Attachment 3 - General Plan 2050 Final Environmental Impact — Santa Rosa City Council, November 4, 2025

Santa Rosa General Plan 2050
Final Environmental Impact Report
SCH: 2023020166 | April 2025

ORANGE COUNTY • BAY AREA • SACRAMENTO • CENTRAL COAST • LOS ANGELES • INLAND EMPIRE • SAN DIEGO PlaceWorks.com
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Environmental Collaborative
Illingworth & Rodkin
Tom Origer & Associates
W-Trans
Santa Rosa General Plan 2050
Final Environmental Impact Report
SCH: 2023020166
April 2025

PLACEWORKS i
Table of Contents
INTRODUCTION ............................................................................................................................ 1-1

1.1 Purpose of the Environmental Impact Report ............................................................ 1-1

1.2 Environmental Review Process ..................................................................................... 1-1 EXECUTIVE SUMMARY ................................................................................................................. 2-1 LIST OF COMMENTERS ................................................................................................................. 3-1

3.1 Government Agencies ................................................................................................. 3-1

3.2 Private Organizations .................................................................................................... 3-1

3.3 Members of the Public .................................................................................................. 3-2

3.4 Public Hearing ................................................................................................................ 3-2

3.5 General Plan Comments .............................................................................................. 3-2

4. COMMENTS AND RESPONSES .................................................................................................... 4-1

4.1 Master Responses .......................................................................................................... 4-1

4.2 Individual Responses ................................................................................................... 4-10 REVISIONS TO THE DRAFT EIR ...................................................................................................... 5-1 MITIGATION MONITORING AND REPORTING PROGRAM ........................................................ 6-1

APPENDICES
Appendix E: Comment Letters on the Draft EIR
Appendix F: Comment Letters on the Draft General Plan

LIST OF TABLES
Table 2-1 Summary of Significant Impacts and Mitigating Policies and Actions .................... 2-2 Table 4-1 Responses to Individual Comments on the Draft EIR .............................................. 4-11 Table 6-1 Santa Rosa General Plan 2050 Mitigation Monitoring and Reporting Program .......................................................................................................................... 6-2

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

TABLE OF CONTENTS
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Introduction

1.1 PURPOSE OF THE ENVIRONMENTAL IMPACT REPORT
This Final Environmental Impact Report (EIR), which has been prepared in compliance with the California Environmental Quality Act (CEQA), provides responses to comments received on the Draft EIR for the adoption and implementation of the proposed Santa Rosa General Plan 2050 (also known as Santa Rosa Forward), along with the associated Specific Plan and Santa Rosa City Code (SRCC) amendments, and the Community-wide Greenhouse Gas Reduction Strategy (GHG Reduction Strategy), herein referred to separately or together as the “proposed project.” The Draft EIR identifies significant impacts associated with the proposed project, identifies and considers alternatives to the proposed project, and identifies mitigation measures to avoid or reduce potential environmental impacts. This Final EIR also contains text revisions to the Draft EIR. This Final EIR, together with the Draft EIR, constitutes the complete EIR for the proposed project.

1.2 ENVIRONMENTAL REVIEW PROCESS
According to CEQA, lead agencies are required to consult with public agencies having jurisdiction over a proposed project, and to provide the general public with an opportunity to comment on the Draft EIR. A Draft EIR was prepared for the proposed project to provide an assessment of the potential environmental consequences of adoption and implementation of the proposed project. A Notice of Preparation of an EIR
was issued by the City of Santa Rosa (City) on February 7, 2023, for a 30-day review period. During this 30- day review period, a Scoping Meeting was conducted on February 27, 2023, to receive comments from members of the public, organizations, and interested public agencies on issues related to the physical environment that should be addressed in the EIR. A Notice of Availability (NOA) was issued by the City on October 7, 2024, and the Draft EIR was made available for public review for a 45-day public review period through November 20, 2024. Written comments received on the Draft EIR are included in their original format as Appendix E, Comments Letters on the Draft EIR, of this Final EIR. These comments are also reproduced in Chapter 4, Comments and Responses, of this Final EIR, and responses to comments that were made on environmental issues are provided. Written comments on the General Plan are also included in their original format in Appendix F, Comment Letters on the Draft General Plan, of this Final EIR.

This Final EIR will be presented at a Planning Commission hearing at which the Commission will advise the City Council on certification of the EIR. However, the Planning Commission will not take final action on the EIR or the proposed project. Instead, the City Council will consider the Planning Commission’s recommendations on the Final EIR and the proposed project during a noticed public hearing and will take the final action with regard to certification of the Final EIR. The City Council will consider certification of the complete EIR (Draft and Final) at a public hearing in spring 2025.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

INTRODUCTION
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Executive Summary
This Final Environmental Impact Report (EIR) has been prepared to provide an assessment of the potential environmental consequences of approving and implementing Santa Rosa General Plan 2050 (also known as Santa Rosa Forward), along with the associated Specific Plan and Santa Rosa City Code (SRCC) amendments, and Community-wide Greenhouse Gas Reduction Strategy (GHG Reduction Strategy), herein referred to separately or together as the “proposed project.” This Final EIR contains responses to comments received on the Draft EIR. This Final EIR also contains corrections, clarifications, and changes to the text and analysis of the Draft EIR, where warranted.

Table 2-1, Summary of Significant Impacts and Mitigating Policies and Actions, summarizes the conclusions of the environmental analysis in the Draft EIR and presents a summary of the identified significant impacts and the proposed mitigating General Plan 2050 policies and actions. 1 These proposed
policies and actions are required as means to mitigate environmental impacts under CEQA. These policies and actions are fully enforceable at the discretion of the decision-maker, regarding applicability to a proposed future development, through permit conditions, agreements, or other legally binding instruments. These mitigating policies and actions use the imperative “shall,” include performance criteria, and are marked with an asterisk (*). Note that all actions are required to be implemented by the City and therefore the imperative “shall,” if not explicitly stated, is implied. Please see Chapter 4.0, Environmental Analysis, of the Draft EIR, and Chapter 4.0, Comments and Responses, of this Final EIR, for further discussion of the proposed mitigating General Plan 2050 policies and actions.

As summarized in Table 2-1, and as required by CEQA, some impacts remain significant and unavoidable after implementation of the proposed mitigating General Plan 2050 policies and actions. Table 2-1 is organized to correspond with the environmental issues in Chapters 4.1 through 4.18 of the Draft EIR.

Table 2-1 is arranged in three columns: (1) impact, (2) proposed mitigating General Plan 2050 policies and actions, and (3) significance with proposed mitigating policies and actions. All environmental topics not listed in this table were found to have less-than-significant impacts without mitigation. For a complete description of potential impacts, please refer to the specific discussions in Chapters 4.1 through 4.18 of the Draft EIR.

Some text revisions in Table 2-1 include typographical corrections, insignificant modifications, amplifications and clarifications to the Draft EIR. Revisions are shown as underlined text to represent language that has been added to the EIR and text with strikethrough represent language that has been deleted from the Draft EIR. None of the revisions constitutes significant new information as defined in CEQA Guidelines Section 15088.5; therefore, the Draft EIR does not need to be recirculated.

1 Public Resources Code Section 21081.6(b) and CEQA Guidelines Section 15126.4(a)(2) establish that when a project examined in an EIR is a plan (such as a General Plan), policy, regulation, or other public project, mitigation measures may be incorporated into the plan, policy, regulation, or project design. Therefore, as this is a General Plan EIR, some policies and actions in the proposed General Plan 2050 are also required as means to mitigate environmental impacts under CEQA.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation

AGRICULTURAL RESOURCES (AG)
Impact AG-1: Implementation of the
proposed project could result in the
conversion of Prime Farmland, Farmland of
Statewide Importance, and Unique Farmland
land (together referred to as “CEQA
Important Farmland”) to non-agricultural
land uses.

Mitigation Measures Considered. In compliance with CEQA, “each public agency shall mitigate or avoid the significant effects on the environment of the project it carries out or approves whenever it is feasible to do so.”(Public Resources Code Section 21002.1(b) The term “feasible” is defined in CEQA to mean, “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors.”(
Public Resources Code Section 21061.1) CEQA Guidelines Section 15370 defines “mitigation” as: (1) avoiding the impact altogether by not taking a certain action or parts of an action; (2) minimizing impacts by limiting the degree or magnitude of an action and its implementation; (3) rectifying the impact by repairing, rehabilitating, or restoring the impacted environment; (4) reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and (5) compensating for the impact by replacing or providing substitute resources or environments. The following is a brief discussion of the mitigation measures considered for mitigating or avoiding the impact of the conversion of agricultural lands to other uses and their infeasibility. However, as shown, no feasible mitigation measures are available that would reduce the agricultural resource impact to less-than-significant levels.  Replacement of Agricultural Resources. This measure would replace the existing agricultural use with the same use on other property that is not currently used for agriculture. From a statewide perspective, the replacement of farmland means that there will be no net loss of farmland in the state. However, CEQA Important Farmland would still be developed. There is limited undeveloped land in the EIR Study Area that is not currently designated as agricultural, restricting the amount of agricultural land that would be able to be replaced elsewhere in the area, and thus conversion of these lands would be insufficient to achieve no net loss. Moreover, even if adequate land could be identified to achieve no net loss, the challenges of creating the soil, irrigation, climatic, and economic conditions that are required for productive farmland (i.e., that achieve the same CEQA Important Farmland status) are significant, and there would be no guarantee that replacement land could be successfully farmed. In addition, replacing existing undeveloped areas with active agriculture could trigger a range of negative environmental impacts, including increased groundwater consumption, habitat destruction, erosion, air quality impacts, and herbicide and pesticide application. As such, the replacement of the existing agricultural uses on other properties within the Sphere of Influence is infeasible.  Transfer of Development Rights. Transferring development rights would involve the purchasing of the right to develop land from a currently undeveloped piece of land and transferring those rights to farmland within the city.

Thus, this option is also infeasible because there would still be a net loss of farmland (i.e., the farmland preserved would still likely be preserved anyhow). Even if farmland would be preserved elsewhere in Sonoma County, the CEQA Important Farmland in the city would be developed, resulting in a net loss of CEQA Important Farmland.

Therefore, for the reasons outlined previously, and in this paragraph, it would not prevent significant impacts Signiﬁcant and
unavoidable
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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EXECUTIVE SUMMARY
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
from occurring in the city and it would not be an effective CEQA mitigation measure; nor is this mitigation measure feasible from an economic perspective within this region.  Relocation of Prime Farmland Topsoil. This measure would remove the top 12 to 18 inches of topsoil from affected areas and haul this soil to a farm site or several farm sites that have lower-quality soils. The Prime Farmland soils may assist in increasing crop yield at the relocated site. This measure would have its own environmental impacts, including increased truck traffic on local roadways from both hauling soil off-site and replacement of soil on-site, increased diesel truck emissions, construction noise, and increased duration of construction. The relocation of prime farmland soils to another active farm would increase other environmental impacts and is therefore considered infeasible.

As described, these measures were considered and found to be infeasible for mitigating or avoiding the impact of the conversion of agricultural lands to other uses pursuant to the definition of CEQA in that there is no guarantee that measures would result in successfully establishing CEQA Important Farmland, if doing so could happen within a reasonable period of time, that their implementation would not potentially cause greater environmental impacts, and that acquiring additional lands to be established as CEQA Important Farmland would be economically possible.

As discussed previously, implementation of the proposed General Plan 2050 would designate CEQA Important Farmland land to non-agricultural land uses. Through the proposed General Plan 2050 goals, policies, and actions, impacts related to the conversion of qualifying agricultural lands would be reduced, but not to a less-than-significant level. The proposed General Plan 2050 contains policies and actions to reduce the conversion of qualifying agricultural lands. Specifically, proposed Policy 3-6.6 and Policy 3-6.7 to conserve and preserve agricultural land and soils, and Action 3-6.28 to prioritize conservation of agricultural properties. Proposed Action 3-6.16 discourages the conversion of agricultural land to non-agricultural use, Action 3-6.17 promotes restorative agricultural and landscaping techniques, and Action 3-6.19 requires the City to partner with the Sonoma County Agricultural Preservation and Open Space District and Sonoma Resource Conservation District to identify opportunities for conserving agricultural lands and preserving soil quality. These proposed General Plan 2050 policies and actions would not reduce the amount of acreage converted through implementation of the proposed project; however, they would forestall development of the best agricultural land within the EIR Study Area.

While these efforts and other mitigation measures were considered, such as preserving agricultural uses in the EIR Study Area, replacement of agricultural resources by replacing lost agricultural uses to other areas of the city, and relocation of Prime Farmland topsoil to other areas, these mitigations are not feasible. Additionally, other mitigating efforts, such as conservation easements, one-to-one preservation, and right-to-farm ordinances all work to mitigate impacts; however, the only way to fully avoid the agricultural impact from implementation of the proposed project is to not allow development on state-designated CEQA Important Farmland, thereby eliminating the agricultural impact. However, doing so is not feasible or practical as the City has a responsibility to meet other conflicting obligations, including to increase the number and types of jobs available in Santa Rosa and to reduce the need for SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

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EXECUTIVE SUMMARY
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
residents to commute to high-quality jobs. These measures are critical to reducing single-occupant vehicle travel to and from Santa Rosa and meeting State targets for greenhouse gas reduction. The City needs to promote both economic development and corresponding residential development, as required by State housing law, within its adopted growth boundary. While possible forms of mitigation for, or avoidance of, conservation of agricultural lands in the EIR Study Area would be implemented by the City through its proposed General Plan 2050 policies and actions, doing so to reduce impacts to a less-than-significant level would be infeasible and inconsistent with City planning goals and objectives. Therefore, impacts would remain significant and unavoidable.

Impact AG-2: Implementation of the
proposed project could result in the loss of
agricultural land under the Williamson Act.

Mitigation Measures Considered. As described under impact discussion AG-1, pursuant to CEQA, the City has considered mitigation to reduce impacts from implementation of the proposed project that could conflict with lands under a Williamson Act contract. However, as shown, no feasible mitigation measures are available that would reduce the agricultural resource impact to less-than-significant levels. Specifically, the City considered a measure that would result in the replacement of Williamson Act contract farmland that would place other farmland under Williamson Act contract. Even if feasible, the placing of alternative farmland under Williamson Act contract would establish a commitment to retain that alternative farmland for agricultural use. The length of time that the alternative land will remain in agricultural use would depend on the terms of the Williamson Act contract. However, the Williamson Act contract will only reduce the potential that the alternative land will convert to non-agricultural use. The individual and cumulative loss of agricultural land caused by the proposed project would still occur.

Therefore, this mitigation measure will not reduce the proposed project’s impacts on agriculture to below the level of significance. For these reasons, placing alternative privately held land under permanent restriction through Williamson Act contracts is considered infeasible.

Signiﬁcant and
unavoidable
As described under impact discussion AG-1, the proposed General Plan 2050 includes goals, policies, and actions to minimize impacts to agricultural lands. Those same proposed General Plan 2050 goals, policies, and actions would also minimize impacts from conflicts with Williamson Act lands and reduce the likelihood of premature contract cancellations by the property owners of the Williamson Act parcels in the EIR Study Area. Mitigation for this impact was considered, including the placement of other farmland under Williamson Act contract. However, the individual and cumulative loss of agricultural land under the Williamson Act caused by the proposed project would still occur.

Given that CEQA does not require that the project be changed to avoid an impact, and no additional mitigation is available, this would result in a significant and unavoidable impact.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
Impact AG-4: The proposed project, in
combination with past, present, and
reasonably foreseeable projects, could result
in a signiﬁcant cumulative impact with
respect to the conversion of CEQA Important
Farmland (Prime Farmland, Farmland of
Statewide Importance, and Unique
Farmland) and Williamson Act properties to
non-agricultural uses.

As described previously, implementation of the proposed project would result in significant and unavoidable impacts related to the conversion of CEQA Important Farmland and Williamson Act properties to non-agricultural uses.

Although the proposed General Plan 2050 goals, policies, and actions would reduce and partially offset regional agricultural impacts, as well as consideration of mitigation measures to preserve agricultural lands, the only way to fully avoid the agricultural impact of the proposed project is to not allow development on state-designated CEQA Important Farmland, thereby eliminating the agricultural impact. However, this would be infeasible and inconsistent with City planning goals and objectives. Further, the amount of growth foreseen in the region and the decisions of Sonoma County and other surrounding counties regarding conversion of agricultural land are outside the control of the City of Santa Rosa. Therefore, this cumulative impact would be significant and unavoidable.

Signiﬁcant and
unavoidable

AIR QUALITY (AIR)
Impact AIR-2a: Construction activities that
could occur over the buildout horizon of the
proposed General Plan 2050 could
potentially violate an air quality standard or
cumulatively contribute to an existing or
projected air quality violation.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-6.31: The City shall Rrequire projects that exceed the Bay Area Air Quality Management District (BAAQMDAir District) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD Air District methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD Air District thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level, consistent with the Air District Guidelines, as subsequently revised, supplemented, or replaced.
*Action 3-6.32: The City shall Ccontinue to implement the Bay Area Air Quality Management District (BAAQMD) Air District Basic Control Measures included in the latest version of BAAQMD’s Air District’s California Environmental Quality Act (CEQA) Air Quality Guidelines, as subsequently revised, supplemented, or replaced, to control fugitive dust (i.e., particulate matter PM2.5 and PM10) during demolition, ground-disturbing activities, and/or construction.

Less than
signiﬁcant
Impact AIR-2b: Buildout of the proposed
project could generate operational
emissions that could exceed the Bay Area Air
Quality Management District’s (BAAQMD)
regional signiﬁcance thresholds for reactive
organic compounds (ROG), nitrogen oxides
(NO
X) and particulate matter (PM2.5 and
PM10).

Signiﬁcant and
unavoidable
Buildout in accordance with the proposed project would generate long-term emissions that would exceed BAAQMD’s regional significance thresholds and cumulatively contribute to the nonattainment designations of the San Francisco Bay Area Air Basin (SFBAAB). The proposed General Plan 2050 goals, policies, and actions would reduce air pollutant emissions to the extent practicable. Additionally, the proposed General Plan 2050 goals, policies, and actions covering topics such as expansion of the pedestrian and bicycle networks, promotion of public and active transit, and support to increase building energy efficiency and energy conservation would also reduce SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

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EXECUTIVE SUMMARY
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
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Mitigation
criteria air pollutants within the EIR Study Area. Specifically, proposed *Action 3-6.31 requires potential future development in Santa Rosa that exceeds the BAAQMD screening sizes to evaluate project-specific operation emissions in conformance with the BAAQMD methodology. Where the technical assessment determines the BAAQMD-adopted thresholds are exceeded, the applicants for new development projects would be required to incorporate mitigation measures to reduce air pollutant emissions during operational activities. Possible mitigation measures to reduce long-term emissions could include, but are not limited to the following:
 Implementing commute trip reduction programs.
 Unbundling residential parking costs from property costs.  Expanding bikeway networks.
 Expanding transit network coverage or hours.
 Using cleaner-fueled vehicles.
 Exceeding the current Title 24 Building Envelope Energy Efficiency Standards.  Establishing on-site renewable energy generation systems.  Implementing all-electric buildings.
 Replacing gas-powered landscaping equipment with zero-emission alternatives.  Implementing organics diversion programs.
 Expanding urban tree planting.

This EIR quantifies the increase in criteria air pollutants emissions in the EIR Study Area. However, at the programmatic level, it is not feasible to quantify the increase in toxic air contaminants (TAC) from stationary sources associated with the proposed project or meaningfully correlate how regional criteria air pollutant emissions above BAAQMD’s significance thresholds correlate with basin wide health impacts.

To determine cancer and noncancer health risk, the location, velocity of emissions, meteorology and topography of the area, and locations of receptors are equally important as model parameters as the quantity of TAC emissions.

The white paper prepared by the Association of Environmental Professionals’ Climate Change Committee, We Can Model Regional Emissions, But Are the Results Meaningful for CEQA, describes several of the challenges of quantifying local effects—particularly health risks—for large-scale, regional projects, and these are applicable to both criteria air pollutants and TACs. Similarly, the two amicus briefs filed by the air districts on the Friant Ranch case describe two positions regarding CEQA requirements, modeling feasibility, variables, and reliability of results for determining specific health risks associated with criteria air pollutants. The discussions also include the distinction between criteria air pollutant emissions and TACs with respect to health risks. The following summarizes major points about the infeasibility of assessing health risks of criteria air pollutant emissions and TACs associated with implementation of a general plan. The white paper and amicus briefs are provided in Appendix B, Air Quality and Greenhouse Gas Emissions Data, of the Draft EIR.

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Mitigation
To achieve and maintain air quality standards, BAAQMD has established numerical emission indicators of significance for regional and localized air quality impacts for both construction and operational phases of a local plan or project. The numerical emission indicators are based on the recognition that the air basin is a distinct geographic area with a critical air pollution problem for which ambient air quality standards (AAQS) have been promulgated to protect public health. The thresholds represent the maximum emissions from a plan or project that are expected not to cause or contribute to an exceedance of the most stringent applicable national or state ambient air quality standard. By analyzing the plan’s emissions against the thresholds, an EIR assesses whether these emissions directly contribute to any regional or local exceedances of the applicable AAQS and exposure levels.

BAAQMD currently does not have methodologies that would provide the City with a consistent, reliable, and meaningful analysis to correlate specific health impacts that may result from a proposed project’s mass emissions.

For criteria air pollutants, exceedance of the regional significance thresholds cannot be used to correlate a project to quantifiable health impacts unless emissions are sufficiently high to use a regional model. BAAQMD has not provided methodology to assess the specific correlation between mass emissions generated and their effect on health (note Appendix B, Air Quality and Greenhouse Gas Emissions Data, of the Draft EIR provides the San Joaquin Valley Air Pollution Control District’s amicus brief, and South Coast Air Quality Management District’s amicus brief).

Ozone concentrations depend on a variety of complex factors, including the presence of sunlight and precursor pollutants, natural topography, nearby structures that cause building downwash, atmospheric stability, and wind patterns. Note, the downwash effect is a wind-related phenomenon commonly observed in urban environments, especially around tall buildings and skyscrapers. This effect occurs when wind strikes the face of these high structures and is deflected downwards, creating strong downdrafts at the street level. These downdrafts can significantly increase wind speeds on the ground, leading to uncomfortable and sometimes hazardous conditions for pedestrians (Building Downwash: How to Mitigate Urban Wind Discomfort | Blog). Secondary formation of particulate matter and ozone can occur far from sources as a result of regional transport due to wind and topography (e.g., low-level jet stream). Photochemical modeling depends on all emission sources in the entire domain (i.e., modeling grid). Low resolution and spatial averaging produce “noise” and modeling errors that usually exceed individual source contributions. Because of the complexities of predicting ground-level ozone concentrations in relation to the National and California AAQS, it is not possible to link health risks to the magnitude of emissions exceeding the significance thresholds.

Current models used in CEQA air quality analyses are designed to estimate potential project construction and operation emissions for defined projects. The estimated emissions are compared to significance thresholds, which are keyed to reducing emissions to levels that will not interfere with the region’s ability to attain the health-based standards. This serves to protect public health in the overall region, but there is currently no CEQA methodology to determine the impact of emissions (e.g., pounds per day) on future concentration levels (e.g., parts per million or SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

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micrograms per cubic meter) in specific geographic areas. CEQA thresholds, therefore, are not specifically tied to potential health outcomes in the region.

The EIR must provide an analysis that is understandable for decision making and public disclosure. Regional-scale modeling may provide a technical method for this type of analysis, but it does not necessarily provide a meaningful way to connect the magnitude of a project’s criteria pollutant emissions to health effects without speculation.

Additionally, this type of analysis is not feasible at a general plan level because the location of emissions sources and quantity of emissions are not known. However, because cumulative development within the EIR Study Area would exceed the regional significance thresholds, this EIR finds that the proposed project could contribute to an increase in health effects in the basin until the attainment standards are met in the SFBAAB.

In summary, as described above, implementation of the proposed project would generate emissions that would exceed BAAQMD’s regional significance thresholds (no net increase). The proposed General Plan 2050 includes goals, policies, and actions to reduce these long-term regional criteria air pollutant emissions. However, due to the programmatic nature of the proposed project, no additional mitigating measures are available, and the impact is considered significant and unavoidable. The identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent individual projects that meet applicable project-level thresholds of significance.

Impact AIR-3a: Construction activities
associated with potential future
development could expose nearby receptors
to substantial concentrations of toxic air
contaminants.

Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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Impact AIR-3b: Large industrial or
warehouse development projects under the
proposed project could expose air quality-
sensitive receptors to substantial toxic air
contaminants (TAC) and particulate matter
(PM

2.5) concentrations and exceed the Bay
Area Air Quality Management District’s
(BAAQMD) project-level and cumulative
signiﬁcance thresholds.

General Plan 2050 Chapter 6, Health, Equity, Environmental Justice, and Parks *Action 6-1.6: The City shall Rrequire an operational health risk assessment for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use or Overburdened Community, as defined by BAAQMDthe Air District. The operational HRA shall be prepared in accordance with policies and procedures of the State Office of Environmental Health Hazard Assessment and BAAQMD the Air District. If the operational HRA shows that the incremental cancer risk exceeds 10 in a million, the noncancer hazard index of 1.0, or the thresholds as determined by BAAQMD the Air District, require the project applicant to identify and demonstrate measures, such as those listed in the General Plan Environmental Impact Report, that can reduce potential cancer and noncancer risks to acceptable levels.

Signiﬁcant and
unavoidable
Potential future development over the buildout horizon of the proposed project could result in new sources of TACs or PM

2.5 near existing or planned sensitive receptors. Review of development projects by BAAQMD for permitted sources of air toxics (e.g., industrial facilities, dry cleaners, and gas stations) in addition to proposed General Plan 2050 goals, policies, and actions would ensure that health risks are minimized. Specifically, the implementation of project-specific operational health risk assessments (HRA) as required by proposed General Plan 2050 *Action 6-1.6 would identify any impacts and mitigation measures to reduce the operational health risks for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, nursing homes) or an “overburdened community,” as measured from the property line of the project to the property line of the nearest sensitive use. Operational HRAs would be required to be prepared in accordance with policies and procedures of the State Office of Environmental Health Hazard Assessment and BAAQMD. If the operational HRA shows that the cumulative and project-level incremental cancer risk, noncancer hazard index, and/or PM

2.5 exceeds the respective threshold as established by
BAAQMD and project-level risk of 10 in one million at the time a project is considered, the project applicant would be required to identify “best available control technologies for toxics” and appropriate enforcement mechanisms, and demonstrate that they are capable of reducing potential cancer, noncancer risks, and PM

2.5 to an acceptable
level. Best available control technologies for toxics may include but are not limited to:
 Restricting idling on-site beyond air toxic control measures idling restrictions  Electrifying warehousing docks
 Requiring use of newer equipment
 Requiring near-zero or zero-emission trucks for a portion of the vehicle fleet based on opening year  Truck electric vehicle (EV) capable trailer spaces
 Restricting off-site truck travel through the creation of truck routes SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
The same proposed General Plan 2050 goals, policies, and actions listed in Section 4.3.2.3, Impacts of the Environment on a Project, would serve to protect sensitive receptors from poor air quality in the EIR Study Area.

Specifically, proposed Action 6-1.11 would require the City to update the Zoning Code to require health impact assessments for nonresidential and developments of 100,000 square feet or more in Equity Priority Areas (EPA) to identify and mitigate any potential negative health implications of the project. Individual development projects would be required to achieve the incremental risk thresholds established by BAAQMD, and TAC and PM2.5 project- level impacts would be less than significant. However, these projects could contribute to significant cumulative risk in the Bay Area that could affect sensitive populations and EPAs. As a result, the proposed project’s contribution to cumulative health risk is considered significant and unavoidable. The identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent individual projects that meet applicable project-level thresholds of significance.

Impact AIR-5: The proposed project, in
combination with past, present, and
reasonably foreseeable projects, could result
in cumulative air quality impacts with
respect to generation of criteria pollutant
and exposure of substantial pollutant
concentrations to sensitive receptors.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-6.31: The City shall Rrequire projects that exceed the Bay Area Air Quality Management District (BAAQMDAir District) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD Air District methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD Air District thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level, consistent with the Air District Guidelines, as subsequently revised, supplemented, or replaced.
*Action 3-6.32: The City shall Ccontinue to implement the Bay Area Air Quality Management District (BAAQMD) Air District Basic Control Measures included in the latest version of BAAQMD’s California Environmental Quality Act (CEQA) Air Quality Guidelines, as subsequently revised, supplemented, or replaced, to control fugitive dust (i.e., particulate matter PM2.5 and PM10) during demolition, ground-disturbing activities, and/or construction.

General Plan 2050 Chapter 6, Health, Equity, Environmental Justice, and Parks *Action 6-1.5: As recommended by the California Air Resources Board, the City shall require projects that would result in construction activities within 1,000 feet of residential and other land uses that are sensitive to toxic air contaminants (e.g., hospitals, nursing homes, day care centers), as measured from the property line of the project, to prepare a construction health risk assessment in accordance with policies and procedures of the Office of Environmental Health Hazard Assessment and the Bay Area Air Quality Management District (BAAQMDAir District) California Environmental Quality Act (CEQA) Guidelines that identifies mitigation measures and appropriate enforcement mechanisms capable of reducing potential cancer and non-cancer risks below the BAAQMD Air District threshold.
*Action 6-1.6: The City shall Rrequire an operational health risk assessment for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and 2) are within 1,000 feet of a sensitive Signiﬁcant and
unavoidable
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
PLACEWORKS 2-11
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
land use or Overburdened Community, as defined by BAAQMD the Air District. The operational HRA shall be prepared in accordance with policies and procedures of the State Office of Environmental Health Hazard Assessment and BAAQMD the Air District. If the operational HRA shows that the incremental cancer risk exceeds 10 in a million, the noncancer hazard index of 1.0, or the thresholds as determined by BAAQMD the Air District, require the project applicant to identify and demonstrate measures, such as those listed in the General Plan Environmental Impact Report, that can reduce potential cancer and noncancer risks to acceptable levels.

Criteria air pollutant emissions generated by land uses within the proposed project could exceed the Bay Area Air Quality Management District’s regional thresholds. Air quality impacts identified under Impacts AIR-2a, AIR-2b, AIR- 3a, and AIR-3b constitute the proposed project’s contribution to cumulative air quality impacts in the San Francisco Bay Area Air Basin. Proposed General Plan 2050 goals, policies, and actions would help reduce project-related emissions to the extent feasible. Specifically, proposed *Action 3-6.31, *Action 3-6.32, *Action 6-1.5, and *Action 6-

1.6 would reduce impacts at the project level. However, due to the programmatic nature of the proposed project, no additional mitigation measures are available. Air pollutant emissions associated with the proposed project would result in a cumulatively considerable contribution to air quality impacts and remain significant and unavoidable at the program level.

BIOLOGICAL RESOURCES (BIO)
Impact BIO-1: Impacts to special-status
species or the inadvertent loss of bird nests
in active use, which would conﬂict with the
federal Migratory Bird Treaty Act (MBTA)
and California Fish and Game Code (CFGC),
could occur as a result of implementation of
the proposed project.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-5.7: The City shall Ccontinue to consult with the California Department of Fish and Wildlife (CDFW) to identify significant environments and priorities for acquisition or maintenance of open space areas based on biological and environmental concerns and develop a strategy for maintaining areas that will preserve the protected and sensitive populations of plants and animals currently found in the UGB. Strategies shall be based on federal, State, and local regulations relevant to the protection of the identified species, including, but not limited to, Federal or California Endangered Species Act, Santa Rosa Plain Conservation Strategy, and United States Fish and Wildlife Service Programmatic Biological Opinion, as subsequently revised, supplemented, or replaced. *Action 3-5.10: The City shall Ccontinue to require the implementation of existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve prior to, during, and after project approval and construction for projects that may affect wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species to ensure their conservation.

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
2-12 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
and Game Code Section 1600 et seq; Clean Water Act; and Porter Cologne Water Quality Control Act, as subsequently revised, supplemented, or replaced.
*Action 3-5.11: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction. The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced. *Action 3-5.12: The City shall Rrequire that construction or other ground-disturbing activities that may affect bird nests or nesting habitat avoid nests of native birds when the nest is in active use by implementing protection measures specified by a qualified ornithologist or biologist to ensure compliance with the California Fish and Game Code and federal Migratory Bird Treaty Act. Compliance guidelines are detailed in the General Plan Environmental Impact Report. If demolition, construction, ground-disturbing, or tree removal/pruning activities occur during the nesting season (February 1 and August 31), preconstruction surveys shall be conducted by a qualified ornithologist or biologist and approved by the City prior to issuance of building permits. Preconstruction surveys are not required for construction, ground-disturbing, or tree removal/pruning activities outside the nesting season. *Action 3-5.13: The City shall Ddevelop and adopt a bird-safe design ordinance in consultation with a qualified biologist and require projects to demonstrate compliance with the ordinance prior to project approval. The ordinance shall apply to all new development and redevelopment projects and include the latest bird-safe design guidelines and best management practice strategies, such as those from the National Audubon Society, to provide specific criteria and refined guidelines as part of design review and/or project approval process of new buildings and taller structures to protect birds from injury and mortality from collisions with buildings, towers, and other human- made structures. Preserve and restore wildlife habitats and corridors. Continue to provide some protection for habitat areas in the city, such as for the rookery on West 9th Street. Prior to adoption of the bird-safe design ordinance, project applicants shall show compliance with bird-safe design requirements, consistent with best practices.

Impact BIO-2: Impacts to riparian areas,
drainages, and sensitive natural
communities could occur from potential
future development under the proposed
General Plan 2050 where natural habitat
remains.

Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
PLACEWORKS 2-13
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
*Action 3-5.10: The City shall Ccontinue to require the implementation of existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve prior to, during, and after project approval and construction for projects that may affect wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species to ensure their conservation.

Existing regulations and procedures include, but are not limited to, Federal and California Endangered Species Act; CDFW 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities; Santa Rosa Plain Conservation Strategy; United States Fish and Wildlife (USFWS) Service Programmatic Biological Opinion; CDFW 2012 Staff Report on Burrowing Owl Mitigation; 2012 USFWS Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls; 2020 Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California; Fish and Game Code Section 1600 et seq; Clean Water Act; and Porter Cologne Water Quality Control Act, as subsequently revised, supplemented, or replaced.
*Action 3-5.11: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support or have the potential to affect special- status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction. The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced.
*Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan, and the concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced. *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.

Impact BIO-3: Potential future development
from implementation of the proposed
General Plan 2050 could result in direct and
indirect impacts to wetland habitat.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-5.10: The City shall Ccontinue to require the implementation of existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve prior to, during, and after project approval and construction for projects that may affect wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species to ensure their conservation.

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
2-14 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
Natural Communities; Santa Rosa Plain Conservation Strategy; United States Fish and Wildlife (USFWS) Service Programmatic Biological Opinion; CDFW 2012 Staff Report on Burrowing Owl Mitigation; 2012 USFWS Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls; 2020 Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California; Fish and Game Code Section 1600 et seq; Clean Water Act; and Porter Cologne Water Quality Control Act, as subsequently revised, supplemented, or replaced.*Action 3-5.11: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support or have the potential to affect special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction. The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced.

CULTURAL RESOURCES (CUL)
Impact CUL-1: Impacts to known or yet to be
classiﬁed historic buildings or structures
could occur from potential future
development under the proposed General
Plan 2050.

General Plan 2050 Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture
*Action 4-3.2: For projects with known or the potential to have historic structures, the City shall require the project to Ffollow the Secretary of the Interior Standards for Preservation, Rehabilitation, Restoration, and Reconstruction for the treatment of historic properties and the California Historic Building Code, as subsequently revised, supplemented, or replaced.
*Action 4-3.6: Identify and minimize or remove obstacles for owners of historic properties to support preservation, including guides for repurposing facilities.

Identify resources to:
 Keep cultural surveys relevant.
 Periodically update the City’s Cultural Heritage Survey to ensure consistency with current guidelines and best practices, to reflect potential changes in status, and to include properties that have become age-eligible for listing.
 Conduct cultural and/or historic inventories or surveys of areas of the city that have not been surveyed.  Install plaques and/or educational signage at locations of cultural significance and significant events.  Implement recommendations in the City’s Cultural Heritage studies.  Partner with the local tourism industry, property owners, businesses, nonprofit organizations, and other public agencies to develop and promote Heritage Tourism opportunities, integrating efforts with ongoing initiatives for economic development and the creative economy.
 Work with local schools and historic organizations to engage and interest residents of all ages in Santa Rosa's history and historic sites, structures, and neighborhoods.

Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
PLACEWORKS 2-15
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
*Action 4-3.7: Identify buildings that should be recognized for cultural significance and/or considered for landmark designation.
*Action 4-3.9: Preserve historic aspects of parks while integrating modern uses and amenities.

Impact CUL-2: Impacts to known and
unknown archeological resources could
occur from potential future development
under the proposed General Plan 2050.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan and concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced. *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.

General Plan 2050 Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture
*Action 4-2.1: The City shall Ccontinue to review proposed developments in conjunction with accordance with federal and State laws, and utilize the California Historical Resources Information System, Northwest Information Center, at Sonoma State University as a resource to determine whether project areas contain known subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources, or if they have the potential to hold such resources and if so, implement mitigation to protect the resource. *Action 4-2.2: The City shall Wwork in good faith with interested communities local tribes and archaeologists to evaluate proposed development sites for the presence of subsurface historic, archaeological resources, both prehistoric and/or historic era, and tribal cultural resources. These efforts may include:
 Consideration of existing reports and studies.
 Consultation with Native American tribes as required by State law.  Appropriate site-specific investigative actions.
 On-site monitoring during excavation if appropriate.
 Work with local tribes to develop and apply tribal protection policies related to tribal cultural resources. *Action 4-2.3: The City shall Ccontinue to require that project areas found to contain significant subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources be examined by a qualified consulting archaeologist with recommendations for protection and preservation, developed in collaboration with local Native American tribes and appropriate tribal monitors, as necessary. Recommendations shall meet the standards of the National Historic Preservation Act, Native American Historic Resource Protection Act, Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
2-16 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
National and California Environmental Quality Act, and applicable Santa Rosa planning guidelines, policies, and procedures to protect the resource.
*Action 4-2.4: During ground disturbance for development projects, IIf tribal cultural resources are encountered during development, halt work shall be halted to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative (if appropriate) have evaluated the situation and recorded identified tribal cultural resources—which may include sites, features, places, cultural and other landscapes, sacred places, objects, animals, structures, landscapes, or plants with cultural value to the tribe(s)—and determined suitable mitigation measures. If human remains are inadvertently discovered, the County coroner shall be notified immediately. If the coroner determines that the remains are those of a Native American, the coroner must contact the NAHC by phone within 24 hours of making that determination (Health and Safety Code § 7050[c]).

The City and the professional archaeologist shall contact the Most Likely Descendent, as determined by the NAHC, regarding the remains.

GEOLOGY AND SOILS (GEO)
Impact GEO-1: Impacts from potential future
development under the proposed General
Plan 2050 where there are known geological
hazards could occur over the buildout
horizon of the proposed project.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Policy 5-1.1: Prior to new development approval, where there are known geological hazards, as shown on Figures 5-2, 5-3, and 5-4 and current maps from the United States Geological Survey, California Geological Survey, California Department of Water Resources, California Office of Emergency Services, the City shall Eensure that new development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards through the preparation of a site-specific geologic study prepared by a California Certified Engineering Geologist and/or Geotechnical Engineer and compliance with identified measures. *Action 5-1.1: Prior to new development approval, the City shall ensure site-specific geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable to appropriately mitigate hazardous conditions.
*Action 5-1.2: The City shall Rrestrict development in areas where adverse impacts conditions associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a California Certified Engineering Geologist and/or Geotechnical Engineer.

Less than
signiﬁcant
Impact GEO-3: Impacts from potential future
development under the proposed General
Plan 2050 where
there are potentially
unstable soils could occur over the buildout
horizon of the proposed project.

Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
PLACEWORKS 2-17
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
*Action 5-1.1: Prior to new development approval, the City shall ensure site-specific geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable to appropriately mitigate hazardous conditions.
*Action 5-1.2: The City shall Rrestrict development in areas where adverse impacts conditions associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a California Certified Engineering Geologist and/or Geotechnical Engineer.

Impact GEO-4: Impacts from potential future
development under the proposed General
Plan 2050 where there are expansive soils
could occur over the buildout horizon of the
proposed project.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Policy 5-1.1: Prior to new development approval where there are known geological hazards, as shown on Figures 5- 2, 5-3, and 5-4 and current maps from the United States Geological Survey, California Geological Survey, California Department of Water Resources, California Office of Emergency Services, the City shall Eensure that new development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards through the preparation of a site-specific geologic study prepared by a California Certified Engineering Geologist and/or Geotechnical Engineer and compliance with identified measures. *Action 5-1.1: Prior to new development approval, the City shall ensure site-specific geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable to appropriately mitigate hazardous conditions.
*Action 5-1.2: The City shall Rrestrict development in areas where adverse impacts conditions associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a California Certified Engineering Geologist and/or Geotechnical Engineer.

Less than
signiﬁcant

HYDROLOGY (HYD)
Impact HYD-1: Impacts to water quality
could occur from implementation of the
proposed project.

Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
2-18 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
*Action 3-5.1211: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction.

The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced.
*Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan, and the concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced. *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-2.14: The City shall Rrequire improvements that maintain and improve the storm drainage system citywide and prioritize areas needing significant investment, consistent with the Santa Rosa Citywide Creek Master Plan goals of preserving natural conditions of waterways and minimizing channelization of creeks. *Action 5-2.15: The City shall Eensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Bicycle and Pedestrian Master Plan, as subsequently revised, supplemented, or replaced, and are incorporated into stormwater improvement projects along creek corridors. *Action 5-2.17: The City shall RrRequire implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system. *Action 5-9.30: The City shall Eevaluate stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 National Pollutant Discharge Elimination System (NPDES) permit to preserve natural conditions of waterways, minimize channelization of creeks, and protect water quality, and identify, educate, and label to promote community awareness that storm drains flow untreated into creeks.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
PLACEWORKS 2-19
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation

NOISE (NOI)
Impact NOI-1a: Construction activities
associated with potential future
development could expose sensitive
receptors to excessive noise from
construction equipment.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-7.1: The City shall Ccontinue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: The City shall Uuse the Federal Transit Administration’s construction noise and vibration thresholds as applicable to assess impacts to surrounding land uses and identify mitigation measures during the project approval process to ensure the threshold is met prior to project approval. *Action 5-7.10: The City shall Uupdate the Noise Ordinance to incorporate construction best management practices (BMP) to minimize construction noise, and require projects to demonstrate compliance with the BMPs prior to project approval.

Signiﬁcant and
unavoidable
In most cases, construction of individual developments associated with implementation of the proposed project would temporarily increase the ambient noise environment in the vicinity of each individual project, potentially affecting existing and future nearby sensitive uses. The policies and actions of the proposed General Plan 2050 would minimize the effects of construction noise. Specifically, proposed *Action 5-7.1 requires the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate impacts, and *Action 5-7.2 and *Action 5-7.10 would mitigate noise impacts by requiring the City to use the noise and vibration thresholds based on the Federal Transit Administration’s criteria for acceptable levels of construction noise and vibration to evaluate and mitigate impacts, and adopt construction best management practices, respectively. However, because construction activities associated with any individual development may occur near noise-sensitive receptors and because—depending on the project type, equipment list, time of day, phasing, and overall construction durations— noise disturbances may occur for prolonged periods of time, during the more sensitive nighttime hours, or may exceed 80 dBA L
eq at residential land uses even with future project-level mitigation, construction noise impacts associated with implementation of the proposed project are considered significant and unavoidable. Due to the programmatic nature of this EIR, project-level conclusions of construction noise would be speculative; however, the identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects analyzed at the project level that do not exceed the noise thresholds.

Impact NOI-1b: Operational vehicle traﬃc
noise increases could exceed the City’s
signiﬁcance thresholds with implementation
of the proposed project.

Signiﬁcant and
unavoidable
SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
2-20 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
*Action 5-7.3: The City shall Rrequire conditions of approval or mitigation development projects to reduce noise exceeding normally acceptable levels as identified in Figure 5-13, unless the activities are specifically exempted by the City Council, on the basis of community health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens.
*Action 5-7.7: The City shall Wwork with Caltrans to evaluate and develop traffic noise mitigation programs along Highway 101 and State Route 12.
*Action 5-7.9: Use conditions of approval to achieve The City shall require development projects to implement measures to reduce noise and vibration impacts primarily through site planning, and avoid engineering solutions for noise and vibration mitigation, such as sound walls, if possible.

Implementation of proposed General Plan 2050 *Action 5-7.1 requires the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate impacts. Proposed *Action 5-7.2 requires the City to apply the Federal Transit Administration’s vibration thresholds to assess impacts to surrounding land uses.

Proposed *Action 5-7.3 requires conditions of approval or mitigation development projects to reduce noise exceeding normally acceptable levels unless the activities are specifically exempted by the City Council on the basis of community health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens. Proposed *Action 5-7.7 requires the City to work with Caltrans to evaluate and develop traffic noise mitigation programs along US Highway 101 and State Route 12. Furthermore, proposed *Action 5-7.9 requires conditions of approval to achieve development projects to implement measures to reduce noise impacts primarily through site planning and avoid engineering solutions for noise mitigation, such as sound walls, if possible. Since project-specific details are unknown and future conditions of approval may not be feasible or reduce vehicle traffic noise below significance thresholds in all cases, this impact is conservatively considered significant and unavoidable. The identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects analyzed at the project level that do not exceed the noise thresholds.

Impact NOI-1c: Operational noise increases
could exceed the City’s signiﬁcance
thresholds and could be incompatible with
existing uses.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-7.1: The City shall Ccontinue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.3: The City shall Rrequire conditions of approval or mitigation development projects to reduce noise exceeding normally acceptable levels as identified in Figure 5-13, unless the activities are specifically exempted by the City Council, on the basis of community health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens.
*Action 5-7.9: Use conditions of approval to achieve The City shall require development projects to implement measures to reduce noise and vibration impacts primarily through site planning, and avoid engineering solutions for noise and vibration mitigation, such as sound walls, if possible.

Less than
signiﬁcant
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

EXECUTIVE SUMMARY
PLACEWORKS 2-21
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
Impact NOI-2a: Construction activities
associated with potential future
development under the proposed General
Plan 2050 could generate excessive short-
term vibration levels during project
construction.

Less than
signiﬁcant
Impact NOI-2b: Operational activities
associated with potential future
development under the proposed General
Plan 2050 could generate excessive long-
term vibration levels.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-7.1: The City shall Ccontinue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: The City shall Uuse the Federal Transit Administration’s construction noise and vibration thresholds as applicable to assess impacts to surrounding land uses and identify mitigation measures during the project approval process to ensure the threshold is met prior to project approval. *Action 5-7.9: Use conditions of approval to achieve The City shall require development projects to implement measures to reduce noise and vibration impacts primarily through site planning, and avoid engineering solutions for noise and vibration mitigation, such as sound walls, if possible.

Less than
signiﬁcant
Impact NOI-4: Implementation of the
proposed project, in combination with past,
present, and reasonably foreseeable
projects, could result in cumulative noise
impacts, with respect to generation of
construction-and transportation related
noise.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-7.1: The City shall Ccontinue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: The City shall Uuse the Federal Transit Administration’s construction noise and vibration thresholds as applicable to assess impacts to surrounding land uses and identify mitigation measures during the project approval process to ensure the threshold is met prior to project approval. *Action 5-7.3: The City shall Rrequire conditions of approval or mitigation development projects to reduce noise exceeding normally acceptable levels as identified in Figure 5-13, unless the activities are specifically exempted by the City Council, on the basis of community health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens.
*Action 5-7.7: The City shall Wwork with Caltrans to evaluate and develop traffic noise mitigation programs along Highway 101 and State Route 12.

Signiﬁcant and
unavoidable
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
*Action 5-7.9: Use conditions of approval to achieve The City shall require development projects to implement measures to reduce noise and vibration impacts primarily through site planning, and avoid engineering solutions for noise and vibration mitigation, such as sound walls, if possible. *Action 5-7.10: The City shall Uupdate the Noise Ordinance to incorporate construction best management practices (BMP) to minimize construction noise, and require projects to demonstrate compliance with the BMPs prior to project approval.

Construction activities associated with potential future development could expose sensitive receptors in close proximity to a construction site to excessive noise from construction equipment (see Impact NOI-1a).

Implementation of proposed General Plan 2050 *Action 5-7.1, *Action 5.7-2, and *Action 5-7.10 would help reduce construction-related noise impacts. In addition, operational vehicle traffic noise increases could exceed the City’s significance thresholds with implementation of the proposed project and expose sensitive receptors in close proximity
to new development-generated roadway noise to excessive levels (see Impact NOI-1b). As with construction noise, implementation of proposed *Action 5-7.1, *Action 5.7-2, and *Action 5-7.10 would help reduce transportation-related noise impacts along with *Action 5-7.3, *Action 5-7.7, and *Action 5-7.9. However, due to the programmatic nature of the proposed project, no additional mitigation measures are available. As such, the cumulative noise impact is considered significant and unavoidable at the program level.

TRANSPORTATION (TRAN)
Impact TRAN-2a: Implementation of the
proposed project could result in a signiﬁcant
vehicle miles traveled (VMT) impact for
residential VMT per capita.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-1.1: For all projects with the potential to increase VMT based on the City’s VMT screening criteria, the City shall Rrequire a qualified transportation engineer to prepare an analysis of projected VMT and mitigation, as necessary, as part of the project review process for projects with the potential to increase VMT consistent with the City’s VMT guidelines, as subsequently revised, supplemented, or replaced.

Signiﬁcant
andunavoidable
Implementation of the proposed General Plan 2050 goals, policies, and actions would reduce the VMT generated by all development including residential uses. In support of proposed General Plan 2050 Policy 3-1.1 to reduce VMT, proposed *Action 3-1.1 requires a qualified transportation engineer to prepare an analysis of project VMT consistent with the City’s VMT guidelines for all projects with the potential to increase VMT based on the City’s VMT screening criteria and mitigation as part of the project review process. Proposed Action 3-1.2 requires the City to work with other local and regional partners to explore developing a VMT mitigation bank. Proposed Action 3-1.3 and Action 3-

1.5 supports prioritizing investments that will reduce VMT and GHG emissions.

If all individual development projects achieve the required residential VMT per capita through mitigation, use of a bank, or implementation of offsite measures, impacts would be reduced to a less-than-significant level. There are, however, two important aspects that introduce uncertainty as to whether these reductions can consistently be achieved. First, the proposed General Plan 2050 is a programmatic plan. Specific development plans defining the size, configuration, and characteristics of residential projects affect VMT projections, but site-specific information SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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PLACEWORKS 2-23
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
about future development projects is not available at this time. Because VMT performance is sensitive to these factors, it is not currently possible to conclusively determine VMT performance metrics and the effectiveness of VMT reduction strategies for individual sites. Second, there is uncertainty about the ability of all residential development projects to achieve the required VMT reductions—particularly projects in suburban locations in the outer areas of Santa Rosa where it may be infeasible to provide new or more frequent transit service and very few VMT reduction strategies are viable. Programs such as VMT mitigation exchanges or banks may provide a viable mitigation mechanism for developments, but the timing of when such programs may become available is unknown.

Given the programmatic nature of the proposed project, uncertainties as to whether individual development projects will be able to successfully meet VMT standards even with mitigation, and uncertainties as to the availability of other mitigation strategies such as VMT exchanges or banks, the impact is considered significant and unavoidable.

Note that this impact conclusion does not preclude the finding of less than significant at the project level for future projects over the 2050 buildout horizon.

Impact TRAN-2b: Implementation of the
proposed project could result in a signiﬁcant
roadway network vehicle miles traveled
(VMT) impact associated with increasing the
capacity of the arterial street network.

Signiﬁcant and
unavoidable
Implementation of the proposed General Plan 2050 goals, policies, and actions listed under impact discussion TRAN- 1 and TRAN-2 would improve the active transportation network, work with partner agencies to reduce VMT, encourage development in TPAs and PDAs, amongst others to reduce VMT generated by all development.

Specifically, proposed *Action 3-1.1 requires a qualified transportation engineer to prepare an analysis of project VMT consistent with the City’s VMT guidelines for all projects with the potential to increase VMT based on the City’s VMT screening criteria and mitigation as part of the project review process. Even with implementation of the proposed General Plan 2050 goals, policies, and actions related to VMT reduction, the effectiveness of VMT- reduction strategies and availability of alternative mitigation strategies such as VMT exchanges or banks is not certain. As such, the impact on roadway network VMT is considered significant and unavoidable.

Impact TRAN-5: The proposed project, in
combination with past, present, and
reasonably foreseeable projects, could result
in signiﬁcant cumulative impact with respect
to vehicle miles traveled (VMT).

Signiﬁcant and
unavoidable
Even with the proposed General Plan 2050 goals, policies, and actions described under impact discussion TRAN-2, including proposed *Action 3-1.1, the effectiveness of VMT-reduction strategies is not certain. As such, the cumulative impact on VMT is considered significant and unavoidable.

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2-24 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation

TRIBAL CULTURAL RESOURCES (TCR)
Impact TCR-1: Impacts to unknown tribal
cultural resources (TCR) could occur from
potential future development under the
proposed General Plan 2050.

General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for multiuse trails and recreation c onsistent with the Santa Rosa Citywide Creek Master Plan, and the concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced. *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.

General Plan 2050 Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture
*Action 4-2.1: The City shall Ccontinue to review proposed developments in conjunction with accordance with federal and State laws and utilize the California Historical Resources Information System, Northwest Information Center, at Sonoma State University as a resource to determine whether project areas contain known subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources, or if they have the potential to hold such resources and if so, implement mitigation to protect the resource. *Action 4-2.2: The City shall Wwork in good faith with interested communities local tribes and archaeologists to evaluate proposed development sites for the presence of subsurface historic, archaeological resources, both prehistoric and/or historic era, and tribal cultural resources. These efforts may include:
 Consideration of existing reports and studies.
 Consultation with Native American tribes as required by State law.  Appropriate site-specific investigative actions.
 On-site monitoring during excavation if appropriate.
 Work with local tribes to develop and apply tribal protection policies related to tribal cultural resources. *Action 4-2.4: During ground disturbance for development projects, Iif tribal cultural resources are encountered during development, halt work shall be halted to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative (if appropriate) have evaluated the situation and recorded identified tribal cultural resources—which may include sites, features, places, cultural and other landscapes, sacred places, objects, animals, structures, landscapes, or plants with cultural value to the tribe(s)—and determined suitable mitigation measures. If human remains are inadvertently discovered, the County coroner shall be notified immediately. If the coroner determines that the remains are those of a Native American, the coroner must contact the NAHC by phone within 24 hours of making that determination (Health and Safety Code § 7050[c]).

Less than
signiﬁcant
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TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
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Mitigation
The City and the professional archaeologist shall contact the Most Likely Descendent, as determined by the NAHC, regarding the remains.

WILDFIRE (WF)
Impact WF-1: Implementation of the
proposed General Plan 2050 could result in
inadequate wildﬁre-related evacuation
access the and impair the implementation of
an emergency evacuation plan.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-5.14: The City shall Rrequire all new development projects to provide adequate access for fire and emergency response personnel.
*Action 5-5.15: The City shall Pprohibit the creation of new single ingress/egress roadway conditions in the city. *Action 5-5.16: The City shall Rretrofit existing single-access residential neighborhoods to include additional access routes or other provisions to increase evacuation safety. *Action 5-5.17: The City shall Aanalyze the capacity, viability, and safety of evacuation routes for hazard areas in the city (e.g., WUIFA) and evacuation locations throughout the city under a range of emergency scenarios and incorporate the results, as necessary, into the City’s Emergency Operations Plan Safety Element of the General Plan.

This analysis will be completed as part of the City’s Annex to the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan in 2026.

Less than
signiﬁcant
Impact WF-2: Potential future development
over the buildout horizon of the proposed
project could increase population, buildings,
and infrastructure in wildﬁre-prone areas,
thereby exacerbating wildﬁre risks.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-3.8: The City shall Rrequire the preparation of fire protection plans for new development and major remodels in the City’s Very High Fire Hazard Severity Zone and Wildland-Urban Interface Fire Area (WUIFA). Require that fire protection plans be consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements (e.g., defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for non-conforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans.

Signiﬁcant and
unavoidable
Goals, policies, and actions identified in the proposed General Plan 2050 provide the best wildfire hazard reduction measures available. Specifically, proposed *Action 5-3.8 requires the preparation of fire protection plans for new development and major remodels in the City’s Wildland-Urban Interface Fire Area (WUIFA), which are highly vulnerable areas; that are consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements (e.g., defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for nonconforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans. However, the only way to fully avoid the wildfire impact from implementation is to prohibit development in Very High Fire Hazard Severity Zones (FHSZ) and the WUIFA. The majority of northern and eastern Santa Rosa is in a Very High FHSZ and/or the WUIFA. Prohibiting new development in this portion of Santa Rosa is not feasible or practical because the City has a responsibility to meet other, conflicting obligations, including increasing the number and type of housing available and allowing reconstruction of homes burned by wildfires. Therefore, this measure is considered and rejected, and there are no feasible mitigation SANTA ROSA GENERAL PLAN 205 0 FINAL EIR

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EXECUTIVE SUMMARY
2-26 APRIL 2025
TABLE 2-1 SUMMARY OF SIGNIFICANT IMPACTS AND MITIGATING POLICIES AND ACTIONS Environmental Impact Proposed Mitigating General Plan 2050 Policies and Actions Significance
with
Mitigation
measures beyond the policies and plans described above. Due to potential unknown impacts from future development over the buildout horizon of the proposed project, impacts at the programmatic level would remain significant and unavoidable. This conclusion does not preclude a finding of less-than-significant impacts at the project level.

Impact WF-5: Potential development over
the buildout horizon of the proposed project
could, in combination with other
surrounding and future projects in the State
Responsibility Areas (SRA), Very High Fire
Hazard Severity Zones (FHSZ), or Wildland-
Urban Interface Fire Areas (WUIFA), result in
cumulative impacts associated with the
exposure of project occupants to pollutant
concentrations from a wildﬁre or
uncontrolled spread of a wildﬁre due to
slope, prevailing winds, or other factors.

General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-3.8: The City shall Rrequire the preparation of fire protection plans for new development and major remodels in the City’s Wildland-Urban Interface Fire Area (WUIFA). Require that fire protection plans be consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements (e.g., defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for non-conforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans.

Signiﬁcant and
unavoidable
Same as Impact WF-2, even with implementation of the proposed General Plan 2050 goals, policies, and actions, including proposed *Action 5-3.8, the only way to fully avoid the cumulative wildfire impact is to prohibit development in the SRA, Very High FHSZs, and WUIFA throughout the region. As a full prohibition of development in these areas is not feasible in the region, this impact is significant and unavoidable.

Note: In addition to the proposed General Plan 2050 policies and actions, potential future development under the proposed project would also be required to comply with applicable federal, State, and local regulations.

Please see Chapters 4.1 through 4.18 of the Draft EIR for the regulatory framework for each environmental resource topic.

PLACEWORKS 3-1
List of Commenters
Comments on the Draft EIR were received from the following agencies, organizations, and members of the public. Each comment letter and comment has been assigned a letter and a number as indicated below.

The comments are organized by government agencies (GOV), private organizations (ORG), members of the public (PUB), and public hearing (PH). Comments on the Draft EIR are presented in their original format in Appendix E, Comment Letters on the Draft EIR, of this Final Environmental Impact Report (EIR).

Comments were also received on the proposed Santa Rosa General Plan 2050 (also known as Santa Rosa Forward). Please see Master Response 1, Standards for Responses and Focus of Review, in Chapter 4, Comments and Responses, of this Final EIR regarding comments on project merits. The comment letters on the proposed General Plan 2050 are acknowledged for the record and are listed below as General Plan Comments (GP). Comments on the General Plan are presented in Appendix F, Comment Letters on the Draft General Plan, of this Final EIR.

3.1 GOVERNMENT AGENCIES
GOV1 Brian Olsen, California Geologic Survey, October 24, 2024 GOV2 Erin Chappell, California Department of Fish and Wildlife, November 19, 2024 GOV3 Yunsheng Luo, California Department of Transportation, November 20, 2024 GOV4 Tennis Wick, Sonoma County, November 20, 2024

3.2 PRIVATE ORGANIZATIONS
ORG1 Chris Guenther, Bikeable Santa Rosa, November 20, 2024 Submitted on behalf of the following additional organizations:
 Sonoma County Bicycle Coalition
 Santa Rosa YIMBY
 Friends of the Santa Rosa Climate Action Plan (FOCAP)  Sierra Club Sonoma Group
 Sonoma County Transportation and Land Use Coalition
 Coalition Opposing New Gas Stations (CONGAS)
 Greenbelt Alliance
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LIST OF COMMENTERS
3-2 APRIL 2025

3.3 MEMBERS OF THE PUBLIC
PUB1 Andrew Smith, October 20, 2024
PUB2 Mark Garay, November 5, 2024
PUB3 Mark Garay, November 6, 2024
PUB4 Kelsey Cody, November 8, 2024
PUB5 Ken MacNab, November 12, 2024
PUB6 Sonia Taylor, November 20, 2024

3.4 PUBLIC HEARING
PH1 Alexis Forester, Bikeable Santa Rosa, November 14, 2024 PH2 Ken MacNab, November 14, 2024
PH3 Planning Commissioner Charles Carter, November 14, 2024 PH4 Planning Commissioner Terrance Sanders, November 14, 2024 PH5 Planning Commissioner Aaron Pardo, November 14, 2024 PH6 Planning Commission Vice Chair Vicki Duggan, November 14, 2024 PH7 Planning Commission Chair Karen Weeks, November 14, 2024

3.5 GENERAL PLAN COMMENTS
GP1 Laural Chambers, Sonoma County Food Systems Alliance, November 1, 2024 GP2 Shan Magnuson, November 2, 2024
GP3 Ken MacNab, November 4, 2024
GP4 Gino Altamirano, November 12, 2024
GP5 Robin North, November 20, 2024
PLACEWORKS 4-1

4. Comments and Responses
This chapter includes a reproduction of comments received, and responses to each significant environmental issue raised during the public review period. Comments are presented in their original format in Appendix E, Comment Letters on the Draft EIR, of this Final Environmental Impact Report (EIR), along with annotations that identify each comment number . Comment letters in this chapter follow the same order as listed in Chapter 3, List of Commenters, of this Final EIR. The comments are organized and categorized by government agencies (GOV), private organizations (ORG), members of the public (PUB), and public hearing (PH).

Responses to those individual comments are provided in this chapter alongside the text of each corresponding comment. Letters are identified by category and each comment is labeled with the comment reference number in the margin. Where the same comment has been made more than once, a response may direct the reader to another numbered comment and response. Where a response requires revisions to analysis presented in the Draft EIR, these revisions are explained and shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR. All comments included in this document are formally acknowledged for the record and will be forwarded to the decision-making bodies as part of this Final EIR for their consideration in reviewing the project.

Certain topics raised by commenters require a lengthy response, and certain topics addressed in this Final EIR require a detailed explanation. In addition, certain topics were raised repeatedly, albeit in slightly different forms, in comments on the Draft EIR. To minimize duplication and provide a more comprehensive discussion, “master responses” have been prepared for some of these issues. Responses to individual comments reference these master responses as appropriate. A particular master response may provide more information than requested by any individual comment. Conversely, the master response may not provide a complete response to a given comment, and additional information may be contained in the individual response to that comment. Master responses in this Final EIR address the topics of Standards for Responses and Focus of Review, Mitigation, and Vehicles Miles Traveled (VMT).

4.1 MASTER RESPONSES
MASTER RESPONSE 1. STANDARDS FOR RESPONSES AND FOCUS OF REVIEW

PROJECT MERITS
During the review of the EIR, some commenters raised issues that related to qualities of the project itself (in this case, the project includes the proposed Santa Rosa General Plan 2050 (also known as Santa Rosa Forward), along with the associated Specific Plan and Santa Rosa City Code (SRCC) amendments, and the SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-2 APRIL 2025
Community-wide Greenhouse Gas Reduction Strategy (GHG Reduction Strategy) or the project’s community consequences or benefits, personal well-being and quality of life, and economic or financial issues (referred to here as “project merits”), rather than the environmental analyses or impacts and mitigations raised in the EIR. However, consistent with the California Environmental Quality Act (CEQA) Guidelines Section 15131, Economic and Social Effects, the Draft EIR is not meant to address these project merits, rather, the purpose of CEQA and the Draft EIR is to fully analyze and mitigate the project’s potentially significant physical impacts on the environment to the extent feasible.

In accordance with CEQA Guidelines Sections 15088, Evaluation of and Response to Comments, and 15132, Contents of Final Environmental Impact Report, a Final EIR must include a response to comments on the Draft EIR pertaining to environmental issues analyzed under CEQA. Several of the comments provided in response to the Draft EIR express an opinion for or against the components of the project, but do not address the adequacy of the analysis or conclusions in the Draft EIR. Rather, these opinions relate to the merits of the project.

Lead Agency review of environmental issues and project merits are both important in the decision of what action to take on a project, and both are considered in the decision-making process for a project.

However, as part of the environmental review process, a lead agency is only required by CEQA to respond to environmental issues that are raised. The City of Santa Rosa (City) will hold a publicly noticed hearing to consider action on the merits of the proposed project for approval or disapproval. The City will consider both the EIR and project merit issues that have been raised prior to acting to approve or disapprove the proposed project.

Section 15204(a), Focus of Review, of the State CEQA Guidelines provides direction for parties reviewing and providing comment on a Draft EIR, as follows:

In reviewing draft EIRs, persons and public agencies should focus on the sufficiency of the document 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. Comments are most helpful when they suggest additional specific alternatives or mitigation measures that would provide better ways to avoid or mitigate the significant environmental effects. At the same time, reviewers should be aware that the adequacy of an EIR is determined in terms of what is reasonably feasible, in light of factors such as the magnitude of the project at issue, the severity of its likely environmental impacts, and the geographic scope of the project. CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters. When responding to comments, lead agencies need only respond to significant environmental issues and do not need to provide all information requested by reviewers, as long as a good faith effort at full disclosure is made in the EIR.

Therefore, in accordance with CEQA Guidelines Section 15204(a), the City is not required to respond to comments that express an opinion about the project merits, but do not relate to environmental issues covered in the Draft EIR. Although such opinions and comments on the project merits that were received during the EIR process do not require responses in the EIR, as previously noted, they do provide important input to the process of reviewing the project overall. Therefore, merits and opinion-based comment letters are included in Appendix F, Comment Letters on the Draft General Plan, of this Final EIR to be SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-3
available for consideration by the City decision-makers at the merits stage of the project. City decision- makers may consider these letters and issues as part of their deliberations on the merits of the project and whether to approve, modify, or disapprove the project.

SPECULATION WITHOUT SUBSTANTIAL EVIDENCE
Various commenters stated or requested that significance conclusions of the EIR should be revised but fail to provide substantial evidence in support of their statement or request. Predicting the project’s physical impacts on the environment without substantial evidence based on facts to support the analysis would require a level of speculation that is inappropriate for an EIR.

CEQA Statute Section 21082.2(a), Significant Effect on Environment; Determination; Environmental Impact Report Preparation, requires that the lead agency “shall determine whether a project may have a significant effect on the environment based on substantial evidence in light of the whole record.” CEQA Guidelines Section 15384(a), Substantial Evidence, clarifies that “‘substantial evidence’… means enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached. Whether a fair argument can be made that the project may have a significant effect on the environment is to be determined by examining the whole record before the lead agency. Argument, speculation, unsubstantiated opinion or narrative evidence which is clearly erroneous or inaccurate, or evidence of social or economic impacts which do not contribute to or are not caused by physical impacts on the environment, does not constitute substantial evidence.” CEQA Guidelines Section 15384(b) goes on to state that “substantial evidence shall include facts, reasonable assumptions predicated upon facts, and expert opinion supported by facts.” Where there are no facts available to substantiate a commenter’s assertion that the physical environment could ultimately be significantly impacted as a result of the project, the City acting as the lead agency, is not required to analyze that effect, nor to mitigate for that effect. CEQA Guidelines Section 15204(c) advises reviewers that comments should be accompanied by factual support:

Reviewers should explain the basis for their comments, and should submit data or references offering facts, reasonable assumptions based on facts, or expert opinion supported by facts in support of the comments. Pursuant to Section 15064, an effect shall not be considered significant in the absence of substantial evidence.

Under CEQA, the decision as to whether an environmental effect should be considered significant is reserved at the discretion of the lead agency based on substantial evidence in the record as a whole. The analysis of the Draft EIR is based on scientific and factual data, which has been reviewed by the lead agency and reflects its independent judgment and conclusions. CEQA permits disagreements of opinion with respect to environmental issues addressed in an EIR. As Section 15151, Standards for Adequacy of an EIR, of the CEQA Guidelines states, even “[d]isagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among experts.” CEQA Guidelines Section 15145, Speculation, provides that:

If, after thorough investigation, a lead agency finds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact.

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COMMENTS AND RESPONSES
4-4 APRIL 2025

ADDITIONAL ANALYSIS
During the review period for the Draft EIR, some commenters requested additional analysis, mitigation measures, or revisions that are not provided in this Final EIR for reasons more specifically addressed in the individual comments in Section 4.2, Individual Responses. As previously described, CEQA Guidelines Section 15204(a) provides that CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters.

CEQA Guidelines Section 15003, Policies, also explains the emphasis of CEQA upon good-faith efforts at full disclosure rather than technical perfection:
(i) CEQA does not require technical perfection in an EIR, but rather adequacy, completeness, and a good-faith effort at full disclosure. A court does not pass upon the correctness of an EIR's environmental conclusions but only determines if the EIR is sufficient as an informational document. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692). (j) CEQA requires that decisions be informed and balanced. It must not be subverted into an instrument for the oppression and delay of social, economic, or recreational development or advancement. (Laurel Heights Improvement Assoc. v. Regents of U.C. (1993) 6 Cal.4th 1112 and Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553).

CEQA Guidelines Sections 15204(a) and 15003 reflect judicial interpretation of CEQA. Under CEQA, lead agencies need only respond to significant environmental issues, and do not need to provide all information requested by reviewers, so long as a good-faith effort at full disclosure is made in the EIR.

MASTER RESPONSE 2. MITIGATION
Some comments on the Draft EIR are about the mitigation measures identified to reduce impacts that were found to be potentially significant. Some comments request new and/or modified mitigation measures and others question how and when mitigation measures will be implemented. Lastly, some comments suggest that every General Plan policy and action apply to every project. This master response provides greater detail on each of the issues raised by commenters with respect to mitigation.

IDENTIFYING SIGNIFICANT IMPACTS AND FEASIBLE MITIGATION Pursuant to CEQA, the decision as to whether an environmental effect should be considered significant is reserved for the discretion of the City, acting as the lead agency, based on substantial evidence in the record as a whole, including the views held by members of the public. An ironclad definition of significant effect is not always possible because the significance of an activity may vary with the setting and other factors. However, the analysis in the Draft EIR is based on scientific and factual data, which has been reviewed by the lead agency and reflects its independent judgment and conclusions. CEQA Guidelines Section 15126.4(a)(3), Consideration and Discussion of Mitigation Measures Proposed to Minimize Significant Effects, does not require mitigation measures for impacts that are not found to be significant; therefore, the mitigation measures in this EIR are only for impacts that were found to be significant, and additional mitigation is not required.

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COMMENTS AND RESPONSES
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As described in Chapters 4.1 through 4.18 of the Draft EIR, implementation of the proposed project, in combination with long-term regional growth projections prepared by the Association of Bay Area Governments (ABAG), has the potential to generate significant environmental impacts. Accordingly, consistent with CEQA Guidelines Section 15126.4, the Draft EIR proposes and describes mitigation measures designed to minimize, reduce, or avoid each identified potentially significant impact whenever it is feasible to do so. The term “feasible” is defined in CEQA Guidelines Section 15364, Feasible, to mean, “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, legal, social, and technological factors.” CEQA Guidelines Section 15370, Mitigation, defines “mitigation” as including: (1) avoiding the impact altogether by not taking a certain action or parts of an action; (2) minimizing impacts by limiting the degree or magnitude of an action and its implementation; (3) rectifying the impact by repairing, rehabilitating, or restoring the impacted environment; (4) reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and (5) compensating for the impact by replacing or providing substitute resources or environments.

While, by definition, mitigation measures may be imposed to require changes be made to the proposed project for purposes of reducing environmental impacts, the proposed mitigation measures in this Final EIR do not alter the description of the project contained in Chapter 3, Project Description, of the Draft EIR, or the analysis. Rather, the purpose of the Draft EIR is to fully disclose the environmental impacts of the project as proposed. Consistent with CEQA Guidelines Section 15126.2, Consideration and Discussion of Significant Environmental Impacts, where there are impacts that cannot be avoided without imposing changes to the project’s design, the EIR identifies the significant and unavoidable impact and the reasons why the project is being proposed, notwithstanding the impact.

Consistent with CEQA Guidelines Section 15126.4(a)(4)(A), the mitigation measures in this Final EIR have a direct nexus (i.e., connection) with the identified significant impact (Nollan v. California Coastal Commission, 483 U.S. 825 (1987)). In addition, consistent with CEQA Guidelines Section 15126.4(a)(4)(B), the mitigation measures are “roughly proportional” to the potential significant impacts of the project (Dolan v. City of Tigard, 512 U.S. 374 (1994)).

As part of the impact analysis process under CEQA, the lead agency must consider the feasibility of proposed mitigation measures. If the City, acting as the lead agency, determines that a mitigation measure is not feasible or cannot be legally imposed, the measure need not be proposed or analyzed. Instead, CEQA Guidelines Section 15126.4(a)(5) allows that the EIR may simply reference that fact and briefly explain the reasons underlying the lead agency’s determination. When a lead agency approves a project that would result in significant and unavoidable impacts (where mitigation measures are either infeasible or do not reduce the impact to less-than-significant levels) the lead agency must prepare a statement of overriding considerations that discloses the reasons for supporting the approved action (including the views held by members of the public), in spite of the identified significant environmental impact. This statement of overriding considerations must be supported by substantial evidence in the record, including the EIR, in compliance with CEQA Guidelines Section 15043, Authority to Approve Projects Despite Significant Effects. As described in CEQA Guidelines Section 15043, the City may approve the project even though the project would cause a significant effect on the environment if the City makes a fully informed and publicly disclosed decision that describes how the merits of the project outweigh reducing or SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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avoiding the significant environmental impacts. Because the proposed project would result in significant and unavoidable impacts, the City would be required to adopt a statement of overriding considerations if it approves the proposed project, consistent with CEQA Guidelines Section 15093, Statement of Overriding Considerations.

IMPLEMENTING MITIGATION MEASURES
The mitigation measures described in this EIR are fully enforceable through permit conditions, agreements, or other legally binding instruments. Under CEQA, an EIR is required to identify feasible mitigation measures that could reduce identified impacts to less-than-significant levels. Under the CEQA Statute Section 21081.6, a lead agency is required to adopt a “reporting or monitoring program for the changes made to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment” (CEQA Guidelines Section 15097, Mitigation Monitoring or Reporting, provides additional direction on mitigation monitoring or reporting). This program is often referred to as a Mitigation Monitoring and Reporting Program (MMRP). The City is the lead agency for the project and is, therefore, responsible for enforcing and monitoring the mitigation measures in the MMRP (see Chapter 6, Mitigation Monitoring and Reporting Program, of this Final EIR).

DEFERRED MITIGATION
CEQA Guidelines Section 15126.4 prohibits the formulation of mitigation measures to be deferred until some future time. The CEQA Guidelines acknowledge an exception, explaining that mitigation measures may specify performance standards for mitigating a significant impact that might be accomplished in various ways. Therefore, when it is known that mitigation is feasible, but it is impractical to devise specific measures during the planning process, the agency can commit itself to devising measures that satisfy performance criteria. Accordingly, pursuant to CEQA Guidelines Section 15126.4(a)(1)(B), the mitigation measures described in this EIR specify performance standards to mitigate the significant effect of the project or show how mitigation can be accomplished in more than one specified way.

GENERAL PLAN POLICIES AND ACTIONS AS MITIGATION
As described in Chapter 3, Project Description, and Chapter 4.0, Environmental Analysis, CEQA Statute Section 21081.6(b) and CEQA Guidelines Section 15126.4(a)(2) establish that when a project examined in an EIR is a plan (such as a General Plan), policy, regulation, or other public project, mitigation measures may be incorporated into the plan, policy, regulation, or project design. Therefore, as this is a General Plan EIR, some policies and actions in the proposed General Plan 2050 are also required as means to mitigate environmental impacts under CEQA. These mitigating policies and actions are fully enforceable at the discretion of the decision maker regarding applicability to a proposed future development and use the imperative “shall,” and in all such cases are mandatory. Not every General Plan policy or action applies to every future project in Santa Rosa. Because a General Plan consists of policies reflecting a wide range of competing interests, projects need not satisfy each and every policy. “It is beyond cavil that no project could completely satisfy every policy stated in [a General Plan], and that state law does not impose such a requirement” (Sequoya Hills Homeowners Association v. City of Oakland (1993) 23 Cal. App. 4th 704, 719).

For example, proposed General Plan 2050 *Policy 5-1.1 only applies to projects where there are known
geological hazards, and as such would not apply to every proposed future development. As described in SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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Chapter 1, Introduction, of the Draft EIR, as a program EIR, this document and the mitigation measures presented herein, will be used as a guide for implementing the proposed General Plan 2050 goals, policies, and actions, as well as adopting changes in City codes, regulations, and practices. This program EIR will also be used as a base resource for reviewing future development projects. This EIR will assist in guiding the assessment of projects and provide environmental review tiering, where appropriate.

As described in Chapter 4.0, Environmental Analysis, the mitigating policies and actions described in the EIR that are fully enforceable through permit conditions, agreements, or other legally binding instruments and include performance criteria are marked with an asterisk (*). In addition, these mitigating actions and policies are also denoted with and asterisk (*) in the General Plan to show they are required as a means to mitigate potential impacts from all future development in Santa Rosa. These proposed General Plan policies and actions are listed in the impact discussions of Chapters 4.1 through 4.18 of the Draft EIR to illustrate where the proposed policies and actions would reduce impacts from future development in Santa Rosa. The proposed General Plan 2050 and EIR were prepared concurrently and as such the policies and actions were crafted to mitigate environmental impacts that would otherwise occur without the added policies or actions.

PROPOSED CHANGES TO MITIGATION MEASURES
Where commenters’ recommendations to change mitigation measures included typographical corrections, insignificant modifications, and amplifications and clarifications, these changes are shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR. However, not all recommended new mitigation measures, or changes to mitigation measures, were accepted by the City. Pursuant to CEQA Guidelines Section 15204(a), CEQA does not require a lead agency to conduct every test or perform all research, study, and experimentation recommended or demanded by commenters, so long as a good-faith effort at full disclosure is made in the EIR. Where impacts are already found to be less than significant, there is no direct nexus to an impact and no mitigation is required, as previously discussed in this master response.

Therefore, suggestions to include additional mitigation measures were not accepted. Some recommendations were determined not to be necessary because existing City procedures, including compliance with City policies, already address the concern. Therefore, suggestions to include additional mitigation measures were also not accepted. In some cases, the City found the recommended mitigation measures to be infeasible, and those recommendations were not accepted as well. Responses are provided and the specific reason why a recommended change to a mitigation measure or new mitigation was not accepted are given in Table 4-1, Responses to Individual Comments on the Draft EIR.

Additionally, Table 2-1, Significant Impacts and Mitigation Measures, in Chapter 2, Executive Summary, of this Final EIR presents a summary of impacts and mitigation measures identified in the Draft EIR, including those that have been revised and any new mitigation measures that have been added in response to comments made on the Draft EIR. These tables are organized to correspond with the environmental issues discussed in Chapters 4.1 through 4.18 of the Draft EIR. These revisions do not affect any conclusions or significance determinations provided in the Draft EIR.

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MASTER RESPONSE 3. VEHICLE MILES TRAVELED
Some commenters expressed concerns about the VMT findings discussed in Chapter 4.15, Transportation, of the Draft EIR, with emphasis on the additional VMT that would be added over the buildout horizon of the proposed General Plan 2050. As identified under Impact Discussion TRANS-2 in Chapter 4.15 of the Draft EIR, the proposed General Plan 2050 is anticipated to result in significant and unavoidable impacts relative to two different categories of VMT at the program level, which does not preclude the finding of less than significant for future development projects in Santa Rosa over the 2050 buildout horizon. The following is an expanded discussion of these impacts to address comments received on transportation- related VMT impacts.

The Draft EIR transportation assessment analyzes four distinct VMT categories. The first three are performance metrics:
 Household VMT per capita, or the amount of VMT generated on average by each resident, is used to determine whether residential-type land uses associated with the proposed General Plan 2050 would have a VMT impact.
 Employment VMT per worker, or the amount of commute-related VMT generated on average by each employee, is used to determine whether employment-based land uses (such as offices) associated with the proposed General Plan 2050 would have a VMT impact.  Total VMT per service population is a performance metric constituting the total VMT generated by all land uses in Santa Rosa divided by the sum of residents and employees (the “service population”) and is used to capture the broad VMT impacts of all land development, including consideration of the interactions among uses.
 Roadway Network VMT is substantially different from the first three categories and targets the VMT effects created by expansion of roadways; specifically, roadway network VMT is focused on the “induced” travel caused through making travel by vehicle easier as a result of expanded roadways and less congestion.

The Draft EIR concludes that the proposed General Plan 2050 could result in significant-and-unavoidable impacts related to residential development (household VMT per capita) and roadway network VMT (induced travel) at the program level.

RESIDENTIAL VMT IMPACT
Residential VMT was assessed by performing dedicated “runs” of the regional travel demand model maintained by the Sonoma County Transportation Authority (SCTA). The custom runs include all land use and roadway network modifications associated with the proposed General Plan 2050. Through analysis of VMT data and output produced by the SCTA model, the home-based VMT per capita generated by the city’s residents (current as well as new residents associated with continued buildout of residential land uses per the proposed General Plan 2050) was calculated. This value was then compared to the significance threshold for residential uses, which is set at a level of 15 percent below the existing countywide VMT per capita. The resulting analysis indicates that with buildout of the proposed General Plan 2050, the applicable residential VMT significance threshold would be exceeded by approximately 8 percent, which is considered to be a significant impact.

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Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, of the proposed General Plan 2050, as well as the proposed Draft Greenhouse Gas Reduction Strategy prepared in August 2024, include extensive policies and strategies intended to reduce VMT and combat the effects of climate change. The land use areas of change identified in the proposed General Plan 2050 have also been intentionally and carefully chosen to focus new development in VMT-efficient areas such as downtown and along major transit corridors. However, the proposed General Plan 2050 also retains many lower- density land use areas in the peripheral areas of Santa Rosa that were identified in prior General Plans.

Residents in these lower-density areas tend to generate higher levels of VMT, primarily attributable to their longer distances from jobs and services, as well as lower levels of transit service. When considering all future residential uses associated with proposed General Plan 2050 buildout in aggregate, Santa Rosa’s overall residential VMT per capita is projected to exceed the significance threshold and cause a significant impact.

Despite the significant residential VMT finding in the Draft EIR, future residential development projects in the city will still be required to achieve a standard of 15 percent below the countywide average residential VMT per capita. Proposed General Plan 2050 *Action 3-1.1 requires that all projects with the potential to increase VMT prepare an analysis of projected VMT and mitigation, as necessary. Accordingly, for individual residential development projects that do not achieve this standard, applicants shall be required to implement mitigation measures to meet the standard. In addition to incorporation transportation demand management (TDM) measures and/or constructing facilities to support non-auto travel, mitigation may take the form of paying into a VMT mitigation bank or exchange, allowing developers in higher-VMT areas to contribute funds toward regional improvements to reduce VMT through other means. While such VMT bank or exchange programs currently do not exist, they are anticipated to become available in the future during the 2050 buildout horizon and are currently being studied by SCTA for implementation in Sonoma County. While it may be possible for most residential development in Santa Rosa to ultimately meet VMT significance thresholds or satisfy one or more of the screening criteria contained in the City’s VMT Guidelines, the Draft EIR conservatively identifies a significant and unavoidable impact for several reasons. First, specific development plans defining the size, configuration, and characteristics of individual residential projects are unknown; this type of site-specific information affects VMT but cannot be analyzed at this time. Second, until programs such as VMT mitigation banks or exchanges are implemented and available to developers, some residential development projects (particularly in suburban locations on the periphery of the city) may be unable to fully mitigate their project-level VMT impacts. For these reasons, it was necessary to categorize the residential VMT impact as significant and unavoidable.

ROADWAY NETWORK VMT IMPACT
VMT analyses for transportation projects, specifically those related to adding vehicular capacity to major roadways, are conducted for CEQA purposes, including for programmatic plans like the proposed General Plan 2050. Unlike other types of VMT analyses that are tied to specific development projects, transportation project (or roadway network) VMT focuses specifically on the phenomenon of induced travel. Induced travel and VMT consists of driving that otherwise would not have occurred without the transportation project and is typically associated with roadway projects that increase capacity in a manner that encourages people to drive more. Reasons for induced travel can include shorter driving times and improved ease of driving compared to using other modes of travel.

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While research supports the premise that induced VMT occurs as a result of major roadway expansions, the phenomenon involves behavioral variables that cannot be captured by conventional models, including the SCTA regional model. CEQA guidance provided by the State directs practitioners to use a tool developed by the National Center for Sustainable Transportation (NCST) that is based on research, including the elasticities of VMT in relation to vehicle lane miles. The NCST tool uses net change in added vehicle lane miles as its primary input variable. The proposed General Plan 2050 identifies several arterial streets on which vehicle lanes would be added or removed. In aggregate, buildout of the proposed General Plan 2050 is estimated to result in a net increase of 17.3 lane miles, which based on output from the NCST calculator, is estimated to result in approximately 158,630 daily induced VMT. This increase in VMT is considered a significant VMT impact.

In addressing the topic of induced VMT for roadway expansion projects, the California Department of Transportation (Caltrans) states that the measures resulting in the largest VMT decreases are generally related to land use patterns and TDM strategies rather than modifications to the transportation project itself. As discussed previously, the proposed General Plan 2050 is consistent with this guidance in that it has focused land development intensification in VMT-efficient areas of Santa Rosa, and has incorporated policies and actions aimed at reducing VMT and greenhouse gas emissions, including Action 3-1.2, which calls for the City to work with SCTA and other local and regional partners to develop a VMT mitigation bank or exchange. Such banks or exchanges, once implemented, are anticipated to be valuable tools allowing the VMT impacts of both transportation projects and development projects to be effectively and feasibly mitigated.

In considering significant impacts related to induced VMT in Santa Rosa, it is also helpful to consider the nature of the roadway expansions themselves. The largest capacity-increasing project is the Farmers Lane extension, which would also incorporate facilities for non-auto travel and would reduce driving distances for travel between many parts of eastern and southern Santa Rosa. Other major projects include widening along Highway 12 in eastern Santa Rosa, which is adjacent to the planned Sonoma Valley Trail, and widening a portion of Stony Point Road in the southern part of the city. All three of these roadway expansion projects would also play a role in providing adequate facilities for emergency evacuations.

Finally, while buildout of the proposed General Plan 2050 would add arterial lane miles, it is also important to recognize that many City projects, including several in the proposed General Plan 2050 would reduce lane miles, reallocating roadway width to provide more robust non-auto facilities, including bike lanes. The Draft EIR ultimately deems the roadway network VMT impact to be significant and unavoidable given the uncertain timing of effective mitigation strategies such as VMT exchanges or banks, which, beyond the land use changes already incorporated into the proposed General Plan 2050, are expected to be the most effective strategies to mitigate the VMT impacts associated with roadway expansions.

4.2 INDIVIDUAL RESPONSES
Responses to individual comments on the Draft EIR are presented in Table 4-1. Individual comments are reproduced from the original versions in Appendix E, Comment Letters on the Draft EIR, of this Final EIR, along with the comment numbers shown in Appendix E, followed by the response.

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Government Organizations
Comment Letter GOV1: Brian Olson, California Geological Survey, October 24, 2024 Comment-GOV1-1:

Thank you for providing the City's Draft EIR for the 2050 Santa Rosa General Plan for our review. This email conveys the following recommendations from CGS concerning geologic issues within the General Plan document:

1. Fault Hazards
• The DEIR provides a discussion of earthquake surface fault rupture and CGS' Alquist-Priolo Earthquake Fault Zones (APEFZ) in the region, including a map depicting the locations of APEFZ within the City limits (Figure 4.7-1). However, CGS notes the surfaces traces of the Rodgers Creek Fault Zone and related APEFZ were recently revised in February 2024. The City should update their figure with these new fault traces and zones. • Current CGS APEFZ maps and GIS data are available here:
• Alquist-Priolo Fault Zones -https://cadoc.maps.arcgis.com/home/item.html?id=29d2f0e222924896833b69ff1 b6d2ca3 • Fault Traces - https://cadoc.maps.arcgis.com/home/item.html?id=15b355c071 ab4ef78831 daef25490a70 • EQZ App - https://maps.conservation.ca.gov/cgs/informationwarehouse/index.html?map=regulatorymaps Response-GOV1-1:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Figure 4.7-1, Regional Faults, in Chapter 4.7, Geology and Soils, of the Draft EIR has been updated to include the most recent version of California Geological Survey’s Alquist-Priolo Earthquake Fault Zones. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment Letter GOV2: Erin Chappell, California Department of Fish and Wildlife, November 19, 2024 Comment-GOV2-1:

The California Department of Fish and Wildlife (CDFW) received a Notice of Availability of the Draft Program Environmental Impact Report (EIR) from the City of Santa Rosa (City) for the Santa Rosa General Plan 2050 Project (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW previously submitted a letter dated March 2, 2023 in response to the EIR Notice to Preparation (NOP) for the Project.

CDFW is submitting comments on the EIR to inform the City, as the Lead Agency, of our concerns regarding potentially significant impacts to biological resources associated with the Project. The City is a participant in the planned Sonoma County Natural Community Conservation Plan/Habitat Conservation Plan and an adequate Program EIR protective of biological resources, including CDFW’s comments presented in this letter, may facilitate this process.

Response-GOV2-1:

This comment serves as an opening remark.

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-GOV2-2:

CDFW ROLE
CDFW is a Trustee Agency with responsibility under CEQA (Pub. Resources Code, § 21000 et seq.) pursuant to CEQA Guidelines section 15386 for commenting on projects that could impact fish, plant, and wildlife resources. CDFW is also considered a Responsible Agency if a project would require discretionary approval, such as permits issued under the California Endangered Species Act (CESA), Lake and Streambed Alteration (LSA) Program, or other provisions of the Fish and Game Code that afford protection to the state’s fish and wildlife trust resources.

Response-GOV2-2:

The comment is acknowledged. Because the comment does not address the adequacy of the Draft EIR, no further response is required pursuant to CEQA. Please see Master Response 1, Standards for Responses and Focus of Review, regarding project merits.

Comment-GOV2-3:

PROJECT DESCRIPTION SUMMARY
Proponent: City of Santa Rosa
Objective: The Project would replace the City’s existing General Plan, which was last comprehensively updated in 2009 and has a buildout horizon of 2035. The proposed Project is intended to guide development and conservation in the City. The proposed General Plan 2050 would build off the current General Plan 2035 and provide a direct framework for the upcoming changes in the City and the expected growth in the coming decades; as well as land use, transportation, and conservation decisions through the horizon year of 2050.

Location: The approximately 49-square-mile planning area, which includes the City of Santa Rosa and its Sphere of Influence, with an approximate center at 38.445699°N, 122.717849°W.

Response-GOV2-3:

Comment-GOV2-4:

REGULATORY REQUIREMENTS
California Endangered Species Act
Please be advised that a CESA Incidental Take Permit (ITP) must be obtained if the Project has the potential to result in “take” of plants or animals listed or candidates for listing under CESA, either during construction or over the life of the project. The Project has the potential to result in take of California tiger salamander (Ambystoma californiense), which is CESA listed as threatened, Coho salmon (Oncorhynchus kisutch), which is CESA listed as endangered, California freshwater shrimp (Syncaris pacifica), which is CESA listed as endangered, Northern Spotted Owl (Strix occidentalis caurina), which is CESA listed as threatened, and several plant species listed in the EIR Table 4.4-2 including, but not limited to, Sonoma sunshine (Blennosperma SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR bakeri), Sebastopol meadowfoam (Limnanthes vinculans), and Burke’s goldfields (Lasthenia burkei), which are CESA listed as endangered species, and burrowing owl (Athene cunicularia), which is a CESA candidate species, as further described below. Issuance of a CESA ITP is subject to CEQA documentation; the CEQA document must specify impacts, mitigation measures, and a mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain a CESA ITP .

CEQA requires a Mandatory Finding of Significance if a project is likely to substantially restrict the range or reduce the population of a threatened or endangered species. (Pub. Resources Code, §§ 21001, subd. (c) & 21083; CEQA Guidelines, §§ 15380, 15064, & 15065). Impacts must be avoided or mitigated to less-than-significant levels unless the CEQA Lead Agency makes and supports Findings of Overriding Consideration (FOC).

The CEQA Lead Agency’s FOC does not eliminate the project proponent’s obligation to comply with CESA.

Lake and Streambed Alteration
An LSA Notification, pursuant to Fish and Game Code section 1600 et seq., is required for Project activities affecting lakes or streams and associated riparian habitat. Notification is required for any activity that may substantially divert or obstruct the natural flow; change or use material from the bed, channel, or bank including associated riparian or wetland resources; or deposit or dispose of material where it may pass into a river, lake, or stream.

Project activities may impact streams or lakes, therefore an LSA Notification may be warranted, as further described below. Work within ephemeral streams, washes, watercourses with a subsurface flow, and floodplains are subject to LSA Notification requirements. CDFW would consider the CEQA document for the Project and may issue an LSA Agreement. CDFW may not execute the final LSA Agreement until it has complied with CEQA as a Responsible Agency.

Raptors and Other Nesting Birds
CDFW has jurisdiction over actions that may result in the disturbance or destruction of active nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include sections 3503 (regarding unlawful take, possession or needless destruction of the nests or eggs of any bird), 3503.5 (regarding the take, possession or destruction of any birds-of-prey or their nests or eggs), and 3513 (regarding unlawful take of any migratory nongame bird). Migratory birds are also protected under the federal Migratory Bird Treaty Act.

Response-GOV2-4:

The City appreciates the summary of the regulatory setting provided by the commenter . Please note that Chapter 4.4, Biological Resources, of the Draft EIR also provides a summary of these regulations. Please see the following pages of the Draft EIR for summaries of the regulations identified by the commenter: California Endangered Species Act, page 4.4-3; California Fish and Game Code with respect to take of birds and Lake and Streambed Alteration, page 4.4-4; and Migratory Bird Treaty Act, page 4.4-3. The City of Santa Rosa routinely complies with all required federal, State, and local regulations, including the California Endangered Species Act, Fish and Game Code, and Migratory Bird Treaty Act, and will continue this practice in the future.

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-GOV2-5:

COMMENTS AND RECOMMENDATIONS
CDFW offers the comments and recommendations below and in Attachment 1 to assist the City in adequately identifying and/or mitigating the Project’s significant, or potentially significant, direct and indirect impacts on fish and wildlife (biological) resources.

I. Project Description and Related Impact Shortcoming
COMMENT 1: Program Environmental Impact Report Subsequent Project Review The EIR is a Program EIR but does not include a checklist for subsequent Project review. As described in CDFW’s letter response to the NOP , while Program EIRs have a necessarily broad scope, CDFW recommends providing as much information related to anticipated future activities as possible.

CDFW recognizes that, pursuant to CEQA Guidelines section 15152, subdivision (c), if a Lead Agency is using the tiering process in connection with an EIR or large-scale planning approval, the development of detailed, site-specific information may not be feasible and can be deferred, in many instances, until such time as the Lead Agency prepares a future environmental document. This future environmental document would cover a Project of a more limited geographical scale and is appropriate if the deferred information does not prevent adequate identification of significant effects of the planning approval at hand. The CEQA Guidelines section 15168, subdivision (c)(4) states, “Where the later activities involve site-specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope of the program EIR.” Based on CEQA Guidelines section 15183.3 and associated Appendix N Checklist, and consistent with other program EIRs (e.g., California Vegetation Treatment Program Environmental Impact Report and associated checklist at https://bof.fire.ca.gov/projects-and-programs/calvtp-homepage-and- storymap/#:~:text=The%20CalVTP%20Program%20Environmental%20Impact,with%20the%20CalVTP%20Program%20EIR and template-psa-checklist- 508-compliant.dotx, https://view.officeapps.live.com/op/view.aspx?src=https%3A%2F%2Fbof.fire.ca.gov%2Fmedia%2Fuqbpmcuq%2Ftemplate-psa- checklist-508-compliant.dotx&wdOrigin=BROWSELINK), CDFW recommends creating a procedure or checklist for evaluating subsequent Project impacts on biological resources to determine if they are within the scope of the Program EIR or if an additional environmental document is warranted. This checklist should be included as an attachment to the EIR. Future analysis should include all special-status species and sensitive habitat including, but not limited to, species considered rare, threatened, or endangered species pursuant to CEQA Guidelines, section 15380.

When used appropriately, the checklist should be accompanied by enough relevant information and reasonable inferences to support a “within the scope” of the EIR conclusion. For subsequent Project activities that may affect sensitive biological resources, a site-specific analysis should be prepared by a Qualified Biologist to provide the necessary supporting information. In addition, the checklist should cite the specific portions of the EIR, including page and section references, containing the analysis of the subsequent Project activities’ significant effects and indicate whether it incorporates all applicable mitigation measures from the EIR.

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-GOV2-5:

The City appreciates the suggestions made by the commenter and respectfully disagrees that the Draft EIR does not adequately identify and/or mitigate potential impacts from implementation of the proposed project, which is a long-term policy document that does not propose any specific development.

The City also appreciates the suggestions made by the commenter regarding a procedure and/or checklist for evaluating future development projects in the EIR Study Area for potential impacts to biological resources and will consider the preparation of a procedure or checklist as suggested by the commenter, as appropriate. However, please note that there is no requirement under CEQA or otherwise to have such a checklist at this time in the General Plan or CEQA process for the evaluation of the proposed General Plan 2050.

Please see Section 1.4, Use of the General Plan EIR, in Chapter 1, Introduction, of the Draft EIR, for a summary of how the City will use the programmatic analysis in the EIR when a new development project is filed with the City. Where future specific development projects qualify for the CEQA streamlining options described by the commenter and identified in Section 1.4.1, Tiering Process, in Chapter 1 of the Draft EIR, the City will continue to use their standard process and rely on the CEQA Guidelines Appendix G, Environmental Checklist Form, or Appendix N, Infill Environmental Checklist Form, as is or as modified, to determine what impacts have been adequately addressed in the program EIR and what impacts require additional analysis and project- specific mitigation.

The CEQA-required MMRP included as Chapter 6, Mitigation Monitoring and Reporting Program, of this Final EIR includes columns that would serve to assist the City and future developers in determining which of the mitigation measures identified in the EIR would apply to a specific development project. Please see Table 6-1, Santa Rosa General Plan 2050 Mitigation Monitoring and Reporting Program, in Chapter 6 of this Final EIR.

Comment-GOV2-6:

II. Environmental Setting and Related Impacts Shortcomings Mandatory Findings of Significance: Does the Project have the potential to substantially reduce the number or restrict the range of an endangered, rare, or threatened species?
And,
Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or United States Fish and Wildlife Service (USFWS)? COMMENT 2: Deferred Mitigation
Issue, specific impacts, why they may occur and be potentially significant: If the Project may result in physical changes in the environment, such as facilitating development, then the Project could: 1) reduce the number or restrict the range of an endangered, rare, or threatened species, or 2) have a substantial adverse effect, either directly or through habitat modifications, on candidate, sensitive, or special-status species. The EIR documents 69 special-status plant species and 55 special-status animal species either within or in the vicinity of the City (4.4-19 through 4.4-27). The Project area has potential to support special-status species including, but not limited to Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields, CESA listed as endangered, California tiger salamander, a CESA listed as threatened species, and burrowing owl, a CESA candidate species and California Species of SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-16 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Special Concern, in addition to the other species mentioned above and in CDFW’s NOP response letter, however, the EIR does not include any mitigation measures for impacts to biological resources.

As described in CDFW’s letter response to the NOP , California tiger salamander may be directly or indirectly impacted by the Project resulting in mortality of individuals from direct impacts or indirect impacts from degradation of habitat adjacent to ground disturbance and other factors. Additionally, the Project may result in the permanent and temporary loss of California tiger salamander habitat.

The EIR indicates that wetlands may be present within Project sites. As described in CDFW’s letter response to the NOP , wetlands in the Santa Rosa Plain may support Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields, and loss of wetland habitat may result in in mortality of individuals and/or indirect impacts from degradation of habitat adjacent to ground disturbance due to altering hydrological conditions or other factors may occur .

The Project could result in burrowing owl injury or mortality of adults, and permanent wintering (i.e., non-nesting) habitat loss. Additionally, the Project may result in a permanent reduction of burrowing owl foraging habitat in Sonoma County. Burrowing owl is a special-status species and was recently approved as a candidate species under CESA because the species’ population viability and survival are adversely affected by risk factors such as precipitous declines from habitat loss, fragmentation, and degradation; evictions from wintering sites without habitat mitigation; and human disturbance (Shuford and Gardali 2008; Department of Fish and Game Staff Report on Burrowing Owl Mitigation (2012); personal communication, CDFW Statewide Burrowing Owl Coordinator Esther Burkett, May 13, 2022, CDFW Petition for western burrowing owl (Athene cunicularia hypugaea), 2024). Based on the foregoing, if burrowing owl are wintering on or within 500 meters (1,640 feet) of the Project site, or if burrowing owl foraging habitat is removed, Project impacts to burrowing owl would be potentially significant.

Response-GOV2-6:

The commenter correctly lists some, but not all, of the species and sensitive habitat that could be impacted from potential future development over the course of the 25-year buildout horizon of the proposed General Plan 2050 and potentially misunderstands how the EIR has included mitigation for potential impacts to these species and habitats and the others identified in Chapter 4.4, Biological Resources, of the Draft EIR.

As described in Chapter 3, Project Description, and Chapter 4.0, Environmental Analysis, of the Draft EIR, some policies and actions in the proposed General Plan 2050 are also required as means to mitigate environmental impacts under CEQA. This is also briefly described in Chapters 4.1 through 4.18 of the Draft EIR. Specifically, for Chapter 4.4, Biological Resources, please see the first paragraph in Section 4.4.3, Impact Discussion. Additional detail is also provided in Master Response 2, Mitigation, under subheading “General Plan Policies and Actions as Mitigation” regarding incorporating mitigation measures as General Plan policies and actions .

As described under impact discussion BIO-1 in Chapter 4.4, Biological Resources, of the Draft EIR, because potential future development under the proposed General Plan 2050 has the potential to occur where there is habitat for special-status species and sensitive natural communities, including wetlands and nesting areas, as stated by the commenter and identified in Chapter 4.4 of the Draft EIR, impacts from the proposed project were found to be potentially significant without (i.e., prior to) mitigation. Impacts were found to be less than significant with (i.e., after) implementation of mitigating General Plan actions included in Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, of the proposed General Plan 2050 SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-17
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR that require local planning and development decisions to consider impacts to biological resources, including special-status species, sensitive habitat, and active bird nests, on a project-by-project basis. As described in the Draft EIR, proposed General Plan 2050 *Action 3-5.7 requires the City to consult with CDFW to identify significant environments and develop a strategy for maintaining areas that will preserve special-status species; *Action 3-5.10 requires the City to continue to require the implementation of existing regulations to conserve habitat for special-status species; and *Action 3-5.11 requires the City to have biological resource assessments (BRA) prepared by qualified biologists that identify potential project- and site-specific impacts and mitigation measures for protecting the resources on sites that may support or have the potential to affect special-status species, habitat, and nesting birds. In addition, proposed *Action 3-5.12 and *Action 3-5.13 require the protection of bird habitat, including the possible loss or disturbance to bird nests in active use, which conflicts with both the federal Migratory Bird Treaty Act and California Fish and Game Code. Consultation with CDFW to identify environments that host special-status species, develop strategies for maintaining these areas, as well as the continued implementation of existing regulations to conserve special-status species would ensure that existing habitat for special-status species is protected, thus ensuring the ongoing protection of the species (proposed *Action 3-5.7 and *Action 3-5.10). The preparation of site-specific BRAs would include site-specific resource assessments and field surveys prepared by qualified biologists to determine the presence or absence of any sensitive resources that could be affected by proposed development, would provide an assessment of the potential impacts, and would define measures for protecting the resource and surrounding buffer habitat, in compliance with City policy and state and federal laws. They would also include following the agency-promulgated protocols and recommended methods and standards of review, including the consultation with CDFW and the United States Fish and Wildlife Service (USFWS) (proposed *Action 3-5.11). Implementing nesting bird protections would ensure any young birds are allowed to mature to the stage where they can successfully leave the nest, thus ensuring their chances for survival (proposed *Action 3-5.12). Bird-safe guidelines provide specific criteria to protect birds from injury and mortality from collisions with buildings, towers, and other human-made structures (proposed *Action 3-5.13 ). As demonstrated, implementation of these proposed General Plan 2050 actions, in conjunction with adherence to State and federal regulations related to the protection of special-status species, would address potential impacts of anticipated future development under the proposed project.

Future development would continue to be reviewed through the City’s entitlement process and CEQA, when applicable, to ensure consistency with local, State, and federal regulations and all General Plan policies and actions intended to protect sensitive biological resources. Ultimately, potential future development in Santa Rosa over the buildout horizon of the proposed General Plan 2050 would be performed in accordance with the proposed General Plan 2050 actions discussed herein and in Chapter 4.4, Biological Resources, of the Draft EIR, which would ensure that potential impacts on special- status species would be less than significant.

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, in response to the comment and information provided regarding the fact that the California Fish and Game Commission recently named burrowing owl as a candidate for listing under the California Endangered Species Act, Table 4.4-3, Special-Status Animal Species in the EIR Study Area, in Chapter 4.4, Biological Resources, of the Draft EIR has been revised to update the state status of burrowing owl to “Candidate.” This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-18 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-GOV2-7:

The EIR states that projects facilitated by the EIR will follow existing local government policies and applicable protective measures in the Santa Rosa Plain Conservation Strategy (SRP CS) (EIR pages 4.4-43 to 4.4-44). However, the SRP CS is a guidance document that was developed several years ago and conditions for some species have deteriorated since it was developed, therefore the SRP CS conservation measures may not adequately mitigate impacts to special-status species to less-than-significant. Additionally, the SRP CS does not cover all special-status species in the Project area. Therefore, while the SRP CS is a useful reference, the EIR should not rely on the SRP CS’s measures to mitigate impacts to less-than-significant and should instead conduct a current evaluation of impacts and appropriate mitigation measures.

Response-GOV2-7:

Please note that the Santa Rosa Plain Conservation Strategy (SRPCS) is only one of the guidance documents recognized in the Draft EIR to be used when assessing impacts to biological resources from potential future development in the EIR Study Area. For reference, the full context of the statement referenced by the commenter in Chapter 4.4, Biological Resources, on page 4.4-44 of the Draft EIR, reads “Implementation of the proposed General Plan 2050 goal, policies, and actions listed above, in conjunction with adherence to State and federal regulations related to the protection of special-status species, including the Santa Rosa Plain Conservation Strategy (SRPCS) where applicable, would address potential impacts of anticipated future development under the proposed project.” At no point in Chapter 4.4 of the Draft EIR is a significance conclusion based solely on the use of the SRPCS.

As recognized by the commenter, current evaluation of impacts and appropriate mitigation measures would be needed for potential future development in Santa Rosa, as required by proposed General Plan 2050 *Action 3-5.11 through the preparation of site-specific BRAs prepared by qualified biologists. It is the purpose of the site-specific BRA to consider the existing conditions on the ground as well as the current regulatory setting that may change over the course of the 25-year buildout horizon to identify impacts and mitigation that are appropriate to that moment in time of a future proposed development project.

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, the text referencing the SRPCS in Chapter 4.4, Biological Resources, of the Draft EIR has been updated to recognize that this document may be updated over time. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-GOV2-8:

The EIR also states that projects facilitated by the EIR “As part of the permitting project with the [US Army Corps of Engineers, Corps], projects affecting federally regulated waters must demonstrate that they would not have an adverse effect on federally listed species or would be required to provide adequate compensatory mitigation where avoidance is infeasible. For those projects within the boundaries of the SRP CS, including western and southern Santa Rosa, they must comply with the rigorous conditions of the Biological Opinion issued by the [US Fish and Wildlife Service, USFWS] in addressing potential effects on California tiger salamander, Burke’s goldfields, Sebastopol meadowfoam, and Sonoma sunshine.” (EIR pages 4.4-42). This does not address Projects that may not be subject to Corps and USFWS jurisdiction, where “take” as defined under CESA may occur .

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-19
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-GOV2-8:

The paragraph referenced by the commenter is part of the overall discussion on impacts to biological resources under impact discussion BIO-1 in Chapter 4.4, Biological Resources, of the Draft EIR and can be taken out of context as a stand-alone statement. For clarification, as described in Response-GOV2-6, project applicants of proposed development projects would be required to comply with General Plan actions, and all local, State, and federal laws, including the CESA. There is nothing in Chapter 4.4 of the Draft EIR that limits any future development project to compliance with one set of regulations. On the contrary, proposed General Plan 2050 *Action 3-5.10, requires the City to continue to implement existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species.

Comment-GOV2-9:

The EIR states that impacts to biological resources would be less-than-significant in part because of a requirement for “the City to have biological resource assessments prepared that identify potential impacts and mitigation measures for protecting the resources for proposed development on sites that may support special-status species.” (See EIR page 4.4-43).

However, the proposed biological resource assessments inappropriately defer formulating mitigation measures and may not appropriately identify special-status species that may be impacted and measures reducing such impacts to less-than-significant. Further, the proposed biological resource assessments would not be subject to public review under CEQA, thereby circumventing key purposes of CEQA including informing the public and governmental decision makers about the potential, significant environmental effects of a proposed project and identifying ways that environmental damage can be avoided or significantly reduced (CEQA Guidelines, § 15002). CEQA Guidelines section 15126.4, subdivision (b) states: “Formulation of mitigation measures shall not be deferred until some future time. The specific details of a mitigation measure, however, may be developed after Project approval when it is impractical or infeasible to include those details during the Project's environmental review provided that the agency (1) commits itself to the mitigation, (2) adopts specific performance standards the mitigation will achieve, and (3) identifies the type(s) of potential action(s) that can feasibly achieve that performance standard and that will considered, analyzed, and potentially incorporated in the mitigation measure. Compliance with a regulatory permit or other similar process may be identified as mitigation if compliance would result in implementation of measures that would be reasonably expected, based on substantial evidence in the record, to reduce the significant impact to the specified performance standards.” No specific mitigation measures are included in the biological resources section of the EIR, especially relating to take of CESA-listed species. The Lead Agency (the City) has therefore not committed itself to mitigation, nor does the EIR adopt specific performance standards for mitigation goals, nor does it identify types of actions that could meet these standards. In addition, the City of Santa Rosa General Plan 2035 EIR includes Mitigation Measure 4.F-5, which specifically requires that the City “…shall incorporate the avoidance and mitigation measures described in the SRP CS and the USFWS Programmatic Biological Opinion, as conditions of approval for development in or near areas with suitable habitat for California tiger salamander, Burke’s goldfields, Sonoma sunshine, Sebastopol meadowfoam, and many-flowered navarretia.” This mitigation measure should be included in the EIR and recognize the updated 2020 USFWS Programmatic Biological Opinion (2020 PBO).

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-20 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR It is conceivable based on the lack of mitigation measures that California tiger salamander, Coho salmon, California freshwater shrimp, Northern Spotted Owl, Sonoma sunshine, Sebastopol meadowfoam, Burke’s goldfields, burrowing owl, and other special-status species would: 1) not be appropriately evaluated in subsequent biological surveys, or 2) that future environmental review pursuant to CEQA would not require appropriate mitigation measures to reduce impacts to less-than-significant.

Therefore, if special-status species occur on or adjacent to Project sites, impacts to special-status species would be potentially significant, and impacts to species considered threatened, endangered, or rare may be considered a mandatory finding of significance (CEQA Guidelines, §§ 15065 & 15380).

Response-GOV2-9:

It is important to note, as recognized by the commenter in Comment-GOV2-5, the proposed General Plan 2050 is a policy-level document that does not include any development projects. Accordingly, the development of detailed, site-specific information is not feasible until such time as a future project is known and reviewed on a more limited geographical scale. The certification of the EIR and the approval of the proposed General Plan 2050 does not approve or deny any potential future development in the City of Santa Rosa or the EIR Study Area. As described in Section 3.9, Intended Uses of the EIR, in Chapter 3, Project Description, of the Draft EIR, this EIR is intended to review potential environmental impacts associated with the adoption and implementation of the proposed project and determine corresponding mitigation measures, as necessary. This EIR is a program-level EIR and does not evaluate the impacts of specific, individual developments that may occur under the buildout horizon of the proposed General Plan 2050. Each specific future project will conduct separate project approval processes, including environmental review as required by CEQA, if necessary, to secure the necessary development permits. For projects that are not subject to CEQA, compliance with the General Plan policies and actions, and other local, State, and federal laws would still be required. Therefore, while subsequent environmental review may be tiered off this EIR, this EIR is not intended to address impacts of individual projects. Subsequent projects will be reviewed by the City for consistency with the General Plan 2050 and this EIR. Because this EIR is a program-level evaluation, the specific details of future projects and the conditions at the time they are proposed are not known, it would be speculative to estimate any potential long-term or permanent changes, including those to the regulatory setting as noted by the commenter(CEQA Guidelines Section 15145, Speculation). Please see Master Response 1, Standards for Responses and Focus of Review, regarding speculation without substantial evidence.

As described in Section 1.4.1.1, Base Resource for General Plan Implementation and Review of Future Development Projects, in Chapter 1, Introduction, of the Draft EIR, when a new development project is filed with the City, it is reviewed for completeness and consistency with the General Plan goals, policies, and actions, and City codes and practices. Because City policies, actions, and codes, presented in this program EIR will minimize impacts, development projects will inherently implement these measures to: (a) mitigate environmental impacts and (b) achieve consistency with the General Plan and compliance with City codes. Pursuant to CEQA and the CEQA Guidelines, where the “project” subject to CEQA is a “plan, policy, regulation, or other public project,” the obligation to mitigate impacts can be effectuated “by incorporating the mitigation measures into the plan, policy, regulation, or project design” (CEQA Statute Section 21081.6(b); CEQA Guidelines, Section 15126.4(a)(2)).

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-21
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR The Draft EIR states that mandatory compliance with federal, State, and local regulations described under Section 4.4.1.1, Regulatory Framework, in Chapter 4.4, Biological Resources, of the Draft EIR, would reduce impacts to biological resources. The proposed General Plan 2050 also includes specific mandatory actions that would also reduce impacts to biological resources, including the State threatened and federally endangered species listed by the commenter throughout their letter, other special-status species, nesting birds, and sensitive habitat such as streams, creeks, and wetlands. These actions are based on the recommendations of the professional biologist who was part of the General Plan 2050 team. Specific proposed General Plan 2050 actions that address potential impacts to biological resources, including those identified by the commenter, are identified under Section 4.4.3, Impact Discussion, in Chapter 4.4 of the Draft EIR. Each of the proposed General Plan 2050 actions identified require local planning and development decisions to consider impacts to biological resources.

As previously stated, the preparation of a site-specific BRA prepared by a qualified biologist would identify special-status species that may be impacted by a potential future development and a site-specific study would identify site-specific mitigation measures. Proposed General Plan 2050 *Action 3-5.11 requires future project applicants to prepare a BRA by a qualified biologist for proposed development on sites that may support special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat. The project-specific BRAs would determine what site- and project-specific mitigation measures would be required for sensitive natural communities at the time of the proposed development throughout the 25-year buildout horizon (2025 to 2050) to ensure sensitive resources identified at the time of future project developments are adequately protected or appropriate project-specific compensatory mitigation is provided as part of new development to reduce impacts to a less-than-significant level, which is appropriate for a city-wide program-level EIR. Site- specific biological resources assessments and field surveys prepared by qualified biologists would follow the agency-promulgated protocols and recommended methods and standards of review including the consultation with CDFW and the USFWS and rely on standard protocol sources, including, but not limited to, those identified by the commenter (e.g., CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities; SRPCS, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain CDFW Staff Report on Burrowing Owl Mitigation; USFWS Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls, dated (revised) January 9, 2012, including Section 9 of the survey protocol, Surveys for Disturbance-Only Projects; and, USFWS guidance, Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California, dated October 1, 2020). Additionally, as described in Chapter 4.4, Biological Resources, of the Draft EIR and recognized by the commenter, where applicable, future projects would be required to comply with the Programmatic Biological Opinion for U.S. Army Corps of Engineers Permitted Projects That May Affect California Tiger Salamander and Three Endangered Plant Species on the Santa Rosa Plain, California (PBO), which was originally issued by the USFWS in 2007, amended in 2009, and reissued in 2020. As described in Chapter 4.4 on pages 4.4-8 and 4.4-9 of the Draft EIR, the PBO provides guidance to the U.S. Army Corps of Engineers (USACE) on projects that may affect these listed species, by defining “Conservation Areas” and “preserves” in the Santa Rosa Plain, describing mitigation and minimization requirements and procedures as they apply to projects that impact the four target species, and providing a comprehensive status report for these species, which includes species descriptions, historical and current distribution, habitat and life history, threats to survival, and environmental baseline information. In 2016, the USFWS adopted a Recovery Plan for the Santa Rosa Plain (Recovery Plan), which was considered as part of the latest PBO. The Recovery Plan identified actions to reduce the threats to these four species SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-22 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR and ensure their long-term viability. Although the 2005 SRPCS has not been formally adopted, the USFWS PBO can still be invoked for projects that have suitable habitat for California tiger salamander, Burke’s goldfields, Sonoma sunshine, and Sebastopol meadowfoam, and that impact regulated wetlands in the Santa Rosa Plain requiring permit authorization by the USACE.

With respect to the portion of the comment regarding the concern that BRAs would not be subject to public review under CEQA, thereby circumventing key purposes of CEQA, including informing the public and governmental decision makers about the potential, significant environmental effects of a proposed project and identifying ways that environmental damage can be avoided or significantly reduced (CEQA Guidelines Section 15002, General Concepts), this misses the purpose of preparing BRAs. The preparation of a BRA itself is not subject to CEQA. However, the preparation of a BRA would not preclude a project that is subject to CEQA from complying with CEQA, and undergoing appropriate public review and comment, including any conclusions and information contained in a BRA prepared as part of that process. It is not the intent of proposed General Plan 2050 *Action 3-5.11 to bypass the public or governmental decision makers any more than any other required technical report such as a geotechnical, transportation, air quality, or noise report. The BRA, like these other types of reports, are to study the effects of project-specific developments and identify any project- and site- specific measures to ensure the protection of the residents and visitors to Santa Rosa and the environment. The results of this BRA would be incorporated into the CEQA document, where appropriate. Furthermore, proposed General Plan 2050 *Action 3-5.7 specifically requires the City to continue to consult with the CDFW to identify significant environments and priorities for acquisition or maintenance of open space areas based on biological and environmental concerns and develop a strategy for maintaining areas that will preserve the populations of plants and animals currently found in the Urban Growth Boundary. Lastly, it is important to note that not every proposed future development in the EIR Study Area that may occur over the 25-year buildout horizon will be subject to CEQA. Some future development projects may be exempt from CEQA, such as redevelopment or in- fill projects in locations that have no potential for presence of special-status species or other sensitive resources. However, even projects that are exempt from CEQA are required to comply with the General Plan policies and actions, and other local, State, and federal laws, thereby ensuring the protection of biological resources.

Comment-GOV2-10:

Recommended Mitigation Measures: To reduce potential impacts to less-than-significant and comply with CESA, CDFW recommends including mitigation measures in the EIR which evaluate such foreseeable potentially significant impacts. Where future site-specific impacts may not be presently foreseeable based on the Project’s broad scope, the checklist discussed in Comment 1 above should be used to determine if a future CEQA environmental document is required. CDFW would appreciate the opportunity to review a revised EIR and may have further comments once more specific-species information is provided.

For example, CDFW recommends including the mitigation measures below in this EIR:

MM-BIO-1. Prior to commencing construction-related activities on grassland or wetland habitat suitable to support California tiger salamander, the Project shall obtain a CESA ITP from CDFW for impacts to California tiger salamander and comply with the ITP . Copies of the ITP shall be provided to the City prior to the commencement of construction-related activities. The Project shall obtain authorization from the USFWS for impacts to California tiger salamander and comply with the authorization. The Project shall also provide habitat compensation for California tiger salamander in accordance with SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-23
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR the ITP , SRP CS, and 2020 PBO. Please note that the CESA ITP habitat compensation requirements are often consistent with the SRP CS and 2020 PBO but may differ based on site-specific conditions.

MM-BIO-2: Prior to ground disturbance, the Project shall submit a special-status plant habitat assessment and an evaluation of potential direct and indirect impacts to any special-status plant habitat, such as modification of hydrological conditions, to CDFW for review and obtain CDFW’s written acceptance of the assessment and evaluation, unless otherwise approved in writing by CDFW.

If direct or indirect impacts to wetlands, which are generally suitable habitat for Sonoma sunshine, Sebastopol meadowfoam, and Burke’s goldfields may occur, the Project shall submit to CDFW two years of completed botanical survey results and obtain CDFW’s written approval of the results prior to Project construction. The botanical survey results should follow CDFW’s 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities (available here: https://nrm.dfg.ca.gov/FileHandler .ashx?DocumentID=18959&inline) and the SRP CS, Appendix D: Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed Plants on the Santa Rosa Plain (available here:
https://www.fws.gov/media/santa-rosa-plain-conservation-strategy-appendix-c-through-e). If suitable habitat for other special-status plants may be impacted, the above 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities shall be conducted and the Project shall obtain CDFW’s written approval of the results prior to Project construction. If CDFW is unable to accept the survey results, the Project shall conduct additional surveys prior to initiation of Project activities or may assume presence of special-status plants, such
as Sonoma sunshine, Burke’s goldfields, and Sebastopol meadowfoam. Please be advised that for CDFW to accept the results, they should be completed in conformance with the above survey protocols and guidelines, including, but not limited to conducting surveys during appropriate conditions, utilizing appropriate reference sites, and evaluating all direct and indirect impacts such as altering off-site hydrological conditions where the above species may be present. Surveys conducted during drought conditions may not be acceptable. If the botanical surveys result in the detection of CESA listed plants that may be impacted by the Project, or the presence of these species is assumed, the Project shall obtain a CESA ITP from CDFW prior to construction and comply with all requirements of the ITP including, but not limited to, providing habitat compensation. In addition, the Project shall consult with the USFWS for any impacts to suitable habitat for plants listed under the federal Endangered Species Act (e.g., wetlands, ESA) and provide compensatory habitat mitigation as required. Impacts to non-CESA listed special-status plants shall be mitigated through compensatory habitat mitigation at a minimum 3:1 mitigation to impact ratio, including a conservation easement and funding and implementing a long-term management plan, unless otherwise approved in writing by CDFW.

MM-BIO-3: If the Project occurs during the burrowing owl wintering season from September 1 to through January 31, prior to Project activities a Qualified Biologist shall conduct a burrowing owl habitat assessment within 1,640 feet of the Project area pursuant to the California Department of Fish and Game (now CDFW) 2012 Staff Report on Burrowing Owl Mitigation (CDFW 2012 Staff Report, available here:
https://wildlife.ca.gov/Conservation/Survey-Protocols#377281284-birds), unless otherwise approved in writing by CDFW. The Qualified Biologist shall have a minimum of two years of experience implementing the CDFW 2012 Staff Report survey methodology resulting in detections. The habitat assessment shall focus on searching the California Natural Diversity Database (CNDDB) and potentially other sources for any burrowing owl records on or within one mile of the Project area, vegetation type and height, suitable burrows (with an opening of greater than 11 centimeters [cm] in diameter and a SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-24 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR depth of greater than150 cm), burrow surrogates (culverts, piles of concrete rubble, piles of soil, burrows created along soft banks of ditches and canals, pipes, and similar structures), and presence of burrowing owl sign (tracks, molted feathers, cast pellets, prey remains, egg shell fragments, owl white wash, and nest burrow decoration material), and the presence of burrowing owl individuals or pairs. If the habitat assessment does not identify suitable habitat and surveys are not conducted as described below, an additional habitat assessment shall be conducted within 14 days prior to construction and if new potentially suitable burrowing owl refugia are present surveys shall be conducted as described below, unless otherwise approved in writing by CDFW. The results of the habitat assessment shall be emailed to the CDFW contact below (see Contact Information section), and the Project shall obtain CDFW’s written approval of the habitat assessment prior to starting Project activities.

If a suitable burrowing owl habitat is observed, four surveys shall be conducted to detect the presence of burrowing owl pursuant to the CDFW 2012 Staff Report. The site visits shall be spread evenly throughout the non-breeding season. The survey results shall be emailed to the CDFW contact below, or if unavailable another CDFW representative, and the Project shall obtain CDFW’s written approval of the survey results prior to starting Project activities. In addition, a take avoidance survey shall be completed within 14 days prior to the start of construction, as described in the CDFW 2012 Staff Report.

If burrowing owl is detected, the Project shall immediately notify CDFW. The Project shall avoid impacts to the burrowing owl and implement a 1,640- foot buffer area around the owl site in which no Project activities shall occur, unless otherwise approved in writing by CDFW. A Qualified Biologist shall monitor any detected owl to ensure it is not disturbed.

If the Project cannot ensure burrowing owl and their burrows are fully avoided, the Project shall consult with CDFW and obtain a take authorization or otherwise demonstrate compliance with CESA. Take is likely to occur and the Project shall obtain an ITP if: 1) burrowing owl surveys of the Project site detect burrowing owl occupancy of burrows or burrow surrogates, or 2) there is sign of burrowing owl occupancy on the Project site within the past three years and habitat has not had any substantial change that would make it no longer suitable within the past three years. Occupancy means a site that is assumed occupied if at least one burrowing owl has been observed occupying a burrow or burrow surrogate within the last three years.

Occupancy of suitable burrowing owl habitat may also be indicated by burrowing owl sign including its molted feathers, cast pellets, prey remains, eggshell fragments, or excrement at or near a burrow entrance or perch site. If burrowing owl, or their burrows or burrow surrogates, are detected within 500 meters (1,640 feet) of the Project site during burrowing owl surveys, but not on the Project site, the Project shall consult with CDFW to determine if avoidance is feasible or an ITP is warranted and shall obtain an ITP if deemed necessary by CDFW.

MM-BIO-4: Project activities shall not occur within 0.25 miles of Northern Spotted Owl nesting habitat from March 15 to July 31, unless Northern Spotted Owl surveys have been completed by a Qualified Biologist following the U.S. Fish and Wildlife Service’s (USFWS) Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls, dated (revised) January 9, 2012, and the survey report is accepted in writing by CDFW.

Surveys shall be conducted in accordance with Section 9 of the survey protocol, Surveys for Disturbance-Only Projects. If breeding Northern Spotted Owl are detected during surveys, the CDFW Bay Delta Region office shall be immediately notified, and a 0.25-mile construction avoidance buffer zone shall be implemented around the nest. Survey results shall be provided to CDFW and to the Spotted Owl Observations Database (https://wildlife.ca.gov/Data/CNDDB/Spotted-Owl-Info). No project activities shall occur within the buffer zone until the end of breeding season, or a SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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COMMENTS AND RESPONSES
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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Qualified Biologist determines that the nest is no longer active, unless otherwise approved in writing by CDFW. If take of Northern spotted owl cannot be avoided by project activities, The Project shall obtain a CESA incidental take permit from CDFW prior to starting project activities, and authorization from USFWS may be required.

Alternate buffer zones may be proposed by a Qualified Biologist after conducting an auditory and visual disturbance analysis following the USFWS guidance, Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California, dated October 1, 2020. Alternate buffers must be approved in writing by CDFW.

MM-BIO-5: In water work shall be avoided where Coho salmon or California freshwater shrimp may occur, as determined by a Qualified Biologist based on a review of CNDDB and consultation with CDFW. If take of Coho salmon cannot be avoided, the Project shall obtain a CESA ITP from CDFW prior to commencing project activities and shall comply with the ITP .

III. Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by CDFW or USFWS?
COMMENT 3: Riparian Habitat, Wetlands, and Lake and Streambed Alteration Notification Issue, specific impacts, why they may occur and be potentially significant: If the Project may result in physical changes in the environment, then the Project could result in potentially significant impacts to riparian habitat, wetlands, or other sensitive natural communities.

Recommended Mitigation Measure: If impacts to riparian habitat, wetlands, or other sensitive natural communities may occur, to reduce potential impacts to less-than-significant and comply with Fish and Game Code section 1600 et seq., CDFW recommends including the mitigation measure below.

MM-BIO-6: The Project shall submit an LSA notification for any direct on-site or indirect off-site impacts to streams or lakes. For Project activities that may substantially alter the bed, bank, or channel of any streams (including ephemeral or intermittent streams), an LSA Notification shall be submitted to CDFW pursuant to Fish and Game Code section 1602 prior to Project construction. If CDFW determines that an LSA Agreement is warranted, the Project shall comply with all required measures in the LSA Agreement, including, but not limited to requirements to mitigate impacts to the streams and riparian habitat. Permanent impacts to the stream and associated riparian habitat shall be mitigated by restoration of riparian habitat at a 3:1 mitigation to impact ratio based on acreage and linear distance as close to the Project area as possible and within the same watershed and year as the impact, unless otherwise approved in writing by CDFW. Temporary impacts shall be restored on-site in the same year as the impact. The Project shall also consult with the Regional Water Quality Control Board (RWQCB) and Corps to impacts to waters such as streams, lakes, and wetlands, and obtain permits if necessary pursuant to the Clean Water Act and Porter Cologne Water Quality Control Act.

Response-GOV2-10:

While the City appreciates the recommended project-specific mitigation measures provided by the commenter, these mitigation measures include specific controls and requirements that could be subject to considerable revision over the 25-year buildout horizon, may in fact not be applicable to conditions found on a particular site, or may not be appropriate for each specific development application received by the City. The mitigation measures recommended by the commenter are already required pursuant to current regulations including California Endangered Species Act (CESA) and California SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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COMMENTS AND RESPONSES
4-26 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Fish and Game Code (CFGC). Please see subheading “State Regulations” under Section 4.4.1.1, Regulatory Framework, in Chapter 4.4, Biological Resources, of the Draft EIR for a summary of the regulations required for the protection of protected species. Additionally, as described in Response- GOV2-9, proposed General Plan 2050 *Action 3-5.11 requires future project applicants to prepare a BRA by a qualified biologist for proposed development on sites that may support special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat. The project-specific BRAs would determine what site- and project-specific mitigation measures would be required for sensitive natural communities at the time of the proposed development such as these listed by the commenter. Site-specific biological resources assessments and field surveys prepared by qualified biologists would follow the agency- promulgated protocols and recommended methods and standards of review including the consultation with CDFW and the USFWS and rely on standard protocol sources, including, but not limited to, those identified by the commenter.

Comment-GOV2-11:

ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative declarations be incorporated into a database which may be used to make subsequent or supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. €.) Accordingly, please report any special-status species and natural communities detected during Project surveys to CNDDB. The CNDDB field survey form can be filled out and submitted online at the following link: https://wildlife.ca.gov/Data/CNDDB/Submitting-Data. The types of information reported to CNDDB can be found at the following link: https://www.wildlife.ca.gov/Data/CNDDB/Plants-and-Animals.

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is required in order for the underlying Project approval to be operative, vested, and final. (See Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.) Response-GOV2-11:

The City of Santa Rosa routinely complies with all required federal, State, and local regulations, including those of CDFW, and will continue this practice in the future, including payment of any required environmental document filing fees.

Comment-GOV2-12:

CONCLUSION
CDFW appreciates the opportunity to comment on the EIR to assist the City in identifying and mitigating Project impacts on biological resources.

Questions regarding this letter or further coordination should be directed to Nick Wagner, Senior Environmental Scientist (Specialist), at (707) 428-2075 or [email protected]; or Melanie Day, Senior Environmental Scientist (Supervisory), at (707) 210-4415 or [email protected].

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-27
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-GOV2-12:

This comment serves as a closing remark. The City appreciates the input from CDFW and will rely on their expertise if and when future development is proposed throughout implementation of the General Plan.

Comment-GOV2-Attachment 1:

The attachment is a Draft Mitigation Monitoring and Reporting Program prepared by CDFW that includes the CDFW project-specific mitigation measure listed in Comment-GOV2-10.

Response-GOV2-Attachment 1:

Please see Response-GOV2-2 through Response-GOV2-11 regarding the recommended mitigation measures.

Comment Letter GOV3: Yunsheng Luo, California Department of Transportation, November 20, 2024 Comment-GOV3-1:

Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the Santa Rosa General Plan 2050 Project. The Local Development Review (LDR) Program reviews land use projects and plans to ensure consistency with our mission and state planning priorities. The following comments are based on our review of the October 2024 DEIR.

Please note this correspondence does not indicate an official position by Caltrans on this project and is for informational purposes only.

Response-GOV3-1:

This comment serves as an opening remark.

Comment-GOV3-2:

Project Understanding
The proposed project will include revisions to the policies and land use map of the existing General Plan. The overall purpose is to create a policy framework that articulates a vision for the long-term physical form and development of Santa Rosa, while preserving and enhancing the quality of life for Santa Rosa residents. The proposed project will add new and expanded policy topics to address the current requirements of State law, modernize the City’s policy framework, and address land use mapping issues and inconsistencies. Zoning and/or land use changes supporting additional development capacity will be concentrated in select areas only. Changes to the city's transportation infrastructure will include new pedestrian and bicycle connections across U.S. 101 and State Route (SR) 12, road diets, and roadway widenings.

Response-GOV3-2:

The comment summarizes the proposed project.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-28 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-GOV3-3:

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

The project VMT analysis and significance determination are undertaken in a manner consistent with the Office of Planning and Research’s (OPR) Technical Advisory. Per the DEIR, this project is found to have a significant and unavoidable VMT impact. Caltrans acknowledges that the General Plan has identified Action 3-1.1, Action 3-1.2, and Action 3-1.3 to help mitigate future developments’ potential VMT impact. We commend the City for working with Sonoma County Transportation Authority (SCTA) and other local and regional partners to explore developing a VMT mitigation bank alternative which would help further reduce VMT.

Response-GOV3-3:

The comment confirms that the VMT analysis presented in the Draft EIR was conducted in a manner consistent with the Office of Land Use and Climate Innovation’s (previously Office of Planning and Research) Technical Advisory and acknowledges the proposed General Plan actions would help to mitigate potential VMT impacts. No further response is required.

Comment-GOV3-4:

Additionally, given that City of Santa Rosa is a large growing city that may see substantial developments in the future, the City should continue to research and explore funding opportunities for investing the appropriate local transit system based on the City’s future needs, particularly for the east- west axis. A strong reliance on U.S. 101 and Sonoma-Marin Area Rail Transit (SMART) would concentrate growth and investments in the north-south direction, which might result in increased VMT compared to a similar-sized city with various axes of importance. We encourage the City to consider strategies to further improve east-west connections that would create a complete, interconnected transportation network that helps advance the General Plan’s goals.

Response-GOV3-4:

The comment encourages continued research and exploration of funding opportunities for investing in the appropriate local transit system.

Comment-GOV3-5:

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

Please note that any Complete Streets reference should be updated to reflect Caltrans Director’s Policy 37 (link) that highlights the importance of addressing the needs of non-motorists and prioritizing space-efficient forms of mobility, while also facilitating goods movement in a manner with the SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR least environmental and social impacts. This supersedes Deputy Directive 64-R1, and further builds upon its goals of focusing on the movement of people and goods.

Response-GOV3-5:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.15, Transportation, of the Draft EIR has been revised to include discussion on the Caltrans District 4 Pedestrian Plan and to reflect the updated Caltrans Director’s Policy 37. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-GOV3-6:

Equity and Public Engagement
We will achieve equity when everyone has access to what they need to thrive no matter their race, socioeconomic status, identity, where they live, or how they travel.

Caltrans is committed to advancing equity and livability in all communities. We look forward to collaborating with the City to prioritize projects that are equitable and provide meaningful benefits to historically underserved communities.

Caltrans encourages the City to foster meaningful, equitable and ongoing public engagement in the General Plan development process to ensure future transportation decisions and investments reflect community interests and values. The public engagement process should include community-sensitive and equity-focused approaches seeking out the needs of individuals from underserved, Tribal, and low-income communities, the elderly, and individuals with disabilities.

Response-GOV3-6:

The comment encourages collaboration with the City to prioritize projects that are equitable and provide meaningful benefits to historically underserved communities.

Comment-GOV3-7:

Thank you again for including Caltrans in the environmental review process. Should you have any questions regarding this letter, please contact Melissa Hernandez, Associate Transportation Planner, via [email protected].

For future early coordination opportunities or project referrals, please visit Caltrans LDR website (link) or contact [email protected].

Response-GOV3-7:

This comment serves as a closing remark. The City appreciates the input from Caltrans and will rely on their expertise if and when future development is proposed throughout implementation of the General Plan.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-30 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment Letter GOV4: Tennis Wick, Sonoma County, November 20, 2024 Comment-GOV4-1:

Thank you for providing the Notice of Availability for the Draft Environmental Impact Report (DEIR) for the City of Santa Rosa’s General Plan Update as issued on 7 October 2024. We appreciate the opportunity to review the DEIR and the Project.

Response-GOV4-1:

This comment serves as an opening remark.

Comment-GOV4-2:

As neighboring jurisdictions striving to support a sustainable future, we share many common issues and challenges. The development of a new General Plan is a unique and valuable opportunity to address these challenges. With Santa Rosa moving toward completion of Santa Rosa Forward and the County of Sonoma beginning the visioning process for General Plan Sonoma, we have an opportunity to not only address local issues, but to recognize local issues of regional significance, and identify opportunities for collaboration to achieve mutual benefits.

Santa Rosa and the unincorporated County have the largest populations in the county (first and second, respectively). Santa Rosa is the fifth largest city in the Bay Area. Land-use policies within these jurisdictions have far-reaching effects on land-use throughout the region. Santa Rosa Forward includes multiple goals and policies that acknowledge this relationship and call for coordination between our jurisdictions.

Natural resource conservation within the city, like transportation, housing, and other land use issues, has significant implications for local ecosystems.

Ongoing commitment to initiatives such as the Citywide Creek Master Plan can enhance waterways, regional trails, and active transportation networks, while also promoting equitable access to parks throughout the city. Projects like the Southeast Greenway offer promising opportunities to improve access to city, county, and state parks.

City-centered growth is fundamental to Santa Rosa Forward and General Plan Sonoma. The unincorporated County and all nine cities share a compact built upon city-centered growth around transit nodes, contained within urban growth boundaries, buttressed by community separators and agricultural preservation and open space acquisitions. These interrelated measures protect our identity, agricultural economy, and open space.

Residents and businesses within multiple unincorporated areas surrounded by or close to city limits are part of the Santa Rosa community. I appreciate Santa Rosa’s Vision represented in the 13 ideals of Santa Rosa Forward, recognizing the impact of land use policies on communities throughout the region, and welcoming the input from all members of the public in the general plan process.

Looking forward to the upcoming Regional Housing Needs Allocation (RHNA) cycle, we recognize the importance of ensuring a fair and equitable housing allocation for all residents of Sonoma County. Instead of relying on the Association of Bay Area Governments (ABAG) to determine the regional fair share of housing, the County is committed to supporting and promoting the formation of a RHNA subregion, as allowed by state law. This approach offers the opportunity for a more equitable and tailored allocation process, benefiting all cities within the subregion. I invite the City to join us in future discussions to further this effort and to work collaboratively with the other cities for a fairer distribution of housing.

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CITY OF SANTA ROSA

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PLACEWORKS 4-31
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-GOV4-2:

The comment describes the relationship between the City and the County and encourages collaboration to achieve mutual benefits.

Comment-GOV4-3:

Thank you for the opportunity to review the DEIR and Project. I look forward to more opportunities to connect as Santa Rosa and the County of Sonoma continue [sic] advance our new General Plans.

Response-GOV4-3:

This comment serves as a closing remark. The City appreciates the input from Sonoma County and will rely on their expertise if and when future development is proposed throughout implementation of the General Plan.

Private Organizations
Comment Letter ORG1: Chris Guenther, Bikeable Santa Rosa, on behalf of multiple organizations (see Chapter 3, List of Commenters, of this Final EIR for the full list) November 20, 2024
Comment-ORG1-1:

We are writing on behalf of the groups listed below to provide feedback on the Draft Environmental Impact Report (EIR) for the proposed General Plan 2050. In particular, we are concerned about the findings of the Transportation chapter of the Draft EIR, which states that the proposed General Plan would result in 57.9 million additional vehicle miles traveled (VMT) per year, or approximately 158,630 daily VMT. We recognize that calculating average projected VMT per capita is complex, and roadway VMT is just one part of the equation. Nevertheless, we are concerned that this additional VMT represents an unnecessary undermining of city and state goals.

Response-ORG1-1:

Please see Master Response 3, Vehicle Miles Traveled, regarding the roadway network VMT impact for a more detailed response to the VMT findings in the Draft EIR. As discussed in Master Response 3 and in Chapter 4.15, Transportation, of the Draft EIR, the significant and unavoidable finding is related to the unknown nature and timing of future projects and mitigation options, which affect VMT but cannot be analyzed at this time. Future projects will be evaluated on a case-by-case basis where these details will be known and adequately mitigated; therefore, meeting the City and State goals with respect to VMT. Further, the General Plan has many competing interests that the City must balance. As discussed in Master Response 3, the largest capacity-increasing project is the Farmers Lane extension, which would also incorporate facilities for non-auto travel and would reduce driving distances for travel between many parts of eastern and southern Santa Rosa. While this adds new lanes, it also reduces the length of many daily trips. Other major projects include widening along Highway 12 in eastern Santa Rosa, which is adjacent to the planned Sonoma Valley Trail, and widening a portion of Stony Point Road in the southern part of the city. As stated, all three of these roadway expansion projects would also play a role in providing adequate facilities for emergency evacuations as the General Plan is built out, thereby meeting important safety goals for the City. In addition, as described under impact discussion TRAN-1 in Chapter 4.15 of the Draft EIR, the proposed General Plan 2050 calls for the City to implement the Santa Rosa 2018 Bicycle and Pedestrian Master Plan (currently being updated and renamed the Active Transportation Plan, Reimagining CityBus, and the Short-Range Transit Plan (as SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR well as future updates to these plans), all of which identify prioritized lists of projects for the City to implement. Additionally, as described under impact discussion GHG-2 in Chapter 4.8, Greenhouse Gas Emissions, of the Draft EIR, the proposed General Plan 2050 would not conflict with applicable plans adopted for the purpose of reducing GHG emissions, which include California Air Resources Board’s (CARB) Scoping Plan and Metropolitan Transportation Commission (MTC)/ABAG’s Plan Bay Area. Accordingly, the findings do not reflect a conflict or undermining of the City and State goals.

Comment-ORG1-2:

As you no doubt understand, an increase in VMT is undesirable, contributing to a host of negative consequences for cities including increased air and noise pollution, greenhouse gas emissions, traffic congestion, traffic violence, high infrastructure costs, and more. For these reasons, the State of California has made it clear that cities should be doing everything in their power to reduce VMT – a goal that is repeatedly and forcefully endorsed by the General Plan itself. And yet the Draft EIR not only finds that the proposed General Plan will result in the opposite, but that that outcome is supposedly unavoidable. We disagree. We can and must do better .

Response-ORG1-2:

Please see Master Response 3, Vehicle Miles Traveled, for additional explanation on the VMT impact calculations and impact conclusions. It is important to understand that “unavoidable” impact description is strictly applied to the program-level findings of the long-range General Plan that will span a 25- year buildout horizon and for which specific development timing and the nature of projects and potential features to reduce VMT on a case-by-case basis is not known. This finding does not mean that over the life of the General Plan 2050 no project can ever achieve the acceptable threshold adopted by the City or other agencies and regulations. As described in Chapter 1, Introduction, of the Draft EIR, this EIR is a program EIR that analyzes the adoption and implementation of the proposed project (General Plan 2050), which is in contrast to a project-level EIR that is used to identify and analyze the potential impacts of site-specific construction and operation. As concluded Master Response 3 and in Chapter 4.15, Transportation, of the Draft EIR, given the programmatic nature of the proposed project, uncertainties as to whether individual development projects will be able to successfully meet VMT standards even with mitigation, and uncertainties as to the availability of other mitigation strategies such as VMT exchanges or banks, the impact is considered significant and unavoidable at the program level. However, this impact conclusion does not preclude the finding of less than significant at the project level for future projects over the 2050 buildout horizon. As discussed in Chapter 4.15 of the Draft EIR, proposed General Plan 2050 *Action 3-1.1, requires that all projects with the potential to increase VMT prepare an analysis of projected VMT and mitigation, as necessary. Likewise, with respect to air quality and noise from automobiles, as discussed in Chapter 4.3, Air Quality, and Chapter 4.12, Noise, of the Draft EIR, due to the unknown nature of project-specific details, it is not possible to state definitely that all Bay Area Air District (Air District) or City noise thresholds will be met by all future development projects over the buildout horizon. Like VMT, the proposed General Plan has mitigation in place that requires project-level analysis on a case-by-case basis to ensure individual projects implement measures to ensure air pollutant emissions and automobile noise meet acceptable thresholds. Additionally, the proposed General Plan 2050 goals, policies, and actions covering topics such as expansion of the pedestrian and bicycle networks, promotion of public and active transit, and support to increase building energy efficiency and energy conservation would also reduce criteria air pollutants and the use of automobiles in the EIR Study Area. Specifically, proposed *Action 3-6.31 requires potential future development in Santa SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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COMMENTS AND RESPONSES
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TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Rosa that exceeds the Air District screening sizes to evaluate project-specific operation emissions in conformance with the Air District methodology and proposed *Action 5-7.1 requires the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate impacts.

With respect to greenhouse gas emissions, as discussed in Response-ORG1-1, impact discussion GHG-2 in Chapter 4.8, Greenhouse Gas Emissions, of the Draft EIR finds that proposed General Plan 2050 would not conflict with applicable plans adopted for the purpose of reducing GHG emissions, which include CARB’s Scoping Plan and MTC/ABAG’s Plan Bay Area. The evaluation of traffic congestion, traffic violence, and high infrastructure costs, are outside the scope of CEQA and this EIR.

Comment-ORG1-3:

We understand that the General Plan calls for many positive VMT reduction strategies, which we applaud. We are concerned that these steps are being negated by continued allegiance to car-centric growth. Specifically, we learned from the analysis and from discussion at the November 14 meeting of the Planning Commission, that the projected growth in VMT is driven primarily by the proposed increase in arterial lane miles and the expected increase in vehicle travel this will induce. On that basis, we believe it is in the best interest of the city and its residents to remove many (if not all) of the projects that would increase road capacity from the proposed General Plan. This is not only desirable as a strategy to limit vehicle miles traveled and their many externalities, but also as a matter of fiscal responsibility. New road infrastructure is expensive to build and even more expensive to maintain over time.

As we currently struggle to maintain the roads we already have, we should not build costly and counter-productive infrastructure liabilities into our general plan.

Response-ORG1-3:

Please see Master Response 3, Vehicle Miles Traveled, for additional explanation on the VMT impact calculations and impact conclusions. It is important to note, as stated in Response-ORG1-1, there are many competing interests that the City must address for projects as big and broad as a long-term General Plan and as stated in Master Response 3, all three of the roadway expansion projects also play a role in providing adequate facilities for emergency evacuations. Additionally, as stated in Master Response 3, and as shown in Table 3-4, Major Planned Roadway Circulation Improvements, in Chapter 3, Project Description, of the Draft EIR, while buildout of the proposed General Plan 2050 would add arterial lane miles, it is also important to recognize that many City projects, including several in the proposed General Plan 2050 would reduce lane miles, reallocating roadway width to provide more robust non-auto facilities, including bike lanes. Accordingly, the City maintains that the need for the roadway infrastructure improvements is important for these reasons and the General Plan 2050 requires project-level analysis and mitigation to ensure that VMT as well as air and noise pollution standards are met.

Comment-ORG1-4:

As a final note, in preparing this letter, we found it very easy to access the information and documents available on the General Plan website. We appreciate your continued efforts to keep the site updated for the benefit of the public.

Response-ORG1-4:

The comment expresses appreciation for the accessibility of the information and documents on the project website.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-34 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Members of the Public
Comment Letter PUB1: Andrew Smith, October 20, 2024
Comment-PUB1-1:

Greetings. Wanted to give some comments on this huge report and process going on for a few years.

The city of Santa Rosa has housing obligations to meet under state requirements and overall doing a good job especially for affordable housing.

Response-PUB1-1:

This comment serves as an opening remark.

Comment-PUB1-2:

My biggest criticism for the city council is the focus on making downtown an urban area and restricting of housing being built on the westside where there seems to be plenty of open spaces to build for all types of housing. The two should not be mutually exclusive. Santa Rosa is a suburban-rural city and while density is increasing naturally over time for housing and where people live, it is not an urban area. Wanting to get people out of their cars to use public transportation, bicycles and walking are good ideas but you can’t transform Santa Rosa to be more urban.

In fact, one of the biggest issues to get people to use public transportation is an outdated bus model in Sonoma County with 3 transit systems. Merging Santa Rosa’s Transit system with Sonoma County Transit means better integration of bus schedules and with SMART train. Right now, the focus is to do a better job of connecting buses and SMART trains but is it happening which the Metro Transportation Commission has recommended doing? Answer seems to be no! Worse, we don’t know the future of the SMART train as it needs to renew its sales tax by 2029 in a 2/3 vote in Sonoma County where there was failure to do that a few years. The hiring of bus personnel for Santa Rosa Transit means competing with Sonoma County Transit. A story in the Press Democrat earlier this year on the inability to hire bus drivers and other important personnel leaving buses not being used. Not a good way to ensure that those people wanting this urban environment will want to live downtown.

In fact, one area that Santa Rosa should focus on is making it easier to use public transportation a policy to go to the three hospitals in our city and related offices for medical appointments. Healthcare is a huge sector in our city. It is used not just by people in Santa Rosa but those in Northern and Southern Sonoma County and probably in Mendocino and Lake Counties. If SMART survives and at least gets to Healdsburg, people in Mendocino and Lake Counties could drive down to the SMART station in Healdsburg and take the train to one of the three hospitals and medical offices as long as there are shuttles or buses available.

One area for home ownership that is lacking in Santa Rosa and I have written the city council on it is building condominiums for first time buyers. A way for home ownership and to build equity. Seems like the focus is just on single family homes and townhouses in Santa Rosa. Condominiums are a good use of land for higher density housing and brings in more needed property taxes and other fees for Santa Rosa. This could help the middle class to stay in Santa Rosa who have to deal with rising costs to live here.

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CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-35
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR The city council has allowed housing to be built in the downtown area without at least one parking place per unit. Supposedly that forces some tenants to pay for parking at a city lot. But what happens if that tenant parks on the street in front of homeowner’s housing? Next thing you have is Santa Rosa implementing Permit Fee parking to park in front of their own houses. That is wrong! If Santa Rosa wants to allow this type of housing built in the downtown area without the minimum one parking place per unit, then a restriction should be made that no one can rent an apartment if they have a vehicle and no parking places in the building are available.

Response-PUB1-2:

The comment expresses an opinion about the proposed project but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the Draft EIR, nor does the comment raise a new environmental issue. Please see Master Response 1, Standards for Responses and Focus of Review, regarding project merits.

Comment-PUB1-3:

I am not sure if this part of the EIR includes Santa Rosa annexing properties inside the city limit. There was a Press Democrat story in 2023 on this issue and 30 islands of Sonoma County property located inside the city limits. Why not annex them which would bring in extra property taxes and other fees needed by Santa Rosa government. And some other areas as well that are within the city’s boundary. There will not be a problem for police and fire services as they just drive by these areas all the time. As long as the annexation is within city limits, a good policy for more property tax revenue and other city fees without stressing important city services.

Response-PUB1-3:

The comment expresses an opinion about annexation but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the Draft EIR, nor does the comment raise a new environmental issue. As described in Section 3.4.1.4, Sphere of Influence, in Chapter 3, Project Description, of the Draft EIR, the Sphere of Influence, which is considered the City’s ultimate potential area for future annexation and provision of City services, was approved by the Sonoma Local Agency Formation Commission (Sonoma LAFCO) in May 2024. Annexations must go through a legal process that requires input from residents or property owners and are subject to Sonoma LAFCO review and approval. The proposed project would not result in any changes to the city limit. As described in Chapter 4.11, Land Use and Planning, on page 4.11-4 of the Draft EIR, although the City does not propose to annex or de-annex any areas of the Sphere of Influence as part of the proposed General Plan 2050, annexation proposals could occur during the buildout horizon of the proposed General Plan 2050.

The commenters opinion regarding the annexation of unincorporated county islands into the city limit is acknowledged for the record and will be forwarded to the decision-making bodies as part of this Final EIR for their consideration in reviewing the project and EIR.

Comment Letter PUB2: Mark Garay, November 5, 2024
Comment-PUB2-1:

Where should we direct any comments regarding the GPU for consideration by Planning Commission.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-36 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-PUB2-1:

As stated in the Notice of Availability and on the project website, written comments on the Draft EIR were accepted by mail or email to Amy Nicholson, Supervising Planner – Advance Planning at the following addresses:

Submit Comments by Mail
Amy Nicholson, Supervising Planner - Advance Planning
Planning & Economic Development Department
City of Santa Rosa
100 Santa Rosa Avenue, Room 3
Santa Rosa, CA 95404
Submit Comment by Email
Send an email to: [email protected] with the subject “Santa Rosa General Plan 2050 EIR.” Comment-PUB2-2:

The Acacia sites which we have been exchanging emails about are part of a combined rezoning application PRJ24--019. They are the proposed as the No Net Loss component of the downzoning of the 3150 Dutton Ave site. We would request that those parcels be footnoted in the EIR to reflect these parcels as being a part of this joint application. Please see attached Notice Of Application.

Response-PUB2-2:

Table 3-2, General Plan Land Use and Zoning Revisions, of the Draft EIR lists the parcels that are proposed to be redesignated and/or rezoned. The Acacia sites are listed as sites with map numbers 6 and 7. The table does not consider applications, as it is not relevant to the analysis presented in the Draft EIR. However, the comment is acknowledged for the record and will be forwarded to the decision-making bodies as part of this Final EIR for their consideration in reviewing the project and EIR.

Comment Letter PUB3: Mark Garay, November 6, 2024
Comment-PUB3-1:

Thank you very much for forwarding my request to Amy Nicholson.

Amy, please submit this request to the Planning Commission and make them part of the comments file.

Response-PUB3-1:

This comment serves as an opening remark.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-37
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-PUB3-2:

As stated, The Acacia sites which we have been exchanging emails about are part of a combined rezoning application with 3150 Dutton Ave. The two parcels are proposed as the upzoning to satisfy the No Net Loss component of the downzoning of the 3150 Dutton Ave site. We would request that those parcels 615 & 625 Acacia Lane, APNs 182-520-098 & 182-520-099 be footnoted in the EIR to reflect the nexus that these parcels as being a part of this current joint application PRJ24-019 . Please see attached Notice Of Application. We want the Council to be aware that this application is in process and may in fact come to them shortly after their approval of the GPU, so they may be fully informed and anticipate this land use change.

Response-PUB3-2:

Please see Response-PUB2-2 regarding the Acacia sites. The commenter’s note that this application is in process and may come to City Council shortly after approval of the proposed project is acknowledged for the record and will be forwarded to the decision-making bodies as part of this Final EIR for their consideration in reviewing the project and EIR.

Comment Letter PUB4: Kelsey Cody, November 8, 2024
Comment-PUB4-1:

I notice that Figure 4-4.3, Special-Status Animals and Critical Habitats, from the Biological Resources chapter does not have a legend indicating what species correspond to the abbreviations. It would be helpful if the map was revised to include that legend, or if a separate legend could be provided in an errata.

Response-PUB4-1:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Figure 4-4.3, Special-Status Animals and Critical Habitats, in Chapter 4.4, Biological Resources, of the Draft EIR has been revised to correct the legend and include species names and acronyms. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment Letter PUB5: Ken MacNab, November 12, 2024
Comment-PUB5-1:

Thank you for the opportunity to provide comments on the Draft EIR for the Santa Rosa 2050 General Plan. This letter is being submitted on behalf of property owners in the Todd Creek area of unincorporated southeast Santa Rosa, who have had a long-standing interest in annexing and developing their land with needed housing. Our comments on the Draft EIR and Draft 2050 General Plan document are summarized below followed by a more detailed statement.

Response-PUB5-1:

This comment serves as an opening remark.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-38 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-PUB5-2:

The Draft Santa Rosa 2050 General Plan and corresponding Draft EIR do not recognize that a major planning study is underway for the 1,900-acre south Santa Rosa area (South Santa Rosa Specific Plan). Both the 2050 General Plan and Draft EIR should acknowledge this effort and anticipate that large areas of land within the south Santa Rosa area will be annexed over the next 25 years. More specifically, the Draft EIR should be revised to: (1) note the potential for large annexations to occur in the south Santa Rosa area; and (2) consider any potential impacts that may be associated with future annexation of land within the south Santa Rosa area.

Response-PUB5-2:

The Draft EIR does not include an evaluation of a potential South Santa Rosa Specific Plan described by the commenter, as it would be speculative to evaluate the impacts of such a potential plan when the details, including proposed boundaries, land uses, density, height limits, and projected buildout, have not been established. CEQA does not allow for speculation and does not require an evaluation of speculative issues or conditions (CEQA Guidelines Section 15145, Speculation). Because the preparation of a potential South Santa Rosa Specific Plan is in the conceptual stage, there is not sufficient data and information and inclusion of the plan as part of the proposed project would be considered speculative and, pursuant to the CEQA Guidelines, should not be considered in making environmental impact determinations. Therefore, exclusion of the potential South Santa Rosa Specific Plan as part of the proposed project in the Draft EIR is appropriate and no revisions to the Draft EIR are required. Please see Master Response 1, Standards for Responses and Focus of Review, regarding speculation without substantial evidence.

Additionally, the proposed General Plan 2050 includes Action 2-1.5 that requires the preparation of a specific plan prior to the annexation of land in south Santa Rosa to identify and accommodate needs related to City services. As the preparation of the South Santa Rosa Specific Plan progresses, it will have its own policies and undergo a separate environmental review as appropriate.

Comment-PUB5-3:

The Todd Creek area presents the single greatest opportunity for the City to secure its housing future. Its development will accommodate a variety of housing types at all income levels that will meet the needs of Santa Rosa residents, including young adults, families, empty nesters and seniors.

Annexation and development of the Todd Creek area will also create a new neighborhood with amenities that are currently lacking for residents of the 1,300 existing homes along the south Santa Rosa Avenue corridor . This new neighborhood will feature a community park, neighborhood-serving stores, and access to open space areas. Future development will also help to support and sustain the operation of transit service along Santa Rosa Avenue by bringing hundreds of new homes in close proximity to bus routes serving the downtown area.

The City has recognized the opportunities presented by the Todd Creek area and has included it as part of the South Santa Rosa Specific Plan study area.

The South Santa Rosa Specific Plan is a major planning effort that includes the City’s Santa Rosa Ave Corridor Priority Development Area (PDA), the County of Sonoma’s South Santa Rosa Ave PDA, and the Moorland Avenue and Industry West areas on the west side of Highway 101. In total, the South Santa Rosa Specific Plan encompasses approximately 1,900 acres – the largest of any Specific Plan prepared by the City.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-39
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-PUB5-3:

The City appreciates the background information on the Todd Creek area provided by the commenter. Please see Response-PUB5-2 regarding the South Santa Rosa Specific Plan.

Comment-PUB5-4:

It was surprising to find that there is no recognition of the South Santa Rosa Specific Plan planning effort in the current draft of the 2050 General Plan document or the Draft EIR for the 2050 General Plan. The City has been in discussions with representatives of the County of Sonoma about possible annexation of the south Santa Rosa area and is also aware of the development interests of property owners in the Todd Creek area. Large-scale annexations of land within the 1,900-acre South Santa Rosa Specific Plan area – whether City-initiated or developer initiated – are likely to occur within the time frame of the 2050 General Plan. Both the 2050 General Plan and Draft EIR should acknowledge this. The 2050 General Plan should provide guidance on the overarching planning interests to be addressed or achieved by the Specific Plan process and how future annexations in the south Santa Rosa area will be integrated into the City’s long-range plan for growth and development. The Draft EIR should note the potential for future large-scale annexations in the south Santa Rosa area as part of the project description and consider potential impacts as appropriate.

Response-PUB5-4:

Please see Response-PUB5-2 regarding the South Santa Rosa Specific Plan. As described, the Draft EIR does not include an evaluation of a potential South Santa Rosa Specific Plan described by the commenter as it would be speculative to evaluate the impacts of such a potential plan when the details, including proposed boundaries, land uses, density, height limits, and projected buildout, have not been established.

Comment-PUB5-5:

Thank you for your consideration of these comments.

Response-PUB5-5:

This comment serves as a closing remark.

Comment Letter PUB6: Sonia Taylor, November 20, 2024
Comment-PUB6-1:

Below are my comments to the Draft Environmental Impact Report for the proposed Santa Rosa General Plan 2050 (SR GP DEIR).

I appreciate the opportunity comment on this SR GP DEIR, and will be happy to answer any questions you might have.

Response-PUB6-1:

This comment serves as an opening remark.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-40 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-PUB6-2:

1. The SR GP DEIR Relies on Discretionary Laws/Regulations/Rules, and Proposes Discretionary Actions As a result of California’s housing crisis, over the past years the California Legislature has passed, and the Governor has signed into effect, multiple laws which streamline housing projects, including laws which allow projects to entirely bypass the California Environmental Quality Act (CEQA). While at least some of these laws don’t go into effect unless a jurisdiction such as Santa Rosa doesn’t have a Certified Housing Element, or when a jurisdiction is determined not to have met their Regional Housing Needs Assessment numbers (RHNA), some of the laws, such as this year’s AB 2243, eliminate the ability of a jurisdiction to use CEQA at all in project approvals.1 Footnote 1: Given the continued erosion of the ability to use CEQA to evaluate projects, I believe it is necessary for Santa Rosa to establish their own local thresholds of significance, which are specific environmental thresholds Santa Rosa would use to determine whether a proposed project’s effects on what would normally be CEQA impacts would be considered significant in Santa Rosa.

Many, if not all, of these laws eliminate the ability of a jurisdiction to make any discretionary findings – only objective findings are permitted.

And, of course, in spite of Santa Rosa’s diligent efforts, it is probable that at some point during the duration of General Plan 2050 Santa Rosa will not meet RHNA and therefore will lose all ability to use any discretion in considering many housing project approvals.

Unfortunately, the SR GP DEIR in multiple instances impermissibly relies on ability of Santa Rosa to use discretion and/or CEQA before approving projects which will have environmental impacts. Further, the SR GP DEIR then reaches conclusions about whether impacts will be significant or less than significant (either with or without mitigation) based on its erroneous reliance on Santa Rosa’s continued ability to use discretion when evaluating projects.

Response-PUB6-2:

The commenter opines about the legislation in California aimed at streamlining the development of new housing in the state due to the ongoing housing crisis. Because this portion of the comment is not related to the EIR, no response is provided.

With respect to the commenter’s suggestion (shown in Footnote 1 of the comment letter), for the City to establish its own local environmental thresholds of significance for projects exempt from CEQA, the City’s General Plan and Municipal Code, as described in this EIR, already include standards that all future development, including those subject to CEQA and those exempt from CEQA, under their jurisdiction must comply with, as applicable, to protect the environment and ensure the conservation of resources in Santa Rosa. These are summarized in Chapters 4.1 through 4.18 of the Draft EIR under the subheading “Regulatory Framework” and where General Plan policies and actions establish standards, these are listed under each impact discussion under the subheading “Impact Discussion.” Further, it would be a conflict of State legislation for the City to impose a quasi-CEQA review process for projects exempt from CEQA.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-41
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR While some proposed future development projects may be subject to CEQA review and others may be exempt from CEQA review, the findings of the General Plan EIR do not rely on the City to review proposed future development projects pursuant to CEQA before the City can approve a project. As summarized in Master Response 2, Mitigation, under subheading “General Plan Policies and Actions as Mitigation, this EIR incorporates mitigation in the form of General Plan policies and actions pursuant to CEQA Statute Section 21081.6(b) and CEQA Guidelines Section 15126.4(a)(2) that are required for all projects under the jurisdiction of the City and not only those projects that are subject to CEQA. In other words, even future projects under the jurisdiction of the City that are exempt from CEQA are still required to comply with the General Plan policies and actions, and other local, State, and federal laws that are applicable to the proposed future project to protect the environment. Specifically, as discussed in Chapter 4.0, Environmental Analysis, on page 4-5 of the Draft EIR, the Draft EIR identifies policies and actions in the proposed General Plan that are also required as means to mitigate environmental impacts. The mitigating policies and actions described in this EIR are fully enforceable through permit conditions, agreements, or other legally binding instruments and include performance criteria. As stated, regardless of whether a project is subject to CEQA review, projects within the jurisdiction of the City would be required to be consistent with the applicable proposed General Plan policies and actions. Therefore, required compliance with the mitigating General Plan policies and actions would serve to minimize environmental impacts even if a project is exempt from CEQA.

Chapter 6, Mitigation Monitoring and Reporting Program, of this Final EIR includes an MMRP that the City and future project applicants may use to ensure proper implementation of the mitigating General Plan policies and actions. Please note that not every General Plan policy and action is intended to directly mitigate an identified significant impact, and, because a General Plan consists of policies reflecting a wide range of competing interests, nor is every policy and action, mitigating or not, applicable to every project. Neither State law nor City regulation impose such a requirement. Please see Master Response 2 regarding implementing mitigation measures and General Plan policies and actions as mitigation.

The commenter speculates that the City may not meet its Regional Housing Needs Assessment (RHNA) allocation of housing units over the course of the 2050 horizon of the General Plan. However, as described in Chapter 4.13, Population and Housing, of the Draft EIR, the City’s 2023-2031 Housing Element was adopted on February 14, 2023, and therefore the City met its assigned 6th Cycle RHNA of 4,685 dwelling units. Further, as part of the proposed project, the City has made strategic planning decisions to meet future RHNA assignments over the 2050 buildout horizon. As described in Chapter 4.13 on page 4.13-7 of the Draft EIR, assuming continued eight-year RHNA cycles, and that the proposed General Plan expected life cycle is 2050, the proposed General Plan should designate sufficient residential land to accommodate the future 7th Cycle (2031–2039), the 8th Cycle (2039– 2047), and some of the 9th Cycle (2047–2055). As described in the Draft EIR, the scale of future housing allocations is unknown and difficult to predict.

However, if the 7th Cycle RHNA uses the same percentage change as the 5th to 6th Cycle RHNA, it would call for approximately 4,455 new units. If the 8th and 9th Cycles continue that trend, it could be expected to call for an additional 4,380 new units by 2047 and an additional 4,430 new units by 2055, for a combined total of around 17,950
new units over the 7th through 9th Cycles, covering the years 2031 to 2055. As described in Chapter 3, Project Description, of the Draft EIR, the EIR evaluates a projected growth of up to 24,090 housing units, thereby addressing future RHNA cycles over the buildout horizon of the proposed General Plan 2050 and the commenter’s concern.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-42 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-PUB6-3:

Without being exhaustive, a few examples of this error in the SR GP DEIR are:

4.12 Noise
Table 4.12-4, Conditionally Acceptable “note”
New construction or development should be undertaken only after a detailed analysis of noise reduction requirements is made and needed noise insulation features included in design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning, will normally suffice.

As is obvious, this Is not objective – “should.” In the case of ministerial housing projects Santa Rosa will have no ability to require any analysis of noise reduction, because this is not objective. This is unacceptable.

Response-PUB6-3:

As described in Chapter 4.12, Noise, on page 4.12-7 of the Draft EIR, the City of Santa Rosa has not adopted its own noise and land use compatibility guidelines. Therefore, the State of California’s compatibility guidelines noted by the commenter and shown in Table 4.12-4, State Community Noise and Land Use Compatibility, in Chapter 4.12 of the Draft EIR, were shown for reference. The table is not an adopted standard or threshold. It is just a reference tool provided by the State. The commenter misunderstands how the State of California General Plan Guidelines presented in the Draft EIR are applied. The use of the term “should,” as noted by the commenter, is not a standard to which a noise impact would be determined or rectified. All future development would be required to meet the City’s noise thresholds. As described in Chapter 4.12 of the Draft EIR, proposed General Plan 2050 *Action 5-7.1 requires the City to continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards. In addition, proposed *Action 5-7.2 requires the City to use the Federal Transit Administration’s construction noise and vibration thresholds as applicable to assess impacts to surrounding land uses and identify mitigation during the project approval process; *Action 5-7.10 requires the City to update the Noise Ordinance to incorporate construction best management practices to minimize construction noise. As described in Response-PUB6-2, ministerial projects in Santa Rosa would still be required to comply with applicable laws, City ordinances, and regulations, including the proposed General Plan 2050 policies and actions. Please see Response-PUB6-2 and Master Response 2, Mitigation, regarding General Plan policies and actions as mitigation.

Comment-PUB6-4:

4.17 Utilities Services Systems
Sewer Design Standards
More stringent requirements may be imposed by the Director of Santa Rosa Water based on specific project conditions.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-43
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR As is obvious, this Is not objective – “may.” In the case of ministerial housing projects Santa Rosa will have no ability to require any more stringent requirements that would be appropriate, because this is not objective. This is unacceptable.

Response-PUB6-4:

As described under impact discussion USS-4 in Chapter 4.17, Utilities and Service Systems, of the Draft EIR, implementation of the proposed project would not require the construction or expansion of the Laguna Treatment Plant or sewer collection system beyond what is already planned or under construction, which is the standard for assessing environmental impacts under CEQA. The increase in wastewater demand with buildout of the proposed project is estimated to be approximately 4.27 million gallons per day (MGD). Combined with the existing average daily flow of 13.1 MGD and the increase with other contributors to the Laguna Treatment Plant flow rates, the estimated total wastewater flow rate in 2050 is estimated to be approximately 18 MGD, which is less than the Laguna Treatment Plant’s permitted average daily flow rate of 21.34 MGD. This is absent any requirement to apply the City’s Sanitary Sewer Standard Specifications, which, as described, are guidelines for design of sewer systems that include sanitary sewer system design standards, standard plans, construction specifications, and an engineer’s list of approved items to reduce the time required for processing the plans. As described in the Draft EIR, in addition to the proposed buildout not exceeding the Laguna Treatment Plant capacity, adherence to the City’s municipal code requirements as well as the proposed General Plan 2050 goal, policy, and actions listed under impact discussion USS-4 would reduce wastewater generation rates over time. As described in Response-PUB6-2, ministerial projects in Santa Rosa would still be required to comply with applicable laws, City ordinances, and regulations and compliance with “more stringent” design standards, while they have benefits to reducing wastewater related impacts, are not required to reduce impacts to a less-than-significant level.

Comment-PUB6-5:

Additionally, the SR GP DEIR also has required Action items which are proposed to mitigate environmental impacts. Unfortunately, some of those Action items themselves are discretionary, assuming that Santa Rosa will continue to have any ability to use that discretion, which is unacceptable, and may result in inaccurate assessment of the environmental impacts, actual mitigation measures required, and determination of levels of significance of housing development in the SR GP DEIR.

Without being exhaustive, some examples of this error in the SR GP DEIR are:

4.10 Hydrology/Water Quality:

Action 3.5-5: Explore options that help to conserve wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species, such as:
• Avoidance of sensitive habitat.
• Clustered development.
• Transfer of development rights.
• Compensatory mitigation, such as habitat restoration or creation.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-44 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR This Action item is neither required nor objective, and requires the use of discretion that will be prohibited in many instances of ministerial housing development. Either this Action item must be amended to be objective, or it cannot be relied upon as mitigation.

Action 5-1.9: Identify enhanced erosion-control measures for properties that exhibit high erosion potential, are in areas of steep slopes, or have experienced past erosion problems.

This Action item is neither required nor objective, and requires the use of discretion that will be prohibited in many instances of ministerial housing development. Either this Action item must be amended to be objective, or it cannot be relied upon as mitigation.

Response-PUB6-5:

As described in Response-PUB6-2 and in Master Response 2, Mitigation, not all the proposed General Plan policies and actions apply to every project, nor are they all to be implemented by every individual project. “It is beyond cavil that no project could completely satisfy every policy stated in [a General Plan], and that state law does not impose such a requirement” (Sequoya Hills Homeowners Association v. City of Oakland (1993) 23 Cal. App. 4th 704, 719). In the case of proposed General Plan 2050 Action 3-5.5 and Action 5-1.9 referenced by the commenter, these require the City to explore options that the City can take to conserve wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species and identify enhanced erosion-control measures for properties that exhibit high erosion potential, are in areas of steep slopes, or have experienced past erosion problems. These are not intended to be implemented by individual development applications nor were they denoted with an asterisk in the Draft EIR. Therefore, the EIR did not consider these actions as mitigating actions.

As described in Chapter 4.4, Biological Resources, and Chapter 4.10, Hydrology and Water Quality, of the Draft EIR, the proposed General Plan 2050 includes specific actions to ensure impacts to sensitive habitats and impacts from erosion would be addressed on a project-by-project basis. For example, proposed *Action 3-5.10, requires the City to implement existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve wetlands and rare plants, riparian habitat, and other sensitive natural communities, and essential habitat for special-status species; *Action 3-5.11 requires that a qualified biologist prepare a BRA for proposed development on sites that may support special- status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat; and *Action 5-1.2 requires that potential future development be restricted in areas where adverse impacts associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a qualified engineer . Please see Chapter 4.4 and Chapter 4.10 of the Draft EIR for a complete list of mitigating polices and actions. Please see Response-PUB6-2 and Master Response 2, Mitigation, with respect to General Plan policies and actions as mitigation.

Comment-PUB6-6:

4.12 Noise
Action 5-7.9: Use conditions of approval to achieve measures to reduce noise and vibration impacts primarily through site planning, and avoid engineering solutions for noise and vibration mitigation, such as sound walls, if possible.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-45
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR This Action item appears to be neither required nor objective, and requires the use of discretion that will be prohibited in many instances of ministerial housing development. Either this Action item must be amended to be objective, or it cannot be relied upon as mitigation.

Response-PUB6-6:

Proposed General Plan 2050 *Action 5-7.9 is marked with an asterisk and is therefore considered a mitigating action in the Draft EIR. As discussed in Chapter 4.12, Noise, on page 4.12-30 of the Draft EIR, proposed General Plan 2050 policies and actions marked with an asterisk (*) are required as means to mitigate environmental impacts under CEQA. These policies and actions are fully enforceable by the decision maker through permit conditions, agreements, or other legally binding instruments. All actions are required to be implemented by the City and therefore the imperative “shall,” if not explicitly stated, is implied. As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, all mitigating policies and actions have been revised to include the word “shall.” Please see Response-PUB6-2 and Master Response 2, Mitigation, with respect to General Plan policies and actions as mitigation.

Comment-PUB6-7:

4.18 Wildfire
Action 5-3.1: Consider ways that new development can incorporate greenbelt zones into the design to reduce wildfire risk and enhance climate resilience.

Action 5-3.2: Work with land use applicants to locate development relative to landscape features that can act as buffers from oncoming wildfires (like agricultural lands and maintained parks and greenbelts).

Neither of these Action items are required nor objective, and require the use of discretion that will be prohibited in many instances of ministerial housing development. Either these Action items must be amended to be objective, or it cannot be relied upon as mitigation.

4.18 Wildfire
Action 5-3.5: Continue to require new development, redevelopment, and remodels to comply with adopted codes and standards and promote implementation of recommendations for firesafe design in the Community Wildfire Protection Plan.

The second half of this action is neither required nor objective – “promote,” and requires the use of discretion that will be prohibited in many instances of ministerial housing development. Either this Action item must be amended to be objective, or it cannot be relied upon as mitigation.

Response-PUB6-7:

As described in Response-PUB6-2 and in Master Response 2, Mitigation, not all the proposed General Plan policies and actions apply to every project nor are all policies and actions to be implemented by individual projects. In the case of proposed General Plan 2050 Action 5-3.1, Action 5-3.2, and Action 5-3.5 referenced by the commenter, these require the City staff to consider ways that new development can incorporate greenbelt zones into the project design to reduce wildfire risk and enhance climate resilience; work with land use applicants to locate development relative to landscape features that can act as buffers from oncoming wildfires; and promote implementation of recommendations in the Community Wildfire Protection Plan for SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-46 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR firesafe design. While proposed Action 5-3.5 would continue to require new development, redevelopment, and remodels to comply with adopted codes and standards, potential future development would be required to comply with existing federal, State, and local regulations, regardless of this action.

These are not intended to be implemented by individual development applications, nor were they denoted with an asterisk in the Draft EIR. Therefore, the EIR did not consider these actions as mitigating actions.

As discussed in Chapter 4.18, Wildfire, of the Draft EIR, the proposed General Plan 2050 includes specific actions to ensure impacts related to wildfire would be addressed on a project-by-project basis and on a citywide scale. For example, proposed *Action 5-3.8 requires the preparation of fire protection plans for new development and major remodels in the City’s Wildland-Urban Interface Fire Area that are consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements, mitigation measures, design considerations for nonconforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans. Future development, regardless of whether it includes new development or redevelopment, would be required to comply with adopted local, regional, and State plans and regulations addressing emergency response and evacuation, including proposed *Action 5-5.14 and *Action 5-5.15, which require the provision of adequate access for fire and emergency response personnel and prohibit the creation of new single-access roadways in the city. Proposed *Action 5-5.17 requires the City to analyze the capacity, viability, and safety of evacuation routes and evacuation locations throughout the city under a range of emergency scenarios and incorporate the results, as necessary, into the Safety Element of the General Plan. This analysis shall be completed as part of the City’s Annex to the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan in 2026. In addition, as described in Chapter 4.18 of the Draft EIR, the proposed changes to the circulation infrastructure include strategic improvements that include evacuation route upgrades primarily on arterials in Wildland-Urban Interface Fire Areas. Please see Chapter 4.18 of the Draft EIR for a complete list of mitigating policies and actions related to wildfire and wildfire-related evacuation. Please see Master Response 2, Mitigation, with respect to General Plan policies and actions as mitigation.

Comment-PUB6-8:

For the SR GP DEIR to be accurate, every instance when said SR GP DEIR relies on any discretionary rule/law/regulation in determining environmental impacts and/or mitigations that may be necessary, including when the SR GP DEIR itself relies on a discretionary Action as mitigation, must be reevaluated to ensure accurate conclusions.

Response-PUB6-8:

The City appreciates the commenter’s careful attention to the proposed General Plan 2050 policies, actions, and development projections. Please see Response-PUB6-2 through Response-PUB6-7 and Master Response 2, Mitigation, regarding compliance by all projects with applicable laws, City ordinances, and regulations; the General Plan consists of policies and actions that reflect a wide range of competing interests and, as such, not all policies and actions apply to every future development and not all General Plan policies and actions act as mitigation.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-47
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-PUB6-9:

2. The SR GP DEIR Relies on the Payment of Impact and Other Fees by Development Projects On Tuesday, November 19, 2024, the Santa Rosa City Council voted to waive some fees for affordable housing to help Santa Rosa meet RHNA. It is possible that there will be future fee reductions and/or waivers required by state law and/or implemented by the City Council. Given that in multiple locations in the SR GP DEIR reliance on those fees is used as mitigation to offset the environmental impacts of development, how will that be affected by this fee waiver, as well as by any future fee reductions/fee waivers? Some examples include:

4.14 Public Services, Parks and Recreation
Chapter 21-04, Capital Facilities Fees. This chapter creates a capital facilities fee (CFF), which is used to alleviate the cost of certain public infrastructure facilities required to serve new development in the City of Santa Rosa. Out of the five account areas, public safety will have 12.8 percent of the revenue from each CFF.

At page 16 of the PDF, the following is stated:

Potential future development that may occur due to implementation of the proposed project would be required to comply with SRCC Chapter 21-014, which requires new development in Santa Rosa to pay a fee that will be used on certain public infrastructure facilities required to serve the new development.

4.17 Utilities and Service System
Storm Water Assessment Funding
The Storm Water Assessment is a charge placed on each city parcel and is used to fund such projects as mapping and evaluating the storm drain system, flood control improvements, responses to flooding issues and creek restoration.

And
Action 5-2.13: Identify and collect development impact fees needed to pay for mitigation of stormwater management impacts for new development.

The SR GP DEIR must reevaluate its conclusions about fees acting to mitigate environmental impacts and reach new conclusions about what those impacts will be when fees are waived, as they now are for some housing projects.

Response-PUB6-9:

As stated by the commenter, the City has adopted an Affordable Housing Capital Facilities Fee Pilot Program to set the capital facilities fees (CFF) for Very Low, Low, and Moderate deed restricted affordable units to zero dollars for a limited period of time not to exceed three years (2024 to 2027) to encourage near-term affordable housing development and achievement of the City’s RHNA requirements. The payment of fees in the examples listed by the commenter and otherwise described in the EIR would continue to be collected by most projects over the three-year time limit established by the SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-48 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR temporary pilot program and would be applied as intended. The CFF for affordable housing is a pilot program that underwent a separate approval process. For the purposes of the EIR, an evaluation of impacts based on what the City may or may not do in the future would be speculative and as such is inappropriate for including in the EIR. Please see Master Response 1, Standards for Responses and Focus of Review, regarding speculation in the EIR. In addition, please note that the payment of CFF is provided for context to demonstrate how the City operates and uses these fees, but no impact conclusions in the Draft EIR other than what is discussed for public schools were determined based on the payment or non-payment of impact fees as asserted by the commenter . With respect to public schools, the mandatory payment of developer impact fees for new development pursuant to Senate Bill 50, California Government Code Section 65995(3)(h) states that the payment of statutory fees is “deemed to be full and complete mitigation of the impacts of any legislative or adjudicative act, or both, involving, but not limited to, the planning, use, or development of real property, or any change in governmental organization or reorganization...on the provision of adequate school facilities.” The school districts are responsible for implementing the specific methods for mitigating school impacts under the Government Code and it would not be within the City’s purview to waive this fee.

Comment-PUB6-10:

3. Project Description Specific Comments
Section 3.6, paragraph 6 calls out a “range of housing,” including Missing Middle housing, but makes no mention of legally affordable housing. Why not? Response-PUB6-10:

The comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the Draft EIR, nor does the comment raise a new environmental issue. Staff notes that deed-restricted affordable ownership and rental options are compatible with all Missing Middle Housing types. Development of more Missing Middle Housing would broaden the range of housing available in walkable neighborhoods of Santa Rosa. Missing Middle Housing is often built as infill housing in existing neighborhoods. These smaller projects with multiple units would not necessarily be built as affordable, deed-restricted units; however, their smaller size (units are generally 500-1,000 square feet) and location in neighborhoods served by transit, Missing Middle Housing units would generally be more affordable than units in many other parts of the city. Please see Master Response 1, Standards for Responses and Focus of Review, regarding project merits.

Comment-PUB6-11:

Section 3.7.1.5, Table 3-4, Chanate Rd is called out for improvements, as a “Resiliency corridor,” with reference to the 2021 Moving Forward 2050 Sonoma County Comprehensive Transportation Plan (hereinafter “the Plan”). That Plan does list Chanate Road as a “project,” with no definition of “resiliency”2 with a 2021 cost of $13 million, but contains no details of either what resiliency means, or what is planned, other than: “The scope of this project includes: Fire evacuation route (Mendocino Avenue to Parker Hill Road) includes roundabout @Parker Hill Rd and Chanate Rd and modifying existing median.”
Footnote 2: This undefined term is used with abandon throughout that Plan, including for conventional road-bed repair, to improve LOS, to add lanes to a conventional freeway interchange, to add lanes to Highway 37, etc.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-49
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR The same problem exists a few items down in Table 3-4, where “Evacuation Routes” are called out for improvements, listed as “Primarily on arterials within wildland-urban interface including Fountaingrove Parkway and Montgomery Drive.” The 2021 Moving Forward 2050 Sonoma County Transportation Plan lists this as a project, with the sum of the details being “"This project would modify existing roadways to enhance evacuation strategies in the event of a disaster primarily on arterials associated with wildland urban interface (WUI) areas. This project could also include intersection improvements.” As is obvious, the last sentence, where intersection improvements “could” be included, is confirmation that nothing contained in that Plan is an actual planned project.

All this Plan appears to be is a list of loosely defined possible projects that will become, by being listed, eligible for future funding. There is no indication either in the SR GP DEIR or in Section 4.15 Transportation how mere reference in the Plan actually reflects any real new and improved traffic circulation that can be relied upon as a mitigation in the SR GP DEIR. In fact, it cannot be relied upon in that way, as it is meaningless.

Response-PUB6-11:

As the regional transportation authority, the SCTA prepares the Comprehensive Transportation Plan (CTP) for Sonoma County. Moving Forward 2050, September 2021, is the most recent CTP approved by the SCTA, and establishes goals and objectives for improving mobility on Sonoma County’s streets, highways, transit systems, and bicycle/pedestrian facilities. Projects in the CTP are included in the Regional Transportation Plan (RTP) adopted by MTC.

The 2021 Moving Forward 2050 Sonoma County CTP was referenced in Table 3-4, Major Planned Roadway Circulation Improvements, and Table 3-5, Major Planned Multimodal Circulation Improvements, in Chapter 3, Project Description, of the Draft EIR because these projects are anticipated to be completed over the buildout horizon of the proposed General Plan 2050. As stated in the CTP , local jurisdictions are responsible for most of the transportation infrastructure and recommend projects from their capital improvement plans for inclusion in the CTP . The City is thereby moving forward with these transportation improvement projects by including them as part of the proposed project and their completion is reflected in the technical modeling and analysis discussed in Chapter 4.15, Transportation, of the Draft EIR. As implementation of these improvements would occur throughout the buildout horizon of the proposed General Plan 2050, they will undergo a separate CEQA review. These improvements are not relied upon as mitigation in the Draft EIR.

Comment-PUB6-12:

Finally, in 4.18 Wildfire, the SR GP DEIR impermissibly relies on these alleged “projects” for “new or expanded roadways in the WUIFA areas of Santa Rosa, to facilitate access of emergency responders.” The following statement in the 4.18 Wildfire section of the SR GP DEIR is wholly unacceptable:

Specifically, improvements include evacuation route upgrades primarily on arterials in the WUIFA, including Fountaingrove Parkway and Montgomery Drive, and on the Farmers Lane Extension from Bennett Valley Road to Petaluma Hill Road, including sidewalks, bike lanes, and transit route. Accordingly, proposed circulation improvements would not substantially impair the implementation of the Santa Rosa EOP .

As already stated, reliance on these illusory projects to reach conclusions regarding environmental impacts and their significance is unacceptable. The SR GP DEIR must be amended to eliminate its reliance on these alleged projects contained in the Plan, and must thereafter reassess the environmental impacts, mitigation measures needed and levels of significance.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-50 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-PUB6-12:

The commenter misunderstands the findings in the Draft EIR and states the findings impermissibly or otherwise rely on the projects in the CTP to facilitate access of emergency responders or to reach findings of less than significant regarding wildfire-related evacuation. Please note, the standard being addressed is if the project would substantially impair an adopted emergency response plan or emergency evacuation plan. As described in Chapter

4.18, Wildfire, of the Draft EIR, the findings show the project’s proposed improvements and actions would not impair responders but would support their efforts to respond to emergencies. Please see Response-PUB6-11 and Response-PUB6-12 regarding CTP projects and how proposed circulation improvements were addressed in the Draft EIR. As discussed in Section 3.7.1.5, Transportation and Infrastructure Improvements, in Chapter 3, Project Description, of the Draft EIR, the new and improved circulation infrastructure is part of the proposed project.

Impacts related to evacuation are described under impact discussion WF-1 in Chapter 4.18, Wildfire, of the Draft EIR. Impacts were found to be potentially significant before mitigation. With implementation of proposed General Plan 2050 *Action 5-5.14, *Action 5-5.15, *Action 5-5.16, and *Action 5-5.17, impacts were found to be less than significant. Future development, regardless of whether it includes new development or redevelopment, would be required to comply with adopted local, regional, and State plans and regulations addressing emergency response and evacuation, including proposed *Action 5-5.14 and *Action 5-5.15, which require the provision of adequate access for fire and emergency response personnel and prohibit the creation of new single-access roadways in the city. Proposed *Action 5-5.16 would reduce the number of evacuation- constrained residential parcels identified on Figure 4.18-5, Evacuation Routes and Evacuation-Constrained Residential Parcels, in Chapter 4.18 of the Draft EIR by retrofitting existing single-access roads in residential neighborhoods to include additional access routes or other provisions to increase evacuation safety. Proposed *Action 5-5.17 would improve evacuation scenarios by requiring the City to analyze the capacity, viability, and safety of evacuation routes and evacuation locations throughout the city under a range of emergency scenarios and incorporate the results, as necessary, into the Safety Element of the General Plan. This analysis shall be completed as part of the City’s Annex to the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan in 2026. Therefore, implementation of the proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan and impacts would be less than significant. As stated in Chapter 4.18 on page 4.18-29 of the Draft EIR, in addition to these General Plan actions, the proposed changes to the circulation infrastructure include strategic improvements that include evacuation route upgrades primarily on arterials in Wildland-Urban Interface Fire Areas. Accordingly, these improvements are not relied on for the findings of less than significant.

The analysis provided in Chapter 4.18 of the Draft EIR analyzes the proposed improvements and concludes that the impacts to emergency response and operations would not be impacted as a result of the proposed improvements, as these improvements would include evacuation route upgrades; therefore, impacts would be less than significant.

Comment-PUB6-13:

Section 3.7.3.2 calls for the creation of a new zoning district for Missing Middle Housing. The SR GP DEIR states that Missing Middle Housing “could be combined with any residential or mixed-use district….” This is unacceptable. The SR GP 2050 itself states clearly that “In Santa Rosa, Missing Middle Housing is compatible in medium-intensity residential zones (Response2, R 3, TV), mixed-use zones, and some planned development areas.” It is SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-51
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR impermissible for the SR GP DEIR to change the General Plan itself by stating that Missing Middle Housing could be in any residential [zoning] district, and this must be corrected.3
Footnote 3: Interestingly, in 4.11 Land Use Planning, the SR GP DEIR in Action 2-1.14 merely states “Create development standards for Missing Middle Housing types.” Nonetheless, the SR GP DEIR is the sum of the whole of its parts, and it’s clear that the General Plan 2050’s intention is for Missing Middle Housing to be limited to only some residential zoning districts.

Response-PUB6-13:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, the discussion of Missing Middle Housing in Chapter 3, Project Description, of the Draft EIR has been revised to clarify that Missing Middle Housing is compatible in medium-density residential zones (Medium Density Multi-Family Residential, Multi-Family Residential, Transit Village-Mixed), mixed-use zones, and some planned development areas. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-PUB6-14:

Thank you for your consideration. Please do not hesitate to contact me if you have any questions.

Response-PUB6-14:

This comment serves as a closing remark.

Public Hearing, Santa Rosa Planning Commission, November 14, 2024 Comment PH1: Alexis Forester, Bikeable Santa Rosa
Comment-PH1-1:

The commenter expresses concern about the predicted amount of VMT increase associated with the proposed project and questions the transportation and land use decisions in the proposed General Plan and states that these impacts can be avoided, it’s just a matter of priorities. In addition, the commenter states that the idea of transportation as a human behavior that cannot be predicted is unacceptable and advocates for pleasant walkable and bikeable roads.

Response-PH1-1:

Please see Master Response 3, Vehicle Miles Traveled, regarding the proposed project’s VMT impacts.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-52 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment PH2: Ken MacNab
Comment-PH2-1:

The commenter states there is no reference to the South Santa Rosa Specific Plan in the proposed General Plan or Draft EIR and provides background information on the Specific Plan and that annexation of areas in South Santa Rosa are reasonably foreseeable and should be acknowledged and addressed in the proposed General Plan and Draft EIR.

Response-PH2-1:

Please see Response-PUB5-2 regarding the South Santa Rosa Specific Plan.

Comment PH3: Commissioner Charles Carter
Comment-PH3-1:

The Commissioner has concerns about the proposed project’s VMT impacts and requests a walkthrough of how project-specific reviews are conducted and how it is integrated with the program-level impacts identified as significant and unavoidable in the General Plan Draft EIR.

Response-PH3-1:

Section 1.4.1.1, Base Resource for General Plan Implementation and Review of Future Development Projects, in Chapter 1, Introduction, of the Draft EIR, describes how the City will use the programmatic analysis in the EIR when a new development project is filed with the City. In addition, please see Master Response 3, Vehicle Miles Traveled, regarding the proposed project’s VMT impacts. As described in Chapter 1 of the Draft EIR, when a new development project is filed with the City, it is reviewed for completeness and consistency with the General Plan 2050 goals, policies, and actions, and City codes and practices. Because City policies, actions, and codes presented in this program EIR will minimize impacts, development projects will implement these measures to: (a) mitigate environmental impacts and (b) achieve consistency with the General Plan 2050 and compliance with City codes. As described in Chapter 4.15, Transportation, of the Draft EIR, proposed General Plan 2050 *Action 3-1.1 requires, as part of the City’s project review process, that a project-specific analysis of projected VMT and if warranted, mitigation, that demonstrates the individual project would meet the City’s adopted VMT threshold be conducted and approved by the City for projects with the potential to increase VMT. Please see https://www.srcity.org/3313/Vehicles-Miles-Traveled for additional information pertaining to VMT in Santa Rosa. The VMT guidelines used by the City when assessing VMT for individual development projects are also available at https://www.srcity.org/DocumentCenter/View/28508/Vehicle-Miles- Traveled-Final-Draft-Guidelines-6520.

As indicated in the City’s VMT Guidelines, several types of development projects would be “screened” from needing to conduct VMT analyses. Examples include small infill projects generating 110 or fewer daily trips, projects in mapped “low VMT” generating areas, certain projects within one-half mile of major transit stops (including SMART stations, the downtown transit mall, and stops along high-frequency bus lines), 100 percent affordable housing developments, local-serving retail uses, and local-serving public facilities. A proposed development generating less VMT than an existing land use that it would replace would also not be required to prepare a VMT study with project-specific mitigation.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-53
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR For development projects subject to VMT analysis, data from the SCTA travel demand model will be used to determine the anticipated level of VMT generated (for residential and employment-based uses, the amount of VMT is determined on a per-person basis). For larger projects, or projects whose characteristics are not well represented by current surrounding land uses, custom runs of the SCTA model typically need to be performed using project- specific land use inputs to produce reliable VMT estimates. The resulting VMT projections are then compared to VMT significance thresholds established by the City for the corresponding proposed land use. If a development project is anticipated to exceed VMT significance thresholds, the City will require the project to implement feasible VMT reduction measures. Such strategies would vary by project type and location but could include, for example, TDM measures, physical improvements supporting non-auto travel, and/or participation in a regional VMT mitigation exchange once established.

As described in Master Response 3, Vehicle Miles Traveled, and in Chapter 4.15, Transportation, of the Draft EIR, the proposed General Plan 2050 is anticipated to result in significant and unavoidable impacts relative to residential VMT at the program level, which does not preclude the finding of less than significant for future development projects in Santa Rosa over the 2050 buildout horizon. Residential development projects that exceed VMT significance thresholds despite including all feasible VMT reduction measures as determined by the City would be able to rely on the significant and unavoidable impact identified in the General Plan EIR and accompanying overriding considerations found by the City Council, rather than needing to conduct their own EIR to disclose significant VMT impacts.

Comment PH4: Commissioner Terrance Sanders
Comment-PH4-1:

The Commissioner asks how the project-level and program-level EIRs relate to each other in terms of VMT projections and thresholds.

Response-PH4-1:

Section 1.4, Use of the General Plan EIR, in Chapter 1, Introduction, of the Draft EIR, describes how the City will use the programmatic analysis in the EIR when a new development project is filed with the City. Section 1.4.1, Tiering Process, in Chapter 1 of the Draft EIR describes how CEQA includes several provisions to streamline the environmental review of qualified projects based on several factors. These include where environmental review has already occurred (e.g., a program-level EIR), which could apply to future development in the EIR Study Area. The CEQA concept of “tiering” refers to the evaluation of general environmental matters in a broad program-level EIR, with subsequent focused environmental documents for individual projects. As described under Section 1.4.1.1, Base Resources for General Plan Implementation and Review of Future Development Projects, in Chapter 1 of the Draft EIR, when a new development project is filed with the City, it is reviewed for completeness and consistency with the General Plan goals, policies, and actions, and City codes and practices.

Comment PH5: Commissioner Aaron Pardo
Comment-PH5-1:

The Commissioner questions if there have been any conversations about infrastructure for advancing technology, such as autonomous cars.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-54 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-PH5-1:

The use of autonomous vehicles has not been considered in the General Plan or the EIR.

Comment PH6: Vice Chair Vicki Duggan
Comment-PH6-1:

The Vice Chair points out that there is evidence that the development of nonmotorized transportation infrastructure will discourage driving and encourage walking and biking.

Response-PH6-1:

The comment is acknowledged. The comment does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the Draft EIR, nor does the comment raise a new environmental issue.

Comment-PH6-2:

The Vice Chair requests a description of VMT mitigation banks - how they work and if there is any in place elsewhere.

Response-PH6-2:

As described in Master Response 3, Vehicle Miles Traveled, mitigation may take the form of paying into a VMT mitigation bank or exchange, allowing developers in higher-VMT areas to contribute funds toward improvements to reduce VMT through other means. VMT mitigation banks are a relatively new concept, and none are currently being implemented in Sonoma County.

The Santa Clara Valley Transportation Authority released Equitable VMT Mitigation Program for Santa Clara County Draft Program Framework in November 2024 and the University of California, Berkeley Center for Law, Energy, and the Environment released Implementing SB 743 Design Considerations for Vehicle Miles Traveled Mitigation Bank and Exchange Programs in August 2022; and the Western Riverside Council of Governments released the VMT Mitigation Through Fees, Banks, & Exchanges, Understanding New Mitigation in April 2020, that all provide background on VMT mitigation banks that demonstrate this type of mitigation is accepted and soon to be implemented by many agencies across the state.

A VMT Mitigation Bank attempts to create a monetary value for VMT reduction such that a developer could purchase VMT reduction credits. The money exchanged for credits could be applied to VMT reduction projects or actions.

A VMT Mitigation Bank would offer a pre-approved list of mitigation actions, which may include operational, programmatic, and capital improvements.

The overall cost of mitigation actions would be divided by the total VMT reduction from these actions to determine the cost per VMT credit; this would be done by the Administering Agency (Bank Administrator). Project applicants could purchase the credits needed to offset their VMT impact, allowing pooled funds from multiple land use projects to support a single mitigation action.

Programmatic approaches that rely on collectively funding larger infrastructure projects appear to hold great promise for VMT mitigation as they allow a project to obtain an amount of mitigation commensurate with their impact, include only a single payment without the complexity of ongoing SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-55
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR management, and do not necessarily require ongoing mitigation monitoring. Programmatic approaches can also provide a public benefit in terms of funding transportation improvements that would not otherwise be constructed, resulting in improvements to congestion, GHG emissions, increased transportation choices, and additional opportunities for active transportation.

Under a Predefined VMT Mitigation Program framework, a fixed set of VMT-reducing projects are grouped together and their associated VMT reductions are monetized in the form of credits. These credits are then purchased for the purpose of mitigating VMT in excess of determined impact thresholds.

The underlying projects may be either regionally or locally beneficial to the area in which the project is located. However, once the total amount of VMT available has been purchased by development projects, the program must be replenished with new projects and the cost per VMT is recalculated producing a new Predefined VMT Mitigation Program.

Like all VMT mitigation, substantial evidence would be necessary that the projects covered by the bank would achieve expected VMT reductions and some form of monitoring may be required.

Comment-PH6-3:

The Vice Chair questions if there is a response to the comment from Ken MacNab regarding the South Santa Rosa Specific Plan.

Response-PH6-3:

Please see Response-PUB5-2 regarding the South Santa Rosa Specific Plan.

Comment-PH6-4:

The Vice Chair references the Staff Report and page 3-18 and 3-20 of the Draft EIR and questions if the owners of the properties proposed for rezoning have been contacted and notified of the proposed changes.

Response-PH6-4:

Some of the rezoning requests came directly from property owners. The rest of the proposed rezonings are required for consistency with the General Plan land use designations pursuant to State law. As the City moves forward with the rezoning process, property owners will be notified of rezoning.

Comment-PH6-5:

The Vice Chair references page 3-22 of the Draft EIR, notes that SCTA is in the process of revising the CTP , and asks if the team has been in coordination with SCTA and if the Draft EIR encompasses the proposed changes of the CTP .

Response-PH6-5:

Please see Response-PUB6-11 regarding the CTP . Local jurisdictions recommend projects from their capital improvement plans for inclusion in the CTP .

Therefore, by including the proposed transportation improvements as part of the proposed General Plan 2050, the City is ensuring that eligibility for these improvements be included in the CTP .

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-56 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Comment-PH6-6:

The Vice Chair references page 5-2 of the Draft EIR and asks for clarification whether future development under the proposed project that are not within Priority Development Areas (PDAs) can tier off the General Plan 2050 Draft EIR.

Response-PH6-6:

Yes, future development under the proposed project that are not within PDAs can still tier off the General Plan 2050 Draft EIR, as appropriate. While the project objectives are related to growth in the 21 Areas of Change, the majority of which capitalize on infill opportunities in and around PDAs and Transit Priority Areas, the EIR Study Area encompasses all land within the city limit, planning area, Urban Growth Boundary, and Sphere of Influence (see Chapter 3, Project Description, page 3-5 of the Draft EIR).

Comment-PH6-7:

The Vice Chair references page 4.14-24 of the Draft EIR and points out that the Kenwood School District is not in Santa Rosa.

Response-PH6-7:

As discussed in Chapter 4.14, Public Services, Parks, and Recreation, on page 4.14-24 of the Draft EIR, Kenwood School District is a one-school district serving Santa Rosa students in kindergarten through sixth grade. While Kenwood Elementary School is not within the EIR Study Area, the school district boundaries encompass the eastern portion of the EIR Study Area and the school district serves students who reside in Santa Rosa. Therefore, discussion of the Kenwood School District is included in the Draft EIR. Please see Response-PH7-5 regarding clarifications to the discussion of public schools in the EIR Study Area.

Comment PH7: Chair Karen Weeks
Comment-PH7-1:

The Chair references page 4.1-6 of the Draft EIR and wonders if the street signs standards for Railroad Square and Courthouse Square downtown should be referenced.

Response-PH7-1:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.1, Aesthetics, of the Draft EIR has been updated to reference the wayfinding signs standards. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-PH7-2:

The Chair references page 4.11-3 of the Draft EIR and requests the definition of an established community be included.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
PLACEWORKS 4-57
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-PH7-2:

As stated under impact discussion LU-1 in Chapter 4.11, Land Use and Planning, of the Draft EIR, the physical division of an established community typically refers to the construction of a physical feature or the removal of a means of access that would impair mobility within an existing community or between a community and outlying areas. For example, an airport, roadway, or railroad track through an existing community could constrain travel from one side of the community to another or impair travel to areas outside of the community. Neither the CEQA Statute, CEQA Guidelines, or General Plan Guidelines provide a formal, or otherwise, definition for an “established community” when considering impacts based on the CEQA Guidelines question “Would the proposed project physically divide an established community?” in Chapter 4.11 of the Draft EIR. As shown in Chapter 5, Revisions to the Draft EIR, Chapter 4.11 has been revised to clarify that for the purposes of this EIR, an established community is considered a place where there is existing permanent infrastructure (roadways, utilities, etc.), structures (buildings, parks, homes, etc.), and populations. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-PH7-3:

The Chair references page 4.14-13 of the Draft EIR and clarifies that the capital facilities fees are only provided to fire protection services and not police services.

Response-PH7-3:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.14, Public Services, Parks, and Recreation, of the Draft EIR has been updated to remove discussion of capital facilities fees for police services. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-PH7-4:

The Chair references page 4.14-14 of the Draft EIR and points out that there is a Sebastopol Road substation and Roseland substation planned and that the police chief has a desire to establish a new substation in East Santa Rosa as well.

Response-PH7-4:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.14, Public Services, Parks, and Recreation, of the Draft EIR has been updated to provide additional information on the planned and desired police substations. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-PH7-5:

The Chair references Table 4.14-1 of the Draft EIR and expresses confusion about why it says Santa Rosa School Districts and not School Districts in Santa Rosa and why Bellevue Union School District has been separated.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

COMMENTS AND RESPONSES
4-58 APRIL 2025
TABLE 4-1 RESPONSES TO INDIVIDUAL COMMENTS ON THE DRAFT EIR Response-PH7-5:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.14, Public Services, Parks, and Recreation, of the Draft EIR has been updated to revise the name of Table 4.14-1, Santa Rosa School Districts, to School Districts in the EIR Study Area. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification. Bellevue Union School District is not separated but rather has a detailed discussion specific to the district, as do all the other school districts included in Table 4.14-1.

Comment-PH7-6:

The Chair references page 4.14-40 of the Draft EIR and wonders if a reference to the Hearn Hub should be included in the discussion regarding libraries.

Response-PH7-6:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.14, Public Services, Parks, and Recreation, of the Draft EIR has been updated to include reference to Hearn Community Hub. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

Comment-PH7-7:

The Chair references page 4.14-44 of the Draft EIR and requests a reference to the renewal of Measure O and a note that it’s now Measure H.

Response-PH7-7:

As shown in Chapter 5, Revisions to the Draft EIR, of this Final EIR, Chapter 4.14, Public Services, Parks, and Recreation, of the Draft EIR has been updated to include reference to the renewal of Measure O and note that it is now Measure H. This revision does not affect any conclusions or significance determinations in the Draft EIR. Therefore, no recirculation of the Draft EIR is required pursuant to CEQA Guidelines Section 15088.5(a), Recirculation of an EIR Prior to Certification.

P LACEWORKS 5-1
Revisions to the Draft EIR
This chapter includes text revisions to the Draft EIR, including the goals, policies, and actions in the Draft General Plan 2050, that were made in response to agency and organization comments, as well as tribal consultation with representatives from the Federated Indians of Graton Rancheria and Lytton Rancheria and staff-directed changes. These text revisions include typographical corrections, insignificant modifications, amplifications and clarifications of the Draft EIR. In each case, the revised page and location on the page is presented, followed by the textual, tabular, or graphical revision. Underlined text represents language that has been added to the EIR; text with strikethrough represents language that has been deleted from the Draft EIR. None of the revisions to the Draft EIR constitutes significant new information as defined in CEQA Guidelines Section 15088.5; therefore, the Draft EIR does not need to be recirculated.

On W
ednesday, January 22, 2025, the Bay Area Air District (Air District), formally the Bay Area Air Quality Management District (BAAQMD), announced its new name and logo to honor the Bay Area’s diversity, environmental justice initiatives, and commitment to clean air for all amongst other reasons. The agency requests that they be referred to as the "Bay Area Air District" or the "Air District" rather than using an acronym. Due to the number of times and locations that the Air District is referenced in the EIR, this change is assumed to occur and is not shown in strikethrough or underlined text in this chapter.

CHAPTER 1, INTRODUCTION
The first paragraph in Section 1.1, Proposed Action, on page 1-1 of the Draft EIR is hereby amended as follows:

If approved by the Santa Rosa City Council, the proposed project would replace the City’s existing General Plan, which was last comprehensively updated in 2009 and has a buildout horizon of 2035. The proposed project is intended to guide development and conservation in the city. The proposed General Plan 2050 would build off the current General Plan 2035 and provide a direct framework for the upcoming changes in Santa Rosa and the expected growth in the coming decades; as well as land use, transportation, and conservation decisions through the horizon year of 2050. Because California Government Code Section 65860 requires the city’s Specific Plans and Zoning Code to be consistent with its General Plan, the proposed project would also introduce amendments to the maps in the North Station Area Specific Plan and Downtown Station Area Specific Plan Roseland Area/Sebastopol Road Specific Plan, as well as new zoning provisions including zoning map revisions on certain parcels throughout the city to ensure that the Specific Plans and Zoning Code conforms to the proposed General Plan 2050. Lastly, the proposed project would replace the City’s existing Climate Action Plan, which was adopted in 2012, with a GHG Reduction Strategy that would serve as the City’s strategic plan to reduce community-wide GHG emissions through 2045 and beyond.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-2 APRIL 2025
CHAPTER 2, EXECUTIVE SUMMARY
The second paragraph in Section 2.2, Summary of Proposed Project, on page 2-4 of the Draft EIR is hereby amended as follows:

The City determined that the current General Plan 2035 provided a good foundation for General Plan 2050. The current General Plan 2035 included a comprehensive review process, resulting in a broad range of community goals and policies. Many of the community issues vetted in the current General Plan 2035 are still relevant, well addressed, and do not require major change. Therefore, the approach to the proposed General Plan 2050 is not a comprehensive update, rather, it builds off of the current General Plan 2035 by incorporating the topics that are now required by State mandate and revises relevant policies and programs to meet those requirements. It also incorporates regional forecasts for 2050, thus moving the planning horizon forward by 15 years from the 2035 horizon year of the current General Plan.

Because California Government Code Section 65860 requires the city’s Specific Plans and Zoning Code to be consistent with its General Plan, the proposed project would also amend the maps in the North Station Area Specific Plan and Downtown Station Area Specific Plan Roseland Area/Sebastopol Road Specific Plan, as well as SRCC Code. The proposed project would also replace the City’s existing 2012 Climate Action Plan with a GHG Reduction to reduce community-wide GHG emissions through 2045 and beyond. Chapter 3, Project Description, of this Draft EIR includes a detailed description of the proposed project Please see Chapter 2, Executive Summary, of this Final EIR for revisions to Table 2-1, Summary of Significant Impacts and Mitigating Policies and Actions.

CHAPTER 3, PROJECT DESCRIPTION
The text in Section 3.7.1.4, Land Use and Zoning Map Revisions, on page 3-16 of the Draft EIR is hereby amended as follows:

The proposed General Plan 2050 land use map is shown on Figure 3-3, Proposed General Plan 2050 Land Use Map. The proposed project includes revisions to the land use designations and as required, zoning districts on 11 12 parcels, as recommended by City staff to better align with the vision of the proposed General Plan 2050. These revisions are shown in Table 3-2, General Plan Land Use and Zoning Revisions, and on Figure 3-4, General Plan Land Use and Zoning Revisions.

The last paragraph in Section 3.2, Overview, on page 3-3 of the Draft EIR is hereby amended as follows:

As part of the proposed project, the City will make amendments to the North Station Area Specific Plan (NSASP), Downtown Station Area Specific Plan (DSASP), Roseland Area/Sebastopol Road Specific Plan (RA/SRSP), and the SRCC to ensure consistency with the proposed General Plan 2050. Concurrent with the proposed General Plan 2050, the City is updating its 2012 Community-wide Climate Action Plan (CCAP) in support of Santa Rosa Forward. The proposed GHG Reduction Strategy is an update to and replacement of the CCAP . It is a strategic planning document that would provide policies and actions that would help the City and the community at large to reduce their GHG emissions and improve community resilience to hazardous conditions associated with climate change. The proposed General Plan 2050, Specific Plan, and SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-3
SRCC amendments, and the proposed GHG Reduction Strategy are discussed in detail in Section 3.7.1, Section 3.7.2, Section 3.7.3, and Section 3.7.4, respectively.

The text in Section 3.7, Project Components, on page 3-10 of the Draft EIR is hereby amended as follows:

As required by State law, the proposed project includes multiple components to ensure that each element of the Santa Rosa General Plan is internally (or horizontally) consistent and the NSASP , DSASP , RA/SRSP , the SRCC, and GHG Reduction Strategy are consistent with the General Plan (also known as vertical consistency). The section provides a description of each project components.

The first paragraph in Section 3.7.1.3, Land Use Designations, on page 3-12 of the Draft EIR is hereby amended as follows:

The proposed General Plan 2050 land use map shows the land use designations that establish the uses, density ranges, and development intensities allowed on each parcel of land. In general, standards of building intensity for residential uses are stated as the allowable range of dwelling units per gross acre (units/acre). Gross acreage includes the entire site (as opposed to net acreage, which excludes unbuildable areas). Nonresidential uses are described with square footage per employee (sf/employee) or may be stated as maximum floor-area ratios (FAR) based on net acreage. FAR is a ratio of the building square footage permitted on a lot to the net square footage of the lot. For example, on a site with 10,000 square feet of net land area, a FAR of 1.0 will allow 10,000 square feet of building floor area to be built.

This could take the form of a two-story building with 50 percent lot coverage, or a one-story building with 100 percent lot coverage. A FAR of 0.4 would allow 4,000 square feet of floor area. The number of residential units permitted and nonresidential FAR are further modified by the zoning district, which, pursuant to California Government Code Section
65860(a), is required to be consistent with the General Plan. The following sections describe the land use designations for the proposed General Plan 2050, which would be carried forward from the existing General Plan 2035. The land use types are residential, mixed use, commercial, office, industrial, and other, which includes public/institutional, parks and recreation, open space, and agriculture. The proposed General Plan 2050 does not introduce any new land use designation types.

The first two bullet points under the “Mixed Use” subheading in Section 3.7.1.3, Land Use Designations, on pages 3-13 and 3-14 of the Draft EIR is hereby amended as follows:
 Transit Village Medium (25-40.0 units/gross acre and 300 sf/employee). This land use designation is intended to accommodate mixed-use development within approximately one-half mile of a transit facility. Development should transition from less intense uses at the outlying edges to higher intensity uses near the transit facility. Residential uses are required, and ground-floor neighborhood-serving retail and Missing Middle Housing types, including Live/Work uses, are encouraged.

 Transit Village Mixed Use (40 units/gross acre minimum and 300 sf/employee). This land use designation is intended to accommodate a well-integrated mix of higher-intensity residential, including Missing Middle Housing, such as Multiplex (small and large), Courtyard buildings, Townhouses, and Live/Work units, office, and commercial uses within one-quarter mile of a transit facility. Development is designed and oriented to create a central node of activity at or near the transit facility. There is no maximum density requirement for this designation.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-4 APRIL 2025
The bulleted list under the “Commercial” subheading in Section 3.7.1.3, Land Use Designations, on page 3-15 of the Draft EIR is hereby amended as follows:
 Retail and Business Services (300 sf/employee). This land use designation allows retail and service enterprises, offices, and restaurants. It includes regional centers, which are large complexes of retail and service enterprises anchored by one or more full line department stores, and destination centers, which are retail centers anchored by discount or warehouse stores. Large grocery stores are expressly permitted in Community Shopping Centers and downtown only, and they may be considered through a Conditional Use Permit process on other commercial sites.  Community Shopping Center (300 sf/employee). The vision for this land use designation is a complex of retail services and enterprises anchored by a large grocery store and serving a community clientele.

Typical uses include restaurants and shops offering convenience goods. These sites are in areas surrounded by residential development and are intended to be walkable areas with a mix of uses that meet the shopping needs for surrounding neighborhoods and provide housing integrated with commercial development. Residential uses shall be incorporated into the overall design but may be provided over time as part of a phased development. Existing community shopping centers are not required to include residential uses for minor alterations or re-occupancy but are required to evaluate and demonstrate through site planning that future residential would not be precluded when significant additions or reconstruction are proposed.
 Neighborhood Shopping Center (300 sf/employee). This land use designation includes small groups of retail and service enterprises providing shopping and services to satisfy the day-to-day needs of local neighborhoods and workplaces. Typical neighborhood center uses include small grocery stores, restaurants, barber or beauty shops, cleaners, shoe repair, and shops offering convenience goods.

Residential development is encouraged but not required. New neighborhood centers are allowed in any land use designation where they can be supported.

The bullet point under the “Office” subheading in Section 3.7.1.3, Land Use Designations, on page 3-15 of the Draft EIR is hereby amended as follows:
 Office (250 sf/employee). This land use designation provides sites for administrative, financial, business, professional, medical, and public offices. There is flexibility in how office space is designed to accommodate changing market conditions.

The bulleted list under the “Industrial” subheading in Section 3.7.1.3, Land Use Designations, on pages 3- 15 and 3-16 of the Draft EIR is hereby amended as follows:
 Business Park (350 sf/employee). This land use designation accommodates holistically planned, visually attractive centers for businesses that do not generate nuisances (noise, clutter, noxious emissions, etc.) in campus-like environments for corporate headquarters, research and development facilities, offices, light manufacturing and assembly, industrial processing, general service, incubator facilities, testing, repairing, packaging, and publishing and printing. Warehousing and distribution facilities, retail, hotels, and residential uses are permissible on an ancillary basis. Restaurants and other related services are permitted as accessory uses. Outdoor storage is not permitted.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-5
 Light Industry (400 sf/employee). This land use designation supports light industrial, warehousing, and some heavier commercial uses. Uses appropriate to this land use category include auto repair, bulk or warehoused goods, general warehousing, manufacturing/assembly, home improvement and landscape materials retail, freight or bus terminals, research-oriented industrial, accessory offices, employee-serving commercial uses, and services with large space needs, such as health clubs.

Professional office buildings are not permitted.
 General Industry (400 sf/employee). This land use designation provides areas for manufacturing and distribution activities with potential for creating nuisances, along with accessory offices and retailing.

Unrelated retail and service commercial uses (which can be appropriately located elsewhere in the city) are not permitted. Uses may generate truck traffic and operate 24 hours a day.

The first bullet point under the “Other” subheading in Section 3.7.1.3, Land Use Designations, on page 3- 16 of the Draft EIR is hereby amended as follows:
 Public/Institutional (25-40 units/gross acre minimum and 300 sf/employee). This land use designation allows for governmental or semi-public facilities, such as hospitals, utilities, and government office centers; however, such facilities may also be allowed in areas with other land use designations, provided they comply with applicable zoning code standards.

The text in Section 3.7.2, Specific Plan Amendments, on page 3-24 of the Draft EIR is hereby amended as follows:

In September 2012, the City Council adopted the NSASP . The primary objective of NSASP is to support future rail transit by increasing the number of residents and employees within walking distance of the SMART station by improving pedestrian, bicycle, auto, and transit connections, increasing residential density, promoting economic development, and enhancing aesthetics and quality of life. In October 2020, the City Council adopted an updated DSASP . The DSASP was updated with the stated purpose to address land use, transportation and infrastructure needs associated with intensification of housing development in the Downtown. In November 2016, the City Council adopted the RA/SRSP to support a unified, vital, healthy and livable Roseland community. The area’s designation as a Priority Development Area supports walkable, bikeable, and transit-rich neighborhoods by increasing the number and proximity of residents to amenities, schools, parks and jobs. The plan aims to do this by improving connectivity, concentrating areas of activity, and enhancing the physical environment. The proposed project would update the NSASP and DSASP RA/SRSP to be consistent with the proposed General Plan 2050 by eliminating the references to local streets in the NSASP and DSASP circulation/mobility figures and text of both specific plans.

The text under the “New Zoning District: Missing Middle Housing” subheading in Section 3.7.3.2, Title 20:

Zoning Code, on page 3-25 of the Draft EIR is hereby amended as follows:

SRCC Title 20, Zoning, would be amended to include a new combining district to accommodate the type of housing referred to as “Missing Middle.” This proposed new combining district provides zones and standards to implement the City’s vision of enabling Missing Middle Housing. Missing Middle Housing refers to housing that provides diverse housing options along the spectrum of affordability, which includes duplexes, triplexes, fourplexes and bungalows. Other examples can include cluster homes and cottage courts house-scale buildings with multiple units in walkable neighborhoods. Missing Middle Housing adds SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-6 APRIL 2025
what is often referred to as “gentle density” because it adds dwelling units without altering the character of neighborhoods. Buildings are generally not more than two and a half stories in height; have multiple units in one building; have amenities such as porches that contribute to the streetscape; have limited off- street parking, generally at the rear of the structure, reached by a narrow (single-lane) driveway; and have some shared open space, often in the form of a courtyard or rear or side yard.. The proposed Missing Middle Housing combining district would be denoted as “-MMH” and could be combined is compatible with any medium-intensity residential or zoning districts (Medium Density Multi-Family Residential, Multi- Family Residential, Transit Village-Mixed), mixed-use primary zoning districts, and some planned development areas, as established by SRCC Section 20-20.020, Zoning Map and Zoning Districts, provided the provisions of the standards of the proposed new combining district are met. The proposed new zoning district identifies Missing Middle Housing zones and allows for a Missing Middle Housing Bonus (MMH Bonus) for potential future housing within these zones. The MMH Bonus would be determined on a case- by-case basis for qualifying projects as determined by the City during the project application and approval process.

Table 3-2, General Plan Land Use and Zoning Revisions, on page 3-18 of the Draft EIR is hereby amended as follows:

TABLE 3-2 GENERAL PLAN LAND USE AND ZONING REVISIONS
Map
No. APN
General Plan
Land Use Designation
Zoning
District
Current
Capacity
(DU)
Future
Capacity
(DU)
Net
Capacity
(DU) Existing Proposed Existing Proposed
1 180-270-050
Low
Density
Residential
Retail and
Business
Services
Single-Family
Residential
(R-1-6)
General
Commercial
(CG)
1 4 3
2 043-041-034
Low
Density
Residential
Medium
Density
Residential
Single-Family
Residential
(R-1-6)
Medium
Density Multi-
Family
Residential (R-
2)
4 4 0
3 035-700-077
Low
Density
Residential
Retail and
Business
Services
Planned
Development
Residential
(PD95-001)
General
Commercial
(CG)
14 11 -3
4 037-131-018
Medium
Density
Residential
Retail and
Business
Services
General
Commercial
(CG)
no change 6 6 0
5 037-131-019
Medium
Density
Residential
Retail and
Business
Services
General
Commercial
(CG)
no change 5 5 0
6 182-520-098
Low
Density
Residential
Medium High
Density
Residential
Rural
Residential
(RR-40)
Multi-Family
Residential (R-
3-10)
2 10 8
7 1802-520-
099
Low
Density
Residential
Medium High
Density
Residential
Rural
Residential
(RR-40)
Multi-Family
Residential (R-
3-10)
3 12 9
8 035-530-044 General
Industry Business Park
General
Industrial
(IG)
Business Park
(BP) 72
72 0
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-7
TABLE 3-2 GENERAL PLAN LAND USE AND ZONING REVISIONS
Map
No. APN
General Plan
Land Use Designation
Zoning
District
Current
Capacity
(DU)
Future
Capacity
(DU)
Net
Capacity
(DU) Existing Proposed Existing Proposed
9 010-091-001
Neighborho
od Mixed
Use
Maker Mixed
Use
Neighborhood
Mixed Use –
Historic
(NMU-H)
Maker Mixed
Use – Historic
(MMU-H)

4.0 FAR

4.0 FAR 0
10 125-252-003 Medium
Residential
Parks/
Recreation
Single-Family
Residential
(R-3-18)
Open Space-
Recreation –
Scenic Road
(OSR-SR)
47 0 -47
11 043-122-007 Medium
Residential
Parks/
Recreation
Single-Family
Residential
(R-3-18)
Open Space-
Recreation –
Scenic Road
(OSR-SR)
69 0 -69
12 041-043-056 Public/Insti
tutional
Transit Village
Mixed Use
North Station
Area
Combining
District (PI-SA)
Transit
Village-Mixed 0
17 17
13 041-043-057 Public/Insti
tutional
Transit Village
Mixed Use
North Station
Area
Combining
District (PI-SA)
Transit
Village-Mixed 0
42 42
14 010-091-007
Neighborho
od Mixed
Use
Maker Mixed
Use
Neighborhood
Mixed Use –
Historic
(NMU-H)
Maker Mixed
Use – Historic
(MMU-H)

4.0 FAR

4.0 FAR 0
Total 223 183 -40
Note: APN = Assessor Parcel Number; FAR = Floor Area Ratio Source: City of Santa Rosa, 2024
Table 3-3, Proposed Rezoning Sites, on page 3-20 of the Draft EIR is hereby amended as follows:

TABLE 3-3 PROPOSED REZONING SITES
Map
No. APN Existing Zoning Proposed Zoning
Current
Capacity
(DU)
Future
Capacity
(DU)
Net
Capacity
(DU)
1 043-071-022 Single-Family Residential (R-1-6) Multi-Family Residential (R-3-10) 29 35 6
2 043-191-021 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 32 25 -7
3 043-200-006 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 27
21 -6
4 043-191-024 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 60 47 -13
5 043-200-007 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 16 12 -4
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-8 APRIL 2025
TABLE 3-3 PROPOSED REZONING SITES
Map
No. APN Existing Zoning Proposed Zoning
Current
Capacity
(DU)
Future
Capacity
(DU)
Net
Capacity
(DU)
6 043-071-007 Single-Family Residential
(R-1-6)
Multi-Family Residential
(R-3-10) 66 81 15
7 043-200-010 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 171 133 -38
8 043-071-023 Single-Family Residential
(R-1-6)
Multi-Family Residential
(R-3-10) 4 5 1
9 043-191-019 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 73 57 -16
10 043-200-009 Planned Development Residential
(PD 06-001)
Multi-Family Residential
(R-3-10) 44 35 -9
11 181-190-004 Planned Development Residential
(PD 98-003) General Commercial (CG) 0
88 88
12 181-190-008 Planned Development Residential
(PD 98-003) General Commercial (CG) 0 16 16
13 181-190-009 Planned Development Residential
(PD 98-003) General Commercial (CG) 0
76 76
14 181-190-006 Planned Development Residential
(PD 98-003) General Commercial (CG) 0 7 7
Total 522 638 116
Source: City of Santa Rosa, 2024.

The text on page 3-20 following Tables 3-2 and 3-2 of the Draft EIR is hereby amended as follows:

As shown in Table 3-2 and Table 3-3, tThe proposed revisions to the land use designations and, as required, zoning districts on the 13 parcels listed in Table 3-2 would result in a net loss for the of potential future development of 40 residential units, and the. However, the proposed revisions to the zoning districts on 14 parcels listed in Table 3-3 would result in a net gain of 116 potential future development of residential units on a scale greater than the net loss from the 13 parcels shown in Table 3-2. Therefore, with these changes, there would not be a loss in housing potential but rather would result in a net gain for the of potential future development of 76 residential units.

CHAPTER 4.0, ENVIRONMENTAL ANALYSIS
The third paragraph under the “General Plan 2050 Goals, Policies, and Actions” subheading on page 4-5 of the Draft EIR is hereby amended as follows:

Public Resources Code (PRC) Section 21081.6(b) and CEQA Guidelines Section 15126.4(a)(2) establish that when a project examined in an EIR is a plan (such as a General Plan), policy, regulation, or other public project, mitigation measures may be incorporated into the plan, policy, regulation, or project design.

Therefore, as this is a General Plan EIR, some policies and actions in the proposed General Plan are also SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-9
required as means to mitigate environmental impacts under CEQA. These policies and actions are fully enforceable at the discretion of the decision-maker regarding applicability to a proposed future development and use the imperative “shall,” and in all such cases are mandatory. The mitigating policies and actions described in the EIR that are fully enforceable through permit conditions, agreements, or other legally binding instruments and include performance criteria are marked with an asterisk (*). These proposed General Plan policies and actions are listed in the impact discussions of Chapters 4.1 through

4.18 of this Draft EIR to illustrate where the proposed polices and actions would reduce impacts from future development in Santa Rosa.

The text under the “Associated Specific Plan and Code Amendments” subheading on page 4-5 of the Draft EIR is hereby amended as follows:

As required by State law, the proposed project includes multiple components to ensure that each element of the Santa Rosa General Plan is internally (or horizontally) consistent3 and the North Station Area Specific Plan (NSASP), Downtown Station Area Specific Plan (DSASP), Roseland Area/Sebastopol Road Specific Plan (RA/SRSP), the Santa Rosa City Code (SRCC), and GHG Reduction Strategy are consistent with the General Plan (also known as vertical consistency). The impacts from the proposed amendments to the NSASP , DSASP , RA/SRSP , and SRCC are therefore analyzed concurrently with the impacts of the proposed General Plan 2050.

CHAPTER 4.1, AESTHETICS
The fifth indented bullet under fourth bullet under the “Santa Rosa City Code” subheading in Section

4.1.1.1, Regulatory Framework, on page 4.1-4 of the Draft EIR is hereby amended as follows:
 Chapter 20-38, Signs. This chapter of the Zoning Code establishes regulations intended to appropriately limit the placement, type, size, and number of signs allowed within the City, and to require the proper maintenance of signs to, among others, preserve and enhance the aesthetic quality of the entire community. Section 20-38.030, Sign Permit requirements, requires a Sign permit prior to the installation, construction, or alteration of any sign. The review authority is required to find that the proposed sign is consistent with the Zoning Code standards, visually complementary
and compatible with the scale, architectural style, and prominent natural features of its surroundings prior to approval of a Sign Permit. Section 20-38.050, General requirements for all signs, outlines the sign area measurement, height measurement, and locations requirements. Section 20-38.080, Standards for Wayfinding Signs, provides standards for public/civic wayfinding and business wayfinding, and allows for the implementation of wayfinding signage within the boundaries of both the North Santa Rosa Station Area Specific Plan and the Downtown Station Area Specific Plan.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-10 APRIL 2025
CHAPTER 4.3, AIR QUALITY
The following actions in the bulleted list of proposed goals, policies, and actions related to air quality under Section 4.3.2.3, Impacts of the Environment on a Project, on pages 4.3-36 through 4.3-38 of the Draft EIR are hereby amended as follows:
 Action 2-1.2: Work with developers to ensure new and redevelopment respects align with the integrity and character of surrounding uses, especially when nonresidential uses are proposed adjacent to residential areas. Consider use of appropriate buffers, landscaping, and other types of screening to minimize noise, light, glare, and odor .  Action 2-5.6: Maintain and expand industrial zoned land close to established transportation corridors, including Highway 101, State Route 12, and the SMART rail line, and focusing on areas away from minimizing impacts of growth on sensitive receptors.  Action 2-9.4: Require industrial developments adjacent to residential areas to provide appropriate mitigation such as buffers, and institute setbacks, landscaping, and screening requirements intended to minimize noise, light, glare, and other impacts.  Goal 6-1: Improve health and well-being for all community members by emphasizing community health in all City policies, programs, actions, and activities.  *Action 6-1.5: As recommended by the California Air Resources Board, the City shall require projects that would result in construction activities within 1,000 feet of residential and other land uses that are sensitive to toxic air contaminants (e.g., hospitals, nursing homes, day care centers), as measured from the property line of the project, to prepare a construction health risk assessment in accordance with policies and procedures of the Office of Environmental Health Hazard Assessment and the Bay Area Air Quality Management District (BAAQMDAir District) California Environmental Quality Act (CEQA) Guidelines that identifies mitigation measures and appropriate enforcement mechanisms capable of reducing potential cancer and non-cancer risks below the BAAQMD Air District threshold.  *Action 6-1.6: The City shall Rrequire an operational health risk assessment for new industrial or warehousing development projects that 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel-powered transport refrigeration units, and 2) are within 1,000 feet of a sensitive land use or Overburdened Community, as defined by BAAQMD the Air District. The operational HRA shall be prepared in accordance with policies and procedures of the State Office of Environmental Health Hazard Assessment and BAAQMD the Air District. If the operational HRA shows that the incremental cancer risk exceeds 10 in a million, the noncancer hazard index of 1.0, or the thresholds as determined by BAAQMD the Air District, require the project applicant to identify and demonstrate measures, such as those listed in the General Plan Environmental Impact Report, that can reduce potential cancer and noncancer risks to acceptable levels.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-11
The following policy and actions in the row for Natural and Working Lands Control Measures in Table 4.3- 8, Control Measures from the BAAQMD Bay Area Air District 2017 Clean Air Plan, on pages 4.3-45 through

4.3-48 of the Draft EIR are hereby amended as follows:
 Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
 *Action 3-5.10: The City shall Ccontinue to require the implementation of existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve prior to, during, and after project approval and construction for projects that may affect wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species to ensure their conservation. Existing regulations and procedures include, but are not limited to, Federal and California Endangered Species Act; CDFW 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities; Santa Rosa Plain Conservation Strategy; United States Fish and Wildlife (USFWS) Service Programmatic Biological Opinion; CDFW 2012 Staff Report on Burrowing Owl Mitigation; 2012 USFWS Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls; 2020 Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California; Fish and Game Code Section 1600 et seq; Clean Water Act; and Porter Cologne Water Quality Control Act, as subsequently revised, supplemented, or replaced.
 *Action 3-5.11: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support or have the potential to affect special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction. The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced.

The following actions in the bulleted list of proposed goals, policies, and actions related to air quality under the “Construction” subheading of Impact Discussion AIR-2 in Section 4.3.3, Impact Discussion, on pages 4.3-55 and 4.3-56 of the Draft EIR are hereby amended as follows:
 *Action 3-6.31: The City shall Rrequire projects that exceed the Bay Area Air Quality Management District (BAAQMDAir District) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD Air District methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD Air District thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level, consistent with the BAAQMD Air District Guidelines, as subsequently revised, supplemented, or replaced.
 *Action 3-6.32: The City shall Ccontinue to implement the Bay Area Air Quality Management District (BAAQMD) Air District Basic Control Measures included in the latest version of BAAQMD Air District’s California Environmental Quality Act (CEQA) Air Quality Guidelines, as SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-12 APRIL 2025
subsequently revised, supplemented, or replaced, to control fugitive dust (i.e., particulate matter PM2.5 and PM10) during demolition, ground-disturbing activities, and/or construction.

The sixth paragraph of the significance discussion for Impact Statement AIR-2b in Section 4.3.3, Impact Discussion, on page 4.3-63 of the Draft EIR is hereby amended as follows:

Ozone concentrations depend on a variety of complex factors, including the presence of sunlight and precursor pollutants, natural topography, nearby structures that cause building downwash,49 atmospheric stability, and wind patterns. Secondary formation of particulate matter and ozone can occur far from sources as a result of regional transport due to wind and topography (e.g., low-level jet stream).

Photochemical modeling depends on all emission sources in the entire domain (i.e., modeling grid). Low resolution and spatial averaging produce “noise” and modeling errors that usually exceed individual source contributions. Because of the complexities of predicting ground-level ozone concentrations in relation to the National and California AAQS, it is not possible to link health risks to the magnitude of emissions exceeding the significance thresholds.

Footnote 5: The downwash effect is a wind-related phenomenon commonly observed in urban environments, especially around tall buildings and skyscrapers. This effect occurs when wind strikes the face of these high structures and is deflected downwards, creating strong downdrafts at the street level. These downdrafts can significantly increase wind speeds on the ground, leading to uncomfortable and sometimes hazardous conditions for pedestrians. (Building Downwash: How to Mitigate Urban Wind Discomfort | Blog)
CHAPTER 4.4, BIOLOGICAL RESOURCES
Figure 4.4-3, Special-Status Animals and Critical Habitats , on page 4.4-29 of the Draft EIR is hereby amended as shown on the following page.

The row for the burrowing owl (Athene cunicularia) under the “Birds” subheading in Table 4.4-3, Special- Status Animal Species in the EIR Study Area, on page 4.4-33 of the Draft EIR is hereby amended as follows:

TABLE 4.4-3 SPECIAL-STATUS ANIMAL SPECIES IN THE EIR STUDY AREA Scientific
Name
Common
Name
Federal
List
California
List CDFW General Habitat
Potential for Occurrence in
EIR Study Area
Birds
Athene
cunicularia
Burrowing
owl None None
Candidate
Species
of
Special
Concern
Open, dry grasslands that contain
abundant ground squirrel
burrows
Moderate. Observed in
Sonoma County where
suitable habitat is present,
with CNDDB records to the
south of EIR Study Area.

Source: California Natural Diversity Database release date 4/1/2023 accessed on 4/6/2023; USFWS critical hatitat data release dare 3/23/2023 accessed on 4/6/2023; Basemap by: ESRI. Map produced bt www.digitalmappingsolutions.com 8/5/2024. 0 Scale (Miles)
2 Figure 4.4-3
Special-Status Animals and Critical Habitats
SANTA ROSA GENERAL PLAN 2050, ASSOCIATED ZONING MAP AMENDMENTS, AND

COMMUNITY-WIDE GHG REDUCTION STRATEGY DRAFT EIR

CITY OF SANTA ROSA

BIOLOGICAL RESOURCES

PLACEWORKS
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-14 APRIL 2025
The following policy and actions in the bulleted list of proposed goals, policies, and actions related to biological resources under Impact Discussion BIO-1 in Section 4.4.3, Impact Discussion, on pages 4.4-42 and 4.4.43 of the Draft EIR are hereby amended as follows:
 Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
 *Action 3-5.7: The City shall Ccontinue to consult with the California Department of Fish and Wildlife (CDFW) to identify significant environments and priorities for acquisition or maintenance of open space areas based on biological and environmental concerns and develop a strategy for maintaining areas that will preserve the protected and sensitive populations of plants and animals currently found in the UGB. Strategies shall be based on federal, State, and local regulations relevant to the protection of the identified species, including, but not limited to, Federal or California Endangered Species Act, Santa Rosa Plain Conservation Strategy, and United States Fish and Wildlife Service Programmatic Biological Opinion, as subsequently revised, supplemented, or replaced.  *Action 3-5.10: The City shall Ccontinue to require the implementation of existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve prior to, during, and after project approval and construction for projects that may affect wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species to ensure their conservation. Existing regulations and procedures include, but are not limited to, Federal and California Endangered Species Act; CDFW 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities; Santa Rosa Plain Conservation Strategy; United States Fish and Wildlife (USFWS) Service Programmatic Biological Opinion; CDFW 2012 Staff Report on Burrowing Owl Mitigation; 2012 USFWS Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls; 2020 Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California; Fish and Game Code Section 1600 et seq; Clean Water Act; and Porter Cologne Water Quality Control Act, as subsequently revised, supplemented, or replaced.
 *Action 3-5.11: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support or have the potential to affect special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction. The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced.  *Action 3-5.12: The City shall Rrequire that construction or other ground-disturbing activities that may affect bird nests or nesting habitat avoid nests of native birds when the nest is in active use by implementing protection measures specified by a qualified ornithologist or biologist to ensure compliance with the California Fish and Game Code and federal Migratory Bird Treaty Act. Compliance guidelines are detailed in the General Plan Environmental Impact SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-15
Report. If demolition, construction, ground-disturbing, or tree removal/pruning activities occur during the nesting season (February 1 and August 31), preconstruction surveys shall be conducted by a qualified ornithologist or biologist and approved by the City prior to issuance of building permits. Preconstruction surveys are not required for construction, ground- disturbing, or tree removal/pruning activities outside the nesting season.  *Action 3-5.13: The City shall Ddevelop and adopt a bird-safe design ordinance in consultation with a qualified biologist and require projects to demonstrate compliance with the ordinance prior to project approval. The ordinance shall apply to all new development and redevelopment projects and include the latest bird-safe design guidelines and best management practice strategies, such as those from the National Audubon Society, to provide specific criteria and refined guidelines as part of design review and/or project approval process of new buildings and taller structures to protect birds from injury and mortality from collisions with buildings, towers, and other human-made structures. Preserve and restore wildlife habitats and corridors. Continue to provide some protection for habitat areas in the city, such as for the rookery on West 9th Street. Prior to adoption of the bird-safe design ordinance, project applicants shall show compliance with bird-safe design requirements, consistent with best practices.

The significance discussion for Impact Statement BIO-1 in Section 4.4.3, Impact Discussion, on pages 4.4- 43 and 4.4-44 of the Draft EIR is hereby amended as follows:

Impact BIO-1: Impacts to special-status species or the inadvertent loss of bird nests in active use, which would conflict with the federal Migratory Bird Treaty Act (MBTA) and California Fish and Game Code (CFGC), could occur as a result of implementation of the proposed project.

Significance with Mitigation: Less than significant. Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, of the proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider impacts to biological resources, including special-status species and active bird nests, on a project-by-project basis.

Proposed General Plan 2050 *Action 3-5.7 requires the City to continue to consult with CDFW to identify significant environments and develop a strategy for maintaining areas that will preserve special-status species; *Action 3-5.10 requires the City to continue to require the implementation of existing regulations to conserve habitat for special-status species; and *Action 3-5.11 requires the City to have biological resource assessments prepared that identify potential impacts and mitigation measures for protecting the resources for proposed development on sites that may support or have the potential to affect special-status species. In addition, proposed *Action 3-5.12 and *Action 3-5.13 require the protection of bird habitat, including the possible loss or disturbance to bird nests in active use, which conflicts with both the MBTA and CFGC. Pursuant to *Action 3-5.12, nesting bird protection measures for new development sites where nesting birds may be present, include but are not limited to, initiating vegetation clearing and construction outside the bird nesting season (February 1 through August 31) or conducting preconstruction surveys by a qualified ornithologists or biologists in advance of any disturbance. If active nests are encountered, appropriate buffer zones may be established based on recommendations by the qualified ornithologist or biologist and remain in place until any young birds have successfully left the nest. Monitoring by the qualified ornithologist SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-16 APRIL 2025
or biologist may also be required based on recommendations by the qualified ornithologist or biologist. Preconstruction surveys are not required for tree removal or construction activities outside the nesting period. Pursuant to *Action 3-5.13, bird-safe guidelines provide specific criteria to protect birds from injury and mortality from collisions with buildings, towers, and other human-made structures (see Impact Discussion BIO-3 for additional details on bird-safe guidelines for development projects). Implementation of the proposed General Plan 2050 goal, policies, and actions listed above, in conjunction with adherence to State and federal regulations related to the protection of special- status species, including the Santa Rosa Plain Conservation Strategy, as subsequently revised, supplemented, or replaced, where applicable, would address potential impacts of anticipated future development under the proposed project. Future development would continue to be reviewed through the City’s entitlement process and CEQA, when applicable, to ensure consistency with local, State, and federal regulations and all General Plan policies and actions intended to protect sensitive biological resources. Ultimately, potential future development in Santa Rosa over the buildout horizon of the proposed General Plan 2050 would be performed in accordance with the proposed General Plan 2050 goal, policies, and actions discussed above, which would ensure that potential impacts on special-status species would be less than significant.

The following policy and actions in the bulleted list of proposed goals, policies, and actions related to biological resources under Impact Discussion BIO-2 in Section 4.4.3, Impact Discussion, on pages 4.4-45 and 4.4.46 of the Draft EIR are hereby amended as follows:
 Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
 *Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for shared use paths and recreation multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan and concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced.
 *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.

The significance discussion for Impact Statement BIO-2 in Section 4.4.3, Impact Discussion, on page 4.4-46 of the Draft EIR is hereby amended as follows:

Impact BIO-2: Impacts to riparian areas, drainages, and sensitive natural communities could occur from potential future development under the proposed General Plan 2050 where natural habitat remains.

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-17
resources, including riparian areas, drainages, and sensitive natural communities, on a project-by- project basis. Proposed *Action 3-5.19 requires that new development along channelized waterways establish an ecological buffer zone between the waterway and development and *Action 3-5.20 requires new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the zZoning cCode as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals. Also, as described under impact discussion BIO-1, proposed *Action 3-5.7, *Action 3-5.10, and *Action 3-

5.11 require agency consultation, implementation of existing regulations, and preparation of technical reports that identify and mitigate project-specific impacts. Implementation of the proposed General Plan 2050 goals, policies, and actions listed above would serve to ensure that occurrences of sensitive natural communities are identified, avoided, or adequately mitigated. Future development would continue to be reviewed through the City’s entitlement process and CEQA to ensure consistency with local, State, and federal regulations and all General Plan policies and actions intended to protect sensitive biological resources, including sensitive natural communities. Potential future development over the buildout horizon of the proposed General Plan 2050 would be performed in accordance with the proposed General Plan 2050 policies and actions discussed above, which would ensure that potential impacts on sensitive natural communities would be less than significant.

The text under Impact Discussion BIO-6 in Section 4.4.3, Impact Discussion, on pages 4.4-50 and 4.4-51 of the Draft EIR is hereby amended as follows:

The EIR Study Area is not in any local, regional, or State HCP areas. Therefore, the proposed General Plan 2050 would not conflict with the conservation strategy in any HCP or Natural Community Conservation Plan. Furthermore, several goals, policies, and actions in the proposed General Plan 2050, listed under impact discussions BIO-1, BIO-2, and BIO-4 along with SRCC regulations, would serve to protect and enhance the sensitive natural communities and special-status species within the EIR Study Area.

Implementation of the proposed General Plan 2050 goals, policies, and actions, in conjunction with adherence to State and federal regulations related to the protection of special-status species and sensitive natural communities, including the SRPCS, as subsequently revised, supplemented, or replaced, where applicable, would address potential impacts of anticipated future development under the proposed Project. Future development would continue to be reviewed through the City’s entitlement process and CEQA to ensure consistency with local, State, and federal regulations and all General Plan policies and actions intended to protect sensitive biological resources. As part of the permitting project with the USACE, projects affecting federally regulated waters must demonstrate that they would not have an adverse effect on federally listed species or would be required to provide adequate compensatory mitigation where avoidance is infeasible. Projects within the boundaries of the SRPCS, including western and southern Santa Rosa, must comply with the rigorous conditions of the Biological Opinion issued by the USFWS in addressing potential effects on CTS, Burke’s goldfields, Sebastopol meadowfoam, and Sonoma sunshine. Therefore, no impact would occur .

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-18 APRIL 2025
CHAPTER 4.5, CULTURAL RESOURCES
The text under the “Ethnographic Setting” subheading in Section 4.5.1.3, Existing Conditions, on pages

4.5-7 and 4.5-8 of the Draft EIR is hereby amended as follows:

Linguists and ethnographers tracing the evolution of languages have found that most of the indigenous languages of the California region belong to one of five widespread North American language groups (the Hokan and Penutian phyla, and the Uto-Aztecan, Algic, and Athabaskan language families). The distribution and internal diversity of four of these groups suggest that their original centers of dispersal were outside, or peripheral to, the core territory of California, that is, the Central Valley, the Sierra Nevada, the Coast Range from Cape Mendocino to Point Conception, and the Southern California coast and islands. Only languages of the Hokan phylum can plausibly be traced back to populations inhabiting parts of this core region during the Archaic period, and there are hints of connections between certain branches of Hokan, such as that between Salinan and Seri, that suggest that at least some of the Hokan languages could have been brought into California by later immigrants, primarily from the Southwest and northwestern Mexico.4
At the time of Euroamerican settlement, people inhabiting this area spoke Southern Pomo, one of seven mutually unintelligible Pomoan languages belonging to the Hokan language stock. The Southern Pomo’s aboriginal territory falls within present-day Sonoma County. To the north, it reaches the divide between Rock Pile Creek and the Gualala River, and to the south it extends to near the town of Cotati. The eastern boundary primarily runs along the western flanks of Sonoma Mountain until it reaches Healdsburg, where it crosses to the west side of the Russian River . Within the larger area that constitutes the Southern Pomo homelands, some bands or tribelets occupied distinct areas.

The Bitagomtara were a triblet of the Southern Pomo and they occupied the lands south of Mark West C
reek, north of Cotati and the boundary of the Coast Miwok, east of the Laguna de Santa Rosa, and west of Sonoma Canyon.5, 6 Primary village sites of the Southern Pomo were occupied continually, while temporary sites were visited to procure resources that were especially abundant or available only during certain seasons. Sites often were situated near freshwater sources and in ecotones where plant life and animal life were diverse and abundant.

Primary village sites of the Southern Pomo were occupied continually, while temporary sites were visited to procure resources that were especially abundant or available only during certain seasons. Sites often were situated near freshwater sources and in ecotones where plant life and animal life were diverse and abundant. There are several ethnographic villages in the EIR Study Area.7 The Southern Pomo population was decimated early in the historic period, especially in the southern part of their territory. Ethnic identity was severely impacted in the region of Santa Rosa and Sebastopol; McLendon and Oswalt reported that the few Southern Pomo speakers remaining in 1976 were from north of Healdsburg.8 In 1992, the Southern Pomo and Coast Miwok established the Federated Indians of Graton Rancheria and were federally recognized in 2000. The Federated Indians of Graton Rancheria is a federally recognized tribe of Southern Pomo and Coast Miwok people, whose ancestral homelands include the City of Santa Rosa.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-19
Footnote 4: V. Golla, 2011, California Indian Languages, Berkeley and Los Angeles: University of California Press.

Footnote 5: R. Milliken, 1995, A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area, 1769- 1810, Menlo Park, CA: Ballena Press.

Footnote 6: O. Stewart, 1943, “Notes on Pomo Ethnogeography”, University of California Publications in American Archaeology and Ethnology 40, no. 2, pp.29–62.

Footnote 7: S. Barrett, 1908, The Ethno-Geography of the Pomo and Neighboring Indians, U niversity of California Publications in American Archaeology and Ethnology, vol. 6, no. 1, Berkeley, California: University of California Press.

Footnote 8: S. McLendon and R. Oswalt, 1978, “Pomo,” In California, edited by R. Heizer, pp. 274–288, H andbook of North American Indians, Vol. 8, W. Sturtevant, general editor, Washington, D.C.: Smithsonian Institution.

The text under the “Native American Resources” subheading in Section 4.5.1.3, Existing Conditions, on page 4.5-12 of the Draft EIR is hereby amended as follows:

Santa Rosa was a site of Native American habitation beginning approximately 7,000 years ago, and Santa Rosa contains approximately 190 recorded Native American resources.12 The Santa Rosa Basin, encompassing the EIR Study Area, contains six major drainages: Santa Rosa, Matanzas, Piner, Rincon, Austin, and Brush Creeks. These creeks may hold prehistoric resources because Native American archaeological sites tend to be near waterways as well as along ridge tops, mid-slope terraces, alluvial flats, the base of hills, and near vegetation ecotones. 13 Trione-Annadel State Park, in the southeast corner
of the EIR Study Area, was an important obsidian source for Native American tools. Resources may include chert or obsidian flakes, projectile points, mortars, pestles, dark friable soil containing shell and bone dietary debris, heat-affected rock, or human burials.

Footnote 12: Based on a 2001 2023 review of records and literature on file with the California Historical Resources Information System.

Footnote 13: Vegetation ecotones are transition areas between different plant communities.

The following actions in the bulleted list of proposed goals, policies, and actions related to cultural resources under Impact Discussion CUL-1 in Section 4.5.3, Impact Discussion, on pages 4.5-15 through

4.5-17 of the Draft EIR are hereby amended as follows:
 *Action 4-3.2: For projects with known or the potential to have historic structures, the City shall require the project to Ffollow the Secretary of the Interior Standards for Preservation, Rehabilitation, Restoration, and Reconstruction for the treatment of historic properties and the California Historic Building Code, as subsequently revised, supplemented, or replaced.  *Action 4-3.6: Identify and minimize or remove obstacles for owners of historic properties to support preservation, including guides for repurposing facilities.

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CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-20 APRIL 2025
 Install plaques and/or educational signage, in consultation with the Historical Society of Santa Rosa and tribes, at locations of cultural significance and significant events.  Implement recommendations in the City’s Cultural Heritage studies.  Partner with the local tourism industry, property owners, businesses, nonprofit organizations, and other public agencies to develop and promote Heritage Tourism opportunities, integrating efforts with ongoing initiatives for economic development and the creative economy.
 Work with local schools, and historic organizations, and local tribes to engage and interest residents of all ages in Santa Rosa's prehistory, history, and historic sites, structures, and neighborhoods, and tribal cultural resources.
 *Action 4-3.7: Identify buildings that should be recognized for cultural significance and/or considered for landmark designation.
 *Action 4-3.9: Preserve historic aspects of parks while integrating modern uses and amenities.
 Action 4-3.10: Ensure that non-confidential historic surveys are available on a dedicated City webpage, easily accessible and promoted online.

The significance discussion for Impact Statement CUL-1 in Section 4.5.3, Impact Discussion, on pages 4.5- 17 and 4.5-18 of the Draft EIR is hereby amended as follows:

Impact CUL-1: Impacts to known or yet to be classified historic buildings or structures could occur from potential future development under the proposed General Plan 2050.

Significance with Mitigation: Less than significant. Implementation of the Santa Rosa City Code (SRCC), Design Guidelines, and the proposed General Plan 2050 goals, policies, and actions, would ensure that new development and exterior remodels are compatible with cultural and historic resources; that landmarks and historic treasures would be preserved, enhanced, and rehabilitated, and that cultural and historic resources of Santa Rosa would be protected and restored. Specifically, proposed General Plan 2050 *Action 4-3.2 would mitigate potential impacts by requiring the City to require projects follow the Secretary of the Interior's Standards for Preservation, Rehabilitation, Restoration, and Reconstruction of historic structures in Santa Rosa and the California Historic Building Code, as subsequently revised, supplemented, or replaced, and *Action 4-3.6 would require the City to work with the owners of historic properties to promote preservation, renovation and rehabilitation of historic structures. Under proposed *Action 4-3.6, *Action 4-3.7, and *Action 4-3.9, the City would require cultural and/or historic inventories or surveys of the city and the identification of buildings and park properties that should be recognized for their cultural significance to further preserve qualifying historic properties in Santa Rosa. Accordingly, implementation of the proposed General Plan 2050 would require the preservation of historic resources and require new development to analyze and avoid any potential impacts to designated historic resources through record searches, preconstruction field surveys, ground-disturbance monitoring, and implementation of appropriate measures or project alternatives to avoid identified significant impacts. Finally, CEQA would require that future potential projects in the EIR Study Area with the potential to significantly impact historical resources be subject to project-level CEQA review wherein the future potential project’s potential to SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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affect the significance of a surrounding historical resource would be evaluated and mitigated to the extent feasible. The requirement for subsequent CEQA review, pursuant to State law, would minimize the potential for new development to indirectly affect the significance of existing historical resources to the maximum extent practicable.

Potential impacts from future development on historical resources could lead to (1) demolition, which by definition results in the material impairment of a resource’s ability to convey its significance; (2) inappropriate modification, which may use incompatible materials, designs, or construction techniques in a manner that alters character-defining features; and (3) inappropriate new construction, which could introduce incompatible new buildings that clash with an established architectural context. While any of these scenarios, especially demolition and alteration, have the potential to change the historic fabric or setting of an architectural resource such that the resource’s ability to convey its significance may be materially impaired, compliance with federal and State laws as described in Section 4.5.1.2, Regulatory Framework, SRCC, and the proposed General Plan 2050 goals, policies, and actions identified would ensure future development would not be detrimental or injurious to property or improvements in the vicinity and impacts would be less than significant.

The following text is hereby added to the first paragraph under Impact Discussion CUL-2 in Section 4.5.3, Impact Discussion, on page 4.5-18 of the Draft EIR:

Historical and pre-contact archaeological deposits that meet the definition of archaeological resources under CEQA could be damaged or destroyed by ground-disturbing activities associated with potential future development in Santa Rosa. A substantial adverse change in the significance of an archaeological resource would occur from its demolition, destruction, relocation, or alteration such that the significance of the resource would be materially impaired per CEQA Guidelines Section 15064.5(b)(1). Should this occur, the ability of the deposits to convey their significance, either through containing information important in prehistory or history, or through possessing traditional or cultural significance to Native American or other descendant communities, would be materially impaired. CEQA Guidelines Section 15064.5(c) sets forth the procedures to follow should an archaeological resource be discovered including first identifying if the resource is either a historical archeological resource or a unique archaeological resource. If the City determines that the archaeological site is an historical resource, the City shall refer to the provisions of CEQA Section 21084.1 and CEQA Guidelines Section 15126.4. If the City determines that the site meets the definition of a unique archaeological resource pursuant to CEQA Section 21083.2, the site shall be treated in accordance with the provisions of Section 21083.2. If an archaeological resource is neither a unique archaeological nor an historical resource, the effects of the project on those resources shall not be considered a significant effect on the environment.

The following text is hereby added after the third paragraph under Impact Discussion CUL-2 in Section

4.5.3, Impact Discussion, on page 4.5-18 of the Draft EIR:

The application of protocols and best management practices to achieve compliance with the National Historic Preservation Act, Native American Historic Resource Protection Act, National Environmental Policy Act, CEQA, and/or applicable Santa Rosa planning guidelines, policies, and procedures to protect the archaeological deposits, both tribal and nontribal include, but are not limited to:

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CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-22 APRIL 2025
 All developers in the study area shall include a standard inadvertent discovery clause in every construction contract to inform contractors of this requirement.  Prior to construction, the project applicant may retain the services of a qualified archaeological monitor and Native American monitor to provide Cultural Awareness Training for all supervisors, contractors, and equipment operators in order to familiarize them with the types of artifacts that could be encountered and the procedures to follow if subsurface cultural resources are unearthed during construction.
 Prior to construction, the project applicant may retain the services of a qualified archaeological monitor and Native American monitor to observe all project-related ground disturbing activities within limits of the ground-disturbing footprint of the proposed project.  During construction, if any prehistoric or historic subsurface cultural resources are discovered during ground-disturbing activities, all work within 50 feet of the resources shall be halted and a qualified archaeologist shall be consulted to assess the significance of the find according to CEQA Guidelines Section 15064.5 and determine whether the resource requires further study.  If any find is determined to be significant and a nontribal resource, representatives from the City and the qualified archaeologist shall meet to determine the appropriate and feasible avoidance, testing, preservation or other measures, in light of factors such as the significance of the find, proposed project design, costs, and other considerations.
 If any find is determined to be significant and a tribal resource, representatives from the City and the qualified archaeologist shall consult with the appropriate tribe to evaluate the significance of the resource and to recommend appropriate and feasible avoidance, testing, preservation or mitigation measures, in light of factors such as the significance of the find, proposed project design, costs, and other considerations.
 For any find determined to be significant, the qualified archaeologist shall prepare and implement a research design and archaeological data recovery plan that will capture those categories of data for which the site is significant. The report shall be submitted to the City of Santa Rosa, Northwest Information Center, and State Historic Preservation Office, as required.  Any previously undiscovered resources found during construction activities shall be recorded on appropriate California Department of Parks and Recreation (DPR) forms and evaluated for significance in terms of the CEQA criteria by a qualified archaeologist.

The last two sentences of the third paragraph under Impact Discussion CUL-2 in Section 4.5.3, Impact Discussion, on page 4.5-18 of the Draft EIR is hereby amended as follows:

The proposed General Plan 2050 Chapter 2, Land Use and Economic Development; Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction; and Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture, contains goals, policies, and actions that require local planning and development decisions to consider impacts to historical and/or unique archaeological resources. The following goals, policies, and actions would minimize impacts to historical and/or unique archaeological resources:

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-23
The following policies and actions in the bulleted list of proposed goals, policies, and actions related to cultural resources under Impact Discussion CUL-2 in Section 4.5.3, Impact Discussion, on pages 4.5-19 and

4.5-20 of the Draft EIR are hereby amended as follows:
 Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
 *Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for shared use paths and recreation multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan and concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced.
 *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.  Policy 4-2.1: Protect Native American tribal heritage, honor the early stewards of this land, and treat Native American remains and resources with sensitivity.  *Action 4-2.1: The City shall Ccontinue to review proposed developments in conjunction with accordance with federal and State laws and utilize the California Historical Resources Information System, Northwest Information Center, at Sonoma State University as a resource to determine whether project areas contain known subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources, or if they have the potential to hold such resources and if so, implement mitigation to protect the resource.  *Action 4-2.2: The City shall Wwork in good faith with interested communities local tribes and archaeologists to evaluate proposed development sites for the presence of subsurface historic, archaeological resources, both prehistoric and/or historic era, and tribal cultural resources. These efforts may include:
 Consideration of existing reports and studies.
 Consultation with Native American tribes as required by State law.  Appropriate site-specific investigative actions.
 On-site monitoring during excavation if appropriate.
 Work with local tribes to develop and apply tribal protection policies related to tribal cultural resources.
 *Action 4-2.3: The City shall Ccontinue to require that project areas found to contain significant subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources be examined by a qualified consulting archaeologist with recommendations for protection and preservation, developed in collaboration with local Native American tribes and appropriate tribal monitors, as necessary. Recommendations shall meet the standards of the National Historic Preservation Act, Native American Historic SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-24 APRIL 2025
Resource Protection Act, National and California Environmental Quality Act, and applicable Santa Rosa planning guidelines, policies, and procedures to protect the resource.  Policy 4-2.2: Collaborate with the most likely descendants, as identified by Contact the Native American Heritage Commission (NAHC) to identify tribes that are traditionally and culturally affiliated with the geographic area of the proposed project.  *Action 4-2.4: During ground disturbance for development projects, Iif tribal cultural resources are encountered during development, halt work shall be halted to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative (if appropriate) have evaluated the situation and recorded identified tribal cultural resources—which may include sites, features, places, cultural and other landscapes, sacred places, objects, animals, structures, landscapes, or plants with cultural value to the tribe(s)—and determined suitable mitigation measures. If human remains are inadvertently discovered, the County coroner shall be notified immediately. If the coroner determines that the remains are those of a Native American, the coroner must contact the NAHC by phone within 24 hours of making that determination (Health and Safety Code § 7050[c]). The City and the professional archaeologist shall contact the Most Likely Descendent, as determined by the NAHC, regarding the remains.

The significance discussion for Impact CUL-2 in Section 4.5.3, Impact Discussion, on pages 4.5-20 and 4.5- 21 of the Draft EIR is hereby amended as follows:

Impact CUL-2: Impacts to known and unknown archeological resources could occur from potential future development under the proposed General Plan 2050.

Significance with Mitigation: Less than significant. Implementation of the proposed General Plan 2050 goals, policies, and actions would ensure that new development in the EIR Study Area reduces and mitigates potential impacts to archaeological resources. As demonstrated, the proposed General Plan 2050 goals, policies, and actions encourage infill development, adaptive reuse of structures, and development on underutilized land, which would reduce the potential for disturbing archaeological deposits since ground-disturbing activities have already taken place in developed areas. Specifically, proposed Policy 2-2.2 encourages compact development in the Areas of Change. Proposed Policy 4-

1.1 requires the preservation and enhancement of the city’s natural waterways and landscapes, Policy 3-5.7 requires that construction adjacent to creek channels is sensitive to the natural environment, preserves topography and vegetation along the creek, does not disrupt or pollute the waterway, and provides an adequate setback buffer, and *Action 3-5.19 and *Action 3-5.20 require new development along channelized waterways to establish an ecological buffer zone between the waterway and development. Additionally, implementation of the proposed *Action 4-2.1 and *Action 4-2.2 would require the preservation of archaeological and historic resources that are found in the EIR Study Area and would require new development to implement protocols and best management practices that analyze and avoid any potential impacts to subsurface archaeological resources through record searches, preconstruction field surveys, ground-disturbance monitoring, and implementation of appropriate measures or project alternatives to avoid identified significant impacts.

Implementation of these protocols and best management practices would ensure compliance with National Historic Preservation Act, Native American Historic Resource Protection Act, National SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-25
Environmental Policy Act, CEQA, and/or applicable Santa Rosa planning guidelines, policies, and procedures to protect the archaeological deposits, both tribal and nontribal. Proposed *Action 4-2.3 requires the City to continue to require that project areas found to contain significant subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources be examined by a qualified consulting archaeologist with recommendations for protection and preservation developed in collaboration with Native American tribes and appropriate tribal monitors and *Action 4-2.4 requires the evaluation and mitigation of tribal cultural resources by a qualified consulting archaeologist and Native American representative as appropriate. The pProposed General Plan 2050 *Action 4-2.2 also requires development project applicants to consult with Native American representatives regarding cultural resources to identify locations of importance to Native Americans, including archaeological sites and traditional cultural properties. Compliance with federal and State laws, as described in Section 4.5.1.2, Regulatory Framework, and the proposed General Plan 2050 goals, policies, and actions listed previously, would protect recorded and unrecorded archaeological deposits in the EIR Study Area by providing for the early detection of potential conflicts between development and resource protection, and by preventing or minimizing the material impairment of the ability of archaeological deposits to convey their significance through excavation or preservation would ensure that potential impacts from implementation of the proposed project would be less than significant.

CHAPTER 4.6, ENERGY
The following policy under the first goal in the bulleted list of proposed goals, policies, and actions related to energy under the “Building Electricity” subheading of Impact Discussion ENE-1 in Section 4.6.3, Impact Discussion, on page 4.6-19 of the Draft EIR is hereby amended as follows:
 Policy 3-5.3: Increase the use of renewable, carbon free, and distributed energy resources throughout the city. Policy 3-7.2: Reduce energy use and increase energy efficiency in existing and new residential, commercial, industrial, and public structures.

The following policy under the first goal in the bulleted list of proposed goals, policies, and actions related to energy under the “Building Natural Gas” subheading of Impact Discussion ENE-1 in Section 4.6.3, Impact Discussion, on page 4.6-22 of the Draft EIR is here by amended as follows:
 Policy 3-5.3: Increase the use of renewable, carbon free, and distributed energy resources throughout the city. Policy 3-7.2: Reduce energy use and increase energy efficiency in existing and new residential, commercial, industrial, and public structures.

CHAPTER 4.7, GEOLOGY AND SOILS
Figure 4.7-1, Regional Faults, on page 4.7-8 of the Draft EIR is hereby revised as shown on the following page.

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REVISIONS TO THE DRAFT EIR
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The following policy and actions in the bulleted list of proposed goals, policies, and actions related to geology and soils under the “Summary” subheading of Impact Discussion GEO-1 in Section 4.7.3, Impact Discussion, on page 4.7-18 of the Draft EIR are hereby amended as follows:
 *Policy 5-1.1: Prior to new development approval, where there are known geological hazards as shown on Figures 5-2, 5-3, and 5-4 and current maps from the United States Geological Survey, California Geological Survey, California Department of Water Resources, California Office of Emergency Services, the City shall ensure that Nnew development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards through the preparation of a site-specific geologic study prepared by a California Certified Engineering Geologist and/or Geotechnical Engineer and compliance with identified measures.  *Action 5-1.1: Prior to new development approval, the City shall ensure site-specific geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable to appropriately mitigate hazardous conditions.  *Action 5-1.2: The City shall Rrestrict development in areas where adverse impacts conditions associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a California Certified Engineering Geologist and/or Geotechnical Engineer .

The significance discussion for Impact GEO-1 in Section 4.7.3, Impact Discussion, on page 4.7-19 of the Draft EIR is hereby amended as follows:

Impact GEO-1: Impacts from potential future development under the proposed General Plan 2050 where there are known geological hazards could occur over the buildout horizon of the proposed project.

Significance with Mitigation: Less than significant. Implementation of the proposed General Plan 2050 goals, policies, and actions, as well as compliance with State, regional, and local regulations pertaining to structural safety regarding fault rupture, ground shaking, liquefaction, and landslides, would ensure that potential future development under the proposed project would not directly or indirectly cause or worsen the likelihood of or substantial adverse effects from seismic hazards related to earthquakes, including the risk of loss, injury, or death. Specifically, proposed General Plan 2050 *Policy 5-1.1 requires that potential future development avoid or mitigate seismic hazards through the preparation of a site-specific geologic study prepared by a California Certified Engineering Geologist and/or Geotechnical Engineer and compliance with identified measures; *Action 5-1.1 requires potential future development to prepare site-specific geologic studies are prepared deemed acceptable by qualified engineers; and *Action 5-1.2 requires that potential future development be restricted in areas where adverse impacts conditions associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a qualified engineer . This includes prohibiting development that would be subject to geological hazard due to its location and/or design and that cannot be mitigated to safe levels. Compliance with the Santa Rosa City Code (SRCC) regulations and proposed General Plan 2050 goals, policies, and actions would mitigate impacts by permitting development only in areas where potential danger to the health, safety, and welfare of the community can be adequately mitigated. Because potential future development under the proposed project would be required to comply with both the California Building Code and the SRCC as well as SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-28 APRIL 2025
proposed General Plan 2050 goals, policies, and actions, implementation of the proposed project would not cause or worsen seismic ground shaking; therefore, impacts would be less than significant.

CHAPTER 4.9, HAZARDS AND HAZARDOUS MATERIALS
The following text is hereby added after the paragraph under the “Hazard Mitigation Plan” subheading in Section 4.9.1.1, Regulatory Framework, on page 4.9-9 of the Draft EIR:

Pursuant to California Government Code Section 65302.15 requirements, the City of Santa Rosa is collaborating with Sonoma County on the 2026 MJHMP to assess and enhance evacuation capabilities.

This plan will evaluate current strategies, identify infrastructure improvements, and integrate best practices for various evacuation scenarios, including wildfires, earthquakes, and floods. As part of the City’s annex to the MJHMP , Santa Rosa will conduct a detailed evacuation analysis. This study will evaluate current evacuation strategies, identify potential improvements, and integrate best practices to ensure the safety and well-being of the community during emergencies.

The following action in the bulleted list of proposed goals, policies, and actions related to hazards and hazardous materials under Impact Discussion HAZ-4 in Section 4.9.3, Impact Discussion, on page 4.9-22 of the Draft EIR is hereby amended as follows:
 Action 5-4.6: Work with landowners and support funding identification and cleanup of identified brownfield sites, particularly prioritizing sites in Equity Priority Areas.

The following policy and actions in the bulleted list of proposed goals, policies, and actions related to hazards and hazardous materials under Impact Discussion HAZ-6 in Section 4.9.3, Impact Discussion, on pages 4.9-24 and 4.9-25 of the Draft EIR are hereby amended as follows:
 Policy 5-5.2: Ensure all community members and businesses are informed and empowered to address hazard vulnerabilities, including especially Equity Priority Populations.  *Action 5-5.14: The City shall Rrequire all new development projects to provide adequate access for fire and emergency response personnel.
 *Action 5-5.15: The City shall Pprohibit the creation of new single ingress/egress roadway conditions in the city.
 *Action 5-5.16: The City shall Rretrofit existing single-access residential neighborhoods to include additional access routes or other provisions to increase evacuation safety.  *Action 5-5.17: The City shall Aanalyze the capacity, viability, and safety of evacuation routes for hazard areas in the city (e.g., WUIFA) and evacuation locations throughout the city under a range of emergency scenarios and incorporate the results, as necessary, into the City’s Emergency Operations Plan Safety Element of the General Plan. This analysis will be completed as part of the City’s Annex to the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan in 2026.

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REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-29
The following text is hereby added after the bulleted list of proposed goals, policies, and actions related to hazardous materials under Impact Discussion HAZ-6 in Section 4.918.3, Impact Discussion, on page 4.9-25 of the Draft EIR:

Additionally, The City has established designated evacuation zones to facilitate organized and efficient evacuations during large-scale emergencies. Residents can identify their specific zones using the interactive Evacuation Zone Look-Up Tool, enabling them to respond promptly to evacuation orders.

Santa Rosa evacuation zones are coordinated with the Sonoma County system, ensuring consistency across the region. Residents can cross-reference their zones using the Sonoma County Evacuation Map, which provides interactive features to look up evacuation status and road closures (Sonoma County Evacuation Zone Map), and the City has developed enhanced evacuation zone and road closure maps.

During active wildfires, the City coordinates and communicates directly with the Sonoma County Department of Emergency Management, ensuring effective and efficient evacuation throughout the county and city.

The City is collaborating with Sonoma County on the 2026 MJHMP to assess and enhance evacuation capabilities. This plan will evaluate current strategies, identify infrastructure improvements, and integrate best practices for various evacuation scenarios, including wildfires, earthquakes, and floods. As part of the City’s annex to the MJHMP , Santa Rosa will conduct a detailed evacuation analysis. This study will evaluate current evacuation strategies, identify potential improvements, and integrate best practices to ensure the safety and well-being of the community during emergencies.

CHAPTER 4.10, HYDROLOGY AND WATER QUALITY
The following policy and actions in the bulleted list of proposed goals, policies, and actions related to hydrology and water quality under the “Summary” subheading of Impact Discussion HYD-1 in Section

4.10.3, Impact Discussion, on pages 4.10-30 through 4.10-33 of the Draft EIR are hereby amended as follows:
 Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
 *Action 3-5.10: The City shall Ccontinue to require the implementation of existing regulations and procedures, including subdivision guidelines, zoning, design review, and environmental law, to conserve prior to, during, and after project approval and construction for projects that may affect wetlands and rare plants, riparian habitat and other sensitive natural communities, and essential habitat for special-status species to ensure their conservation. Existing regulations and procedures include, but are not limited to, Federal and California Endangered Species Act; CDFW 2018 Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Sensitive Natural Communities; Santa Rosa Plain Conservation Strategy; United States Fish and Wildlife (USFWS) Service Programmatic Biological Opinion; CDFW 2012 Staff Report on Burrowing Owl Mitigation; 2012 USFWS Protocol for Surveying Proposed Management Activities That May Impact Northern Spotted Owls; 2020 Estimating the Effects of Auditory and Visual Disturbance to Northern Spotted Owls and Marbled Murrelets in Northwestern California; Fish and Game Code Section 1600 et seq; Clean Water SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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REVISIONS TO THE DRAFT EIR
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Act; and Porter Cologne Water Quality Control Act, as subsequently revised, supplemented, or replaced.
 *Action 3-5.11: The City shall Rrequire a qualified biologist to prepare a biological resource assessment (BRA) as part of project approval for proposed development on sites that may support or have the potential to affect special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters to identify potential impacts and measures for protecting the resource and surrounding habitat prior to, during, and after project construction. The BRA shall be prepared to address conformance with all applicable federal, State, and local regulations and protocols, including, but not limited to, those listed in Action 3-5.10, as subsequently revised, supplemented, or replaced.  *Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for shared use paths and recreation multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan and concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced.
 *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.  Action 5-2.13: Identify and collect development impact fees needed to pay for mitigation of stormwater management impacts for of new development.
 *Action 5-2.14: The City shall Rrequire improvements that maintain and improve the storm drainage system citywide and prioritize areas needing significant investment, consistent with the Santa Rosa Citywide Creek Master Plan goals of preserving natural conditions of waterways and minimizing channelization of creeks.
 *Action 5-2.15: The City shall Eensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Active Transportation Bicycle and Pedestrian Master Plan, as subsequently revised, supplemented, or replaced, and are incorporated into stormwater improvement projects along creek corridors.
 *Action 5-2.17: The City shall Rrequire implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system.
 *Action 5-9.30: The City shall Eevaluate stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 National Pollutant Discharge Elimination System (NPDES) permit to preserve natural conditions of waterways, minimize channelization of creeks, and protect water quality, and identify, educate, and label to promote community awareness that storm drains flow untreated into creeks.

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CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-31
The significance discussion for Impact HYD-1 in Section 4.10.3, Impact Discussion, on page 4.10-34 of the Draft EIR is hereby amended as follows:

Impact HYD-1: Impacts to water quality could occur from implementation of the proposed project.

Significance with Mitigation: Less than significant. Implementation of the proposed General Plan 2050 goals, policies, and actions listed above would reduce impacts related to water quality. Specifically, proposed *Action 3-5.10 and *Action 3-5.11 require the evaluation and mitigation of impacts to sensitive habitats, which includes wetlands and waterways, and would ensure impacts to water quality would be mitigated. Proposed *Action 3-5.19 and *Action 3-5.20 require that new development along channelized waterways establish an ecological buffer zone between the waterway and development and that adequate setbacks be maintained to protect water quality. Proposed *Action 5-2.14 and *Action 5-2.15 require improvements that maintain and improve the storm drainage system citywide and that ensure creekside paths and trails are developed consistent with the Citywide Creek Master Plan, which ensures runoff is captured and water quality is protected.

Proposed *Action 5-2.17 requires the City to require implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system. Lastly, proposed *Action 5-9.30, requires the the City to evaluateion of stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 NPDES permit. Implementation of the proposed General Plan 2050 goals, policies, and actions, in conjunction with adherence to MS4 permit requirements, the CGP , and the City’s Low Impact Development Technical Design Manual, would ensure that potential future development under the proposed project would not violate any water quality standards or waste discharge requirements for both construction and operational phases, and impacts would be less than significant.

The following action in the bulleted list of proposed goals, policies, and actions related to hydrology and water quality under the “Summary” subheading of Impact Discussion HYD-2 in Section 4.10.3, Impact Discussion, on page 4.10-36 of the Draft EIR is hereby amended as follows:
 Action 5-9.11: Continue working with the Santa Rosa Plain Cooperate with the State and Groundwater Sustainability Agencyies to in implementing the Sustainable Groundwater Sustainability Plan and Management Act, achieveing the sustainability goal for the Subbasin, and seeking any available State or federal assistance to support of local groundwater resources management programs.

CHAPTER 4.11, LAND USE AND PLANNING
The text under Impact Discussion LU-1 in Section 4.11.3, Impact Discussion, on page 4.11-3 of the Draft EIR is hereby amended as follows:

For the purposes of this EIR, an established community is considered a place where there are existing permanent infrastructure (roadways, utilities, etc.), structures (buildings, parks, homes, etc.), and populations. The physical division of an established community typically refers to the construction of a physical feature or the removal of a means of access (such as a local road or bridge) that would impair SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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REVISIONS TO THE DRAFT EIR
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mobility within an existing community or between a community and outlying areas. For example, an airport, roadway, or railroad track through an existing community could constrain travel from one side of the community to another or impair travel to areas outside of the community.

The following actions in the bulleted list of proposed goals, policies, and actions related to land use and planning under the “Sonoma Local Agency Formation Commission” subheading of Impact Discussion LU-2 in Section 4.11.3, Impact Discussion, on pages 4.11-4 and 4.11-5 of the Draft EIR are hereby amended as follows:
 Action 2-1.6: Require a Rely upon appropriate fiscal impact and marketing analysis for proposed annexations when determined necessary by staff to ensure a full accounting of infrastructure and public service costs and confirm whether revenue enhancement mechanisms are necessary to ensure net fiscal balance.
 Action 2-1.9: Continue to meet with County of Sonoma staff to coordinate land use and economic development issues of mutual concern in the Urban Growth Boundary.

The following actions in the bulleted list of proposed goals, policies, and actions related to land use and planning under the “Plan Bay Area” subheading of Impact Discussion LU-2 in Section 4.11.3, Impact Discussion, on pages 4.11-6 and 4.11-7 of the Draft EIR are hereby amended as follows:
 Action 2-1.10: Consider Pursue updating the Zoning Code to allow for compatible residential and commercial uses in office parks, light industrial areas, and other similar areas.

Such compatible uses could include, but are not limited to, live-work units, artisan studios/shops, galleries, brew pubs, coffee shops, tasting rooms, sports and entertainment venues, and event spaces.

 Action 2-2.1: Work with landowners and developers to encourage development that will increase access to goods and services that support daily life, such as access to fresh produce, recreation and sporting opportunities, community gathering places, active transportation infrastructure, and transit, especially in Equity Priority Areas and Areas of Change.  Action 2-2.5: Explore ways to encourage development in Areas of Change and Equity Priority Areas that include services within one-half mile walking and biking distance of residential neighborhoods
 Action 2-3.1: Update the Zoning Code to permit residential and mixed-use development by right in some nonresidential zoning districts, as mandated by State law.  Action 2-3.2: Identify Work to reduce barriers and/or create incentives to for mixed-use redevelopment in areas that are currently lacking components of a complete neighborhood and mitigate/implement these.

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CHAPTER 4.12, NOISE
The following actions in the bulleted list of proposed goals, policies, and actions related to noise under the “Construction” subheading of Impact Discussion NOI-1 in Section 4.12.3, Impact Discussion, on pages

4.12-35 and 4.12-36 of the Draft EIR are hereby amended as follows:
 *Action 5-7.1: The City shall Ccontinue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.  *Action 5-7.2: The City shall Uuse the Federal Transit Administration’s construction noise and vibration thresholds as applicable to assess impacts to surrounding land uses and identify mitigation measures during the project approval process to ensure the threshold is met prior to project approval.
 *Action 5-7.10: The City shall Uupdate the Noise Ordinance to incorporate construction best management practices (BMP) to minimize construction noise, and require projects to demonstrate compliance with the BMPs prior to project approval.

The following actions in the bulleted list of proposed goals, policies, and actions related to noise under the “Vehicular Noise” subheading of Impact Discussion NOI-1 in Section 4.12.3, Impact Discussion, on pages 4.12-45 through 4.12-48 of the Draft EIR are hereby amended as follows:
 *Action 5-7.3: The City shall Rrequire conditions of approval or mitigation development projects to reduce noise exceeding normally acceptable levels as identified in Figure 5-13, unless the activities are specifically exempted by the City Council, on the basis of community health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens.  *Action 5-7.7: The City shall Wwork with Caltrans to evaluate and develop traffic noise mitigation programs along Highway 101 and State Route 12.  *Action 5-7.9: Use conditions of approval to achieve The City shall require development projects to implement measures to reduce noise and vibration impacts primarily through site planning, and avoid engineering solutions for noise and vibration mitigation, such as sound walls, if possible.

The significance discussion for Impact NOI-1b in Section 4.12.3, Impact Discussion, on page 4.12-48 of the Draft EIR is hereby amended as follows:

Impact NOI-1b: Operational vehicle traffic noise increases could exceed the City’s significance thresholds with implementation of the proposed project.

Significance with Mitigation: Significant and unavoidable. Implementation of proposed General Plan 2050 *Action 5-7.1 requires the City to continue to require the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate noise impacts. Proposed *Action 5-7.2 requires the City to apply the Federal Transit Administration’s vibration thresholds to assess impacts to surrounding land uses. Proposed *Action 5-7.3 requires conditions of approval or mitigation the City to require development projects to reduce noise exceeding normally acceptable levels unless the activities are specifically exempted by the City Council on the basis of community SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens. Proposed *Action 5-7.7 requires the City to work with Caltrans to evaluate and develop traffic noise mitigation programs along US Highway 101 and State Route 12. Furthermore, proposed *Action 5-7.9 requires conditions of approval to achieve the City to require development projects to implement measures to reduce noise impacts primarily through site planning and avoid engineering solutions for noise mitigation, such as sound walls, if possible. Since project-specific details are unknown and future conditions of approval may not be feasible or reduce vehicle traffic noise below significance thresholds in all cases, this impact is conservatively considered significant and unavoidable. The identification of this program-level impact does not preclude the finding of less-than-significant impacts for subsequent projects analyzed at the project level that do not exceed the noise thresholds.

The text under the “Stationary Source Noise” subheading in Section 4.12.3, Impact Discussion, on page

4.12-49 of the Draft EIR is hereby amended as follows:

Stationary sources of noise may occur on all types of land uses. Residential uses generate noise from landscaping, maintenance activities, and air conditioning systems. Commercial uses generate noise from HVAC systems, loading docks, and other sources. Industrial uses may generate noise from HVAC systems, loading docks, and possibly machinery. Noise generated by residential or commercial uses is generally short and intermittent. Industrial uses may generate noise on a more continual basis. Nightclubs, outdoor dining areas, gas stations, car washes, fire stations, drive-throughs, swimming pool pumps, school playgrounds, athletic and music events, and public parks are other common noise sources. The proposed General Plan 2050 includes proposed Action 5-8.2 that addresses impacts from stationary sources and requires the City to consider updates to the Noise Ordinance to identify noise mitigation measures and other strategies to allow support the establishment, growth, and/or continuation of music, sports, and entertainment venues. Proposed Action 5-8.2 also encourages and allows these uses with appropriate noise thresholds. Some operational noise sources used for emergency purposes shall be exempt from City noise limits. Such activities would include emergency vehicle sirens, emergency medical helicopter operations, operation of emergency generators during emergency power outages, etc. Stationary noise sources are controlled by SRCC Chapter 17-16, which would ensure that potential future projects would not exceed the City’s established thresholds (see Table 4.12-5). Accordingly, impacts would be less than significant.

The significance discussion for Impact NOI-1c in Section 4.12.3, Impact Discussion, on page 4.12-50 of the Draft EIR is hereby amended as follows:

Impact NOI-1c: Operational noise increases could exceed the City’s significance thresholds and could be incompatible with existing uses.

Significance with Mitigation: Less than Significant. Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of the proposed General Plan 2050, requires local planning and development decisions to consider noise and land use compatibility. Specifically, proposed Policy 5-

7.1 requires the City to maintain and enforce the City’s Noise Ordinance to protect the health and comfort of people living, working, going to school, and recreating in Santa Rosa. Proposed *Action 5-

7.1 directs the City to continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Santa Rosa City Code standards. Proposed *Action 5-7.3 requires SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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conditions of approval or mitigation the City to require development projects to reduce noise exceeding normally acceptable levels unless the activities are specifically exempted by the City Council on the basis of community health, safety, and welfare, such as emergency medical vehicles, helicopters, and sirens. Proposed Action 5-7.5 requires the City to consider ways to reduce roadway noise to normally acceptable levels in areas where noise standards may otherwise be exceeded (e.g., where homes front regional/arterial streets and in areas of mixed-use development). Proposed Action 5-7.6 requires the City to consider updating the Municipal Code to require new development to provide buffers other than sound walls and allow sound walls only when other techniques would not prevent projected noise levels from exceeding adopted land use compatibility standards. Proposed *Action 5-7.9 requires the City to use conditions of approval to achieve require development projects to implement measures to reduce noise impacts primarily through site planning and avoid engineering solutions for noise mitigation, such as sound walls, if possible. Accordingly, implementation of the proposed policies and actions of the General Plan 2050, noise and land use compatibility would be a factor in project approval decisions, to verify that the proposed development would not increase noise beyond the City’s established thresholds and that it would not generate noise that would be incompatible with existing uses in the vicinity of the proposed development.

Accordingly, impacts associated with land use compatibility would be less than significant.

The significance discussion for Impact NOI-2a in Section 4.12.3, Impact Discussion, on page 4.12-52 of the Draft EIR is hereby amended as follows:

Impact NOI-2a: Construction activities associated with potential future development under the proposed General Plan 2050 could generate excessive short-term vibration levels during project construction.

Significance with Mitigation: Less than significant. As described under impact discussion NOI-1, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, of the proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider noise impacts, including those from vibration. Specifically, proposed *Action 5-7.1 requires the City to continue to require the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate noise impacts. Proposed *Action 5-7.2 requires the City to use the Federal Transit Administration’s (FTA) construction and noise vibration thresholds to assess impacts to surrounding land uses. Proposed *Action 5-7.10 requires the City to adopt construction best management practices (BMP) to reduce vibration caused from construction equipment and require projects to demonstrate compliance with BMPs. In most cases of individual developments associated with implementation of the proposed project, construction that requires the use of vibration-causing construction equipment, such as pile driving, caisson drilling, vibratory roller, or a large bulldozer, would temporarily increase the ambient noise environment in the vicinity of the individual project, potentially affecting existing and future nearby sensitive users. The use of alternate methods/equipment for construction required in proposed *Action 5-7.10 throughout the entire active construction period would help to ensure that construction noise from vibration is minimized to the extent feasible. Some common alternate methods/equipment used for construction include, but are not limited to:

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 For pile driving, the use of caisson drilling (drill piles), vibratory pile drivers, oscillating or rotating pile installation methods, pile pressing, “silent” piling, and jetting or partial jetting of piles into place using a water injection at the tip of the pile.
 For paving, use of a static roller in lieu of a vibratory roller .  For grading and earthwork activities, off-road equipment limited to 100 horsepower or less.

Proposed *Action 5- 7.1 requires the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate impacts and proposed *Action 5-7.2 requires the City to use vibration thresholds based on the FTA criteria for acceptable levels of groundborne vibration for various types of construction equipment. Should the FTA criteria be exceeded, a list of alternate methods/equipment can be used, as provided above. This would ensure that construction vibration impacts would remain less than significant because alternate methods/equipment with less or no vibration, such as those shown in Table 4.12-14, Reference Vibration Source Levels for Construction Equipment, would meet the thresholds. The potential vibration impacts associated with demolition and construction activities would be reduced to a less-than-significant level by establishing safe limits to protect structures from potential damage and would minimize vibration impacts.

The significance discussion for Impact NOI-2b in Section 4.12.3, Impact Discussion, on page 4.12-53 of the Draft EIR is hereby amended as follows:

Impact NOI-2b: Operational activities associated with potential future development under the proposed General Plan 2050 could generate excessive long-term vibration levels.

Significance with Mitigation: Less than significant. Implementation of proposed General Plan 2050 *Action 5-7.1 requires the preparation of acoustical studies prepared by qualified acoustical consultants to evaluate and mitigate impacts and *Action 5-7.2 requires the City to use vibration thresholds based on the Federal Transit Administration’s (FTA’s) groundborne vibration for various types of construction equipment. As described in Section 4.12.2.2, Federal Transit Administration Vibration Limits, the FTA establishes vibration limits from operational activities for impacts to be less than significant on a project-by-project basis. For vibration annoyance from operational sources, the FTA recommends criteria for frequent, occasional, and infrequent events. Furthermore, proposed *Action 5-7.9 requires conditions of approval to achieve the City to require development projects to implement measures to reduce noise impacts primarily through site planning, and avoid engineering solutions for noise mitigation, such as sound walls, if possible. As part of the project approval process, future project applicants would be required to comply with the FTA thresholds and the City would review all development proposals to verify that the proposed development would not significantly increase noise beyond the City’s established thresholds. Therefore, with implementation of the proposed General Plan 2050 *Action 5-7.1, *Action 5-7.2, and *Action 5-7.9, vibration impacts from operation are considered less than significant.

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The first section under the “Regulatory Framework” subheading in Section 4.14.2.1, Environmental Setting, on page 4.14-13 of the Draft EIR is hereby amended as follows:

State Regulations
The Mello-Roos Communities Facilities Act of 1982
The Mello-Roos Community Facilities Act, Government Code Section 53311 et seq., provides an alternative method of financing certain public capital facilities and services through special taxes. This State law empowers local agencies to establish CFDs to levy special taxes for facilities such as police service facilities.

The third bullet under the “Santa Rosa City Code” subheading in Section 4.14.2.1, Environmental Setting, on page 4.14-13 of the Draft EIR is hereby amended as follows:
 Chapter 21-04, Capital Facilities Fees. This chapter creates a CFF, which is used to alleviate the cost of certain public infrastructure facilities required to serve new development in the City of Santa Rosa.

Out of the five account areas, public safety will have 12.8 percent of the revenue from each CFF.

The text under the “Facilities” subheading in Section 4.14.2.1, Environmental Setting, on page 4.14-14 of the Draft EIR is hereby amended as follows:

There is one main SRPD police station, which is at 965 Sonoma Avenue, directly adjacent to SRFD Station 1 and east of Downtown Santa Rosa. Together, this complex is commonly referred to as the Public Safety Building. SRPD has a fleet of 150 vehicles. SRPD reports that the Public Safety Building is aging and in need of extensive repairs and required updates, and it no longer meets SRPD’s needs. Based on current conditions and anticipated growth, SRPD has stated its needs for a larger facility with an on-site training center in the next 10 years and two additional substations, one in east Santa Rosa and one in the Roseland neighborhood to replace a temporary substation, to reach SRPD’s goal to provide better coverage of the entire city. SRPD has planned for the addition of a Sebastopol Road substation and a Roseland substation and has desires to establish a new substation in East Santa Rosa as well.

The last paragraph under Impact Discussion PS-3 in Section 4.14.2.3, Impact Discussion, on page 4.14-17 of the Draft EIR is hereby amended as follows:

Similar to impact discussion PS-1, while the proposed project would increase demand on police protection services, growth would most likely occur incrementally over the lifetime of the project, and it would be unlikely that the magnitude of increased demands as a result of the full buildout potential of the proposed project would be placed on facilities within the immediate timeframe or all at once. Payment of capital facilities fees, cConsistency with the proposed General Plan goals, policies, and actions discussed above, and compliance with the regulations described under Section 4.14.2.1, Environmental Setting, would ensure that the SRPD is involved as potential future development occurs in the EIR Study Area.

Furthermore, future construction of new police stations would be subject to separate project-level environmental review pursuant to CEQA, as required, to identify potential environmental impacts and mitigation measures as needed and would also be subject to the mitigation measures contained SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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throughout this EIR to reduce potential environmental impacts. Therefore, impacts on police service facilities would be less than significant.

The third paragraph under the “Existing Conditions” subheading in Section 4.14.3.1, Environmental Setting, on page 4.14-20 of the Draft EIR is hereby amended as follows:

Table 4.14-1, Santa Rosa School District’s Student Enrollment and School Capacity of School Districts in the EIR Study Area, gives an overview of all the school districts in the EIR Study Area and their enrollment and capacity numbers. Overall, school districts in the area are operating below capacity.

Table 4.14-1, Santa Rosa School District’s Student Enrollment and School Capacity, on page 4.14-20 of the Draft EIR is hereby renamed to Student Enrollment and School Capacity of School Districts in the EIR Study Area, as shown:

TABLE 4.14-1 SANTA ROSA SCHOOL DISTRICT’S STUDENT ENROLLMENT AND SCHOOL CAPACITY OF SCHOOL

DISTRICTS IN THE EIR STUDY AREA
School Districts Student Enrollment School Capacity
Student Enrollment
of School Capacity
Bellevue Union School District 1,612 1,875 86%
Bennett Valley School District 1,015 1,040 98%
Kenwood School District 137 160 86%
Piner-Olivet School District 1,265 2,230 57%
Rincon Valley Unified School District 3,075 3,654 84%
Roseland School District 2,915 3,700 79%
Santa Rosa City School District 15,570 18,061 85%
Wright Elementary School District 1,481 2,400 62%
Private Schools 2,155 --- ----
Total Students 27,070 a 33,120 a 62% a
Note:
a. Private schools were not counted in the total due to limited information about student capacity.

The first section under the “State Regulations” subheading in Section 4.14.4.1, Environmental Setting, on page 4.14-37 of the Draft EIR is hereby amended as follows:

Mello-Roos Community Facilities Act of 1982
The Mello-Roos Community Facilities Act, Government Code Section 53311 et seq., provides an alternative method of financing certain public capital facilities and services through special taxes. This State law empowers local agencies to establish CFDs to levy special taxes for facilities such as libraries.

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The first paragraph under the “Sonoma County Library” subheading in Section 4.14.4.1, Environmental Setting, on page 4.14-38 of the Draft EIR is hereby amended as follows:

The Sonoma County Library (SCL) consists of the Central Library, which includes 10 branches, 2 rural stations, and 1 temporary site to serve the population of Sonoma County. It also encompasses three special collections: the Sonoma County Wine Library, the History and Genealogy Annex, and the Petaluma History Room. Of these locations, four are in the EIR Study Area: Central Library, Northwest Santa Rosa Library, Rincon Valley Library, and Roseland Community Library. In 2015, SCL served almost two million visitors; circulated more than 3.5 million books, audiobooks, DVDs, and electronic resources; and answered over 250,000 reference questions. The City of Santa Rosa and SCL are currently in the process of developing the Hearn Community Hub, a project that includes a new library on a 6-acre site in southwest Santa Rosa.

The “Measure O” subheading in Section 4.14.5.1, Environmental Setting, on page 4.14-44 of the Draft EIR is hereby renamed to “Measure H (previously Measure O)” and the associated text is hereby amended as follows:

Measure H (previously Measure O)
Measure O, approved by Santa Rosa voters in 2004, imposed a special transaction and use tax to generate revenue for police, fire, and gang prevention and intervention. Measure O funds are presided over by a Citizens Oversight Committee. A portion of these funds are used for year-round special recreational programming that supports the mission of the gang prevention and intervention program. Measure O was renewed in 2022 for an additional 20 years, and is now referred to as Measure H.

The following action in the bulleted list of proposed goals, policies, and actions related to parks and recreation under Impact Discussion PS-9 in Section 4.14.5.3, Impact Discussion, on pages 4.14-50 through

4.14-52 of the Draft EIR is hereby amended as follows:
 Policy 6-7.1: Work to eEnsure adequate funding to keep parks safe, attractive, and responsive to community needs, including funding for park acquisition, planning, capital improvements, lifecycle replacement of amenities, recreation programming, recreation centers, and maintenance operations.
 Action 6-7.2: Evaluate park development impact fees annually to address projects that that meet the Quimby Act guidelines, as well as those for projects that do not meet Quimby Act guidelines,and maintenance costs periodically. Work to ensure sufficient funds for park acquisition, development, and maintenance from developers.  Action 6-7.3: Use the Parks Condition Assessment and Prioritization Report’s data-driven evaluation of park assets to develop a replacement schedule for park amenities and plan for future budgetary needs.
 Action 6-7.6: Develop and maintain a five-year capital improvement plan for acquisition, development, and replacement that considers equity by providing opportunities for public input and prioritizing investment in the parks and recreation center sites in areas of the city where need is greatest.

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 Action 6-7.8: When diversion or disposal of parkland is determined to be in the public interest, work to acquire additional parklands to replace those lands, preferably within the same quadrant of the city.
 Action 6-7.16: Explore uUpdateing the City Code to require dedication of new parkland or recreation center sites when redevelopment of a developed site results in increased residential densities that create a need for such facilities.  Action 6-7.17: Facilitate equitable, authentic community engagement in recreation and parks planning to identify the needs and priorities of all segments of the community, including individuals in Equity Priority Areas and those unable to attend public meetings.

CHAPTER 4.15, TRANSPORTATION
The text under the “California Complete Streets Act of 2008” subheading in Section 4.15.1.2, Regulatory Framework, on page 4.15-2 of the Draft EIR is hereby amended as follows:

California Complete Streets Act of 2008
The Complete Streets Act (Assembly Bill [AB] 1358) requires city and county general plans to include policies that support the development of facilities for a multimodal transportation network. Complete Streets principles should be incorporated into street design to meet the needs of all users—drivers, bicyclists, pedestrians, and transit riders—regardless of age or physical ability. Jurisdictions that undertake updates of their general plan must plan for a balanced multimodal transportation network that meets the needs of all users, incorporating appropriate goals, policies, and actions into the mandatory circulation element.
2 In December 2021, Directors Policy 37 was adopted which establishes an implementation structure to streamline complete street projects. This policy also stipulates that all transportation projects funded or overseen by Caltrans will provide comfortable, convenient, and connected complete streets facilities for people walking, biking, and taking transit or passenger rail unless an exception is documented and approved.3 This policy supersedes Deputy Directive 64-R1, and carries forward its goals of creating a safe and reliable transportation network.
3 California Department of Transportation, December 2021, Directors Policy Dp-37, https://dot.ca.gov/-/media/dot- media/programs/esta/documents/dp-37-complete-streets-a11y.pdf accessed on November 26, 2024.

The following text is hereby added before the “Caltrans District 4 Bike Plan” subheading in Section

4.15.1.2, Regulatory Framework, on page 4.15-3 of the Draft EIR:

Caltrans District 4 Pedestrian Plan
Adopted in 2021, the Caltrans District 4 Pedestrian Plan for the Bay Area identifies pedestrian needs on Caltrans roadways in District 4. This plan analyzes the frequency and quality of crossing opportunities, as well as sidewalk coverage and conditions. Needs were then prioritized and areas for improvement were SANTA ROSA GENERAL PLAN 2050 FINAL EIR

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identified. The next steps in the plan include leveraging local partnerships and identifying and initiating projects.

The following policy and actions in the bulleted list of proposed goals, policies, and actions related to transportation under Impact Discussion TRAN-1 in Section 4.15.3, Impact Discussion, on pages 4.15-19 through 4.15-25 of the Draft EIR are hereby amended as follows:
 Policy 3-3.2: Bolster outreach, marketing, and education about non-automobile modes of transportation, especially. Outreach should pay for give priority to marketing efforts in Equity Priority Areas and Priority Development Areas.
 Action 3-3.14: Require new development to provide transit improvements where needed, including:
 Direct, paved pedestrian access to transit stops.
 Bus turnouts and weather-protected shelters.
 Bus-ready travel lanes.
 Action 3-4.1: Require traffic studies for development projects that may have an substantial impact on the circulation system and use traffic study findings to define improvements that would also support active and public transportation.

The following action in the bulleted list of proposed goals, policies, and actions related to transportation under Impact Discussion TRAN-2 in Section 4.15.3, Impact Discussion, on pages 4.15-27 and 4.15-28 of the Draft EIR is hereby amended as follows:
 *Action 3-1.1: For all projects with the potential to increase VMT based on the City’s VMT screening criteria, the City shall Rrequire a qualified transportation engineer to prepare an analysis of projected VMT and mitigation, as necessary, as part of the project review process for projects with the potential to increase VMT consistent with the City’s VMT guidelines, as subsequently revised, supplemented, or replaced.

The first paragraph of the significance discussion for Impact Statement TRAN-2a in Section 4.15.3, Impact Discussion, on page 4.15-28 of the Draft EIR is hereby amended as follows:

Impact TRAN-2a: Implementation of the proposed project could result in a significant vehicle miles traveled (VMT) impact for residential VMT per capita.

Significance with Mitigation: Significant and unavoidable. Implementation of the proposed General Plan 2050 goals, policies, and actions would reduce the VMT generated by all development including residential uses. In support of proposed General Plan 2050 Policy 3-1.1 to reduce VMT, proposed *Action 3-1.1 requires the City to require a qualified transportation engineer to prepare an analysis of project VMT consistent with the City’s VMT guidelines for all projects with the potential to increase VMT based on the City’s VMT screening criteria and mitigation as part of the project review process.

Proposed Action 3-1.2 requires the City to work with other local and regional partners to explore developing a VMT mitigation bank. Proposed Action 3-1.3 and Action 3-1.5 supports prioritizing investments that will reduce VMT and GHG emissions.

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The significance discussion for Impact Statement TRAN-2b in Section 4.15.3, Impact Discussion, on page

4.15-31 of the Draft EIR is hereby amended as follows:

Impact TRAN-2b: Implementation of the proposed project could result in a significant roadway network vehicle miles traveled (VMT) impact associated with increasing the capacity of the arterial street network.

Significance with Mitigation: Significant and unavoidable. Implementation of the proposed General Plan 2050 goals, policies, and actions listed under impact discussions TRAN-1 and TRAN-2 would improve the active transportation network, work with partner agencies to reduce VMT, encourage development in TPAs and PDAs, amongst others to reduce VMT generated by all development.

Specifically, proposed *Action 3-1.1 requires the City to require a qualified transportation engineer to prepare an analysis of project VMT consistent with the City’s VMT guidelines for all projects with the potential to increase VMT based on the City’s VMT screening criteria and mitigation as part of the project review process. Even with implementation of the proposed General Plan 2050 goals, policies, and actions related to VMT reduction, the effectiveness of VMT-reduction strategies and availability of alternative mitigation strategies such as VMT exchanges or banks is not certain. As such, the impact on roadway network VMT is considered significant and unavoidable.

CHAPTER 4.16, TRIBAL CULTURAL RESOURCES
The text under the “Ethnographic Setting” subheading in Section 4.16.1.2, Existing Conditions, on pages

4.16-5 and 4.16-6 of the Draft EIR is hereby amended as follows:

Linguists and ethnographers tracing the evolution of languages have found that most of the indigenous languages of the California region belong to one of five widespread North American language groups (the Hokan and Penutian phyla, and the Uto-Aztecan, Algic, and Athabaskan language families). The distribution and internal diversity of four of these groups suggest that their original centers of dispersal were outside, or peripheral to, the core territory of California, that is, the Central Valley, the Sierra Nevada, the Coast Range from Cape Mendocino to Point Conception, and the Southern California coast and islands. Only languages of the Hokan phylum can plausibly be traced back to populations inhabiting parts of this core region during the Archaic period, and there are hints of connections between certain branches of Hokan, such as that between Salinan and Seri, that suggest that at least some of the Hokan languages could have been brought into California by later immigrants, primarily from the Southwest and northwestern Mexico.2
At the time of Euroamerican settlement, people inhabiting this area spoke Southern Pomo, one of seven mutually unintelligible Pomoan languages belonging to the Hokan language stock. The Southern Pomo’s aboriginal territory falls within present-day Sonoma County. To the north, it reaches the divide between Rock Pile Creek and the Gualala River, and to the south it extends to near the town of Cotati. The eastern boundary primarily runs along the western flanks of Sonoma Mountain until it reaches Healdsburg, where it crosses to the west side of the Russian River . Within the larger area that constitutes the Southern Pomo homelands, some bands or tribelets occupied distinct areas.

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The Bitagomtara were a triblet of the Southern Pomo and they occupied the lands south of Mark West Creek, north of Cotati and the boundary of the Coast Miwok, east of the Laguna de Santa Rosa, and west of Sonoma Canyon.
3, 4 Primary village sites of the Southern Pomo were occupied continually, while temporary sites were visited to procure resources that were especially abundant or available only during certain seasons. Sites often were situated near freshwater sources and in ecotones where plant life and animal life were diverse and abundant.

Primary village sites of the Southern Pomo were occupied continually, while temporary sites were visited to procure resources that were especially abundant or available only during certain seasons. Sites often were situated near freshwater sources and in ecotones where plant life and animal life were diverse and abundant. There are several ethnographic villages in the EIR Study Area.5 The Southern Pomo population was decimated early in the historic period, especially in the southern part of their territory. Ethnic identity was severely impacted in the region of Santa Rosa and Sebastopol; McLendon and Oswalt reported that the few Southern Pomo speakers remaining in 1976 were from north of Healdsburg.6 In 1992, the Southern Pomo and Coast Miwok established the Federated Indians of Graton Rancheria and were federally recognized in 2000. The Federated Indians of Graton Rancheria is a federally recognized tribe of Southern Pomo and Coast Miwok people, whose ancestral homelands include the City of Santa Rosa.

Footnote 2: V. Golla, 2011, California Indian Languages, Berkeley and Los Angeles: University of California Press.

Footnote 3: R. Milliken, 1995, A Time of Little Choice: The Disintegration of Tribal Culture in the San Francisco Bay Area, 1769- 1810, Menlo Park, CA: Ballena Press.

Footnote 4: O. Stewart, 1943, “Notes on Pomo Ethnogeography”, University of California Publications in American Archaeology and Ethnology 40, no. 2, pp.29–62.

Footnote 5: S. Barrett, 1908, The Ethno-Geography of the Pomo and Neighboring Indians, U niversity of California Publications in American Archaeology and Ethnology, vol. 6, no. 1, Berkeley, California: University of California Press.

Footnote 6: S. McLendon and R. Oswalt, 1978, “Pomo,” In California, edited by R. Heizer, pp. 274–288, H andbook of North American Indians, Vol. 8, W. Sturtevant, general editor, Washington, D.C.: Smithsonian Institution.

The third paragraph under the “Native American Consultation: Assembly Bill 52” subheading in Section

4.16.1.2, Existing Conditions, on page 4.16-7 of the Draft EIR is hereby amended as follows:

As a result of the consultations to date, no TCRs have been identified and as described in Chapter 4.5 of this Draft EIR, only the following requests have been made:
 Work to develop a better communication system for the required AB 52 and Senate Bill 18 consultation between City staff and tribes.
 Tribal acknowledgment to be added to the Housing Element and to be carried forward in the comprehensive General Plan.
 Consider Phase 1 archaeological survey for all projects that involve ground disturbance: allowing potential exceptions where the ground has already been disturbed.  Develop a threshold for when ministerial projects with ground disturbance can include consultation.  Expand consideration of projects along waterways to include historical locations and trajectories.

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 Ensure the plan includes adequate goals, policies, and actions related to resilience.

The first paragraph under Impact Discussion TCR-1 in Section 4.16.3, Impact Discussion, on pages 4.16-8 and 4.16-9 of the Draft EIR is hereby amended as follows:

As previously described in Section 4.16.1.1, Regulatory Framework, CEQA defines a TCR as a site, feature, place, or cultural landscape that is geographically defined in terms of size and scope, sacred place, or object with cultural value to a California Native American tribe that is either included or eligible for inclusion in the California Register or included in a local register of historical resources, or if the City of Santa Rosa, acting as the lead agency, supported by substantial evidence, chooses at its discretion to treat the resource as a TCR.1 Through the consultation process described in Section 4.16.1.2, Existing Conditions, no California Native American Tribe has identified the presence of TCRs in the EIR Study Area.

However, there is the potential for TCRs to be identified as part of project-specific development over the course of the implementation of the proposed project.

The first row in Table 4.16-1, Tribal Consultation Requests and City Responses, on page 4.16-9 of the Draft EIR is hereby amended as follows:

TABLE 4.16-1 TRIBAL CONSULTATION REQUESTS AND CITY RESPONSES Request Response
Work to develop a better communication system for the required SB 18 and AB 52 consultation between City staff and tribes.

Proposed General Plan 2050 Policy 4-2.2, *Action 4-2.1, a nd *Action 4-2.2 require the review of projects, consultation with Native American tribes as required by State law, and
collaboration with the most likely descendants, as identified by the Native American Heritage Commission.

The third paragraph under Impact Discussion TCR-1 in Section 4.16.3, Impact Discussion, on page 4.16-10 of the Draft EIR is hereby amended as follows:

While no TCRs have been acknowledged as part of the consultation process or otherwise, tThere is the potential to unearth archeological resources or human remains, which could be identified as TCRs upon discovery. The proposed General Plan 2050 Chapter 2, Land Use and Economic Development; Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction; and Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture, contains goals, policies, and actions that require local planning and development decisions to consider impacts to TCRs and archaeological resources, which have the potential to be identified as TCRs upon discovery archaeological resources. The following goals, policies, and actions would minimize impacts to TCRs and archaeological resources:

The following policies and actions in the bulleted list of proposed goals, policies, and actions related to tribal cultural resources under Impact Discussion TCR-1 in Section 4.16.3, Impact Discussion, on pages

4.16-10 and 4.16-11 of the Draft EIR are hereby amended as follows:
 Policy 3-5.3: Conserve and protect creeks, wetlands, vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-45
 *Action 3-5.19: The City shall Rrequire new development along channelized waterways to establish an ecological buffer zone between the waterway and development that also provides opportunities for shared use paths and recreation multiuse trails and recreation, consistent with the Santa Rosa Citywide Creek Master Plan and concept plans that have been developed for specific reaches of the creek network, as subsequently revised, supplemented, or replaced.
 *Action 3-5.20: The City shall Rrequire new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Creekside Development Standards in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans, as subsequently revised, supplemented, or replaced, to meet restoration and enhancement goals.  Policy 4-2.1: Protect Native American tribal heritage, honor the early stewards of this land, and treat Native American remains and resources with sensitivity.  *Action 4-2.1: The City shall Ccontinue to review proposed developments in conjunction with accordance with federal and State laws and utilize the California Historical Resources Information System, Northwest Information Center, at Sonoma State University as a resource to determine whether project areas contain known subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources, or if they have the potential to hold such resources and if so, implement mitigation to protect the resource.  *Action 4-2.2: The City shall Wwork in good faith with interested communities local tribes and archaeologists to evaluate proposed development sites for the presence of subsurface historic, archaeological resources, both prehistoric and/or historic era, and tribal cultural resources. These efforts may include:
 Consideration of existing reports and studies.
 Consultation with Native American tribes as required by State law.  Appropriate site-specific investigative actions.
 On-site monitoring during excavation if appropriate.
 Work with local tribes to develop and apply tribal protection policies related to tribal cultural resources.
 *Action 4-2.3: The City shall Ccontinue to require that project areas found to contain significant subsurface archaeological resources, both prehistoric and/or historic-era, and tribal cultural resources be examined by a qualified consulting archaeologist with recommendations for protection and preservation, developed in collaboration with local tribes and tribal monitors, as appropriate. Recommendations shall meet the standards of the National Historic Preservation Act, Native American Historic Resource Protection Act, National and California Environmental Quality Act, and applicable Santa Rosa planning guidelines, policies, and procedures to protect the resource.
 Policy 4-2.2: Collaborate with the most likely descendants, as identified by Contact the Native American Heritage Commission (NAHC) to identify tribes that are traditionally and culturally affiliated with the geographic area of the proposed project.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-46 APRIL 2025
 *Action 4-2.4: During ground disturbance for development projects, Iif tribal cultural resources are encountered during development, halt work shall be halted to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative (if appropriate) have evaluated the situation and recorded identified tribal cultural resources—which may include sites, features, places, cultural and other landscapes, sacred places, objects, animals, structures, landscapes, or plants with cultural value to the tribe(s)—and determined suitable mitigation measures. If human remains are inadvertently discovered, the County coroner shall be notified immediately. If the coroner determines that the remains are those of a Native American, the coroner must contact the NAHC by phone within 24 hours of making that determination (Health and Safety Code § 7050[c]). The City and the professional archaeologist shall contact the Most Likely Descendent, as determined by the NAHC, regarding the remains.

The significance discussion for Impact Statement TCR-1 in Section 4.16.3, Impact Discussion, on page

4.16-12 of the Draft EIR is hereby amended as follows:

Impact TCR-1: Impacts to unknown tribal cultural resources (TCR) could occur from potential future development under the proposed General Plan 2050.

Significance with Mitigation: Less than significant. The proposed General Plan 2050 includes goals, policies, and actions that require local planning and development decisions to reduce impacts to archaeological resources that could qualify as TCRs and to conduct consultation with Native American tribes as required by State law. Specifically, proposed Policy 2-2.2 encourages infill development in Areas of Change, which reduces opportunities to unearth potential TCRs and Action 3-5.4 requires the City to collaborate with regional agencies to expand open space that would protect historic and TCRs.

Proposed *Action 4-2.1 and *Action 4-2.2 requires the City to continue to review proposed developments to determine if TCRs are present and evaluate proposed development sites for TCRs through consultation with local Native American tribes. Additionally, proposed *Action 4-2.4 requires that if TCRs are encountered during development ground disturbance, work is halted to avoid altering the materials and their context until a qualified consulting archaeologist and Native American representative have evaluated the situation, and recorded identified cultural resources, which may include sites, features, places, cultural and other landscapes, sacred places, objects, animals, structures, landscapes, and plants with cultural value to the tribe(s), and determined suitable site- specific mitigation measures.

The proposed General Plan 2050 also includes policies and actions to protect historic and cultural resources, including waterways as Native American archaeological sites tend to be located near waterways and these locations may hold prehistoric resources. As listed under impact discussion CUL- 1 in Chapter 4.5, Cultural Resources, of this Draft EIR, proposed General Plan 2050 Policy 4-1.1 requires the preservation and enhancement of the city’s natural waterways and landscapes; Policy 3-

5.7 requires that construction adjacent to creek channels is sensitive to the natural environment, preserves topography and vegetation along the creek, does not disrupt or pollute the waterway, and provides an adequate setback buffer; and *Action 3-5.19 and *Action 3-5.20 require new development along channelized waterways to establish an ecological buffer zone between the waterway and development.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-47
Compliance with federal and State laws, as described in Section 4.16.1.1, Regulatory Framework, and the proposed General Plan 2050 goals, policies, and actions would protect unrecorded TCRs in the EIR Study Area by providing for the early detection of potential conflicts between development and resource protection, and by preventing or minimizing the material impairment of the ability of archaeological deposits to convey their significance through excavation or preservation. Therefore, impacts to TCRs would be less than significant.

The first paragraph under Impact Discussion TCR-2 in Section 4.16.3, Impact Discussion, on page 4.16-13 of the Draft EIR is hereby amended as follows:

Cumulative impacts to TCRs occur when a series of actions leads to adverse effects on local Native American tribes or tribal lands. No TCRs have been identified in the EIR Study Area. Further, iIn association with CEQA review, future AB 52 consultations with Native American tribes to identify TCRs would be required for projects that have the potential to cause significant impacts to TCRs.

CHAPTER 4.17, UTILITIES AND SERVICE SYSTEMS
The following action in the bulleted list of proposed goals, policies, and actions related to water under the “Water Demand Analysis” subheading of Impact Discussion USS-1 in Section 4.17.1.3, Impact Discussion, on pages 4.17-23 through 4.17-25 of the Draft EIR is hereby amended as follows:
 *Action 5-9.30: The City shall Eevaluate stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 National Pollutant Discharge Elimination System (NPDES) permit to preserve natural conditions of waterways, minimize channelization of creeks, and protect water quality, and identify, educate, and label to promote community awareness that storm drains flow untreated into creeks.

The following actions in the bulleted list of proposed goals, policies, and actions related to stormwater under Impact Discussion USS-7 in Section 4.17.3.3, Impact Discussion, on pages 4.17-46 and 4.17-47 of the Draft EIR are hereby amended as follows:
 Action 5-2.13: Identify and collect development impact fees needed to pay for mitigation of stormwater management impacts for of new development.
 *Action 5-2.14: The City shall Rrequire improvements that maintain and improve the storm drainage system citywide and prioritize areas needing significant investment, consistent with the Santa Rosa Citywide Creek Master Plan goals of preserving natural conditions of waterways and minimizing channelization of creeks.
 Action 5-2.15: The City shall Eensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Active Transportation Bicycle and Pedestrian Master Plan, as subsequently revised, supplemented, or replaced, and are incorporated into stormwater improvement projects along creek corridors.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-48 APRIL 2025
 *Action 5-2.17: The City shall Rrequire implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system.

The following policy under the first goal in the bulleted list of proposed goals, policies, and actions related to energy infrastructure under Impact Discussion USS-12 in Section 4.17.5.3, Impact Discussion, on page

4.17-67 of the Draft EIR is hereby amended as follows:
 Policy 3-5.3: Increase the use of renewable, carbon free, and distributed energy resources throughout the city. Policy 3-7.2: Reduce energy use and increase energy efficiency in existing and new residential, commercial, industrial, and public structures.

CHAPTER 4.18, WILDFIRE
The following text is hereby added after the bulleted list under the “Hazard Mitigation Plan” subheading in Section 4.18.1.1, Regulatory Framework, on page 4.18-11 of the Draft EIR:

Pursuant to California Government Code Section 65302.15 requirements, the City of Santa Rosa is collaborating with Sonoma County on the 2026 MJHMP to assess and enhance evacuation capabilities.

The first paragraph under the “Wildfire in Santa Rosa” subheading in Section 4.18.1.2, Existing Conditions, on page 4.18-16 of the Draft EIR is hereby amended as follows:

As shown on Figure 4.18-1, Fire Hazard Severity Zones, the EIR Study Area is in both the LRA and SRA.

Lands within the city limit are within the LRA, and lands between the city limit and the Planning Area boundary are within the SRA. Figure 4.18-1 shows Very High FHSZs in the LRA are in the Fountaingrove, Skyhawk, Bennett Valley and Oakmont neighborhoods of the city. High FHSZ in the LRA border the northern, eastern, and southeastern inner boundaries of the EIR Study Area and Moderate FHSZ covering the northern, eastern, and southwestern portions of the EIR Study Area. The SRA to the north and south of the city limits contain Moderate, High, and Very High FHSZs. As shown on Figure 4.18-2, General Plan Land Uses in Wildland Urban Interface Fire Areas, land uses within the WUIFA consist of very low and low density residential, with other land uses consisting of parks and recreation, medium density residential, medium low density residential, public/institutional, and retail and business services.

Figure 4.18-1, Fire Hazard Severity Zones, on page 4.18-1 of the Draft EIR is hereby amended as shown on the following page.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-50 APRIL 2025
The following actions in the bulleted list of proposed goals, policies, and actions related to wildfire under Impact Discussion WF-1 in Section 4.18.3, Impact Discussion, on pages 4.18-28 and 4.18-29 of the Draft EIR are hereby amended as follows:
 *Action 5-5.14: The City shall Rrequire all new development projects to provide adequate access for fire and emergency response personnel.
 *Action 5-5.15: The City shall Pprohibit the creation of new single ingress/egress roadway conditions in the city.
 *Action 5-5.16: The City shall Rretrofit existing single-access residential neighborhoods to include additional access routes or other provisions to increase evacuation safety.  *Action 5-5.17: The City shall Aanalyze the capacity, viability, and safety of evacuation routes for hazard areas in the city (e.g., WUIFA) and evacuation locations throughout the city under a range of emergency scenarios and incorporate the results, as necessary, into the City’s Emergency Operations Plan Safety Element of the General Plan. This analysis will be completed as part of the City’s Annex to the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan in 2026.

The following text is hereby added after the bulleted list of proposed goals, policies, and actions related to wildfire under Impact Discussion WF-1 in Section 4.18.3, Impact Discussion, on page 4.18-29 of the Draft EIR:

Additionally, the City has established designated evacuation zones to facilitate organized and efficient evacuations during large-scale emergencies. Residents can identify their specific zones using the interactive Evacuation Zone Look-Up Tool, enabling them to respond promptly to evacuation orders. Santa Rosa evacuation zones are coordinated with the Sonoma County system, ensuring consistency across the region. Residents can cross-reference their zones using the Sonoma County Evacuation Map, which provides interactive features to look up evacuation status and road closures, and the City is developing enhanced evacuation zone and road closure maps. During active wildfires, the City coordinates and communicates directly with the Sonoma County Department of Emergency Management, ensuring effective and efficient evacuation throughout the county and city.

The City is collaborating with Sonoma County on the 2026 MJHMP to assess and enhance evacuation capabilities. This plan will evaluate current strategies, identify infrastructure improvements, and integrate best practices for various evacuation scenarios, including wildfires, earthquakes, and floods. As part of the City's annex to the MJHMP , Santa Rosa will conduct a detailed evacuation analysis. This study will evaluate current evacuation strategies, identify potential improvements, and integrate best practices to ensure the safety and well-being of the community during emergencies.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-51
Impact Statement WF-1 and the associated significance discussion in Section 4.18.3, Impact Discussion, on page 4.18-29 of the Draft EIR is hereby amended as follows:

Impact WF-1: Implementation of the proposed General Plan 2050 could result in inadequate wildfire- related evacuation access the and impair the implementation of an emergency evacuation plan.

Significance with Mitigation: Less than significant. Implementation of the proposed General Plan 2050 goals, policies, and actions would increase the effectiveness of emergency operations and wildfire- related evacuation, and therefore would not impair or conflict with applicable plans. Specifically, proposed *Action 5-5.16 would reduce the number of evacuation-constrained residential parcels identified on Figure 4.18-5, Evacuation Routes and Evacuation-Constrained Residential Parcels, by requiring the City to retrofitting existing single-access roads in residential neighborhoods to include additional access routes or other provisions to increase evacuation safety. Proposed *Action 5-5.17 would improve evacuation scenarios by requiringes the City to conduct an analysis analyze the capacity, viability, and safety of the evacuation route network to determine the capacity, viability, and safety of evacuation routes and evacuation locations throughout the city under a range of emergency scenarios and incorporate the results into the Safety Element of the General Plan, which would be incorporated into the Emergency Operations Plan and would improve evacuation scenarios. This analysis shall be completed as part of the City’s Annex to the Sonoma County Multi-Jurisdictional Hazard Mitigation Plan in 2026. In addition, as described, the proposed changes to the circulation infrastructure include strategic improvements that include evacuation route upgrades primarily on arterials within Wildland-Urban Interface Fire Areas. Future development, regardless of whether it includes new development or redevelopment, would be required to comply with adopted local, regional, and State plans and regulations addressing emergency response and evacuation, including proposed *Action 5-5.14 and *Action 5-5.15, which require the provision of adequate access for fire and emergency response personnel and prohibit the creation of new single access roadways in the city. Therefore, implementation of the proposed project would not substantially impair an adopted emergency response plan or emergency evacuation plan and impacts would be less than significant.

The following policy and actions in the bulleted list of proposed goals, policies, and actions related to wildfire under Impact Discussion WF-2 in Section 4.18.3, Impact Discussion, on pages 4.18-31 through

4.18-33 of the Draft EIR are hereby amended as follows:
 *Policy 5-1.1: Prior to new development approval, where there are known geological hazards as shown on Figures 5-2, 5-3, and 5-4 and current maps from the United States Geological Survey, California Geological Survey, California Department of Water Resources, California Office of Emergency Services, the City shall ensure that Nnew development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards through the preparation of a site-specific geologic study prepared by a California Certified Engineering Geologist and/or Geotechnical Engineer and compliance with identified measures.  *Action 5-1.1: Prior to new development approval, the City shall ensure site-specific geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable to appropriately mitigate hazardous conditions.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-52 APRIL 2025
 *Action 5-1.2: The City shall Rrestrict development in areas where adverse impacts conditions associated with known natural or human-caused geologic hazards cannot be effectively mitigated, as determined by a California Certified Engineering Geologist and/or Geotechnical Engineer.
 Action 5-3.3: Seek provision of land management plans or alternative methods to fund vegetation management efforts, support defensible space maintenance on private property and create fire breaks, greenbelts, and staging areas in strategic locations in conformance with Title 14 of the California Code of Regulations for all existing and new development.  Policy 5-3.2: Increase wildfire resiliency using required and voluntary risk reduction regulations and strategies in addition to Title 14 of the California Code of Regulations.  Action 5-3.4: Adhere to the most current State and local regulations and recommendations for the Community Wildfire Protection Plan that address wildfire risk and vulnerabilities and adopt the latest versions of the fire hazard severity zone maps released by CAL FIRE.  Action 5-3.6: Continue to require conformance with the California Fire Safe Regulations Title 14 of the California Code of Regulations for existing nonconforming properties in the Wildland-Urban Interface Fire Area (WUIFA) (includes the Very High Fire Hazard Severity Zone).
 *Action 5-3.8: The City shall Rrequire the preparation of fire protection plans for new development and major remodels in the City’s Very High Fire Hazard Severity Zone and Wildland-Urban Interface Fire Area (WUIFA). Require that fire protection plans be consistent with requirements of the California Fire Code and include a risk analysis, fire response capabilities, fire safety requirements (e.g., defensible space, infrastructure, and building ignition resistance), mitigation measures, design considerations for non-conforming fuel modifications, wildfire education maintenance and limitations, and evacuation plans.  Policy 5-3.3: Promote new development in areas of the community that have lower risk of wildfire hazards (outside of the WUIFA).
 Action 5-3.14: Establish a maintenance and monitoring program to track the effectiveness and long-term financial capabilities of Community Wildfire Protection Plan fuel-treatment activities, such as community fire breaks, and roadway (public/private) clearance.

The following actions in the bulleted list of proposed goals, policies, and actions related to wildfire under Impact Discussion WF-4 in Section 4.18.3, Impact Discussion, on pages 4.18-37 through 4.18-39 of the Draft EIR are hereby amended as follows:
 Action 5-2.13: Identify and collect development impact fees needed to pay for mitigation of stormwater management impacts for of new development.
 *Action 5-2.14: The City shall Rrequire improvements that maintain and improve the storm drainage system citywide and prioritize areas needing significant investment, consistent with the Santa Rosa Citywide Creek Master Plan goals of preserving natural conditions of waterways and minimizing channelization of creeks.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
P LACEWORKS 5-53
 Action 5-2.15: The City shall Eensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Active Transportation Bicycle and Pedestrian Master Plan, as subsequently revised, supplemented, or replaced, and are incorporated into stormwater improvement projects along creek corridors.
 *Action 5-2.17: The City shall Rrequire implementation of best management practices for all new development to reduce discharges of nonpoint-source pollutants to the storm drain system.
 *Action 5-9.30: The City shall Eevaluate stormwater capture and reuse consistent with goals of the Santa Rosa Citywide Creek Master Plan and the MS4 National Pollutant Discharge Elimination System (NPDES) permit to preserve natural conditions of waterways, minimize channelization of creeks, and protect water quality, and identify, educate, and label to promote community awareness that storm drains flow untreated into creeks.

CHAPTER 5, ALTERNATIVES TO THE PROPOSED PROJECT
The first paragraph in Section 5.3.1, Description, on page 5-10 of the Draft EIR is hereby amended as follows:

Pursuant to CEQA Guidelines Section 15126.6(e)(1), the No Project Alternative is required as part of the “reasonable range of alternatives” to allow decision makers to compare the impacts of approving the proposed project with the impacts of taking no action or not approving the proposed project. Consistent with CEQA Guidelines Section 15126.6(e)(3)(A), when the project is the revision of a plan, as in this case, the no project alternative will be the continuation of the existing plan. Under Alternative A, potential future development in Santa Rosa would continue to be subject to existing policies, regulations, development standards, and land use designations of the existing General Plan 2035. Alternative A would not implement the amendments to the North Station Area Specific Plan (NSASP), Downtown Station Area Specific Plan (DSASP), Roseland Area/Sebastopol Road Specific Plan (RA/SRSP), or Santa Rosa City Code (SRCC) associated with the proposed General Plan 2050 and Land Use Map. Alternative A would also not adopt the proposed GHG Reduction Strategy to serve as the strategic plan for how the City will reduce GHG emissions and foster a sustainable community through 2050 and beyond The first paragraph in Section 5.4.1, Description, on page 5-22 of the Draft EIR is hereby amended as follows:

Alternative B assumes the General Plan would be updated as well as the associated amendments to the NSASP , DSASP , RA/SRSP , and SRCC associated with the proposed General Plan 2050 and Land Use Map.

Accordingly, Alternative B, like the proposed project, would focus future commercial and residential growth in PDAs and/or TPAs and in the Areas of Change that are near Downtown, transit facilities, and along central thoroughfares connected to transit facilities. Alternative B assumes the same number of households, residential units, population, and jobs as under the proposed project, but would allow for more opportunity for dense housing connected to transit facilities. Alternative B presumes the same General Plan land use designations as the proposed project, except that the parcels designated as Medium Low density residential (8.0-13.0 units per gross acre) in Areas of Change that are in or adjacent SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

REVISIONS TO THE DRAFT EIR
5-54 APRIL 2025
to PDAs and/or TPAs would be redesignated to Medium High density residential (8.0-18.0-30.0 units per gross acre).

PLACEWORKS 6-1
Mitigation Monitoring and Reporting
Program
This Mitigation Monitoring and Reporting Program (MMRP) has been prepared for the proposed Santa Rosa General Plan 2050 (also known as Santa Rosa Forward), along with the associated Specific Plan and Santa Rosa City Code (SRCC) amendments, and Community-wide Greenhouse Gas Reduction Strategy (GHG Reduction Strategy), herein referred to as the “proposed project.” The purpose of the MMRP is to ensure the implementation of mitigation measures identified as part of the environmental review for the proposed project. The MMRP includes the following information:
 The full text of the mitigation measures;
 The party responsible for implementing the mitigation measures;  The timing for implementation of the mitigation measure;  The agency responsible for monitoring the implementation; and  The monitoring action and frequency.

The mitigation measures in this MMRP shown in Table 6-1, Santa Rosa General Plan 2050 Mitigation Monitoring and Reporting Program, shall be applied to all future development anywhere in the EIR Study Area. The City of Santa Rosa must adopt this MMRP , or an equally effective program, if it approves the proposed project with the mitigation measures that were adopted or made conditions of project approval.

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-2 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 3-1.1: For all projects with the potential
to increase VMT based on the City’s VMT
screening criteria, the City shall require a
qualified transportation engineer to prepare an
analysis of projected VMT and mitigation
consistent with the City’s VMT guidelines, as
subsequently revised, supplemented, or
replaced.
(Mitigates transportation impacts)

City of Santa
Rosa; Project
applicant;
Qualified
transportation
engineer
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review VMT
analysis and
mitigation and
confirm
consistency
with City’s VMT
guidelines
Once, prior to
project
approval

Action 3-5.7: The City shall continue to consult
with the California Department of Fish and
Wildlife (CDFW) to identify significant
environments and priorities for acquisition or
maintenance of open space areas based on
biological and environmental concerns and
develop a strategy for maintaining areas that
will preserve the protected and sensitive
populations of plants and animals currently
found in the UGB. Strategies shall be based on
federal, State, and local regulations relevant to
the protection of the identified species,
including, but not limited to, Federal or
California Endangered Species Act, Santa Rosa
Plain Conservation Strategy, and United States
Fish and Wildlife Service Programmatic
Biological Opinion, as subsequently revised,
supplemented, or replaced.
(Mitigates impacts to biological resources)

City of Santa
Rosa; California
Department of
Fish and Wildlife
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 3-5.10: The City shall continue to
require the implementation of existing
regulations and procedures, including
subdivision guidelines, zoning, design review,
and environmental law, prior to, during, and
after project approval and construction for
City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-3
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
projects that may affect wetlands and rare
plants, riparian habitat and other sensitive
natural communities, and essential habitat for
special-status species to ensure their
conservation. Existing regulations and
procedures include, but are not limited to,
Federal and California Endangered Species Act;
CDFW 2018 Protocols for Surveying and
Evaluating Impacts to Special-Status Native
Plant Populations and Sensitive Natural
Communities; Santa Rosa Plain Conservation
Strategy; United States Fish and Wildlife
(USFWS) Service Programmatic Biological
Opinion; CDFW 2012 Staff Report on
Burrowing Owl Mitigation; 2012 USFWS
Protocol for Surveying Proposed Management
Activities That May Impact Northern Spotted
Owls; 2020 Estimating the Effects of Auditory
and Visual Disturbance to Northern Spotted
Owls and Marbled Murrelets in Northwestern
California; Fish and Game Code Section 1600 et
seq; Clean Water Act; and Porter Cologne
Water Quality Control Act, as subsequently
revised, supplemented, or replaced.
(Mitigates impacts to biological resources and
hydrology)

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-4 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 3-5.11: The City shall require a qualified
biologist to prepare a biological resource
assessment (BRA) for proposed development
on sites that may support or have the potential
to affect special-status species, sensitive
natural communities, important wildlife
corridors, or regulated wetlands and waters to
identify potential impacts and measures for
protecting the resource and surrounding
habitat prior to, during, and after project
construction. The BRA shall be prepared to
address conformance with all applicable
federal, State, and local regulations and
protocols, including, but not limited to, those
listed in Action 3-5.10, as subsequently revised,
supplemented, or replaced.
(Mitigates impacts to biological resources and
water quality)

City of Santa
Rosa; Project
applicant;
Qualified
biologist
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
biological
resource
assessment and
confirm
conformance
with all
applicable
federal, State,
and local
regulations and
protocols
Once, prior to
project
approval

Action 3-5.12: The City shall require that
construction or other ground-disturbing
activities that may affect bird nests or nesting
habitat avoid nests of native birds when the
nest is in active use by implementing
protection measures specified by a qualified
ornithologist or biologist to ensure compliance
with the California Fish and Game Code and
federal Migratory Bird Treaty Act. If demolition,
construction, ground-disturbing, or tree
removal/pruning activities occur during the
nesting season (February 1 and August 31),
preconstruction surveys shall be conducted by
a qualified ornithologist or biologist and
approved by the City prior to issuance of
building permits. Preconstruction surveys are
not required for construction, ground-
City of Santa
Rosa; Project
applicant;
Qualified
ornithologist or
biologist
Prior to ground
disturbing
activities
City of Santa
Rosa Planning
and Economic
Development
Confirm
implementation
of protection
measures
Once, prior to
ground
disturbing
activities

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-5
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
disturbing, or tree removal/pruning activities
outside the nesting season.
(Mitigates impacts to biological resources and
hydrology and water quality)
Action 3-5.13: The City shall develop and adopt
a bird-safe design ordinance by a qualified
biologist and require projects to demonstrate
compliance with the ordinance prior to project
approval. The ordinance shall apply to all new
development and redevelopment projects and
include the latest bird-safe design guidelines
and best management practice strategies, such
as those from the National Audubon Society, to
provide specific criteria and refined guidelines
as part of design review and/or project
approval process of new buildings and taller
structures to protect birds from injury and
mortality from collisions with buildings, towers,
and other human-made structures. Prior to
adoption of the bird-safe design ordinance,
project applicants shall show compliance with
bird-safe design requirements, consistent with
best practices.
(Mitigates impacts to biological resources)

City of Santa
Rosa; Qualified
biologist
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 3-5.19: The City shall require new
development along waterways to establish an
ecological buffer zone between the waterway
and development that also provides
opportunities for multiuse trails and
recreation, consistent with the Santa Rosa
Citywide Creek Master Plan and concept plans
that have been developed for specific reaches
of the creek network, as subsequently revised,
supplemented, or replaced.

City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Confirm
establishment
of ecological
buffer zone
Once, prior to
project
approval

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-6 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
(Mitigates impacts to biological resources,
cultural resources, and hydrology and water
quality)
Action 3-5.20: The City shall require new
development to maintain an adequate setback
from waterways to recognize the 100-year
flood elevation, with setbacks in the Creekside
Development Standards in the Zoning Code as
minimums and larger setbacks encouraged in
accordance with Restoration Concept Plans, as
subsequently revised, supplemented, or
replaced, to meet restoration and
enhancement goals.
(Mitigates impacts to biological resources,
cultural resources, and hydrology and water
quality)

City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Confirm
establishment
of ecological
buffer zone
Once, prior to
project
approval

Action 3-6.31: The City shall require projects
that exceed the Bay Area Air District (Air
District) screening sizes to evaluate project-
specific operation and construction emissions
in conformance with the Air District
methodology and if operation or construction-
related criteria air pollutants exceed the Air
District thresholds of significance, require the
project applicant to mitigate the impacts to an
acceptable level, consistent with the Air District
Guidelines, as subsequently revised,
supplemented, or replaced.
(Mitigates air quality impacts)
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
emissions
evaluation and
mitigation
Once, prior to
project
approval

Action 3-6.32: The City shall continue to
implement the Air District Basic Control
Measures included the Air District’s California
Environmental Quality Act (CEQA) Air Quality
Guidelines, as subsequently revised,
City of Santa
Rosa; Project
applicant
Prior to ground
disturbing
activities
City of Santa
Rosa Planning
and Economic
Development
Review
emissions
evaluation and
mitigation
Once, prior to
ground
disturbing
activities

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-7
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
supplemented, or replaced, to control fugitive
dust (i.e., particulate matter PM2.5 and PM10)
during demolition, ground-disturbing activities,
and/or construction.
(Mitigates air quality impacts)
Action 4-2.1: The City shall continue to review
proposed developments in accordance with
federal and State laws and utilize the California
Historical Resources Information System,
Northwest Information Center at Sonoma State
University as a resource to determine whether
project areas contain known subsurface
archaeological resources, both prehistoric
and/or historic-era, and tribal cultural
resources, or if they have the potential to hold
such resources.
(Mitigates impacts to cultural resources)

City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Determine
presence or
potential for
subsurface
archaeological
resources, both
prehistoric
and/or historic-
era, and tribal
cultural
resources and
review
mitigation as
needed
Once, prior to
project
approval

Action 4-2.2: The City shall work in good faith
with local tribes and archaeologists to evaluate
proposed development sites for the presence
of subsurface archaeological resources, both
prehistoric and/or historic era, and tribal
cultural resources. These efforts include:
 Consideration of existing reports and
studies.
 Consultation with Native American tribes
as required by State law.

City of Santa
Rosa; Local
tribes;
Archaeologists
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-8 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
 Appropriate site-specific investigative
actions.
 On-site monitoring during excavation if
appropriate.
 Work with local tribes to develop and apply
tribal protection policies related to tribal
cultural resources.
(Mitigates impacts to cultural resources)
Action 4-2.3: The City shall continue to require
that project areas found to contain significant
subsurface archaeological resources, both
prehistoric and/or historic-era, and tribal
cultural resources be examined by a qualified
consulting archaeologist with
recommendations for protection and
preservation, developed in collaboration with
local Native American tribes and appropriate
tribal monitors, as necessary.

Recommendations shall meet the standards of
the National Historic Preservation Act, Native
American Historic Resource Protection Act,
National and California Environmental Quality
Act, and applicable Santa Rosa planning
guidelines, policies, and procedures to protect
the resource.
(Mitigates impacts to cultural resources)

City of Santa
Rosa; Project
applicant;
Qualified
consulting
archaeologist;
local Native
American tribes
and appropriate
tribal monitors
Prior to project
approval; In the
instance
significant
archaeological
resources are
uncovered
City of Santa
Rosa Planning
and Economic
Development
Review
recommendatio
ns for
subsurface
archaeological
resources, both
prehistoric
and/or historic-
era, and tribal
cultural
resources
protection and
preservation
Once, prior to
project
approval; As
needed, in
the instance
significant
archaeologica
l resources
are
uncovered

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-9
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 4-2.4: During ground disturbance for
development projects, if tribal cultural
resources are encountered, work shall be
halted to avoid altering the materials and their
context until a qualified consulting
archaeologist and Native American
representative have evaluated the situation
and recorded identified tribal cultural
resources—which may include sites, features,
places, cultural and other landscapes, sacred
places, objects, animals, structures, or plants,
with cultural value to the tribe(s)—and
determined suitable mitigation measures. If
human remains are inadvertently discovered,
the County coroner shall be notified
immediately. If the coroner determines that
the remains are those of a Native American,
the coroner must contact the NAHC by phone
within 24 hours of making that determination
(Health and Safety Code § 7050[c]). The City
and the professional archaeologist shall
contact the Most Likely Descendent, as
determined by the NAHC, regarding the
remains.
(Mitigates impacts to cultural resources)
City of Santa
Rosa; Project
applicant;
Qualified
consulting
archaeologist;
Native American
representative;
County coroner;
NAHC; Most
Likely
Descendant
In the instance
tribal cultural
resources and/or
human remains
are encountered
City of Santa
Rosa Planning
and Economic
Development
Review tribal
cultural
resources
evaluation and
mitigation;
Confirm
notification of
County Clerk
and Most Likely
Descendant
As needed, in
the instance
tribal cultural
resources
and/or
human
remains are
encountered

Action 4-3.2: For projects with known or the
potential to have historic structures, the City
shall require the project to follow the Secretary
of the Interior Standards for Preservation,
Rehabilitation, Restoration, and Reconstruction
for the treatment of historic properties and the
California Historic Building Code, as
subsequently revised, supplemented, or
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Confirm
compliance
with standards
Once, prior to
project
approval

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-10 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
replaced.
(Mitigates impacts to cultural resources)
Policy 5-1.1: Prior to new development
approval, where there are known geological
hazards as shown on Figures 5-2, 5-3, and 5-4
and current maps from the United States
Geological Survey, California Geological Survey,
California Department of Water Resources,
California Office of Emergency Services, the
City shall ensure that new development,
redevelopment, and major remodels avoid or
adequately mitigate seismic and geologic
hazards through the preparation of a site-
specific geologic study prepared by a California
Certified Engineering Geologist and/or
Geotechnical Engineer and compliance with
identified measures.
(Mitigates impacts to geology and soils)

City of Santa
Rosa; Project
applicant;
California
Certified
Engineering
Geologist and/or
Geotechnical
Engineer
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review geologic
studies and
analyses
Once, prior to
project
approval

Action 5-1.1: Prior to new development
approval, the City shall ensure site-specific
geologic studies and analyses are deemed
acceptable by a California Certified Engineering
Geologist and/or Geotechnical Engineer to
appropriately mitigate hazardous conditions.
(Mitigates impacts to geology and soils)

City of Santa
Rosa; Project
applicant;
California
Certified
Engineering
Geologist and/or
Geotechnical
Engineer
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Confirm review
by a California
Certified
Engineering
Geologist
and/or
Geotechnical
Engineer
Once, prior to
project
approval

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-11
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 5-1.2: The City shall restrict
development in areas where adverse
conditions associated with known natural or
human-caused geologic hazards cannot be
effectively mitigated, as determined by a
California Certified Engineering Geologist
and/or Geotechnical Engineer.
(Mitigates impacts to geology and soils)

City of Santa
Rosa; California
Certified
Engineering
Geologist and/or
Geotechnical
Engineer
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 5-2.14: The City shall require
improvements that maintain and improve the
storm drainage system citywide and prioritize
areas needing significant investment,
consistent with the Santa Rosa Citywide Creek
Master Plan goals of preserving natural
conditions of waterways and minimizing
channelization of creeks.
(Mitigates impacts to hydrology and water
quality)

City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 5-2.15: The City shall ensure creek-side
paths and trails are consistent with the
Citywide Creek Master Plan and Bicycle and
Pedestrian Master Plan, as subsequently
revised, supplemented, or replaced, and are
incorporated into stormwater improvement
projects along creek corridors.
(Mitigates impacts to hydrology and water
quality)

City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-12 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 5-2.17: The City shall require
implementation of best management practices
for all new development to reduce discharges
of nonpoint-source pollutants to the storm
drain system.
(Mitigates impacts to hydrology and water
quality)
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Confirm
implementation
of best
management
practices
Once, prior to
project
approval

Action 5-3.8: The City shall require the
preparation of fire protection plans for new
development and major remodels in the City’s
Very High Fire Hazard Severity Zone and
WUIFA. Require that fire protection plans be
consistent with requirements of the California
Fire Code and include a risk analysis, fire
response capabilities, fire safety requirements
(e.g., defensible space, infrastructure, and
building ignition resistance), mitigation
measures, design considerations for non-
conforming fuel modifications, wildfire
education maintenance and limitations, and
evacuation plans.
(Mitigates wildfire impacts)

City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review fire
protection plans
Once, prior to
project
approval

Action 5-5.14: The City shall require all new
development projects to provide adequate
access for fire and emergency response
personnel.
(Mitigates wildfire impacts)
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review site
plans
Once, prior to
project
approval

Action 5-5.15: The City shall prohibit the
creation of new single ingress/egress roadway
conditions in the city.
(Mitigates wildfire impacts)
City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-13
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 5-5.16: The City shall retrofit existing
single-access residential neighborhoods to
include additional access routes or other
provisions to increase evacuation safety.
(Mitigates wildfire impacts)
City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 5-5.17: The City shall analyze the
capacity, viability, and safety of evacuation
routes and evacuation locations throughout
the city under a range of emergency scenarios
and incorporate the results, as necessary, into
the Safety Element of the General Plan. This
analysis will be completed as part of the City’s
Annex to the Sonoma County Multi-
Jurisdictional Hazard Mitigation Plan in 2026.
(Mitigates wildfire impacts)

City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 5-7.1: The City shall continue to require
acoustical studies prepared by qualified
acoustical consultants in accordance with
Municipal Code standards.
(Mitigates noise impacts)
City of Santa
Rosa; Project
applicant;
Qualified
acoustical
consultant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
acoustical
studies
Once, prior to
project
approval

Action 5-7.2: The City shall use the Federal
Transit Administration’s construction noise and
vibration thresholds as applicable to assess
impacts to surrounding land uses and identify
measures during the project approval process
to ensure the threshold is met prior to project
approval.

(Mitigates noise impacts)
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
acoustical
studies and
mitigation
Once, prior to
project
approval

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-14 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 5-7.3: The City shall require
development projects to reduce noise
exceeding normally acceptable levels as
identified in Figure 5-13, unless the activities
are specifically exempted by the City Council,
on the basis of community health, safety, and
welfare, such as emergency medical vehicles,
helicopters, and sirens.
(Mitigates noise impacts)

City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
acoustical
studies
Once, prior to
project
approval

Action 5-7.7: The City shall work with Caltrans
to evaluate and develop traffic noise mitigation
programs along Highway 101 and State Route

12. (Mitigates noise impacts)
City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 5-7.9: The City shall require
development projects to implement measures
to reduce noise and vibration impacts primarily
through site planning, and avoid engineering
solutions for noise and vibration mitigation,
such as sound walls, if possible.
(Mitigates noise impacts)

City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review site
plans, acoustical
studies, and
mitigation
Once, prior to
project
approval

Action 5-7.10: The City shall update the Noise
Ordinance to incorporate construction best
management practices (BMP) to minimize
construction noise, and require projects to
demonstrate compliance with the BMPs prior
to project approval.
(Mitigates noise impacts)

City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
PLACEWORKS 6-15
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 5-9.30: The City shall evaluate
stormwater capture and reuse consistent with
goals of the Santa Rosa Citywide Creek Master
Plan and the MS4 National Pollutant Discharge
Elimination System (NPDES) permit to preserve
natural conditions of waterways, minimize
channelization of creeks, and protect water
quality, and identify, educate, and label to
promote community awareness that storm
drains flow untreated into creeks.
(Mitigates impacts to hydrology and water
quality)

City of Santa
Rosa
Ongoing City of Santa
Rosa Planning
and Economic
Development
Follow Santa
Rosa General
Plan 2050
Implementation
Plan
Ongoing
Action 6-1.5: As recommended by the
California Air Resources Board, the City shall
require projects that would result in
construction activities within 1,000 feet of
residential and other land uses that are
sensitive to toxic air contaminants (e.g.,
hospitals, nursing homes, day care centers), as
measured from the property line of the
project, to prepare a construction health risk
assessment in accordance with policies and
procedures of the Office of Environmental
Health Hazard Assessment and the Bay Area Air
District (Air District) California Environmental
Quality Act (CEQA) Guidelines that identifies
mitigation measures and appropriate
enforcement mechanisms capable of reducing
potential cancer and non-cancer risks below
the Air District threshold.
(Mitigates air quality impacts)
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
construction
health risk
assessment and
mitigation
Once, prior to
project
approval

SANTA ROSA GENERAL PLAN 2050 FINAL EIR

CITY OF SANTA ROSA

MITIGATION MONITORING AND REPORTING PROGRAM
6-16 APRIL 2025
TABLE 6-1 SANTA ROSA GENERAL PLAN 2050 MITIGATION MONITORING AND REPORTING PROGRAM Mitigating General Plan Policies/Actions
Implementation Monitoring Status
Party
Responsible for
Implementation
Implementation
Timing
Agency
Responsible for
Monitoring
Monitoring
Action
Monitoring
Frequency
Is the measure applicable to the
project? (Y/N) (if no, provide
brief reason why)
Date
Completed
Action 6-1.6: The City shall require an
operational health risk assessment for new
industrial or warehousing development
projects that 1) have the potential to generate
100 or more diesel truck trips per day or have
40 or more trucks with operating diesel-
powered transport refrigeration units, and 2)
are within 1,000 feet of a sensitive land use or
Overburdened Community, as defined by the
Air District. The operational HRA shall be
prepared in accordance with policies and
procedures of the State Office of
Environmental Health Hazard Assessment and
the Air District. If the operational HRA shows
that the incremental cancer risk exceeds 10 in
a million, the noncancer hazard index of 1.0, or
the thresholds as determined by the Air
District, require the project applicant to
identify and demonstrate measures that can
reduce potential cancer and noncancer risks to
acceptable levels.
(Mitigates air quality impacts)
City of Santa
Rosa; Project
applicant
Prior to project
approval
City of Santa
Rosa Planning
and Economic
Development
Review
operational
health risk
assessment and
mitigation
Once, prior to
project
approval

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Santa Rosa City CouncilNovember 4, 2025

Santa Rosa City Council
November 4, 2025