Attachment 6b - Final EIR — Santa Rosa City Council, March 15, 2022

CITY OF SANTA ROSA

ROSELAND AREA /S EBASTOPOL ROA D

SPECIFIC PLAN AND

ROSELAND AREA ANNEXATION PROJECTS

FINAL ENVIRONMENTAL IMPACT REPORT
State Clearinghouse No. 2016012030
Pr
epared for:

CITY OF SANTA ROSA

PLANNING AND ECONOMIC DEVELOPMENT DEPARTMENT
100 SANTA ROSA AVENUE, ROOM 3
SANTA ROSA, CA 95404
Prepared by:
2729 PROSPECT PARK DRIVE, SUITE 220
RANCHO CORDOVA, CA 95670
AUGUST 2016
At tachment 6b

CITY OF SANTA ROSA

R OSELAND AREA /S EBASTOPOL R OAD S PECIFIC

P LAN AND R OSELAND AREA A NNEXATION

P ROJECTS

FINAL ENVIRONMENTAL IMPACT REPORT
SCH No. 2016012030

Prepared for:

CITY OF SANTA ROSA

COMMUNITY DEVELOPMENT DEPARTMENT
100 SANTA ROSA AVENUE, ROOM 3
SANTA ROSA, CA 95404

Prepared by:

MICHAEL BAKER INTERNATIONAL
2729 PROSPECT PARK DRIVE, SUITE 220
RANCHO CORDOVA, CA 95670

AUGUST 2016

TABLE OF CONTENTS
City of Santa Rosa Roseland Area/ Sebastopol Road Specific Plan and Roseland Area Annexation Projects July 2016 Final Environmental Impact Report
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1.0 I NTRODUCTION

1.1 Background and Purpose of the EIR ......................................................................................... 1.0-1

1.2 Intended Uses of the EIR .............................................................................................................. 1.0-2

1.3 Organization and Scope of the Final EIR ................................................................................. 1.0-2

2.0 C OMMENTS AND RESPONSES TO COMMENTS ON THE DRAFT EIR

2.1 List of Commenters ........................................................................................................................ 2.0-1

2.2 Comments and Responses .......................................................................................................... 2.0-1

3.0 M INOR REVISIONS TO THE DRAFT EIR

3.1 Introduction ................................................................................................................................... 3.0-1

3.2 Minor Changes and Edits to the Draft EIR ................................................................................ 3.0-1 TABLES
Table 3.14-15 Existing plus Project PM Peak-Hour Freeway Ramp Operations .............................. 3.0-4

TABLE OF CONTENTS
Roseland Area/ Sebastopol Road Specific Plan and Roseland Area Annexation Projects City of Santa Rosa Final Environmental Impact Report August 2016
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1.0 I NTRODUCTION

1.0 INTRODUCTION
City of Santa Rosa Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation Project August 2016 Final Environmental Impact Report

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This Final Environmental Impact Report ( Final EIR) was prepared in accordance with the California Environmental Quality Act (CEQA) and the State CE QA Guidelines (Section 15132) .

The City of Santa Rosa (City) is the lead agency for the environmental review of the proposed Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation Project (project; proposed project). The City has the principal responsibility for approving the project . This Final EIR assesses the expected environmental impacts resulting from approval and implementation of the proposed project, as well as responds to comments received on the Draft EIR .

1.1 B ACKGROUND AND PURPOSE OF THE EIR

BACKGROUND OF ENVIRONMENTAL REVIEW PROCESS FOR THE PROJECT The following is an overview of the environmental review process for the proposed project that has led to the preparation of this Final EIR.

Notice of Preparation
The Notice of Preparation (NOP) for the Draft EIR was submitted for public review on January 15, 2016, with the review period ending on February 16 , 2016 . A scoping meeting was held on February 1 , 201 6, to solicit input from interested agencies and the public. The City received several comment letters on the NOP and during the public scoping meeting. These comment letters are provided in Appendix 1.0 of the Draft EIR.

Draft EIR
The D raft EIR was released for public and agency review on May 20 , 2016 , with the 45-day review period ending on July 5, 2016 . The D raft EIR contains a d escription of the project, description of the environmental setting, identification of project impacts, and mitigation measures for impacts found to be significant, as well as an analysis of project alternatives . The Draft EIR was provided to interested public agencies and the public and was made available for review at City offices, at the Sonoma County Library (Downtown Santa Rosa and Roseland locations), and on the City’s website.

Final EIR
The City received comment letters from public agencies, interest groups , and the public regarding the Draft EIR . This document responds to the written comments and Planning Commission public hearing comments received during the 45 -day public review period, as required by CEQA . This document also contains minor edits to the Draft EIR, which are included in Section 3.0, Minor Revisions to the Draft EIR . This document, together with the Draft EIR, constitutes the Final EIR.

Certification of the Final EIR/Project Consideration
The City will review and consider the F inal EIR. If the City finds that the Final EIR is “adequate and complete,” the City may certify the Final EIR. The rule of adequacy generally holds that the EIR can be certified if it: (1) shows a good faith effort at full disclosure of environmental information; and (2) provides sufficient analysis to allow decisions to be made regarding the project in contemplation of its environmental consequences.

1.0 INTRODUCTION
Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation Project City of Santa Rosa Final Environmental Impact Report August 2016

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Upon review and consideration of the Final EIR, the City may take action to adopt, revise, or reject t he proposed project . A decision to approve the project would be accompanied by written findings in accordance with State CEQA Guidelines Section s 15091 and 15093 . Public Resources Code Section 21081.6 also requires lead agencies to adopt a mitigation monit oring and reporting program to describe measures that have been adopted or made a condition of project approval in order to mitigate or avoid significant effects on the environment.

1.2 I NTENDED USES OF THE EIR
The EIR is intended to evaluate the environmental impacts of the proposed project to the greatest extent possible and provide for future CEQA streamlining . This EIR, in accordance with CEQA Guidelines Section 15126, addresses the significant environmental effects of the project, any potential growth inducing impacts, proposed mitigation measures and potential alternative and should be used as the primary environmental document to evaluate all planning and permitting actions associated with the project. Please refer to Section 2 .0, Project Description, of the Draft EIR for a detailed discussion of the proposed project.

In addition, it is anticipated that, pursuant to CEQA Guidelines Section 15182, as well as Sections 15152, 15168, and others, this EIR may provide the foundation for evaluation of individ ual projects within the project area. Depending upon the nature and circumstances of such future projects, additional focused environmental review may be required.

1.3 O RGANIZATION AND SCOPE OF THE FINAL EIR
This document is organized in the following manner:

SECTION 1.0 – INTRODUCTION
Section 1.0 provides an overview of the EIR process to date and what the Final EIR is required to contain.

Section 2.0 – COMMENTS AND RESPONSES TO COMMENTS ON THE DRAFT EIR Section 2.0 includes a list of commenters, copie s of written comments (coded for reference) , and the responses to those written and oral comments made on the Draft EIR.

Section 3.0 – MINOR REVISIONS TO THE DRAFT EIR
Section 3.0 provides a list of minor edits made to the Draft EIR as a result of co mments received and other staff-initiated changes.

2.0 COMMENTS AND RESPONSES TO

COMMENTS ON THE DRAFT EIR

2.0 COMMENTS AND RESPONSES TO COMMENTS ON THE DRAFT EIR Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation Project City of Santa Rosa Final Environmental Impact Report August 2016

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2.1 L IST OF COMMENTERS
The following individuals and representatives of organizations and agencies submitted written comments on the Draft EIR.

Letter Agency, Organization, or Individual Date
A Reg Elgin, Dry Creek Rancheria Band of Pomo Indians May 31, 2016 B Brenda L. Tomaras on behalf of the Lytton Rancheria June 2, 2106 C Ken Chiang, California Public Utilities Commission June 2, 2016 D Arthur Deicke June 8, 2016
E Trish and Greg Tatarian June 8, 2016
F Frederick W. Krueger June 9, 2016
G Gabi Shader June 19, 2016
H Curt Groninga June 29, 2016
I Patricia Maurice, California Department of Transportation, District 4 June 30, 2016 J Ashle Crocker June 23, 2016
K Mark Bramfitt, Sonoma Local Agency Formation Commission July 5, 2016 L Kenneth Tam, Sonoma County Regional Parks July 5, 2016 M G.P. Radich July 5, 2016
TR City of Santa Rosa Planning Commission Public Hearing Transcript June 9, 2016

2.2 C OMMENTS AND RESPONSES

REQUIREMENTS FOR RESPONDING TO COMMENTS ON A DRAFT EIR
State CEQA Guidelines Section 15088 requires that lead agencies evaluate all comments on environmental issues received on the Draft EIR and prepare a written response . The written response must address the significant environmental issues raised and must be detailed, especially when specific comments or suggestions (e.g., additional mitigation measures) are not accepted by the lead agency. In addition, there must be a good faith and reasoned analysis in the written response. However, lead agencies need only respond to significant environmental issues associated with the project and do not need to provide all the information requested by commenters, as long as a good faith effort at full disclosure is made in the EIR (State CEQA Guidelines Section 15204).

State CEQA Guidelines Section 15204 recommends that commenters provide detailed comments that focus on the sufficiency of the Draft EIR in identifying and analyzing the possible impacts on the environment and ways in which the significant effects of the project might be avoided or mitigated. State CEQA Guidelines Section 15204 also notes that commenters should include an explanation and evidence supporting their comments. Pursuant to State CEQA Guidelines Section 15064, an effect shall not be considered significant in the absence of substantial evidence supporting such a conclusion.

2.0 COMMENTS AND RESPONSES TO COMMENTS ON THE DRAFT EIR Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation Projects City of Santa Rosa Final Environmental Impact Report August 2016

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State CEQA Guidelines Section 15088 also recommends that where a response to comments results in revisions to the Draft EIR , those revisions be incorporated as a revision to the Draft EIR or as a separate section of the Final EIR.

RESPONSES TO COMMENT LETTERS
Written comments on the Draft EIR are reproduced on the following pages, along with responses to those comments.

Where changes to the Draft EIR text result from responding to comments, those changes are included in the response and demarcated with revision marks (underline for new text, strikeout for deleted text).

2.0 COMMENTS AND RESPONSES TO COMMENTS ON THE DRAFT EIR City of Santa Rosa Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation Project August 2016 Final Environmental Impact Report

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Letter A Reg Elgin, Dry Creek Rancheria Band of Pomo Indians Response A-1: The commenter states that in response to the City’s letter notifying the Dry Creek Rancheria of the proposed project, research was conducted which determined that there are areas of cultural/historic significance on or adjacent to the project site. The commenter requests to open a dialogue with the City regarding the protection of the site’s cultural significance.

In response to the letter, the City sent an email to Mr. Elgin on June 6, 2016 , to the address provided, acknowledging receipt of the letter, sending a link to the Draft EIR, and suggesting times for a meeting. On June 20, 2016, City staff called the phone number provided and left a voice mail message for Mr. Elgin. To date, the City has not received a response.

The existing cultural resource s setting and potential effects of the proposed project are discussed in Sec tion 3.5, Cultural Resources, in the Draft EIR. The Draft EIR (Impact 3.5.2) concluded that the project would have a potentially significant impact on archaeological and tribal cultural resources and included mitigation measures MM 3.5.2a and MM 3.5.2b to reduce the impact to a less than significant level. No further analysis or additional mitigation measures are required.

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Letter B Brenda L. Tomaras on behalf of the Lytton Rancheria Response B-1: The commenter requests that the EIR require further cultural analysis prior to approval of future projects in the project area. The commenter is referred to Impact 3.5.2 in Section 3.5, Cultural Resources , of the Draft EIR. Mitigation measure MM 3.5.2a requires preparation of Phase I archaeological resource studies for future projects that involve ground disturbance. Mitigation measures MM 3.5.2b and MM 3.5.3b require measures to protect any archaeological resources or human remains that are discovered during c onstruction of such future projects. City staff responded to the initial email comment , dated June 2, 2016, indicating that mitigation measures were included in the Draft EIR. In a follow-up email to City staff dated June 3, 2016, the commenter stated the Draft EIR mitigation measures “look great.” No further analysis, or additional mitigation measures are required.

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Letter C Ken Chiang, California Public Utilities Commission Response C-1: The commenter states that the project area contains active at -grade railroad crossings and requests that the Draft EIR include mitigation measures requiring future development projects in the vicinity of rail right -of-way to consider rail safety.

The commenter is referred to Specific Plan Goal PBN-3 and associated policies regarding safety along and across the Sonoma-Marin Area Rail Transit (SMART) corridor. These policies would ensure that the City coordinates with SMART on future improvements that affect the SMART corridor, to ensure safe railway crossings for all users. No additional mitigation measures are warranted.

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Letter D Arthur Deicke
Response D-1: The commenter provides several comments regarding the proposed Specific Plan. The comments do not address issues related to the adequacy of the Draft EIR. No further response is required.

Response D-2: The commenter states that the maps in the Draft EIR do not show two small streets (Deep Harbor Lane and Rising Moon Lane) south of Hearn Avenue at Sally Ann Street.

These streets were recently constructed and are not yet included in available mapping databases. These new streets do not sig nificantly change traffic or circulation. The adequacy of the Draft EIR is not affected by the inclusion or exclusion of these streets in Draft EIR figures. N o change in the Draft EIR is required.

Response D-3: The commenter states that the discussion of the proposed annexation areas on page 3.12-1 in the Draft EIR does not include the Roseland and Victoria areas.

As defined in Section 2.0, Project Description, in the Draft EIR, the term Annexation Areas used throughout the Draft EIR refers to the portions of the project area that are located outside of the Specific Plan area. Where the Draft EIR refers to the Specific Plan area, that reference includes the Roseland and Victoria areas. No change to the Draft EIR is necessary.

Response D-4: The comm enter disagrees with the statement on Draft EIR page 3.13-1 that upon incorporation the annexation areas would no longer be served by the California Highway Patrol (CHP).

The annexation areas would continue to be served by the CHP as applicable and may be served by the Sonoma County Sheriff’s Office under a mutual aid agreement with the Santa Rosa Police Department ( SRPD). Service transition may take time beyond the annexation date. The third paragraph of Draft EIR page 3.13-1 has been revised as follows:

The majority of the project area is currently served by the Santa Rosa Police Department (SRPD). The unincorporated islands in the project area are currently served by th e Sonoma County Sheriff’s Office and the California Highway Patrol; upon annexation, these areas would be primarily served by the SRPD only.

Response D-5: The commenter states that the Draft EIR does not discuss the Sustainable Groundwater Management Act (SGMA).

The following text is added to page 3.9-9 in the Draft EIR between the Porter - Cologne Water Quality Control Act and the General Construction Activity Storm Water Permits subheadings:

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Sustainable Groundwater Management Act
California enacted legislation in 2014 known as the Sustainable Groundwater Management Act (SGMA). The legislation outlines a framework for sustainable management of groundwater supplies by local authorities, with a limited role for state intervention only if necessary to protect the resource. The act requires the formation of local groundwater sustainability agencies (GSAs) that must assess conditions in their local water basins and adopt locally based management plans. GSAs are to be formed by June 2017, with groundwater management plans to be adopted several years later.

The Santa Rosa Plain Basin Advisory Panel prepared the Santa Rosa Plain Watershed Groundwater Management Plan in 2014.

As discussed in Draft EIR Section 3.9, Hydrology and Water Quality, and Section

3.15, Public Utilities, the City anticipates having surplus water supply in year 2035 and the proposed project’s water demand would be approximately 0.02 million gallons per day (mgd) or 22.4 acre -feet per year (AFY) less than that projected in the City’s 2014 Water Master Plan Update. Therefore, the proposed project would not result in the need to pump more water from the local groundwater basin than assumed in the City’s Urban Water Management Plan (UWMP) or otherwise affect groundwater resources in the region.

Response D-6: The commenter states that the Draft EIR should reflect the recent (June 14, 2016) adoption of the City’s 2015 UWMP.

At the time the Draft EIR was published for public review (May 20, 2016), the City Council had not yet adopted the City’s 2015 UWMP. Thus, the data and conclusions of the 2015 UWMP could not be relied upon during development of the Draft EIR. The City’s 2015 UWMP indicates sufficient water supply will be available to meet all demands under normal hydrologic conditions through year 2040. In addition, based on reliability modeling prepared by the Sonoma County Water Agency ( SCWA), SCWA concluded that the single -dry year hydrologic condition will result in an adjusted 14 percent demand reduction for the City that will be necessary to meet available supply. Under this scenario, the City would reduce demands by enacting the appropriate stage of its Water Shortage Contingency Plan included as part of the City’s 2015 UWMP. Thus, the recent adoption of the 2015 UWMP does not affect the conclusions of the Draft EIR and no revisions are warranted.

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Letter E Trish and Greg Tatarian
Response E-1: The commenter s express general concern about the project regarding the level of proposed development, pedestrian safety, and lack of adequate parkland.

The commenter s are referred to the following detailed responses regarding these concerns.

Response E-2: The commenters state that higher-density development is being concentrated in the Roseland area and provide population growth data for the Roseland area, the City of Santa Rosa, and Sonoma County to support this assertion. The comment does not address issues related to the adequacy of the Draft EIR. No further response is required.

Response E-3: The commenters support new development along Sebastopol Road and north along the Joe Ro dota Trail but do not support development along Burbank Avenue. There is also a reference to proposed land use change s along Hearn Avenue from Medium Density Residential to Medium High Density Residential and Transit Village Medium, and along Burbank Avenue from Very Low Density Residential to Medium Low Density Residential. The commenter s state that the Burbank Avenue area should remain designated Very Low Residential to support parkland and the roadway’s current County designation as a scenic roadway.

To clarify, pursuant to Figure 3 -1 (Land Use Map) in the Specific Plan, the proposed land use changes along Hearn Avenue include the following:
• Change from Medium Density Residential to Medium High Density Residential along the north side of Hearn Avenue, near the intersection of Stony Point Road; and
• Change from Medium Density Residential and Medium Low Density Residential to a mix of Medium High Density Residential and Public Institutional on the south side of Hearn Avenue, adjacent to Southwest Community Park.

The Specific Plan does not include a proposal to add the Transit Village Medium land use designation on Hearn Avenue.

Further, the commenters’ reference to a land use change along Burbank Avenue from Very Low Density Residential to Medium Low Density Residential is not accurate. The only land use changes proposed along Burbank Avenue are as follows:
• The existing Roseland Creek Elementary School site will be changed from Low and Medium Density Residential to Public Institutional, to recognize the existing school;
• The future location of Roseland Creek Community Park, on the east side of Burbank Avenue (across from Roseland Creek Elementary School),

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will be changed from Medium Density Residential to Parks and Recreation; and
• An area on the east side of Burbank Avenue (south of the proposed Roseland Creek Community Park) will be chang ed from Medium Density Residential/Retail and Business Services to Medium Low Density Residential, consistent with the existing land use designation of the adjacent properties.

The commenters’ support and objections to development in specific locations in the project area are noted. No development is currently being proposed as part of this project and no development would be approved with approval of the project. As discussed in Impact 3.1.2 on Draft EIR page 3.1 -21, future development along Burbank Avenue would be subject to Santa Rosa General Plan Goal T -G and associated policies , which serve to protect the scenic quality of designated scenic roadways in the city by requiring large setbacks and special design considerations. In addition, the proposed Spec ific Plan includes special street designs for Burbank Avenue , including narrower travel lanes, no on -street parking, and either landscape buffers or vegetated bioswales (see Draft EIR Figure 2.0-9).

Furthermore, as discussed in Impact 3 .13.3.1 on Draft EIR pages 3.13-13 and

3.13-14, the project would redesignate approximately 16.4 acres of land from residential to the Parks and Recreation land use category, allowing additional parks to be development that will serve area residents. The additional land for parks would exceed the 1.7 acres required by the City’s park standards for the additional 282 residents that would potentially be added at buildout of the Specific Plan. This acreage includes Roseland Creek Community Park, which is already in the planning stages in one of the areas proposed for redesignation.

Response E-4: The commenters indicate that “Figure 10, Planned and Proposed Development in the Plan Area” does not include two currently proposed development projects within plan area and thus is an inaccurate account of planned residential units in the plan area. The commenter s reiterate that affordable, high-density housing should be distributed throughout the c ity and not concentrated in one area.

The Draft EIR does not include a Figure 10 or a figure titled Planned and Proposed Development in the Plan Area. The referenced Figure 10 is from the April 15, 2015 Market Analysis, prepared for the Specific Plan by Strategic Economics (Appendix B to the Roseland Area/Sebastopol Road Specific Plan Existing Conditions Report, dated June 2015). The commenters are referring to the Lantana Place and Stony Village North projects.

The Lantana Place project was approved by the Santa Rosa Design Review Board on November 19, 2009. Per the Santa Rosa Zoning Code, Design Review approvals are valid for two years, unless a time extension is requested and approved. The applicant did not request a time extension for the project, and, as a result, the project approval expired on November 19, 2011.

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The Stony Village North project was submitted to the Planning and E conomic Development Department i n December 2014, and deemed complete in January 2015. The pending development list identified in Figure 10 of the Market Analysis was developed based on 2014 information from the City and County of Sonoma, prior to the submittal of the Stony Village North project.

The comment does not address issues related to the adequacy of the Draft EIR.

No further response is required.

Response E-5: The commenters state that the addition of new roads connecting to Burbank Avenue would worsen existing traffic congestion during drop- off and pick -up times at Roseland Creek Elementary School.

As shown in Impact 3.14.1 on Draft EIR pages 3.14 -28 and -33, the proposed project would have a less than significant impact on operations a long the major corridors in the plan area . In general, the addition of the proposed roadways would create a more complete and efficient roadway network that would allow for more evenly distributed vehicle trips, thus reducing congestion.

This would also allow motorists to choose an alternate route to avoid regular areas of congestion. No further analysis or additional mitigation measures are required.

Response E-6: The commenter s state that the proposed connection of Northpoint Parkway and Hearn Avenue near Burbank Avenue would direct heavy, high -speed traffic through the plan area, reducing safety for pedestrians and bicyclists and negatively impacting the scenic character.

As discussed in Impact 3.14.7 on D raft EIR pages 3.14-37 through -39, pedestrian, bicycle, and transit levels of service are expected to improve compared to existing conditions on almost every roadway segment analyzed in the Draft EIR, including along Burbank Avenue and the adjacent segment of Hearn Avenue. The project includes numerous improvements to enhance pedestrian and bicycle circulation and safety , including new sidewalks and crossings, increased visibility, and slower vehicle speeds. Thus, implementation of the proposed project is expected to improve safety for all modes of transportation in the plan area . The commenters are referred to Response E -3 regarding the scenic quality of the Burbank Avenue corridor. No further analysis or additional mitigation measures are required.

Response E-7: The commenters disagree with the conclusions of the Draft EIR regarding the provision of parkland in the plan area and assert that existing parkland is not sufficient to serve the existing population, nor is there sufficient planned parkland to serve the project ed population. The commenters also cite City of Santa Rosa General Plan Policy PSF-A-5, which describes the City’s priorities for the location and type of future park development.

The commenters are referred to S ection 3.13, Public Services, in the Draft EIR.

The City’s parkland standard is 6 acres per 1,000 residents including 3.5 acres of developed parkland, 1.4 acres of school recreational land, and 1.1 acres of open space. According to the City’s General Plan, the City currently meets or exceeds these standards. It should be noted that the City’s parkland standard is citywide and the City does not mandate where the required parkland is to

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be located. Thus, residents within t he plan area can be served by parkland located outside of the plan area.

In order to meet the parkland demands of the c ity’s projected population resulting from buildout of the General Plan, the City identified numerous potential neighborhood and communit y p ark s ites (see General Plan Figure 6-1) throughout the city , including eight neighborhood parks and one community park within the plan area . One of these planned parks is currently in the planning stages of development. However, t he locations of these p arks shown on General Plan Figure 6 -1 are approximate and will be refined as individual projects are planned.

As discussed in Response E-3, the project would increase the population of the area beyond that projected in the General Plan by approximately 282 residents. Based on the City’s parkland standard, this population increase would increase parkland demand beyond that identified in the General Plan by 1.7 acres . The increased demand generated by the project would be addressed through the proposed redesignation of 16.4 acres of land from Residential to Parks and Recreation, allowing for future park development.

Therefore, according to the City’s parkland standard, there is currently sufficient parkland available to serve the existing population , and the project would ensure there is sufficient planned parkland to serve the projected population under both the Santa Rosa General Plan and the proposed project.

No further analysis or additional mitigation is required.

Response E-8: The commenters state that additional parkland could be provided within the plan area through the creation of natural parks or open space , which could also eliminate the need to mitigate for the loss of wildlife habitat, specifically for California tiger salamander . The commente rs also suggest a youth - recreation-only park on Burbank Avenue across from Sheppard Middle School.

The Draft EIR identified mitigation measure MM3.4.1a, which requires future project to incorporate the avoidance and mitigation measures described in the San ta Rosa Plain Conservation Strategy and the USFWS Programmatic Biological Opinion (see Draft EIR page 3.4-27). Implementation of this measure would ensure no net loss of habitat or species, which would be a less than significant impact. Thus, the recommendation in the comment is not required to reduce a significant effect identified for the project. No further analysis or additional mitigation is required..

Response E-9: The commenter s reiterate their comment that a higher proportion of renter - occupied units are located in the plan area and that the project would result in excessive traffic, reduced safety, and loss of parkland.

This is not a comment on the adequacy of the Draft EIR. See Responses E-3 and E-7 regarding the commenters’ co ncerns regarding parks, Response E -6 regarding pedestrian and bicycle safety, and Responses E-5 and E-6 regarding traffic.

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Letter F Frederick W. Krueger
Response F-1: The commenter states that the air quality data presented in the Draft EIR is inadequate, as it is too broad and does not focus on the Sebastopol Road corridor. The commenter summarizes some findings of an EIR published in 2006 regarding traffic operations in the project area.

The commenter is not clear about which data is considered inadequate and does not provide alternative data. The Draft EIR includes a programmatic analysis of the proposed project ’s air quality impacts. Future development projects and roadway improvements would require further CEQA review of project-level traffic impacts , and associated air emissions, prior to implementation. No further analysis or additional mitigation is required.

Response F-2: The commenter states that the traffic analysis is inadequate because it fails to consider traffic generat ed by other planned projects, such as relocation of Roseland School, in addition to that of the proposed project.

Draft EIR pages 3.14-46 through -51 analyze traffic impacts under the Future plus Project scenario. This scenario considers buildout in the region and the entire project area, including all planned projects and roadway improvements. No further analysis or additional mitigation is required.

Response F-3: The commenter describes existing areas of traffic congestion in the project area and suggests that conditions could be improved by widening all of Sebastopol Road to four lanes and restricting left turns from existing driveways.

As shown in Draft EIR Table 3.14-12 on page 3.14-28, the segment of Sebastopol Road within the project area currently operates acceptably at level of service (LOS) C or better consistent with City standards. As discussed in Draft EIR Impact

3.14.1 on pages 3.14 -28 through - 33, the addition of project traffic would not degrade operations along this segment of Sebas topol Road to an unacceptable level. No mitigation is required. The comment is noted.

Response F-4: The commenter states that existing traffic congestion on Sebastopol Road interferes with emergency response and the addition of project traffic would worsen this condition . The commenter believes that the Draft EIR does not adequately address this issue.

The proposed project’ s potential effects on emergency response a re addressed in Draft EIR Impact 3.8.5 on pages 3.8-13 and -14 and Impact 3.14.5 on page 3.14- 36. Current and projected traffic conditions in the project area are discussed in Draft EIR Section 3.14, Traffic and Transportation.

As discussed on these pages , the addition of project -related traffic would not substantially degrade traffic operation on local streets within the project area (see Draft EIR Impact 3 .14.1 on pages 3.14- 28 through -33) . Additionally, the proposed Specific Plan includes new streets that would improve connectivity within the project area, creating new routes for all users, including emergency responders. Furthermore, the Santa Rosa Fire Department would review construction plans for roadway improvement projects and establish temporary alternative emergency routes as necessary. The Draft EIR adequately

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addresses the issue of emergency response and no modifications are warranted.

Response F-5: The commenter states that the Roseland area has grown at a faster pace than the remainder of the city without a proportional increase in infrastructure.

The Priority Development Area Profile developed for the 1,800 acre plan area notes that the Plan Area population increased 76% between 1990 and 2013 as compared to the City of Santa Rosa, which grew 49% during that period. This growth is partially related to growth in the southern plan area. The conditions that the commenter describes represent existing conditions that are not caused by the proposed project. No further analysis or mitigation is required.

Response F-6: The commenter describes incidents of asthma among schoolchildren at Roseland Elementary School on Sebastopol Road and states that diesel exhaust from traffic congestion is the cause , citing a n unreferenced 2009 medical study. The commenter further states that increased development in the area would increase traffic, thus worsening health conditions.

Mobile sources (e.g., automobiles and diesel- fueled trucks) associated with project operation would generate toxic air contaminants (TACs), but based on the Cal ifornia Air Resources Board’s ( CARB) Air Quality and Land Use Handbook: A Community Health Perspective, traffic from local roads in the project area would not be high enough to produce TACs that would cause adverse health effects for sensitive receptors. F or mobile sources, CARB’s handbook identifies only high traffic freeways and roads, including urban roads with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day, as a source of TACs that could present a potentially significant health risk (CARB 2005). None of the roadways in the project area would carry these volumes.

Draft EIR Impact 3.3.6 on pages 3.3-36 through -50 considered effects of toxic air contaminants, including mobile-source diesel emissions. The Draft EIR found the primary mobile sources that could affect the project area would be the US Highway 101 (US 101) corridor and the State Route ( SR) 12 corridor. Mitigation measure MM 3.3.6 is included to reduce the risk of exposure to any development that would occur in the project area by requiring site -specific analysis to determine the level of health risk and implementing measures to reduce the risk to below thresholds. No further analysis or additional mitigation is required.

Response F-7: The commenter states that the location of the school bus parking lot in proximity to Roseland Elementary School exacerbates health problems associated with diesel exhaust.

The commenter describes an existing condition within the project area.

Emissions associated with existing bus trips contribute to the local ambient air quality data provided in Draft EIR Table 3.3-2 on page 3.3-3, which serves as the basis for the project’s air quality impact analysis . The Bay Area Air Quality Management District has set standards for acceptable levels of criteria air pollutants including particular matter (the primary pollutant generated by diesel engines). As discussed in Impact 3.3.2, the proposed project would not violate these standards or contribute substantially to an existing violation.

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Response F-8: The commenter states that no additional traffic should be permitted within the project area until air quality is improved and describes various potential societal effects of poor air quality.

See Responses F-6 and F-7.

Response F-9: The commenter states that any additional housing units approved along Sebastopol Road or Hearn Avenue should be very low density due to the insufficient transportation capacity in the area. The comment does not address issues related to the adequacy of the Draft EIR. See Responses F-3 and F-4 for a discussion of the commenter’s concerns about traffic. No further response is required.

Response F-10: The commenter states that existing traffic congestion along Sebastopol Road causes accidents and traffic violations at intersectio ns. There is no evidence in the record to suggest that there would be an increase in accidents as a result of the project. Please also see Response F-3. No further response is required.

Response F-11: The commenter states that there is insufficient on -street parking in the project area and requests code enforcement to regulate parking. The comment does not address issues related to the adequacy of the Draft EIR. No further response is required.

Response F-12: The commenter cites the National Recreation and Parks Association, which has a national park standard of 10 acres per 1,000 residents. The commenter further states that the City’s parkland standard of 6 acres per 1,000 residents is inadequate, that the Roseland area does not have sufficient existing parkland, and that planned development in Roseland would eliminate the potential for new park development. The commenter also describes the various societal benefits of parks. The commenter further asserts that the failure of the project to designate more la nd for park development represents racial and environmental injustice.

The issue of parks and recreational facilities is discussed in Draft EIR Section 3.13, Public Services , on pages 3.13 -9 through -15. The Quimby Act, discussed on Draft EIR pages 3.13-10 and -11, establishes parkland standards in California at 3 to 5 acres per 1,000 residents. The National Recreation and Parks Association, cited by the commenter, is a private , nonprofit organization. It does not set standards for the provision of parkland that must be applied by local jurisdictions, and there is no requirement that the City achieve this ratio.

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per 1,000 residents, which consists of 3.5 acres of parkland per 1,000 residents plus 1.4 acres of school recreational land and 1.1 acres of public-serving open space. As of January 2015, the parkland ratio for the City was 3.8 acres of parkland per 1,000 residents, which exceeds the standard. The Draft EIR (Impact 3.13.3.1) determined that Santa Rosa , as a whole, currently meets its adopted parkland standard and that the proposed project would provide sufficient additional land for future park development to serve the project’s projected population increase. It should also be noted that parks and recreational facilities are permitted in most residential zones , and additional

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neighborhood parks are designated by the Draft Specific Plan and General Plan.

As discussed in Response E-3, the project would increase the population of the area beyond that projected in the General Plan by approximately 282 residents. Based on the City’s parkland standard, this population increase would increase parkland demand beyond that identified in the G eneral Plan by 1.7 acres. The proposed redesignation of 16.4 acres of land from Residential to Parks and Recreation, which would allow for future park development , would satisfy the parkland needs created by the potential buildout of the Specific Plan.

Response F-13: The commenter describes observations and concerns with regards to homelessness in the Roseland area. The comment does not address issues related to the adequacy of the Draft EIR. No further response is required.

Response F-14: The commenter sta tes that the City should spread higher -density housing across the entire c ity rather than concentrating it in the Roseland area and expresses concerns for public safety and the need for a general grocery store and more open space. The comment does not addr ess issues related to the adequacy of the Draft EIR. No further response is required.

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Letter G Gabi Shader
Response G-1: The commenter summarizes Draft EIR traffic-related findings.

On page s 3.14-33 and -34, the Draft EIR acknowledges that the addition of project traffic would result in a significant and unavoidable impact to mainline freeway operations on northbound US 101 between Todd Road and SR 12. The comment is noted.

Response G-2: The commenter summari zes her understanding of the Draft EIR traffic -related findings, stating that multiple surface streets and freeway ramps currently operate at unacceptable levels, which is not accurate. The commenter asserts that the addition of project traffic would make the project area unlivable and that traffic would be backed up most of the day , thus conflicting with the quality of life objective.

Draft EIR pages 3.14 -3 through -8 summarize existing traffic operation levels of service within the project area . As shown in Table 3.14 -2, all four of the arterial corridors in the project area currently operate acceptably at LOS D or better, meeting the City’s operational standards. As shown in Table 3.14 -4, all studied freeway ramps also currently operate acceptably at LOS C or better.

As discussed on Draft EIR pages 3.14 -28 through - 33 (see Table 3.14- 13), the addition of project traffic would not degrade the level of service to an unacceptable level on local roadway segments ; therefore, the impact was determined to be less than significant. Impact 3.14.2 on Draft EIR page 3.14-34 found that the mainline freeway on northbound US 101 between Todd Road and SR 12 currently operates at an unacceptable level and the project would increase traf fic density by more than 1 percent, which was considered a significant impact. Widening SR 12 would reduce the impact, but due to constraints related to right-of-way acquisition, this was determined to be infeasible. No other mitigation is available, so th is impact was considered significant and unavoidable.

Impact 3.14.3 on Draft EIR page 3.14- 35 found off-ramp queues would extend onto the mainline freeway due to spillback from upstream signals and capacity constraints created by the existing two -lane Hearn Avenue freeway overpass and would degrade freeway ramp operations at the southbound US 101 freeway off- ramp at Hearn Avenue. The Draft EIR disclosed that the City is currently in the environmental phase of Caltrans project approval for the Hearn Avenue overpass widening project, which would ultimately alleviate adverse queuing conditions. However, because the project would not be complete under Existing plus Project conditions, the proposed project’s impacts were considered significant and unavoidable in the near term. In the future conditions with the overpass project, this impact would be less than significant.

With respect to cumulative impacts, Impact 3.14.11 on Draft EIR page 3.14 -48 determined that freeway study segments of US 101 and SR 12 are expected to operate unacceptably even without traffic from the project, but increases in freeway density from the project would exceed 1 percent on northbound US 101, eastbound SR 12, and westbound SR 12. For this reason, the project’s impact was considered significant. Widening would reduce the impact, but it

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would require major reconstruction of multiple freeway structures, right -of-way acquisition including many homes and businesses, closure or relocation of city streets paralleling the freeway corridor, and substantial environmental impacts associated with the construction. This impact was therefore considered significant and unavoidable. No further analysis or additional mitigation is required.

Response G-3: The commenter supports consideration of Project A lternative 2 (Reduced Development Alternative). The commenter believes that the project’s objectives to increase quality of life and to achieve desired building densities are in conflict. The commenter further suggests that the City implement Alternative 2, allowing one-third of the proposed development now and the rest of the proposed development after planned roadway and freeway improvements are completed.

This is not a comment on the adequacy of the Draft EIR. The comment is noted.

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Letter H Curt Groninga, Member, Planning Commission, City of Santa Rosa The comment letter includes comments on the Specific Plan document and the Draft EIR. Specific Plan–related comments will be addressed by staff in the staff report and in public meetings. The responses below focus on comments related to the environmental analysis in the Draft EIR.

Response H-1: The commenter suggests that a courtesy letter be sent to the owners of properties listed in Draft EIR Appendix 3.8 regard ing the hazardous materials contamination identified on the properties to notify them that remediation may be required prior to development.

The issue of existing hazardous materials contamination within the project area is addressed in Draft EIR Impact 3.8.4 on pages 3.8 -10 through -13. Mitigation measure MM 3.8.4a requires preparation of a Phase I Environmental Site Assessment prior to development of any property within the project area, so such notification would be required for all properties in the projec t area.

Notification in conjunction with publication of this Draft EIR would not be practical, especially since the timing of any development in the project area is not known at this time. It should also be noted that preparation of a Phase I ESA is a common practice as part of the development process, as a Phase I ESA is the vehicle by which buyers and lenders perform and document their due diligence. The Phase I ESA investigation would include property owner notification and interviews. This mitigation me asure, in addition to MM 3.8.4b, would reduce the impact to a less than significant level and no additional mitigation is warranted.

Response H-2: The commenter concurs with the findings in the Aesthetics section of the Draft EIR. No response is required.

Response H-3: The commenter concurs with the findings in the Agriculture and Forest resources section of the Draft EIR. No response is required.

Response H-4: The commenter states that the Draft EIR should discuss any current efforts being taken to resolve the identified transportation and stationary source health risks listed in Draft EIR Tables 3.3-9 and 3.3-11.

The issue of exposure to toxic air contaminants is addressed in Draft EIR Impact

3.3.6 on pages 3.3-36 through -46. The comment refers to existing facilities that contribute to the existing stationary source health risks in the project vicinity.

Because these are existing uses, the Draft EIR cannot impose mitigation to reduce emissions at these sources, unless a new discretionary action is requested at those particular facilities. At the time a request that requires a discretionary action by the City occurs at any of these properties, the City would require compliance with Draft EIR mitigation measure MM 3.3.6, which would reduce TAC and PM

2.5 exposure. In addition, t he Bay Area Air Quality
Management District (BAAQMD) is responsible for enforcing air quality regulations in the project area , including those related to toxic air contaminants. Those air quality regulations applicable to the proposed project are described in Draft EIR subsection 3.3.2. These plans, programs, and regulations are intended to improve air quality in the region and assist the basin in achieving the adopted standards for criteria air pollutants , thus reducing associated health risks. No further analysis or additional mitigation is required.

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Response H-5: The commenter suggests that construction documents for future projects under the proposed Specific Plan require monitoring of construction-phase air quality mitigation measure implementation and hold contractors liable for any fees or penalties resulting from air quality violations.

As discussed in Impact 3.3.3 (Draft EIR pages 3.3-29 through -33), all construction projects would be subject to BAAQMD rules and regulations adopted to reduce air pollutant emissions. Construction projects would also be subject to Draft EIR mitigation measure MM 3.3.3, which requires that construction projects also implement BAAQMD basic construction mitigation measur es, as well as additional measures outlined in the BAAQMD Guidelines, as specified in the mitigation measure . In addition to City enforcement, c onstruction projects would be subject to BAAQMD inspection as part of the air district’s permit requirements. The Santa Rosa Engineering Development Services Grading Inspector or Building Inspector would also be aware of dust issues and require the contractor to use water or other dust control methods to prevent dust from going off-site as part of the Standard Urban Storm Water Mitigation Plan and CALGreen compliance criteria.

Response H-6: The commenter suggests that Draft EIR Table 3.3 -9 on pages 3.3-38 and -39 be revised to more prominently identify the existing air quality violation at US 101 Link 652.

The text on Draft page 3.3-36 has been revised as follows:

Mobile Sources
The primary mobile sources affecting the project area include the US 101 corridor and the SR 12 corridor. Per BAAQMD guidance, all other sources within 1,000 feet of a proposed sensitive receptor need to be identified and analyzed. According to the BAAQMD’s (2012a) Highway Screening Analysis Tool, three segments of US 101 and two segments of SR 12 are located adjacent to the project area. These segments have been modeled for health risk by the BAAQMD. Table 3.3-9 identifies the PM

2.5 concentration,
cancer risk, and non- cancer hazard index exposure at distances of 10 through 1,000 feet from the segments of US 101 and SR 12 in locations adjacent to the project area. As shown in the table, of the highway segments identified, one (US 101 Link 652) is estimated to have predicted cancer risks in excess of the BAAQMD’s risk threshold for PM2.5 at 10 feet from the source. At 25 feet from this highway, the cancer risk for PM 2.5 is below the threshold.

Response H-7: The commenter suggests that the Draft EIR identify any measures currently implemented to address the existing air quality violations identified in Draft EIR Table 3.3 -11 (Stationary Source Health Risks) on pages 3.3 -42 through -44.

Mitigation being implemented by existing construction projects is outside the scope of the Draft EIR. Please see Response H-4.

Response H-8: The commenter asks how the City monitors operational construction mitigation measures to ensure compliance. Please see Response H-5.

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Response H-9: The commenter asks what mitigation measures are currently being implemented to address the air quality violations identified in Draft EIR Table

3.3-9 and Table 3.3-11. Please see Response H-5.

Response H-10: The commenter suggests that the City utilize where possible and appropriate outside conservation organizations to assist with implementation of conservation mitigation measures such as Draft EIR mitigation measure MM

3.4.2b on page 3.4-30. The comment does not address issues related to the adequacy of the Draft EIR. No further response is required.

Response H-11: The commenter asks if the City would consider approving development within the tiger salamander habitat identified in the project area and what regulatory processes would be involved with such an approval.

The proposed land plan for the project area (see Draft EIR Figure 2.0 -7) would allow development in areas designated as habitat for California tiger salamander. However, no specific projects are proposed as part of the project, and approval of the project would not allow any development project to proceed. Future development projects would be required to comply with all applicable mitigation identified for the project. As described in Draft EIR mitigation measure MM 3.4.1a on page 3.4-27, development projects in or near areas with suitable habitat for California tiger salamander would be subject to the avoidance and mitigation measures described in the Santa Rosa Plain Conservation Strategy and the US Fish and Wildlife Service ( USFWS) Programmatic Biological Opinion.

Response H-12: The commenter asks whether eligibility of newly annexed neighborhoods as historic districts, would be based upon the date of establishment of the neighborhood or the date of annexat ion. Eligibility as a historic resource or district is based upon the age of that resource or district. The date of annexation is not a factor for eligibility.

Response H-13: The commenter suggests that applicable public school earthquake standards including the Field Act should be referenced in Draft EIR Section 3.6, Geology and Soils.

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Act between the Seismic Hazards Mapping Act and the California Building Code subheadings:

Field Act
The Field Act was enacted on April 10, 1933 , after the Long Beach earthquake in which 70 schools were destroyed, 120 schools suffered major damage, and 300 schools had minor damage. The act requires the following:
• School building construction plans be prepared by qualified California licensed structural engineers and architects.

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• Designs and plans be checked by the Division of the State Architect (DSA) for compliance with the Field Act before a contract for construction can be awarded.
• Qualified inspectors, independent of the contractors and hired by the school districts, continuously inspect construction and verify full compliance with plans.
• The responsible architects and/or structural engineers observe the construction periodically and prepare changes to plans (if needed) subject to approval by the DSA.
• Architects, engineers, inspectors , and contractors file reports, under penalty of perjury, to verify compliance of the construction with the approved plans emphasizing the importance of testing and inspections to achieve seismically safe construction. Any person who violates the provisions or makes any false statement in any verification report o r affidavit required pursuant to the act is guilty of a felony.

The addition of this text does not alter the findings of the Draft EIR or result in any new significant impacts. No further analysis or additional mitigation is required.

Response H-14: The commenter concurs with the findings in the Greenhouse Gas Emissions section of the Draft EIR. No response is required.

Response H-15: The commenter concurs with the findings in the Hazards and Hazardous Materials section of the Draft EIR. No response is required.

Response H-16: The commenter references Draft EIR Impact 3.9.6 on pages 3.9 -21 and -22, which identifies potential effects of cumulative development on water quality, runoff, and flooding. The commenter suggests the Draft EIR should note that a private organization, the Laguna de Santa Rosa Foundation, works with the City and other local and state agencies to protect water quality in the region from the effects of growth.

The comment references the impact statement, which is intended to summarize the impact discussion that follows. A reference to the Laguna de Santa Rosa Foundation in this context would not be appropriate because it does not substantially contribute to the reduction of impacts as described in the Draft EIR. The Foundation’s efforts to restore and conserve the Laguna de Santa Rosa are noted.

Response H-17: The commenter concurs with the findings in the Land Use section of the Draft EIR. No response is required.

Response H-18: The commenter asks if the number of planned daily passenger trains on the Sonoma-Marin Area Rail Transit (SMART) system used in the Draft EIR noise analysis (see Draft EIR Section 3.11, Noise) is still accurate. The information in the Draft EIR is based on a 2016 informational brochure for the SMART project, which states trains will operate in both directions every 30 minutes during peak commute hours, with a midday trip . This information is consistent with the

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information provided on the S MART website as of August 2016 (See http://main.sonomamarintrain.org/).

Response H-19: The commenter concurs with the findings in the Population and Housing section of the Draft EIR. No response is required.

Response H-20: The commenter suggests that the Draft EIR discuss the potential reuse of the vacated site once Santa Rosa Fire Department (SRFD) Station #8 is relocated.

Relocation of SRFD Station #8 is discussed in Draft EIR subsection 3.13.1, Fire Protection, Emergency Medical, and Law Enforcement Service s, on pages

3.13-1 and -4. The station’s current site is designated by the Draft Specific Plan and Santa Rosa General Plan 2035 as Retail/Medium Density Residential, which would allow a variety of retail uses and medium -density housing. There is currently no development proposal for the site . I f it is vacated , a future development project could be proposed consistent the site’s existing land use designation.

Response H-21: The commenter suggests that the Draft EIR describe higher education services provided by Santa Rosa Junior College (SRJC) and Sonoma State University on existing elementary school campuses within the project area. The commenter notes previous personal discussions with City staff regarding a potential collaboration between SRJC and the Mult i-Cultural Center envisioned in the Santa Rosa General Plan 2035.

Based on the relatively small anticipated increase in population attributed to the proposed project compared to G eneral Plan assumptions (282 residents), the project would not substantially increase demand for higher education services in the project area. The issue does not warrant further evaluation in the Draft EIR.

Response H-22: Potential alternative land uses for Santa Rosa Fire Department Station # 8, the status of discussions related to Santa Rosa Junior College and City of Santa Rosa facilities, and planning between local school districts are not within the scope of the EIR and are not related to potential physical impacts of the project. No response is required.

Response H-23: The commenter concurs with the analysis provided in Draft EIR Section 3.14, Traffic and Transportation, as well as the related traffic impact study provided as Appendix 3.14. The commenter notes that the identified deficiencies at the Hearn Avenue overpass and the Dutton Avenue w estbound off-ramps are existing conditions and that the proposed project alone would not trigger the need for the identified improvements at those location s. The commenter further states that the Hearn Avenue overpass widening and Dutton Avenue westbound off-ramp widening projects should be given top priority and must be implemented regardless of project approval.

Draft EIR page 3.14- 35 acknowledges the existing deficiency at the southbound US 101 Hearn Avenue off-ramp and discusses the proposed Hearn Avenue overpass widening project , which is already in the environmental phase of Caltrans project approval and will proceed regardless of the outcome of the proposed project. Impact 3.14.3 was determined to be

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significant and unavoidable because this improvement project would not be completed prior to approval of the proposed project.

As discussed on Draft EIR page 3.14 -50, the identified deficiency at the westbound SR 12 Dutton Avenue off -ramp would occur under cumulative (existing plus project plus future growth) conditions. Thus, widening of the Dutton Avenue westbound off -ramp would be triggered only in part by the proposed project and would be implemented as part of the City’s overall Capital Improvement Program, in collaboration with Caltrans.

Response H-24: The commenter notes that pedestrian and bicycle levels of service are deficient along several corridors and segments in the project area , as noted on Draft EIR page 3.14-12.

The comment refers to existing conditions in the project area that are not a result of the project. With regard to the condition of sidewalks, as discussed in Response E -6, t he project includes numerous improvements to enhance pedestrian and bicycle circulation and safety, including new sidewalks and crossings, increased visibility, and slower vehicle speeds. Thus, implementation of the proposed project is expected to improve safety for pedestrians and bicyclists.

The other comments related to trails, bus schedules, and SMART fees are not comments on the adequacy of the EIR. Any changes in funding priorities for SCTA are not within the scope of the EIR. No response is required.

The comment refers to the findings related to multimodal levels of service in the project vicinity discussed on Draft EIR pages 3.14-8 through -12. No response is required.

Response H-25: The commenter asks approvals of the Hearn Overpass Project and Highway 12 at Dutton Avenue affect SCTA’s funding priorities, the extent to which plans to extend and connect the Roseland Creek and Colgan Creek to the Laguna de Santa Rosa trail are developed and coordinated, and if a statement of overriding considerations for the project’s significant and unavoidable traffic impacts identified in Draft EIR Section 3.14, Traffic and Transportation, would be required to implement the identified traffic mitigation.

SCTA’s funding priorities and coordination with external entities regarding trail connections are not physical impacts of the project and are, therefore, outside the scope of the EIR. Because the proposed project would generate or contribute to impacts that would be considered significant and unavoidable, a statement of overriding considerations would be required pursuant to CEQA Guidelines Section 15093 if the EIR is certified and the propose d project is approved. If the EIR is not certified and the project is not approved, a statement of overriding considerations is not required. In a scenario in which the EIR is not certified and the proposed project is not approved, the mitigation measures contained in the EIR would not be implemented. However, it should be noted that the Hearn Avenue overpass widening project is already in the environmental phase of Caltrans project approval and is expected to proceed regardless.

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Response H-26: The commenter concurs with the findings in the Public Utilities section of the Draft EIR. No response is required.

Response H-27: The commenter asserts that, given the existing conditions described in Draft EIR Section 3.14, Traffic and Transportation, the identified traffic deficiencies exist with or without the project and the associated mitigation measures should be implemented regardless. Mitigation measures identified for a proposed project are not required to be implemented if the project is not approved.

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Letter I Patricia Maurice, California Department of Transportation (Caltrans), District 4 Response I-1: The commenter summarizes the proposed project characteristics. This comment does not address the analysis in the Draft EIR.

Response I-2: The commenter recommends that the City condition the proposed project to pay its fair share of the cost to construct the Hearn Avenue overpass widening project.

The City has been actively working toward identifying funding for the Hearn Avenue i nterchange project, which has been a lo ng-planned improvement that predates the proposed project and was identified in the Santa Rosa General Plan 2035 and the Sonoma County Transportation Authority’s Comprehensive Transportation Plan. As discussed on Draft EIR page 3.14-42, the City has recently been collaborating with Caltrans in preparing a Project Approval and Environmental Document (PA&ED) for the overpass project.

Caltrans’ acceptance of the PA&ED is one of the critical steps needed to pursue funding sources to complete the improvement project. Chapter 6 (page 6-2) of the proposed Specific Plan also outlines the implementation and financing strategies: “Priority Action A: Identify Funding for the Hearn Avenue Overcrossing” is listed as a priority project and is d escribed as , “Identify all possible funding sources and financing mechanisms to construct the Hearn Avenue overcrossing of US Highway 101, including grants, fees, and regional funds.” Potential funding sources identified in the implementation strategy include development impact fees, One Bay Area Grants (OBAG), Caltrans, the City’s General Fund, and the Traffic Relief Act for Sonoma County (Measure M).

Because the Specific Plan is a long -range planning document that will guide the development of many individual projects over a 20-year period, rather than an individual development project, there is no mechanism to condition a fair share contribution to the Hearn Avenue overpass widening project as recommended by the commenter. Rather, the City will seek multi ple funding sources, including the use of development impact fees that will effectively allow developments within the plan area and surrounding areas to contribute their fair share of funding toward completing the project. As indicated by the commenter and as described on Draft EIR page 3.14- 36, however, under theoretical Existing plus Project traffic conditions before the overpass widening project is complete, a potential significant and unavoidable impact may occur.

Response I-3: The commenter requests th at the City coordinate with Caltrans on implementation of Draft EIR mitigation measure MM 3.14.12, widening the westbound SR 12 off-ramp at Dutton Avenue.

Mitigation measure MM 3.14.12 states, “The City shall collaborate with Caltrans in obtaining approvals to comple te the widening project.” The City acknowledges that the design of the ramp modifications would need to be approved by Caltrans and that an encroachment permit would be required prior to commencing any work.

Response I-4: The commenter requests clarification for why high occupancy vehicle (HOV) lanes are excluded from the freeway analysis on Draft EIR page 3.14-2.

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The freeway analysis methodology uses industry -standard methodologies established by the Transportation Research Board in the Hig hway Capacity Manual 2010 (HCM). The Freeway Facilities methodology incorporates the operations of several different freeway components , including individual freeway segments, ramp merge, ramp diverge, and waving areas, all of which heavily influence the freeway’s capacity and operation. While the HCM methodology does not explicitly include the effects of HOV lanes, HOV facilities by design and intent typically operate substantially better than the mainline.

When determining the potential significance of a proje ct, analysis of a freeway’s non-HOV components therefore represents t he most conservative and “worst-case” condition.

Response I-5: The commenter requests clarification and further information on the future US 101 projects that are mentioned on Draft EIR page 3.14 -27, including a full project description, funding status, and projected completion date.

The Draft EIR refers to future US 101 widening projects in southern Sonoma County. These projects are collectively referred to by the Sonoma County Transportation Authority (SCTA) and Transportation Authority of Marin (TAM) as the Marin-Sonoma Narrows (MSN). The project has been broken up into sub- segments with separate completion time frames and funding sources. Segment B2 includes new bridges over the Petalum a River, new frontage roads, and a reconstructed interchange at Petaluma Boulevard South. The project is under construction and is anticipated to be complete by October 2016. Segment B3 will realign a portion of US 101 near San Antonio Creek and the Marin -Sonoma county line. The project is under construction and anticipated to be complete in 2017. Sonoma Segment B will add HOV lanes from the county line to Petaluma Boulevard South. Design is complete and funding is being pursued by the SCTA, though no completion date has been set. Marin Segment B will extend HOV lanes from the county line to existing HOV lanes through Petaluma between Old Redwood Highway and Highway 116. Design is nearly complete and funding for right-of-way has been secured, though remaining construction funds are still being pursued by the SCTA, and no completion date has been set.

Response I-6: The commenter requests clarification on the inconsistent level of service (LOS) data provided in Draft EIR Table 3.14 -15 and on page 41 of the traf fic impact study in Appendix 3.14 for the southbound US 101/Hearn Avenue intersection.

The identified inconsistency is a typographica l error in Draft EIR Table 3.14-15, which has been revised to be consistent with the traffic impact study, as follows:

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TABLE 3.14-15

EXISTING PLUS PROJECT PM PEAK-HOUR FREEWAY RAMP OPERATIONS Freeway Interchange
Intersection Operations Off-Ramp Queuing
Existing
Delay/LOS
Plus Project
Delay/LOS
Available
Storage
Existing
Max. Queue
Plus Project
Max. Queue
SR 12/Stony Point Road
Westbound 30.1/C 29.0/C29.1/C 930 466 332
Eastbound 10.6/B 15.8/B 710 243 229251
SR 12/Dutton Avenue
Westbound 23.1/C 31.2/C 990 409 909
Eastbound 14.1/B 16.6/B 770 126 148
US 101/Baker Avenue
Northbound 31.4/C 30.6/C 810 152 144
Southbound 9.9/A 18.0/B 340 163 132
US 101/Hearn Avenue
Northbound 33.0/C 33.7/C 960 183 190
Southbound 16.7/B 22.3/C17.3/B 620 495 1059
Source: W-Trans 2016
Notes: Delay is measured in seconds; LOS = level of service; Max Queue is the averaged maximum queue observed in 10 SimTraffic model runs measured in feet; bold = queuing exceeds available storage Response I-7: The commenter requests clarification as to whether A M peak-hour data was considered in the traffic impact study (TIS).

The traffic study included analysis of both AM peak-hour and PM peak-hour conditions for all scenarios. Results for roadway segments (which rely on intersection LOS calculations) as well as mainline freeway operations are presented throughout the TIS for both peak hours. Because PM peak-hour operation was determined to represent worst -case conditions at the freeway ramps (particularly at the Hearn Avenue interchange , which is heavily influenced by nearby retail traffic), the TIS and Draft EIR tables report ramp intersection and queuing results only for the PM peak hour. However, full calculations for the AM peak hour are also included in the TIS in Draft EIR Appendix 3.14 for reference (TIS Appendix C contains queuing calculations).

Response I-8: The commenter states that any work or traffic control that encroaches onto the state right -of-way requires an encroachment permit issued by Caltrans. This comment does not address the analysis in the Draft EIR, and no further response is required.

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Letter J Ashle Crocker, Member, Planning Commission, City of Santa Rosa Commissioner Crocker was unable to attend the June 9, 2016 , Planning Commission meeting at which time the public hearing for the Draft EIR was held. Comments given at the public hearing on June 9, 2016 are addressed in L etter M. Commissioner Crocker provided comments at the Planning Commission hearing on June 23 , which are addressed below. The comments address both the Specific Plan document and the Draft EIR. Specific Plan –related comments will be addressed by staff in the staff report and in public meetings. The responses below focus on comments related to the environmental analysis in the Draft EIR.

Response J-1: The commenter suggests consideration of the City’s overarching policies in the EIR as well as the addition of new policies ; however, the commenter did not provide specific examples of such polic ies. As s uch, a detailed response cannot be provided. Each technical section of the Draft EIR contains a list of General Plan policies that are relevant to implementation of the proposed project. Where appropriate, proposed Specific Plan policies are also identified in the impact analysis with an explanation of the policy’s effectiveness in reducing potential environmental impacts of implementing the Specific Plan.

As required under CEQA, the Draft EIR is required to identify any inconsistency with General Plan policies in the Environmental Setting. With the proposed General Plan amendment, no inconsistencies are expected to occur as a result of implementing the proposed project. Under CEQA, the EIR is not required to evaluate or recommend policy direction. The comments, however, are noted.

Response J-2: The commenter recommends that the Draft EIR and the Specific Plan provide additional explanation as to how both documents may be used to streamline future projects so the City may help incentivize future private development. The purpose of the Draft EIR is to disclose the environmental impacts of implementing the Specific Plan and the annexations . The commenter’s suggestion that the EIR include more information about streamlining is acknowledged; however, it is not the purpose of the Draft EIR to develop a specific implementation process for future individual projects under the Specific Plan. The Draft EIR does describe some potential streamlining opportunities for environmental review in S ubsection 1.3, Intended U ses of the EIR. The commenter notes that some citations to pertinent regulations in the Draft EIR concerning CEQA streamlining may be incorrect and some should be added but did not identify which ones should be corrected or added. As such, no further response is possible on this topic.

Response J-3: The commenter notes that the Draft EIR did not analyze vehicle miles traveled (VMT) and speculates this is because there is no official CEQA guidance at this time. The Draft EIR considers VMT but does acknowledg e that there are currently no standards for vehicles miles traveled. Page 3.14-25 in Section 3.14, Traffic and Transportation, describes the legislative background for the analysis, and as noted in the comment and stated in the Draft EIR, the State has not set forth standards by which to determine whether VMT impacts would be significant. In addition, neither the City nor the Sonoma County Transportation Authority has adopted a standard for VMT.

While a goal or standard was not applied for VMT, the Draft EIR does quantify VMT for existing conditions, General Plan buildout, and Specific Plan buildout.

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The results are presented in Table 3.14-10 on page 3.14-26 in Section 3.14 of the Draft EIR, along with an explanation of the results. Although an impact level of significance was not made for VMT, this does not diminish the importance of the analysis and its usefulness for future projects under the Specific Plan.

Establishing VMT goals or standards would be more appropriate in the context of the entire General Plan area, considering regional VMT levels and goals, rather than establishing standards that would apply only to the project area.

Response J-4: The commenter notes that CEQA’s provision for tiering may not be available for individual projects in all cases if the project has significant and unavoidable impacts. Subsequent projects proposed in the project area would be required to comply with CEQA prior to project approval, but the extent of analy sis and type of document would depend on the specifics of the project that is proposed. Given the project’s significant and unavoidable air quality and traffic impacts, some tiering provisions may, in fact, be limited in application.

A number of CEQA pro visions, however, allow reliance on previous analysis to reduce the amount of new analysis required for the subsequent project. For instance, CEQA Guidelines Section 15162 allows the preparation of a subsequent EIR or negative declaration where the subsequ ent project could have new significant impacts or impacts that are substantially more severe than shown in the previous EIR, or if changed circumstances or new information indicates that such impacts may occur. CEQA Guidelines Section 15163 allows the prep aration of a supplement to an EIR where only minor additions or changes would be necessary to make the previous EIR adequately apply to the subsequent project.

Pursuant to CEQA Guidelines Section 15164, an addendum can be prepared for a subsequent project where some changes or additions to the EIR are necessary, but none of the conditions described in Section 15162 calling for preparation of a subsequent EIR have occurred. Residential projects undertaken pursuant to and in conformity with a Specific Plan can be exempt from further environmental analysis if none of the conditions described in Section 15162 have occurred (Guidelines Section 15182). CEQA Guidelines Section 15183 provides that projects that are consistent with the development density established by existing zoning, community plan, or general plan policies for which an EIR was certified shall not require additional environmental review unless the lead agency determines there are project-specific significant effects that are peculiar to the projec t or its site. It is unclear what additional steps, if any, may be required under these provisions in light of the significant and unavoidable impacts identified in the original EIR.

Given the generalized nature of the traffic analysis, however, a project-specific traffic analysis will generally be required for future projects to determine impacts related to each project , required local roadway improvements, and fair-share fees toward programmed traffic improvements. The traffic analysis would also likely include project-specific VMT. At such time that VMT standards are adopted (by the City or the California Governor’s Office of Planning and Research), Future projects would need to demonstrate compliance with the adopted standard. If the analysis determines that the project -specific VMT achieves the newly adopted standard, a determination may be made that the project does not trigger the need for further environmental review with respect to VMT impacts and one of the provisions noted above may apply . If th e

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adopted VMT standard is exceeded, however, a further environmental review would be required to address the potential for a new significant impact.

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Letter K Mark Bramfitt, Sonoma Local Agency Formation Commission Response K-1: The commenter summarizes the Sonoma Local Agency Formation Commission’s (LAFCO) interest in the proposed project and the annexation approval process. The Draft EIR (Section 1. 0, Introduction; S ubsection 2.3, Project Objectives; and Subsection 2.5, Regulatory Requirements, Permits, and Approvals) acknowledges LAFCO’s role in the proposed project. This is not a comment on the adequacy of the Draft EIR and no response is required.

Response K-2: The commenter summarizes the content s of an environmental doc ument necessary for Sonoma LAFCO to act on a proposed annexation (consistency between the proposed land use and the City’s General Plan designation, traffic and circulation impacts, infrastructure impacts related to the capacity of city water, sanitation, and flood control systems to support proposed density; impacts on the provision of other public services that the City provides such as fire and police; and impacts in meeting local housing needs, if appropriate ).

The commenter states that the Draft EIR appears to address these areas, with indications that sufficient water and wastewater system capacity exists to serve the proposed annexation areas and that proposals for development will include infrastructure improvements. This is not a comment on the adequacy of the Draft EIR and no response is required.

Response K-3: T he commenter notes the traffic and circulation issues appear to remain major impacts and recommends that the project contribute to a regional fund to mitigate traffic impacts on neighboring jurisdictions. The commenter cites an example of a recent annexation project in Rohnert Park approved by Sonoma LAFCO, which was conditioned to contribute to such a regional traffic fund.

As discussed in the Draft EIR, the project area was considered for development in the City’s General Plan, so regional traffic generated from the project area has already been considered in regional plans. The proposed project also differs from the example cited in the comment in that the example is a largely undeveloped 100-acre site that would be a new source of traffic at the edge of Rohnert Park. Here, the proposed project would consist of infill development in a largely developed portion of Santa Ros a. Traffic impacts of the proposed project are disclosed in Section 3.14 of the Draft EIR, which determined proposed project traffic would contribute to impacts on local highways, but would not substantially impact traffic in other jurisdictions.

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Letter L Kenneth Tam, Sonoma County Regional Parks
Response L-1: The commenter refers to Table 2.0 -1 (Proposed Roadway Modifications and Configurations), which indicates that the current limits of Roberts Avenue on either side of SR 12 will be maintained under the Specific Plan. This would be a change from the General Plan, which identifies a street extension and connection under SR 12. The commenter expresses agreement with the Specific Plan’s proposal.

It should be noted that, at the July 14, 2016 Planning Commission meeting, during a discussion regarding an unrelated proposed development project on Roberts Avenue, the Commission unanimously moved to direct staff to return with a realignment option for Roberts Avenue with the Specific Plan project , rather than elimination of the connection. The proposed realignment would extend Roberts Avenue straight (north/south) under US Highway 12, rather than the curvilinear route under the existing US Highway 12 overpass, as currently depicted in the 2007 Downtown Station Area Specific Plan. The realignment would eliminate a second crossing of the Joe Rodota Trail, which would address the commenters stated concerns regarding negative impacts on the Trail.

Based on that direction, the text on Table 2.0 -1 on page 2.0-18 in the Draft EIR is changed as follows:

Roadway Description General Plan Consistency
Roberts Avenue Maintain current limits of street on either side of SR 12 Extend Roberts Avenue, straight north/south, to connect under SR 12, rather than the curvilinear route, under the existing SR 12 overpass, depicted in the 2007
Downtown Station Area Specific Plan
Change from Consistent with the
General Plan, which shows street
extension and connection under
SR 12

The presence of the Roberts Avenue connection would have no consequential effect on the EIR traffic analysis. No further response is required.

Response L-2: The commenter supports proposed Specific Plan Policy PBN-2.4 (listed on page

3.3-19 in the Draft EIR), which would enhance safety at the intersection of the Joe Rodota Trail and Stony Point Road. This is not a comment on the Draft EIR analysis, and no further response is required.

Response L-3: The commenter suggests that proposed Specific Plan Policy PBN -2.5 (listed on page 3.3-22 in the Draft EIR) be revised to include language about minimizing vehicle cross -flow traffic by limiting the number of proposed driveways and new roads crossing Class I bike paths and trails. This is not a comment on the Draft EIR analysis. The commenter’s suggestion is noted.

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Letter M GP Radich
Response M-1: The commenter states the less than significant conclusion in the Draft EIR related to water supply is incorrect given the current drought conditions .

As discussed in Responses D-5 and D-6, the proposed project’s water demand would be approximately 0.02 million gallons per day (mgd) or 22.4 acre -feet per year (AFY) less than that projected in the City’s 2014 Water Master Plan Update and the project would not affect groundwater resources in the region.

The Draft EIR relied upon the City’s 2010 UWMP, but the City Council adopted the City’s 2015 UWMP on June 14, 2016 after the May 20, 2016 release date of the Draft EIR . The City’s 2015 UWMP indicates sufficient water supply will be available to meet all demands under normal hydrologic conditions through year 2040. In addition, based on reliability modeling prepared by the Sonoma County Water Agency (Agency), the Agency c oncludes that the single -dry year hydrologic condition will result in an adjusted 14 percent demand reduction for the City that will be necessary to meet available supply. Under this scenario, the City would reduce demands by enacting the appropriate stage of its’ Water Shortage Contingency Plan included as part of the City’s 2015 UWMP. Therefore, the less than significant conclusion in the Draft EIR regarding water supply is appropriate.

Response M-2: The commenter notes that low density residential would be a more appropriate land use for areas identified as Farmland of Local Importance or Prime Farmland.

As discussed on Draft EIR page 3.2 -7, there is no Prime Farmland in the project area. While future development in these areas would result in the conversion of Farmland of Local Importance to non -agricultural use (Draft EIR page 3.2 -7), these properties were previously designated for urban uses in the General Plan.

A change in the land use designation in these areas would not reduce or alter the effect of conversion to non-agricultural use. Therefore, the suggested land use change would have no mitigating effect.

Response M-3: The commenter expresses concern about the increase in paved areas resulting in additional flows into Colgan Creek, as well as local climate change .

As discussed in Impact 3.9.3 and Draft EIR pages 3.9-18 and -19, future projects would be conditioned to include dedication, improvement, and maintenance of stormwater flow and retention areas. Projects would also be required to implement erosion and sediment control measures to maintain an operational drainage system and preserve drainage capacity. S ubsequent projects in the project area would also need to demonstrate conformance with the applicable policies in the Santa Rosa Citywide Creek Master Plan, such as Policies SW-2-1 through SW-2-3, which require new development to comply with the City’s NPDES stormwater permit and the Storm Water Low Impact Development Technical Design Manual. As discussed in Impact 3.9.4 on Draft EIR pag es 3.9 -19 and -20, every private development project would be required to comply with Sonoma County Water Agency flood control criteria, including preparation of hydrology and hydraulic calculations, maps, and a report. All culverts and drainage systems in the City of Santa Rosa are required

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to be designed to accommodate the runoff from a 10-year recurrence interval storm event and protect finished floors from the 100 -year recurrence interval storm. The City also requires that features be included in proje ct design to demonstrate that the storm system has capacity to accommodate any increased flows resulting from the proposed project, or that upgrades to the system are made. Compliance with these existing requirements would ensure that new development would not negatively affect stormwater flows.

With respect to increased temperatures at paved areas, the term climate change as used in the comment is not the same as climate change as analyzed in the Draft EIR. As discussed in Draft EIR Section 3.7, climate change refers to a phenomenon in which human activities change climate on a global scale.

Response M-4: The commenter states the Bellevue Avenue overpass should be constructed prior to allowing new development to occur.

Traffic conditions under the existing conditions and existing -plus-project conditions did not assume construction of the Bellevue Avenue overpass in the short term, because the overpass is not considered for construction in the short term. As noted on Draft EIR page 3.14- 41, the Bellevue Avenue overpass was considered in the traffic analysis for the cumulative conditions.

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Transcript - TR City of Santa Rosa Planning Commission – Transcript of Public Hearing on Specific Plan and Draft EIR (June 9, 2016)
The Santa Rosa Planning Commission held a public hearing on the Specific Plan and the Draft EIR on June 9, 2016. Comments from the public were accepted on both the Specific Plan and the Draft EIR. Responses have been prepared for comments that pertain to environmental impacts or that specifically address the Draft EIR. Comments on the Specific Plan that are not germane to the analysis of environmental impacts do not require responses in this Final EIR, as provided under CEQA. Specific Plan–related comments will be addressed by staff in the staff report and in public meetings. For completeness, however, all individuals who offered comments during the public hearing are noted below. For ease of reference, responses are organized by the name of the individual commenter.

Duane DeWitt
Response TR-1: The commenter expresses concern that paving over the southwest area could affect groundwater recharge. The Draft EIR evaluated groundwater recharge impacts in Impact 3.9.2 on pages 3.9-17 and -18. As stated in the Draft EIR, the areas of potential future development in the project area are generally limited to vacant and underutilized parcels. Most of the parcels in the project area are planned for lo w-density residential and open space, which would allow continued on- site percolation of runoff. Higher -density development is generally limited to corridors along Sebastopol Road and Hearn Avenue, which, to a large extent, are mostly developed. No develop ment would be allowed within the floodways of Colgan and Roseland creeks, which are identified as primary areas of recharge in the city. Therefore, the proposed project would not be anticipated to significantly alter groundwater recharge.

Further, the aquifer is much larger than just the southwest area. As stated in the Draft EIR (page 3.9-1), the Santa Rosa Plain Subbasin of the Santa Rosa Valley Groundwater Basin covers an area of 80,000 acres, or approximately 125 square miles. The Santa Rosa area's Nati onal Pollutant Discharge Elimination System ( NPDES) storm water permit (Order No. R1-2009-0050) regulates both storm water and non -storm water discharges into the Santa Rosa municipal storm drain system. The intent of the permit is to reduce storm water pollution and protect the water quality of local creeks and waterways and continue to promote groundwater recharge. Compliance with the permit would further reduce potential for impacts on groundwater.

Response TR-2: The commenter su ggests 60 to 70 more acres of parks are needed and that school districts’ land is available. Please see Responses E-3 and F-12.

Chris Meyer
This commenter did not provide any comments on the Draft EIR or raise significant environmental issues that should have been considered.

Arthur Deicke
Response TR-3: The commenter states he submitted an email with comments concerning perceived errors and omissions in the Specific Plan and Draft EIR. Responses to

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comments on the Draft EIR in the commenter’s email can be found in Responses D-2 through D-6.

Response TR-4: The commenter notes there will be significant and unavoidable traffic impacts.

The Draft EIR evaluated traffic impacts and concluded there would be significant and unavoidable freeway mainline impacts under existing plus project and cumulative conditions (Impacts 3.14.2 and 3.14.11, respectively) and significant and unavoidable impacts at the southbound US 101 freeway off-ramp at Hearn Avenue under e xisting plus project conditions (Impact

3.14.3). The City will consider adopting a statement of overriding considerations for these impacts as required under CEQA Guidelines Section 15093.

Sam McMillan
Response TR-5: The commenter expresses concern that there will be more significant impact s to residents as a result of the Hearn Avenue overpass widening. The commenter did not submit any documentation indicating how this would occur. Widening the Hearn Avenue overpass is identified on pag e 6-2 of the Specific Plan as a “high priority” project, and the City of Santa Rosa is actively pursuing funding to complete the widening and associated interchange improvements. With these improvements, a considerable reduction in congestion on the Hearn Avenue corridor is expected. Because there would be less congestion, localized air quality impacts (e.g. , exhaust odors) would be expected to decrease, not increase. Also see Response TR-7 regarding widening the Hearn Avenue overpass. As construction of improv ements occur, the city and Caltrans will work with area residents and businesses in design/construction to minimize local impacts. With regard to fumes generated at stop signs in the area, as discussed in Response F -6, none of the roadways in the project a rea would carry traffic volumes that would present a potentially significant health risk.

Response TR-6: The commenter asks whether the traffic study took into consideration the possible Yolanda/Farmers Lane extension. This project was included in the traffic modeling and analysis for the cumulative scenarios. It is a roadway link that is identified in the City’s 2035 General Plan and is included as Project 708 in the City’s Capital Improvement Program. It has been designed , but no construction date has been set.

G. P. Radich
Response TR-7: The commenter makes some general observations about traffic conditions in the Victoria Drive/Hearn Avenue area and how conditions could be further degraded with the project.

The existing congestion encountered at the Victoria Drive/Hearn Avenue intersection is acknowledged in the Draft EIR on page s 3.14- 3 and - 4 when describing the bottleneck condition created by the existing two -lane Hearn Avenue overpass. Widening the Hearn Avenue overpass is identified on page 6-2 of the Specific Plan as a “high priority” project, and the City of Santa Rosa is actively pursuing funding to complete the widening and associated interchange improvements. With these improvements, a considerable

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reduction in congestion on the Hearn Avenue corridor is expected, with less potential for queuing to extend through the Victoria Drive intersection. City General Plan Policy T -D-1 requires level of service analysis to be conducted along major corridors. Determining corridor LOS considers the influen ces of signalized intersections, but not unsignalized intersections like Victoria Drive/Hearn Avenue. While the City does not maintain LOS standards for unsignalized intersections, potential issues or impacts are still captured in many cases through corrid or LOS analyses, which reveal the need for capacity improvements along arterials like Hearn Avenue. Additionally, as shown in the Specific Plan and summarized in Table 13 of the traffic impact study (Draft EIR Appendix 3.14), the Specific Plan includes widening Hearn Avenue to include two travel lanes in each direction plus a center turn lane between the SMART rail corridor and Dutton Avenue, which is the segment that includes the Victoria Drive intersection. This improvement will help maintain traffic flow and reduce the potential for vehicle queues to block Victoria Drive, as currently happens.

Implementation of the project would, therefore, be expected to improve conditions at the Hearn Avenue/Victoria Drive intersection rather than cause them to worsen, though as with any minor street intersection along a major arterial, delays are still likely to be encountered by drivers waiting to turn left from Victoria Drive onto Hearn Avenue during peak traffic periods. Based on the City’s LOS criteria and applied significance thresholds, such delays would not be considered to represent an environmental impact.

Response TR-8: The commenter notes she was unable to find a definition of the term “less than significant” in the Draft EIR. As stated on page 3.0-3 in Section 3.0, Introduction to the Analysis, “A less than significant impact would cause no substantial change in the environment. No mitigation is required.” Draft EIR page 3.0-3 also provides explanations of other terms used to described the envir onmental effects of the proposed project.

Response TR-9: The commenter suggests that animals could be affected by construction, which should be considered. Draft EIR Section 3.4, Biological Resources, describes the types of terrestrial wildlife and aquatic species that may be present in the various habitats throughout the project area and the potential impacts on those species. The Draft EIR (Impacts 3.4.1 and 3.4.2 on pages 3.4- 26 to -28) specifically addresses animal species that are protected by laws and regulations and identifies mitigation measures to ensure species are protected during construction act ivities and thereafter . Impact 3.4.5 (page 3.4 -31) evaluates potential effects on wildlife corridors, particularly those in undisturbed open space.

Frank Baumgardner
The commenter did not provide any comments on the Draft EIR or raise significant environmental issues that should have been considered.

Fred Krueger
Response TR-10: The commenter, representing the Hughes Avenue Neighborhood Association, is of the opinion that the Draft EIR is too academic and “legalistic” and is not personalized to Roseland. Section 1.0, Introduction, in the Draft EIR explains the purpose of the EIR and its legal requirements. An EIR must be factual, accurate,

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and objective and its conclusions supported by substantial evidence. The Draft EIR fully complies with CEQA requirements.

Response TR-11: The commenter states that the Draft EIR measured ambient air across Santa Rosa. The Draft EIR reported ambient air quality measurements collected by the Bay Area Air Quality Management District, as stated on page 3.3 -2 in Section 3.3, Air Quality that monitors air quality throughout the basin . The local ambient air quality data are summarized in Table 3.3-2 on page 3.3-2.

The commenter describes i ncidents of asthma among schoolchildren in the project area and states that diesel exhaust from traffic congestion is the cause, citing a New York University 2009 medical study. The commenter further states that increased traffic would increase agents that trigger asthma and that these hazards are not documented in the Draft EIR. Table 3.3 -1 on page 3.3-2 in the Draft EIR summarizes the health effects of criteria air pollutants. The table notes that one of the effects of particulate matter is as thma. Page 3.3-5 in the Draft EIR, under the Sensitive Receptors subheading, acknowledges that children are particularly sensitive to air pollution. This comment reiterates concerns stated in the commenter’s written letter submitted to the City. Please see Responses F-6 and F-7, which substantiate that EIR mitigation measure 3.3.6 would ensure measures are implemented to reduce health risks to below thresholds and ensure that the proposed project would not violate BAAQMD standards or cause significant health impacts.

Response TR-12: The commenter asserts the project area does not have enough parks and that adding housing will obviate the possibility of new places for parks. This comment reiterates concerns stated in the commenter’s written letter submitted to the City. Please see Response F -12. New housing would not be located in places that would eliminate a planned park site.

Response TR-13: The commenter states there is a severe groundwater overdraft problem that is causing subsidence. The commenter did not submit any documentation to substantiate the statement. According to the City’s 2015 Urban Water Management Plan (UWMP) adopted in June 2016, the groundwater basin underlying Santa Rosa is not in an overdraft condition, nor is it anticipated to become o verdrafted. In addition, the 2014 Santa Rosa Plain Watershed Groundwater Management Plan discusses GPS data that has been collected as part of a monitoring effort to detect tectonic movement. Three GPS stations are located within the watershed and have revealed a single location where a few millimeters of subsidence have been recorded southwest of Cotati while the other two locations have demonstrated no changes in land surface elevation. W hether the changes are related to tectonic movement, groundwater ext raction, or other factors has not been examined and this would not affect the adequacy of the Draft EIR.

Magdalena Ridley
The commenter did not provide any comments on the Draft EIR or raise significant environmental issues that should have been considered.

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Tom Shader
Response TR-14: The commenter expresses concern about the height of housing in the Medium Density Residential/Retail and Business Services land use designation behind his property and opines that is would be visually intrusive. This comment d oes not specifically address the adequacy of the analysis in the Draft EIR and reflects the commenter’s opinion about the land use designation. The Draft EIR includes a programmatic evaluation of aesthetics impacts in Section 3.1, Aesthetics.

While a Master Plan was developed and approved by the City for this area, a specific development project has not been proposed that would adjoin the commenter’s property, and it would be speculative for the Draft EIR to identify what building heights would be proposed for that site and what associated impacts would result. At the time a specific development proposal is submitted to the City, it would be required to demonstrate compliance with the City’s Zoning Code regulations and Design Guidelines, and the site plan and building design would be made available to the public for review and comment prior to the issuance of any approvals, among other requirements.

Response TR-15: The commenter notes that access to the park site on Dutton Meadow is constrained by the roadway configuration in the vicinity of Hearn Avenue/Victoria Drive. This is an existing condition. The Draft EIR is not required to identify mitigation to remedy an existing condition , but it is required to evaluate if the proposed project would worsen an existing condition. See Response TR-7 regarding operations at the Hearn Avenue/Victoria Drive intersection, which shows widening Hearn Avenue to include two travel lanes in each direction plus a center turn lane between the SMART rail corridor and Dutton A venue will help maintain traffic flow and reduce the potential for vehicle queues to block Victoria Drive. The project would, therefore, be expected to improve conditions at the Hearn Avenue/Victoria Drive intersection rather than cause them to worsen.

Gabi Shader
Response TR-16: The commenter presents comments about Alternative 2 (Reduced Development Alternative) and the analysis presented in Section 4.0, Alternatives, in the Draft EIR, focusing primarily on traffic considerations, and makes a general comment questioning the purpose of the EIR. See also Reponses to Letter G, submitted by the commenter.

As stated on page 4.0 -1 in the Draft EIR, the primary intent of the alternatives analysis is to disclose other ways that the objectives of the proposed project could be attained while reducing the magnitude of, or avoiding, the proposed project’s environmental impacts. The Reduced Development Alternative is intended to eliminate the impact on freeway operations on US 101 North between Todd Road a nd SR 12. The traffic study for the project determined that development in the project area would result in an increase in delays from existing conditions by approximately 3 percent; an increase of greater than 1 percent is considered significant. In order to reduce the impact to less than significant, this alternative assumes a reduction in development intensity in the project area to one-third of that proposed by the project. The Draft EIR (page

4.0-9) concluded the Reduced Development Alternative is cons idered to be

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the environmentally superior alternative. It was determined to have the fewest negative impacts on the physical environment and would have less adverse environmental impacts than the proposed project. However, given the substantial reductions in development intensity required to achieve the reductions in impacts to a less than significant level, the resulting development may not achieve densities required to meet the project objectives related to transit-supportive land uses. In addition, although the reduced densities in the project area would result in fewer impacts generated in the project area, the inability to accommodate planned growth in this portion of the c ity may induce growth in other areas and result in similar impacts elsewhere in Santa Rosa or the region. The extent of impacts outside the project area have not been analyzed.

The analysis of the proposed project ’s environmental impacts, along with a comparative analysis of the Reduced Development Alternative’s analysis presented in the Draft EIR, is to present an objective analysis to the public and decision-makers about the potential environmental impacts of the project and its alternatives, as required by CEQA. It is not the purpose of the Draft EIR to advocate for approval of the project or any of the alternatives.

Gregory Fearon
The commenter did not provide any comments on the Draft EIR or raise significant environmental issues that should have been considered.

Ron Lopez
The commenter did not provide any comments on the Draft EIR or raise significant environmental issues that should have been considered.

Peter Bruce
Response TR-17: The commenter offers personal observations about traffic conditions on Hearn Avenue, particularly during PM peak hours, and how traffic congestion affects access to properties, which could also affect emergency response. This comment of a general nature addresses existing traffic conditions. The Draft EIR (page 3.14-4 in Section 3.14, Traffic and Transportation) acknowledges that the segment of Hearn Avenue near US 101 typically operates poorly during peak hours due to the bottleneck created by the existing two -lane overpass, even though the overall segment from Stony Point Road to Santa Rosa Avenue operates at levels of service during the peak hours that are considered acceptable based on City standards . The Draft EIR is not required to identify mitigation to correct existing problems, but it is required to evaluate whether the addition of project traffic would worsen conditions such that the Hearn Avenue segment in the project area would operate unacceptably. Impact

3.14.1 (page 3.14 -28) evaluates operations on Hearn Avenue during the AM and PM peak hours. Under existing plus project conditions, Hear n Avenue would continue to operate acceptably at LOS D with the project -generated traffic and roadway improvements identified with the proposed project (see Draft EIR Tables 3.14-12 and 3.14-13 on pages 3.14-28 and 3.14-33, respectively).

Widening the Hearn Avenue overpass is identified on page 6 -2 of the Specific

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Plan as a “high priority” project, and the City of Santa Rosa is actively pursuing funding to complete the widening and associated interchange improvements.

With these improvements, a considerable reduction in congestion on the Hearn Avenue corridor is expected, with less potential for queuing, which contributes to the congestion experienced by the commenter. As stated on Draft EIR page

3.14-33, incorporation of the roadway improvements identified in the Specific Plan into the City’s traffic impact fee program or another appropriate long - range funding mechanism, and continued monitoring of corridor operation over time through review of traffic impact studies conducted for proposed development, will ensure this impact is less than significant. The City will continue to work to identify funding mechanisms and monitor corridor operations over time through review and implementation of individual development projects in the project area.

Response TR-18: T he commenter questions where water will come from. S ubsection 3.15.1 , Water, on pages 3.15-1 and -2 in the Draft EIR describes the City’s water supply, which consists of a combination of groundwater and surface water. Impact

3.15.1.1 on Draft EIR page 3.15 -5 evaluates the impacts of project implementation on water supply. The analysis determined that there would be adequate supply to meet existing demands and planned future demands, including the proposed project , and no new or expanded water entitlements would be necessary.

Response TR-19: The commenter asks where sewage will go when houses are built. S ubsection

3.15.2, Wastewater, on Draft EIR pages 3.15-8 and -9 describes the wastewater collection and treatment system in Santa Rosa. All wastewater flow in the project area is collected and conveyed in a gravity sewer system to the Laguna Wastewater Treatment Plant (WTP). Impact 3.15.2.1 on Draft EIR page

3.15-12 evaluates the impacts of project implementation on WTP capacity. As stated on Draft EIR page 3.15-13, there is sufficient capacity in the Laguna WTP, and development of the project area has already been considered in the City’s General Plan 2035 and 2014 Sanitary Sewer System Master Plan Update.

The City’s modeling of the anticipated wastewater flow s in the project area indicates that the proposed project would not worsen existing capacity issues in the City’s conveyance system and would not require any pipe upsizing or other improvements beyond those previously identified in the City’s 2014 Sanitary Sewer System Master Plan Update.

Vicki Duggan, Member, Planning Commission, City of Santa Rosa Response TR-20: The commenter indicates this is a comment on the EIR, referring to “Appendix D, page 5.” The appendix referenced by the commenter (Public Review Draft, City of Santa Rosa Services and Capital Costs Estimates, Roseland Area Annexation) is part of the Infrastructure Report for Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexation (May 5, 2016), which is included in the Draft EIR as Appendix 2.0. The commenter notes no ongoing or one-time costs estimated for the Planning and Economic Development Department associated with plan implementation. This is not a comment on the Draft EIR and does not raise any environmental issue.

2.0-141
Attachments H and J referenced in the comment are attachments to the June 9 Planning Commission staff report, not attachments to the Draft EIR. No response is required.

Response TR-21: The commenter indicates the traffic study did not include much detail on how level of service is calculated for bicyclists and pedestrians , and asks if such information can be quantified.

Pedestrian and bicycle levels of service are presented in the Draft EIR and traffic impact study in order to help communicate the circulation con ditions encountered by these modes upon implementation of the Specific Plan. The methodology used to determine level of service is described on page 3.14 -24 to -25 in the Draft EIR, and the detailed sheets showing the scoring criteria used to assess multimodal levels of service are included in Appendix A of the traffic impact study (contained in Draft EIR Appendix 3.14). In response to the comment, the methodology includes factors that represent the ease of travel, or convenience of travel, for each mode. Pedestrian LOS considers the presence of pedestrian facilities, number of vehicle lanes, quality of and amenities used at crossings, streetscape components (including sidewalk widths, street trees, lighting, and buffers between pedestrians and moving vehicles), and urban context. Bicycle LOS considers the type of bicycle facility present, connectivity to other bike facilities, presence of amenities (bike racks, bike signage), use of bicycle detection at signals, use of innovative bike facility striping techniques, vehicle speeds, and type of on -street parking. No further analysis or additional mitigation is required.

Response TR-22: The commenter refers to the discussion of sites in the project area where soil or groundwater contamination may be present (Draft EIR pages 3.8-1 and -2 and Appendix 3.8, which contains a list of sites ). Potential impacts of development on these sites are evaluated in Impact 3.8.4 on pages 3.8-10 and -11. The word action refers to activities that may be necessary to investigate a s ite to determine if there is contamination and/or to remediate (clean up) the site if contamination is present at levels that could pose a risk to human health or the environment. Action may also refer to the responsibility of an agency to ensure a site is investigated and/or remediated.

Mitigation m easure MM 3.8.4a (Draft EIR page 3.8- 11) directs that sites be investigated and remediated (as necessary) before construction activities can begin. For private property, the investigation and/or cleanup action( s) is typically the responsibility of the property owner who engages a professional consultant to perform the work . The Santa Rosa Fire Department would be responsible for ensuring the actions are implemented and for reviewing and approving work plans and reports. In some cases, the Sonoma County Environmental Health Department, the California Department of Toxic Substances Control , and/or the North Coast Regional Water Quality Control Board may also be involved in an approval and oversight role.

Response TR-23: The commenter refers to the evaluation of noise from existing industrial uses on new residences that may be placed next to them. The Draft EIR (Impact 3.11.1 on pages 3.11 -17 through - 19) evaluated the impacts of stationary noise sources on new receptors. As explained in the analysis, General Plan Policy NS- B-4 requires all new projects proposed for areas with existing noise above 60

2.0-142
dBA to submit an acoustical study prepared by a qualified acoustical consultant. In cases where acceptable or conditio nally acceptable noise thresholds would be exceeded, project proponents would need to incorporate measures, such as adding buffers and/or landscaped earth berms, orienting windows and outdoor living areas away from unacceptable noise exposure, and/or incorporating state -of-the-art structural sound attenuation and setbacks, to reduce noise effects. The need for noise attenuation measures in building construction and project design from any noise source and for all land uses will be determined on a project-by-project basis at the time development is proposed. The City land use compatibility noise standard for all sensitive receptors in the city is 60 dBA L
dn, though noise levels up to 70 dBA are
conditionally acceptable (General Plan noise standards for all la nd uses are summarized in Draft EIR Figure 3.11-2 on page 3.11-14).

Response TR-24: The commenter requests that there be an evaluation of traffic impacts associated with the Victoria Drive/Hearn Avenue intersection. Ple ase see Response TR-7.

Response TR-25: The commenter requests information on whether there would be additional air quality impacts as a result of the Hearn Avenue improvements and Farmers Lane extension. These improvements would help reduce traffic congestion, which would, in turn, reduce vehicle idling that is a source of exhaust emissions.

Please see Responses TR-6 and TR-7.

Hans Dippel, Member, Planning Commission, City of Santa Rosa Commissioner Dippel did not provide any comments on the Draft EIR or raise significant environmental issues that should have been considered.

Casey Edmondson, Member, Planning Commission, City of Santa Rosa Response TR-26: The commenter requests clarification whether traffic level of service improvements are as a result of street improvements or changes in land use proposed for the project.

The Specific Plan identifies land use changes and circulation improvements that will affect the Plan area into the future. The traffic analysis of the Future plus Project scenario includes buildout of land uses that will add new vehicle trips to the circulation network, and also includes completion of roadway, bicycle, pedestrian, and transit circulation improvements identified in the Specific Plan document and the Draft EIR project description. Some of these improvements are intended to rectify existing deficiencies, such as filling gaps in the bicycle and sidewalk networks and improving circulation on Hearn Avenue, while others will help to accommodate planned growth into the future. Buildout of the project area in tandem with the City’s General Plan will also result in more subtle changes that will help area -wide circulation, such as creating a better balance of housing and jobs in s outhwest Santa Rosa, thereby reducing auto reliance and trip lengths. The combination of the Specific Plan’s roadway infrastructure upgrades and modifications, land use changes, and emphasis on strengthening travel options by non -auto modes results in a level of service that is better than existing conditions in some locations.

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Peter Stanley, Vice Chair, Planning Commission, City of Santa Rosa Response TR-27: The commenter refers to the disclosure in the Draft EIR that there are a number of sites in the project area which may require additional action related to potential contamination on the sites and the extent to which cleanup can be completed with funding from the City to incentivize development of these areas. As discussed abov e, the purpose of the EIR is objectively evaluate the potential physical effects of the project on the environment. While cleanup of contaminated sites would be necessary to ensure people are not exposed to hazardous levels of contamination, cleanup of pro perties to hasten development on those sites is not a requirement of the Specific Plan or the EIR.

As discussed in Response H -1, mitigation measure MM 3.8.4a requires preparation of a Phase I Environmental Site Assessment prior to development of any property within the project area, to identify any remediation necessary to ensure that people are not exposed to hazardous levels of con tamination as a result of development in the project area. Additional mitigation measures to change the timing of cleanup or responsibility of the funding for cleanup is not required for purposes of the EIR.

Response TR-28: The commenter correctly summariz es information regarding vehicle miles traveled (VMT) presented on pages 3.14-25 and -26 in Section 3.14, Traffic and Transportation, in the Draft EIR. Table 3.14 -10 on page 3.14- 26 presents the annual vehicle miles data noted by the commenter. As stated o n page 3.14- 26 in the Draft EIR, implementation of the Specific Plan is expected to reduce annual VMT by approximately 16 million miles, or approximately 5 percent compared to buildout of the Specific Plan area under current General Plan land use designations.

2.0-144

REFERENCES
CARB (California Air Resources Board). 2005. Air Quality and Land Use Handbook: A Community Health Perspective.

3.0 MINOR REVISIONS

TO THE DRAFT EIR

3.0 MINOR REVISIONS TO THE DRAFT EIR
City of Santa Rosa Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexations Project August 2016 Final Environmental Impact Report

3.0-1

3.1 I NTRODUCTION
This section includes minor edits to the Draft EIR. These modifications resulted from responses to comments received during the Draft EIR public review period as well as staff -initiated changes.

Revisions herein do not result in new significant environmental impacts, do not constitute significant new information, and do not alter the conclusions of the environmental analysis.

Changes are provided in revision marks (underline for new text and strikeout for deleted text).

3.2 M INOR CHANGES AND EDITS TO THE DRAFT EIR
SECTION 1.0 INTRODUCTION
The second sentence in the first paragraph under the heading “Intended Uses of the EIR” on page 1.0-1 in the Draft EIR has been revised as follows:

This Draft EIR, in accordance with CEQA Guidelines Section 15126, addresses the significant environmental effects of the project, any potential growth inducing impacts, proposed mitigation measures, and potential alternatives, and should be used as the primary environmental document to evaluate all planning and permitting actions associated with the project.

The first complete paragraph at the top of page 1.0 -1 in the Draft EIR has been revised as follows:

The analysis included in this EIR may also be relied upon in conjunction with the City’s consideration of future development proposals , as summarized below under CEQA Guidelines Sections 15152 (Tiering), 15162 (Subsequent EIRs and Negative Declarations, and 15168 (Program EIR). I n addition, CEQA Guidelines provide a number of avenues for streamlining environmental review, which may be applicable to specific categories of future projects, including the following:

SECTION 2.0 PROJECT DESCRIPTION
On July 14, 2016, t he Planning Commission unanimously directed staff to return with the realignment option for Ro berts Avenue, in -lieu of completely eliminating the connection .

Therefore, the following is a staff -initiated text change. The presence of the Roberts Avenue connection would have no consequential effect on the EIR traffic analysis . The text on Table 2.0- 1 on page 2.0-18 in the Draft EIR is changed as follows:

3.0 MINOR REVISIONS TO THE DRAFT EIR
Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexations Project City of Santa Rosa Final Environmental Impact Report August 2016

3.0-2
SECTION 3.3 AIR QUALITY
The second sentence under Impact 3.3.2 on Draft EIR page 3.3-28 has been revised as follows:

According to the BAAQMD CEQA Guidelines, in order to ensure that the proposed project would not violate any ambient air quality standard or contribute substantially to an exi sting or projected air quality violation, the proposed project must demonstrate consistency with the control measures contained in the Bay Area 2010 Clean Air Plan and show that projected vehicle miles traveled (VMT) increases as a result of the proposed p roject are less than or equal to projected population increases over the project’s planning period.

The last paragraph page 3.3-36 in the Draft EIR has been revised as follows:

2.5 concentration, cancer risk,
and non -cancer hazard index exposure at distances of 10 thr ough 1,000 feet from the segments of US 101 and SR 12 in locations adjacent to the project area. As shown in the table, of the highway segments identified, one (US 101 Link 652) is estimated to have predicted cancer risks in excess of the BAAQMD’s risk thr eshold for PM 2.5 at 10 feet from the source. At 25 feet from this highway, the cancer risk for PM2.5 is below the threshold.

SECTION 3.4 B IOLOGICAL RESOURCES
The mitigation numbers under impact 3.4.4 on Draft EIR page 3.4-30 are corrected as follow:

MM 3.4.42a Implement Mitigation Measure 3.4.1a
MM 3.4.42b A formal wetland delineation shall be conducted for areas that will be permanently or temporarily impacted by the project. If jurisdictional waters cannot be avoided, the City shall apply for a CWA Section 404 permit from the USACE and a Section 401 permit from the RWQCB. These permits shall be obtained prior to issuance of grading permits and implementation of the proposed project.
[Text of measure has not changed. S ee Draft EIR Section 3.4 for the complete text of the mitigation measure.]
SECTION 3.6 G EOLOGY AND SOILS

Page 3 ends

the Seismic Hazards Mapping Act and the California Building Code subheadings:

3.0 MINOR REVISIONS TO THE DRAFT EIR
City of Santa Rosa Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexations Project August 2016 Final Environmental Impact Report

3.0-3
Field Act
The Field Act was enacted on April 10, 1933 , after the Long Beach earthquake in which 70 schools were destroyed, 120 schools suffered major damage, and 300 schools had minor damage. The act requires the following:
• School building construction plans be prepared by qualified California licensed structural engineers and architects.
• Designs and plans be checked by the Division of the State Architect (DSA) for compliance with the Field Act before a contract for construction can be awarded . • Qualified inspectors, independent of the contractors and hired by the school districts, continuously inspect construction and verify full compliance with plans . • The responsible architects and/or structural engineers observe the construction periodically and prepare changes to plans (if needed) subject to approval by the DSA.
• Architects, engineers, inspectors , and contractors file reports, under penalty of perjury, to verify compliance of the construction with the approved plans emphasizing the importance of testing and inspections to achieve seismically safe construction. Any person who violates the provisions or makes any false stateme nt in any verification report or affidavit required pursuant to the act is guilty of a felony.

SECTION 3.9 H YDROLOGY AND WATER QUALITY
The followi ng text is added to page 3. 9-9 in the Draft EIR between the Porter -Cologne Water Quality Control Act and the General Construction Activity Storm Water Permits subheadings:

Sustainable Groundwater Management Act
California enacted legislation in 2014 known as the Sustainable Groundwater Management Act (SGMA). The legislation outlines a framework for sustainable management of groundwater supplies by local authorities, with a limited role for state intervention only if necessary to protect the resource. The act requires the formation of local groundwater sustainability agencies (GSAs) that must assess conditions in their local water basins and adopt locally based management plans. GSAs are to be formed by June 2017, with groundwater management plans to be adopted several years later.

The Santa Rosa Plain Basin Advisory Panel prepared the Santa Rosa Plain Watershed Groundwater Management Plan in 2014.

SECTION 3.13 P UBLIC SERVICES
The third paragraph on page 3.13-1 in the Draft EIR has been revised as follows:

The majority of the project area is currently served by the Santa Rosa Police Department (SRPD). The unincorporated islands in the project area are currently served by the Sonoma County Sheriff’s Office and the California Highway Patrol; upon annexation, these areas would be primarily served by the SRPD only.

3.0 MINOR REVISIONS TO THE DRAFT EIR
Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexations Project City of Santa Rosa Final Environmental Impact Report August 2016

3.0-4
SECTION 3.14, TRAFFIC AND TRANSPORTATION
Table 3.14-15 on page 3.14-25 in the Draft EIR has been revised as follows:

TABLE 3.14-15

EXISTING PLUS PROJECT PM PEAK-HOUR FREEWAY RAMP OPERATIONS Freeway Interchange
Intersection Operations Off-Ramp Queuing
Existing
Delay/LOS
Plus Project
Delay/LOS
Available
Storage
Existing
Max. Queue
Plus Project
Max. Queue
SR 12/Stony Point Road
Westbound 30.1/C 29.0/C29.1/C 930 466 332
Eastbound 10.6/B 15.8/B 710 243 229251
SR 12/Dutton Avenue
Westbound 23.1/C 31.2/C 990 409 909
Eastbound 14.1/B 16.6/B 770 126 148
US 101/Baker Avenue
Northbound 31.4/C 30.6/C 810 152 144
Southbound 9.9/A 18.0/B 340 163 132
US 101/Hearn Avenue
Northbound 33.0/C 33.7/C 960 183 190
Southbound 16.7/B 22.3/C17.3/B 620 495 1059
Source: W-Trans 2016
Notes: Delay is measured in seconds; LOS = level of service; Max Queue is the averaged maximum queue observed in 10 SimTraffic model runs measured in feet; bold = queuing exceeds available storage SECTION 4.0 PROJECT ALTERNATIVES
The following text, which was omitted in error, is added to page 4.0 -2 in the Draft EIR – this is not a new significant and unavoidable impact:

Summary of Significant Effects
The analysis presented in the technical sections of this Draft EIR (Sections 3.1 through 3.15) concluded the following significant and unavoidable impacts would result from implementation of the proposed project:

Impact 3.3.8 The proposed project, in combination with cumulative development in the SFBAAB, could result in a significantly cumulative increase of criteria air pollutants for which the air basin is designated nonattainment.

Impact 3.14.2 Project traffic would have the potential to degrade mainline fre eway operations to unacceptable levels of service under Existing plus Project conditions (US 101 North – Todd Rd to SR 12).

3.0 MINOR REVISIONS TO THE DRAFT EIR
City of Santa Rosa Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexations Project August 2016 Final Environmental Impact Report

3.0-5
Impact 3.14.3 Project traffic would have the potential to degrade freeway ramp operations to an unacceptable level of service at the southbound US 101 freeway off- ramp at Hearn Avenue under Existing plus Project conditions.

Impact 3.14.11 Project traffic, when considered together with other past, present, and future development, would have the potential to degrade mainline freeway operations to unacceptable levels of service.

SECTION 5.0 OTHER CEQA ANALYSIS
The following text, which was omitted in error, is added to page 5.0 -1 of the Draft EIR – this is not a new significant and unavoidable impact:

5.1 Significant Effects That Cannot Be Avoided
The analysis presented in the technical sections of this Draft EIR (Sections 3.1 through 3.15) concluded the following significant and unavoidable impacts would result from implementation of the proposed project:

Impact 3.14.2 Project traffic would have the potential to degrade mainline freeway operations to unacceptable levels of service under Existing plus Project conditions (US 101 North – Todd Rd to SR 12).

Impact 3.14.3 Project traffic would have the potential to degrade freeway ramp operations to an unacceptable level of service at the southbound US 101 freeway off -ramp at Hearn Avenue under Existing plus Project conditions.

3.0 MINOR REVISIONS TO THE DRAFT EIR
Roseland Area/Sebastopol Road Specific Plan and Roseland Area Annexations Project City of Santa Rosa Final Environmental Impact Report August 2016

3.0-6
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Santa Rosa City CouncilMarch 15, 2022

Santa Rosa City Council
March 15, 2022