building faces greater than 30 feet in length, as required.

SCMC 24.12.185.16: As conditioned, a lighting plan fully compliant with the referenced Municipal Code provisions will be submitted.

The project has been thoughtfully designed for consistency with applicable Municipal Code requirements and applicable provisions of the Building and Fire Codes. Through iterative revision, the proposed design ensures preservation of existing trees and prevent adverse impacts to natural resources to the degree possible. The design of the project and all landscaping will enhance the aesthetics of the project site and allow for an intensity of use and activity appropriate for the site’s industrial and residential surroundings, while site improvements will combine for improved circulation and site access.

The project scope of work includes new landscaping integrating native vegetation and low water-use, drought-tolerant plant varieties. The project will further be required to comply with all applicable provisions of Municipal Code Chapter 16.16, Water-Efficient Landscaping, related to regulation of landscape design, construction, and maintenance, thereby promoting efficient water use, facilitating management of peak season water demand, and assisting with the preservation of water storage to ensure a reliable and adequate public water supply. The application has been conditioned to provide a final landscape plan for review and approval with the building permit plans.

Through removal of underutilized buildings and a largely abandoned surface parking lot, the proposed project will allow for better use of the subject property while maintaining cohesiveness to surrounding uses.

Provision of 100 new residential units to house educators and support staff will provide residences tailored to the needs of the Santa Cruz City School District, intended for attraction and retention of a high-quality

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AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 22
workforce while adding to the stock of affordable housing providing accommodations for an underserved segment of the community, demonstrating clear benefits to the public.

Heritage Tree Removal Permit, Chapter 9.56, City Council Resolution No. NS-23, 710

14. A heritage tree or shrub, as defined in Chapter 9.56 of the City of Santa Cruz Municipal Code shall only be altered or removed in the following circumstances:
a) Alteration of a heritage tree or shrub would only affect less than twenty-five percent (25%) of the crown of said heritage tree or heritage shrub; b) Findings by the Director of Parks & Recreation can be established in conformity with the City’s Urban Forest and Wildland Interface Policy Statement; c) One or more of the following findings are established by the applicant and confirmed by the Director of Parks & Recreation:
1) The heritage tree or heritage tree shrub has, or is likely to have, an adverse effect upon the structural integrity of a building, utility, or public or private right of way;
2) The physical condition or health of the tree or shrub, such as disease or infestation, warrants alteration or removal;
3) A construction project design cannot be altered to accommodate existing heritage trees or heritage shrubs.

The arborist report prepared by ISA Certified Arborist Nigel Belton dated May 24, 2023, confirms that six (5) trees, 14 inches diameter (or greater), located within the project work area, will present locational conflicts with the proposed building, with the removal of such trees therefore recommended. Additionally, one tree appears in poor condition as demonstrated in the submitted arborist report and not suitable for retention in the project. Thus, the number of Heritage trees recommended for removal because of high construction impacts or poor condition totals six (6).

The project design has elicited mindful review of available options resulting in minimal impacts to existing trees. A condition of approval requires replacement of each tree proposed to be removed at a ratio of two, 24-inch-box-sized trees. Given the disparate arrangement of trees throughout the parcel and the objective of maintaining minimal impact to existing foliage, the project balances the potentially conflicting motivations of retention of existing trees and provision of affordable housing.

Submitted by:

Timothy Maier
Senior Planner
Approved by:

Samantha Haschert
Principal Planner
Exhibits:

1. Draft Resolution, Including Findings and Recommended Conditions of Approval

2. Project Plans, prepared by EHDD, dated November 1, 2024

3. Arborist Report, prepared by Nigel Belton, dated May 24, 2023

4. Noise Evaluation (Basis of Design), prepared by Smith, Fause, and McDonald, Inc. (undated)

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AGENDA REPORT
PC Meeting of February 6, 2025
SUBJECT: CP24-0104 – 313 Swift Street
PAGE 23

5. Geotechnical and Groundwater Field Exploration and Evaluation report, prepared by Moore Twining Associates, Inc., dated February 14, 2024

6. Phase I Environmental Site Assessment, prepared by Moore Twining Associates, dated June 21, 2023

7. Phase II Environmental Site Assessment, prepared by Moore Twining Associates, dated October 22, 2024

8. Trip Generation Memorandum, prepared by Fehr and Peers Transportation Consultants, dated October 25, 2024

9. Initial Study of Environmental Significance, prepared by Dudek, dated December 12, 2024

10. Mitigated Negative Declaration, prepared by Dudek, dated December 10, 2024

11. Mitigation Monitoring and Reporting Program, prepared by Dudek, dated January 20, 2025

12. Table Demonstrating Project Compliance with Objective Design Standards for Multifamily Development

13. Public Notification Radius Map

14. Public Correspondence

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CITY OF SANTA CRUZ
City Hall
809 Center Street
Santa Cruz, California 95060

PLANNING COMMISSION

ACTION SUMMARY
Regular Meeting
February 6, 2025
7:00 P.M. GENERAL BUSINESS AND MATTERS OF PUBLIC INTEREST, COUNCIL CHAMBERS Call to Order - Chair Polhamus called the meeting to order at 7:00 p.m.

Roll Call - Commissioners Dann, Gordon, Kelley, Kennedy, Thompson, and Chair Polhamus were present.

Absent: Commissioner McKelvey was absent.

Statements of Disqualification – Commissioner Kennedy recused himself from the February 20, 2025 Planning Commission meeting due to a conflict of interest on the 908 Ocean Street project.

Oral Communications-Chair Polhamus opened Oral Communications for members of the public who wished to speak regarding items not listed on the agenda. The following person(s) spoke: None.

Approval of Minutes

1. Approval of the Minutes of December 19, 2024.

MOTION: Commissioner Dann moved, seconded by Commissioner Gordon, to approve the minutes of December 19, 2024.

ACTION: The motion carried by the following vote:

AYES: Commissioners Dann, Gordon, Kelley, Kennedy, Thompson, and Chair Polhamus.

NOES: None
ABSENT: Commissioner McKelvey

2. Approval of the Special Meeting Minutes of January 9, 2025.

MOTION: Commissioner Dann moved, seconded by Commissioner Gordon, to approve the minutes of January 9, 2025.

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ACTION: The motion carried by the following vote:

AYES: Commissioners Dann, Gordon, Kelley, Kennedy, Thompson, and Chair Polhamus.

NOES: None
ABSENT: Commissioner McKelvey

3. Approval of the Minutes of January 16, 2025.

MOTION: Commissioner Dann moved, seconded by Commissioner Gordon, to approve the minutes of January 16, 2025.

ACTION: The motion carried by the following vote:

AYES: Commissioners Dann, Gordon, Kelley, Kennedy, Thompson, and Chair Polhamus.

NOES: None
ABSENT: Commissioner McKelvey
Public Hearings

4. 313 Swift Street Project Number: CP24-0104 Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to allow a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of six(6) Heritage trees, on a site located in the P-F/CZ-O (Public Facilities/Coastal Zone Overlay) zone district.

MOTION: Motion made by Commissioner Thompson, seconded by Commissioner Dann, to recommend to the City Council acknowledgment of the environmental determination and approval of a Planned Development Permit, Coastal Permit, Design Permit, and Heritage Tree Removal Permit to allow a new, four-story, approximately 120,604 square-foot multifamily educator workforce housing project encompassing approximately 100 residential units, approximately 119 parking spaces, new landscaping, and associated site modifications, including the removal of six (6) Heritage trees, on a site located in the P-F/CZ-O (Public Facilities/Coastal Zone Overlay) zone district, based on the findings listed below and Conditions of Approval listed in Exhibit “A" of the staff report dated January 31, 2025.

FRIENDLY AMENDMENT: Commissioner Dann requested the following new Condition of Approval be recommended to the City Council:
 The temporary access path to Derby Park shall be available to the public during construction.

ACTION: Commissioner Thompson approved the inclusion of the friendly amendment to the motion.

FRIENDLY AMENDMENT: Commissioner Kennedy requested the additional Conditions of Approval and a revision to Condition of Approval 32 be included in the recommendation to the City Council:

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 Applicant shall enter into a contract with Santa Cruz Metropolitan Transit District (Santa Cruz Metro) to provide unlimited local transit passes for all residents.
 For multi-family rental projects with common laundry rooms, all washing machines provided for common use among tenants shall be equipped with microplastic filters to reduce plastic pollution.
 Condition of Approval 32 shall be revised as follows: Final colors and materials shall be approved by the Zoning Administrator prior to application for building permits.

Commissioner Kennedy further requested the following additional Condition of Approval be recommended to the City Council:
 The project shall provide six street trees as shown in the project plans.

ACTION: Commissioner Thompson accepted the friendly amendment.

ACTION ON THE MOTION AS AMENDED: The motion carried by the following vote:

AYES: Commissioners Dann, Gordon, Kelley, Kennedy, Thompson, and Chair Polhamus.

NOES: None
ABSENT: Commissioner McKelvey
Information Items – Principal Planner Samantha Haschert discussed the actions of the City Council, upcoming community meetings, and items to be considered at future Commission meetings.

Subcommittee/Advisory Body Oral Reports-None.

Adjournment-The meeting adjourned at 9:32 p.m.

22.1679
From: [email protected]
To: Timothy Maier
Subject: 313 Swift Street Question/Comment Received
Date: Friday, April 26, 2024 8:19:39 AM
A new entry to a form/survey has been submitted.

Form Name: 313 Swift Street
Date & Time: 04/26/2024 8:19 AM
Response #: 2
Submitter ID: 109714
IP address: 47.155.104.82
Time to complete: 5 min. , 15 sec.

Survey Details

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