Santa Rosa General Plan 2050
Draft Environmental Impact Report
SCH: 2023020166 | October 2024
(~ Cityof
~ SantaRosa ~7 CALIFORNIA
~ PLACEWORKS
(~ Cityof
~ SantaRosa
-;" CALIFORNIA
ORANGE COUNTY • BAY AREA • SACRAMENTO • CENTRAL COAST • LOS ANGELES • INLAND EMPIRE • SAN DIEGO PlaceWorks.com
Prepared by: PlaceWorks
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Santa Rosa General Plan 2050
Draft Environmental Impact Report
SCH: 2023020166
October 2024
(~ Cityof
~ SantaRosa "7 CALIFORNIA
~ PLACEWORKS
PLACEWORKS i
Table of Contents
INTRODUCTION ............................................................................................................................ 1-1
1.1 Proposed Action ............................................................................................................ 1-1
1.2 EIR Scope ........................................................................................................................ 1-2
1.3 Environmental Review Process ..................................................................................... 1-3
1.4 Use of the General Plan EIR .......................................................................................... 1-4 EXECUTIVE SUMMARY ................................................................................................................. 2-1
2.1 Environmental Procedures ............................................................................................ 2-2
2.2 Summary of Proposed Project...................................................................................... 2-4
2.3 Summary of Project Alternatives .................................................................................. 2-4
2.4 Issues to be Resolved .................................................................................................... 2-5
2.5 Areas of Controversy ..................................................................................................... 2-5
2.6 Summary of Significant Impacts ................................................................................. 2-6 PROJECT DESCRIPTION ............................................................................................................... 3-1
3.1 Background .................................................................................................................... 3-1
3.2 Overview ......................................................................................................................... 3-2
3.3 Location and Setting ..................................................................................................... 3-2
3.4 Planning Boundaries and EIR Study Area ................................................................... 3-3
3.5 Planning Process ............................................................................................................ 3-7
3.6 Project Objectives ......................................................................................................... 3-8
3.7 Project Components ................................................................................................... 3-10
3.8 2050 Development Projections .................................................................................. 3-28
3.9 Intended Uses of the EIR ............................................................................................. 3-29
3.10 Required Permits and Approvals ............................................................................... 3-29 ENVIRONMENTAL ANALYSIS ....................................................................................................... 4-1
4.1 Aesthetics .................................................................................................................... 4.1-1
4.2 Agricultural Resources ................................................................................................ 4.2-1
4.3 Air Quality .................................................................................................................... 4.3-1
4.4 Biological Resources ................................................................................................... 4.4-1
4.5 Cultural Resources ...................................................................................................... 4.5-1
4.6 Energy .......................................................................................................................... 4.6-1
4.7 Geology and Soils ....................................................................................................... 4.7-1
4.8 Greenhouse Gas Emissions ........................................................................................ 4.8-1
4.9 Hazards and Hazardous Materials ............................................................................ 4.9-1
4.10 Hydrology and Water Quality ................................................................................. 4.10-1
1. 2.
3. 4.
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4.11 Land Use and Planning ............................................................................................ 4.11-1
4.12 Noise .......................................................................................................................... 4.12-1
4.13 Population And Housing .......................................................................................... 4.13-1
4.14 Public Services, Parks, and Recreation .................................................................. 4.14-1
4.15 Transportation ........................................................................................................... 4.15-1
4.16 Tribal Cultural Resources .......................................................................................... 4.16-1
4.17 Utilities and Service Systems .................................................................................... 4.17-1
4.18 Wildfire ........................................................................................................................ 4.18-1 ALTERNATIVES TO THE PROPOSED PROJECT ............................................................................. 5-1
5.1 Purpose ........................................................................................................................... 5-1
5.2 Selection of a Reasonable Range of Alternatives .................................................... 5-1
5.3 Alternative A: No Project (General Plan 2035) ......................................................... 5-10
5.4 Alternative B: Increased Density ................................................................................ 5-22
5.5 Environmentally Superior Alternative......................................................................... 5-33 CEQA-REQUIRED CONCLUSIONS .............................................................................................. 6-1
6.1 Impacts Found Not to be Significant .......................................................................... 6-1
6.2 Significant and Unavoidable Impacts ........................................................................ 6-2
6.3 Growth Inducement ...................................................................................................... 6-4
6.4 Significant and Irreversible Changes ........................................................................... 6-5 ORGANIZATIONS AND PERSONS CONSULTED .......................................................................... 7-1
7.1 Lead Agency ................................................................................................................. 7-1
7.2 Organizations Consulted .............................................................................................. 7-3
7.3 Consultants ..................................................................................................................... 7-3 ACRONYMS AND ABBREVIATIONS ............................................................................................ 8-1
APPENDICES
Appendix A: Notice of Preparation and Scoping Comments
Appendix B: Air Quality and Greenhouse Gas Emissions Data Appendix C: 2020 VMT Guidelines
Appendix D: Water Supply Assessment
SOURCES
In addition to the technical appendices, all documents cited in this report and used in its preparation are hereby incorporated by reference into this Draft EIR. Copies of documents referenced herein are available for review online at www.santarosaforward.com.
5. 6.
7. 8.
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LIST OF FIGURES
Figure 3-1 Regional and Vicinity Map ........................................................................................... 3-5 Figure 3-2 General Plan 2050 Planning Boundaries and EIR Study Area .................................. 3-6 Figure 3-3 Proposed General Plan 2050 Land Use Map ........................................................... 3-17 Figure 3-4 General Plan Land Use and Zoning Revisions .......................................................... 3-19 Figure 3-5 Proposed Rezoning Sites ............................................................................................. 3-21 Figure 3-6 Proposed General Plan 2050 Areas of Change....................................................... 3-30 Figure 4-1 Priority Development Areas and Transit Priority Areas ............................................. 4-10 Figure 4.2-1 Important Farmland and Williamson Act Contracts .............................................. 4.2-6 Figure 4.2-2 CEQA Important Farmland ...................................................................................... 4.2-10 Figure 4.3-1 CES4 Indicator – Cumulative Score by Percentile ................................................ 4.3-23 Figure 4.3-2 BAAQMD Overburdened Communities................................................................. 4.3-24 Figure 4.3-3 Santa Rosa Equity Priority Areas .............................................................................. 4.3-25 Figure 4.3-4 CES4 Indicator – Pollution Burden by Percentile ................................................... 4.3-26 Figure 4.3-5 CES4 Indicator – Asthma by Percentile .................................................................. 4.3-27 Figure 4.3-6 BAAQMD Siting Recommendations ....................................................................... 4.3-28 Figure 4.4-1 Vegetative Cover ..................................................................................................... 4.4-12 Figure 4.4-2 Special-Status Plant Species and Sensitive Natural Communities ...................... 4.4-20 Figure 4.4-3 Special-Status Animal Species and Critical Habitat ............................................. 4.4-28 Figure 4.4-4 Wetlands .................................................................................................................... 4.4-39 Figure 4.7-1 Regional Faults ............................................................................................................ 4.7-8 Figure 4.7-2 Landslide Map........................................................................................................... 4.7-11 Figure 4.7-3 Liquefaction Susceptibility ....................................................................................... 4.7-12 Figure 4.10-1 Subwatersheds ........................................................................................................ 4.10-16 Figure 4.10-2 Groundwater Subbasins ........................................................................................ 4.10-17 Figure 4.10-3 Potential Flood Hazards ......................................................................................... 4.10-22 Figure 4.10-4 Dam Inundation Zones ........................................................................................... 4.10-25 Figure 4.12-1 Long-Term and Short-Term Noise Measurement Locations ............................... 4.12-13 Figure 4.12-2 Traffic Noise Contours for the Existing (2019) Scenario ....................................... 4.12-26 Figure 4.12-3 Charles M. Schulz Sonoma County Airport 2030 Noise Contours ..................... 4.12-27 Figure 4.12-4 Traffic Noise Contours for the Existing Plus Project Scenario .............................. 4.12-46 Figure 4.12-5 Traffic Noise Contours for the Future Plus Project (2050) Scenario ................... 4.12-47 Figure 4.14-1 Fire and Police Stations ............................................................................................ 4.14-7 Figure 4.14-2 Schools in the EIR Study Area ................................................................................ 4.14-21 Figure 4.15-1 Roadway Network .................................................................................................... 4.15-9 Figure 4.15-2 Existing Transit Providers and Routes ..................................................................... 4.15-13 Figure 4.15-3 Existing Bicycle Facilities ......................................................................................... 4.15-16 Figure 4.17-1 Water Distribution System ...................................................................................... 4.17-15 Figure 4.17-2 City of Santa Rosa Sewer Collection System ....................................................... 4.17-33 Figure 4.17-3 City of Santa Rosa Stormwater System ................................................................ 4.17-44 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Figure 4.18-1 Fire Hazard Severity Zones ..................................................................................... 4.18-18 Figure 4.18-2 General Plan Land Uses in Wildland Urban Interface Fire Areas ...................... 4.18-19 Figure 4.18-3 CPUC Fire-Threat Map ............................................................................................ 4.18-20 Figure 4.18-4 Historic Wildfire Perimeters ..................................................................................... 4.18-21 Figure 4.18-5 Evacuation Routes and Evacuation-Constrained Residential Parcels ............ 4.18-26
LIST OF TABLES
Table 2-1 Summary of Significant Impacts and Mitigating Policies and Actions .................... 2-7 Table 3-1 EIR Study Area ................................................................................................................ 3-7 Table 3-2 General Plan Land Use and Zoning Revisions .......................................................... 3-18 Table 3-3 Proposed Rezoning Sites ............................................................................................. 3-20 Table 3-4 Major Planned Roadway Circulation Improvements .............................................. 3-22 Table 3-5 Major Planned Multimodal Circulation Improvements ........................................... 3-23 Table 3-6 Proposed 2050 Buildout Projections in the EIR Study Area ...................................... 3-28 Table 4-1 Proposed General Plan 2050 Areas of Change by PDA/TPA ................................. 4-11 Table 4.2-1 Sonoma County Agricultural Land Conversion 1984 to 2018 ................................ 4.2-5 Table 4.2-2 Important Farmland by Acreage in the EIR Study Area ........................................ 4.2-5 Table 4.2-3 Qualifying Farmland Potentially Converted to Other Uses at General Plan Buildout ........................................................................................................................ 4.2-9 Table 4.3-1 Criteria Air Pollutant Health Effects Summary .......................................................... 4.3-2 Table 4.3-2 CARB Recommendations for Siting New Sensitive Land Uses ............................... 4.3-6 Table 4.3-3 Ambient Air Quality Standards for Criteria Pollutants ............................................. 4.3-8 Table 4.3-4 Attainment Status of Criteria Pollutants in the San Francisco Bay Area Air Basin ........................................................................................................................... 4.3-19 Table 4.3-5 Ambient Air Quality Monitoring Summary ............................................................. 4.3-20 Table 4.3-6 Existing EIR Study Area Regional Criteria Air Pollutant Emissions Inventory ........ 4.3-29 Table 4.3-7 BAAQMD Regional (Mass Emissions) Criteria Air Pollutant Significance Thresholds ................................................................................................................... 4.3-31
Table 4.3-8 Control Measures from the BAAQMD 2017 Clean Air Plan.................................. 4.3-40 Table 4.3-9 Comparison of the Change in Population and Daily VMT in the EIR Study Area ............................................................................................................................ 4.3-51 Table 4.3-10 Proposed Project Criteria Air Pollutant Emissions Forecast (Scenario 1, Comparison to Existing Conditions) ........................................................................ 4.3-57
Table 4.3-11 Net Change in Regional Criteria Air Pollutant Emissions Forecast (Scenario 2, Comparison to Future No Project Conditions) .................................................. 4.3-58
Table 4.4-1 Estimated Vegetation Cover in the EIR Study Area ............................................. 4.4-11 Table 4.4-2 Special-Status Plant Species in the EIR Study Area ............................................... 4.4-21 Table 4.4-3 Special-Status Animal Species in the EIR Study Area ........................................... 4.4-30 Table 4.5-1 Historical Resources in the EIR Study Area ............................................................. 4.5-10 Table 4.5-2 Buildings Classified as Locally Important in the EIR Study Area ........................... 4.5-11 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Table 4.6-1 Estimated Existing Electricity and Natural Gas Demand ..................................... 4.6-15 Table 4.6-2 Existing Operation-Related Annual VMT ................................................................ 4.6-16 Table 4.6-3 Year 2050 Forecast Electricity Consumption ......................................................... 4.6-19 Table 4.6-4 Year 2050 Forecast Natural Gas Consumption ..................................................... 4.6-20 Table 4.6-5 Operation-Related Annual Fuel Usage: Net Change from Existing ................... 4.6-24 Table 4.7-1 Distances and Directions to Active Faults ............................................................... 4.7-9 Table 4.8-1 Greenhouse Gas Emissions and Their Relative Global Warming Potential Compared to CO2 ...................................................................................................... 4.8-2 Table 4.8-2 Summary of Greenhouse Gas Emissions Risk to California..................................... 4.8-5 Table 4.8-3 Priority Strategies for Local Government Climate Action Plans ............................ 4.8-9 Table 4.8-4 Existing Greenhouse Gas Emissions Factors ........................................................... 4.8-20 Table 4.8-5 Existing Greenhouse Gas Emissions Inventory in the EIR Study Area .................. 4.8-21 Table 4.8-6 EIR Study Area GHG Emissions Business-as-Usual Forecast .................................. 4.8-24 Table 4.8-7 Proposed GHG Reduction Measures ..................................................................... 4.8-26 Table 4.8-8 GHG Reduction Target Analysis with the Proposed GHG Reduction Strategy ...................................................................................................................... 4.8-27
Table 4.9-1 Active Hazardous Materials Sites ............................................................................ 4.9-12 Table 4.10-1 Designated Beneficial Uses in the EIR Study Area .............................................. 4.10-20 Table 4.10-2 Listed Impaired Water Bodies in the EIR Study Area ........................................... 4.10-21 Table 4.10-3 Dams With Inundation zones in the EIR Study Area ............................................ 4.10-24 Table 4.12-1 Typical Noise Levels .................................................................................................. 4.12-4 Table 4.12-2 Human and Architectural Reactions to Typical Vibration Levels in Peak Particle Velocity ........................................................................................................ 4.12-5 Table 4.12-3 Human Reaction to Typical Vibration Levels in Vibration Decibels .................... 4.12-5 Table 4.12-4 State Community Noise and Land Use Compatibility .......................................... 4.12-8 Table 4.12-5 Ambient Base Noise Level Criteria ........................................................................ 4.12-10 Table 4.12-6 Summary of Long-Term Noise Monitoring ............................................................ 4.12-14 Table 4.12-7 Summary of Short-Term Noise Monitoring ............................................................ 4.12-15 Table 4.12-8 Existing Noise Levels in the EIR Study Area ........................................................... 4.12-16 Table 4.12-9 Groundborne Vibration Criteria: Architectural Damage .................................. 4.12-30 Table 4.12-10 FTA Groundborne Vibration Impact Criteria ....................................................... 4.12-30 Table 4.12-11 Typical Ranges of Noise Levels at 50 Feet from Construction Sites (dBA Leq) . 4.12-32 Table 4.12-12 Construction Equipment 50-Foot Noise Emission Limits ...................................... 4.12-32 Table 4.12-13 Existing, Existing Plus Project, and Future Plus Project Noise Levels in the EIR Study Area ............................................................................................................... 4.12-37
Table 4.12-14 Reference Vibration Source Levels for Construction Equipment ..................... 4.12-51 Table 4.13-1 Total Population, 2010 to 2019 ................................................................................ 4.13-3 Table 4.13-2 Housing Units, 2010 to 2019 ...................................................................................... 4.13-4 Table 4.13-3 Santa Rosa Regional Housing Needs Allocation .................................................. 4.13-5 Table 4.13-4 Proposed General Plan 2050 Growth Projections ................................................. 4.13-6 Table 4.13-5 Santa Rosa Projected Regional Housing Needs Allocation ................................ 4.13-7 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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Table 4.14-1 Santa Rosa School District’s Student Enrollment and School Capacity .......... 4.14-20 Table 4.14-2 Bellevue Union School District Student Enrollment and School Capacity ....... 4.14-20 Table 4.14-3 Bennett Valley School District Student Enrollment and School Capacity ....... 4.14-23 Table 4.14-4 Kenwood School District Student Enrollment and School Capacity ................ 4.14-24 Table 4.14-5 Piner-Olivet School District Student Enrollment and School Capacity ............. 4.14-25 Table 4.14-6 Rincon Valley Unified School District Student Enrollment and School Capacity .................................................................................................................. 4.14-26 Table 4.14-7 Roseland School District Student Enrollment and School Capacity ................ 4.14-28 Table 4.14-8 Santa Rosa City School District Student Enrollment and School Capacity ..... 4.14-30 Table 4.14-9 Wright Elementary School District Student Enrollment and School Capacity . 4.14-32 Table 4.14-10 Private Schools Student Enrollment and School Capacity ................................ 4.14-33 Table 4.14-11 Existing Neighborhood and Community Parks and Acreages ......................... 4.14-46 Table 4.15-1 Existing VMT Performance Metrics ........................................................................ 4.15-12 Table 4.15-2 Daily VMT Performance Metrics for the EIR Study Area ..................................... 4.15-26 Table 4.15-3 Changes in Arterial Lane Miles .............................................................................. 4.15-30 Table 4.16-1 Tribal Consultation Requests and City Responses ................................................ 4.16-9 Table 4.17-1 Outdoor Water Use Standards for Residential and Commercial Accounts ...... 4.17-5 Table 4.17-2 Santa Rosa Municipal Groundwater Wells .......................................................... 4.17-16 Table 4.17-3 City of Santa Rosa Existing and Future Water Supplies (acre-feet) ................. 4.17-17 Table 4.17-4 Santa Rosa Existing Water Demand .................................................................... 4.17-17 Table 4.17-5 Santa Rosa Projected Normal, Dry, and Multiple Dry Year Supply and Demand (AFY) ........................................................................................................ 4.17-18 Table 4.17-6 Proposed General Plan 2050 Buildout ................................................................. 4.17-20 Table 4.17-7 Water Demand Increase: Proposed General Plan 2050 .................................. 4.17-21 Table 4.17-8 Total Water Demand, 2050 ................................................................................... 4.17-21 Table 4.17-9 Water Supply and Demand with Proposed General Plan 2050 Buildout (AFY) ......................................................................................................................... 4.17-22 Table 4.17-10 Wastewater Demand Increase, Proposed General Plan 2050 ......................... 4.17-36 Table 4.17-11 Central Landfill Data .............................................................................................. 4.17-54 Table 4.17-12 Increase in Solid Waste Generation Rates at 2050 Buildout .............................. 4.17-55 Table 4.17-13 Year 2050 Forecast Electricity Consumption ....................................................... 4.17-66 Table 4.17-14 Year 2050 Forecast Natural Gas Consumption ................................................... 4.17-66 Table 5-1 Forecast Additional Growth for the Proposed Project and the Alternatives to the Proposed Project ................................................................................................ 5-7 Table 5-2 Impact Comparison of the Proposed Project and the Alternatives by Environmental Topic ...................................................................................................... 5-7
Table 5-3 Comparison of Significant and Unavoidable Impacts of the Proposed Project and the Alternatives by Environmental Topic and Standard of Significance .................................................................................................................... 5-8
Table 5-4 2019 to 2050 Growth Under the Proposed Project and Alternative A .................. 5-11 PLACEWORKS 1-1
Introduction
Pursuant to the California Environmental Quality Act (CEQA) Guidelines, Chapter 14 of the California Code of Regulations, Section 15378(a), 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) is considered a “project” subject to environmental review. The implementation of these plans is “an action [undertaken by a public agency] which has the potential for resulting in either a direct physical change in the environment or a reasonably foreseeable indirect physical change in the environment.” This Draft Environmental Impact Report (EIR) provides an assessment of the potential environmental consequences of adoption and implementation of the proposed Santa Rosa General Plan 2050, associated Specific Plan and SRCC amendments, and GHG Reduction Strategy, herein referred to together or separately as the “proposed project.”
This Draft EIR identifies mitigation measures and alternatives to the proposed project that would avoid or reduce significant impacts. This Draft EIR compares the development of the proposed project with the existing baseline condition, described in detail in Chapter 4.0, Environmental Analysis, of this Draft EIR.
The City of Santa Rosa (City) is the lead agency for the proposed project. This assessment is intended to inform the City’s decision makers, other responsible agencies, and the public of the nature of the proposed project and its effect on the environment.
1.1 PROPOSED ACTION
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, 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.
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The environmental analysis in this Draft EIR assumes that the adoption and implementation of the proposed project would result in up to 24,090 new housing units, 65,766 new residents, and 14,091 new jobs by 2050. See Chapter 3, Project Description, of this Draft EIR for additional details on the proposed project. See Chapter 5, Alternatives to the Proposed Project, of this Draft EIR for a comparison of the current General Plan 2035 (No Project) and the proposed General Plan 2050.
1.2 EIR SCOPE
This EIR is a program EIR that analyzes the adoption and implementation of the proposed project. This is in contrast to a project-level EIR, which is used to identify and analyze the potential impacts of site- specific construction and operation. CEQA1 and the CEQA Guidelines2 allow the lead agencies to prepare a number of types of EIRs. Different types of EIRs are used for varying situations and intended uses. CEQA Guidelines Section 15168 states that program EIRs are appropriate when a project consists of a series of actions related to the issuance of rules, regulations, and other planning criteria.
In this case, the proposed project that is the subject of this EIR consists of long-term plans and a set of regulatory changes that would be implemented over time as policy documents and regulations guiding future development activities and City actions. No specific development projects are proposed as part of the proposed project. Therefore, this EIR is a program-level EIR that analyzes the potential environmental effects of the adoption and implementation of the proposed project. As a program EIR, it does not evaluate the impacts of individual projects that may be proposed in the future under the proposed project. However, if the program EIR addresses the program’s effects as specifically and comprehensively as is reasonably possible, and later activities are within the scope of the effects examined in the program EIR, then additional environmental review may not be required for those future projects. 3 When a program EIR is relied on for a subsequent activity, the lead agency must incorporate feasible mitigation measures and alternatives developed in the program EIR into the subsequent activities (CEQA Guidelines Section 15168[c][3]). If a subsequent activity would have effects that are not within the scope of the program EIR, the lead agency must prepare a new Initial Study leading to a Negative Declaration, a Mitigated Negative Declaration, or an EIR, unless the activity qualifies for an exemption. For these subsequent environmental review documents, this program EIR will serve as the first-tier environmental analysis. The program EIR can also serve to streamline future environmental review of subsequent projects.
1 The CEQA Statute is found at Public Resources Code, Division 13, Environmental Quality, Sections 21000 to 21189. 2 The CEQA Guidelines are found at California Code of Regulations, Title 14, Natural Resources, Division 6, Resources Agency, Chapter 3, Guidelines for Implementation of the California Environmental Quality Act, Sections 15000 to 15387. 3 CEQA Guidelines Section 15168(c) and CEQA streamlining provisions.
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1.3 ENVIRONMENTAL REVIEW PROCESS
1.3.1 DRAFT EIR
Pursuant to CEQA Section 21080(d) and CEQA Guidelines Section 15063, the City determined that the proposed project could result in potentially significant environmental impacts and that a program EIR would be required. In compliance with CEQA Section 21080.4, the City circulated a Notice of Preparation (NOP) of an EIR for the proposed project to the Office of Planning and Research State Clearinghouse and interested agencies and persons on February 7, 2023, for a 30-day review period. A public Scoping Meeting was held virtually on Monday, February 27, 2023, at 5:30 p.m. The NOP and scoping process solicited comments from responsible and trustee agencies, as well as interested parties regarding the scope of the environmental analysis to be conducted in the Draft EIR. Appendix A, Notice of Preparation and Scoping Comments, of this Draft EIR contains the NOP as well as the comments received by the City in response to the NOP .
This Draft EIR will be available for review by the public and interested parties, agencies, and organizations for a 45-day comment period starting Monday, October 7, 2024, and ending Wednesday, November 20, 2024. The Planning Commission will conduct a public hearing during this period to receive comments on the Draft EIR. During the comment period, the public is invited to submit written comments via mail or email on the Draft EIR to the City of Santa Rosa Planning and Economic Development Department by 5:00 p.m. on Wednesday, November 20, 2024. Comments may also be hand-delivered to the Planning and Economic Development Department, Room 3, by this deadline.
Written comments should be submitted to Amy Nicholson to the address or email below with “Santa Rosa General Plan 2050 EIR” as the subject.
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
Email: a [email protected]
1.3.2 FINAL EIR
After completion of the 45-day review period for the Draft EIR, the City will review all written comments received and prepare written responses to each comment on the adequacy of the Draft EIR. A Final EIR will then be prepared, which contains all of the comments received, responses to comments raising environmental issues, and any changes to the Draft EIR. The Final EIR will then be presented to the Planning Commission where a public hearing will allow for public comment on the Final EIR and to consider recommendation for certification of the Final EIR. Following the public hearing, the Final EIR will be presented to the City Council for consideration of the certification as the environmental document for the proposed project. All persons who commented on the Draft EIR and provided contact information will SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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be notified of the availability of the Final EIR and the date of the public hearing, which is tentatively scheduled to be held in early 2025.
All responses to comments submitted on the Draft EIR by agencies will be provided to those agencies at least 10 days prior to certification of the EIR. The City Council will make findings regarding the extent and nature of the impacts as presented in the Final EIR. The Final EIR will need to be certified as having been prepared in compliance with CEQA by the City prior to deciding to approve or deny the proposed project.
Public input is encouraged at all public hearings before the City.
If the City Council certifies the EIR, it may then consider action on the proposed project. If approved, the City Council would adopt and incorporate into the project all feasible mitigation measures identified in the EIR and may also require other feasible mitigation measures.
In some cases, the City Council may find that certain mitigation measures are outside the jurisdiction of the City to implement, or that no feasible mitigation measures have been identified for a given significant impact. In that case, the City Council, pursuant to CEQA Guidelines Section 15093, may nonetheless determine that economic, legal, social, technological, or other benefits of the proposed project outweigh the unavoidable, significant effects on the environment.
1.3.3 MITIGATION MONITORING
CEQA Section 21081.6 requires that the lead agency adopt a Mitigation Monitoring and Reporting Program (MMRP) for any project for which it has made findings pursuant to CEQA Section 21081 or adopted a Negative Declaration pursuant to CEQA Section 21080(c). Such a program is intended to ensure the implementation of all mitigation measures adopted through the preparation of an EIR or Negative Declaration. If mitigation measures are required, the MMRP for the proposed project will be completed congruently as part of the Final EIR process.
1.4 USE OF THE GENERAL PLAN EIR
1.4.1 TIERING PROCESS
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. CEQA and the CEQA Guidelines encourage the use of tiered environmental documents to reduce delays and excessive paperwork in the environmental review process. This is accomplished in tiered documents by eliminating repetitive analyses of issues that were adequately addressed in the program EIR and by incorporating those analyses by reference.
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CEQA Guidelines Section 15168(d) provides for simplifying the preparation of environmental documents by incorporating by reference analyses and discussions. Where an EIR has been prepared or certified for a program or plan, the environmental review for a later activity consistent with the program or plan should be limited to effects that were not analyzed as significant in the prior EIR or that are susceptible to substantial reduction or avoidance (CEQA Guidelines Section 15152[d]).
By tiering from the program EIR, the environmental analysis for a future project would rely on the program EIR for the following:
A discussion of general background and setting information for environmental topic areas; Overall growth-related issues;
Issues that were evaluated in sufficient detail in the program EIR for which there is no significant new information or change in circumstances that would require further analysis; Assessment of cumulative impacts; and
Mitigation measures adopted and incorporated into the proposed project.
BASE RESOURCE FOR GENERAL PLAN IMPLEMENTATION AND
REVIEW OF FUTURE DEVELOPMENT PROJECTS
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 document will assist in guiding the assessment of projects and provide environmental review tiering, where appropriate. Currently, the City completes the following steps in reviewing development projects, which will be carried forward under the proposed General Plan 2050 if adopted.
Project Consistency with the General Plan and City Codes. 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.
Projects Subject to Environmental Review. For future development projects subject to environmental review, the resources contained in this EIR and carried forward in the General Plan 2050 will guide the scope of this review. For project-level environmental review, many of the topic areas studied in this program EIR will adequately cover and provide environmental clearance for the project. However, the preparation of site-specific studies and reports may be necessary based on the location and nature of the development project. The resources presented in this program EIR will assist in determining when and where a special, site-specific study is warranted. The City will develop a checklist that will be used as a guide for determining the scope of environmental analysis required for subsequent projects. Projects Exempt from Environmental Review. CEQA includes a long list of environmental review exemptions. Some of the future development projects may be exempt from environmental review as the project impacts will be adequately covered by this program EIR. However, many of the CEQA exemptions require compliance with specific criteria for the development project to qualify for the
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exemption. The resources contained in this EIR and carried forward in General Plan 2050 will be used to determine if the CEQA-prescribed criteria have been met to qualify for the exemption. One example of a CEQA exemption is for projects that are infill development and consistent with the General Plan land use designation and zoning district. CEQA provides for these types of projects to conduct streamlined review under CEQA Guidelines Section 15332 and CEQA Guidelines Section 15138.3 where the project meets certain criteria.
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Executive Summary
This chapter presents an overview 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 amendments, and Community-wide Greenhouse Gas Reduction Strategy (GHG Reduction Strategy) herein referred to together or separately as the “proposed project.” This chapter also provides a summary of the alternatives to the proposed project, identifies issues to be resolved, areas of controversy, and conclusions of the analyses contained in Chapters 4.1 through 4.18 of this Draft Environmental Impact Report (EIR). For a complete description of the proposed project, see Chapter 3, Project Description, of this Draft EIR. For a discussion of alternatives to the proposed project, see Chapter 5, Alternatives to the Proposed Project, of this Draft EIR.
This Draft EIR addresses the environmental effects associated with adoption and implementation of the proposed project. The California Environmental Quality Act (CEQA) requires that local government agencies, prior to taking action on projects over which they have discretionary approval authority, consider the environmental consequences of such projects. An EIR is a public document designed to provide the public, local, and State governmental agency decision makers with an analysis of potential environmental consequences to support informed decision making.
This Draft EIR has been prepared pursuant to the requirements of CEQA 1 and the CEQA Guidelines2 to
determine if approval of the identified discretionary actions and related subsequent development could have a significant physical impact on the environment. As lead agency, the City of Santa Rosa (City) has reviewed and revised as necessary all submitted drafts, technical studies, and reports to reflect its own independent judgment, including reliance on applicable City technical personnel and review of all technical reports. Information for this Draft EIR was obtained from on-site field observations; discussions with public service agencies; analysis of adopted plans and policies; review of available studies, reports, data, and similar literature in the public domain; and specialized environmental assessments (e.g., air quality, cultural resources, biological resources, greenhouse gas emissions, noise, transportation, tribal cultural resources, and utilities and service systems).
1 The CEQA Statute is found at Public Resources Code, Division 13, Environmental Quality, Sections 21000 to 21189. 2 The CEQA Guidelines are found at California Code of Regulations, Title 14, Natural Resources, Division 6, Resources Agency, Chapter 3, Guidelines for Implementation of the California Environmental Quality Act, Sections 15000 to 15387.
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2.1 ENVIRONMENTAL PROCEDURES
This Draft EIR has been prepared to assess the environmental effects associated with implementation of the proposed project. The main objectives of this document, as established by CEQA, are:
To disclose to decision makers and the public the significant environmental effects of proposed activities.
To identify ways to avoid or reduce environmental damage. To prevent environmental damage by requiring implementation of feasible alternatives or mitigation measures.
To disclose to the public reasons for agency approval of projects with significant environmental effects.
To foster interagency coordination in the review of projects. To enhance public participation in the planning process.
An EIR is the most comprehensive form of environmental documentation identified in the CEQA statute and CEQA Guidelines. It provides the information needed to assess the environmental consequences of a proposed project, to the extent feasible. EIRs are intended to provide an objective, factually supported, full-disclosure analysis of the environmental consequences associated with a proposed project that has the potential to result in significant, adverse environmental impacts. An EIR is also one of various decision- making tools used by a lead agency to consider the merits and disadvantages of a project that is subject to its discretionary authority. Prior to approving a proposed project, the lead agency must consider the information contained in the EIR, determine whether the EIR was properly prepared in accordance with CEQA and the CEQA Guidelines, determine that it reflects the independent judgment of the lead agency, adopt findings concerning the project’s significant environmental impacts and alternatives, and adopt a Statement of Overriding Considerations
3 if the proposed project would result in significant and unavoidable impacts.
2.1.1 REPORT ORGANIZATION
This Draft EIR is organized into the following chapters:
Chapter 1, Introduction. Provides an overview describing the Draft EIR. Chapter 2, Executive Summary. Summarizes environmental consequences that would result from implementation of the proposed project, describes recommended mitigation measures, and indicates the level of significance of environmental impacts with and without mitigation. Chapter 3, Project Description. Describes the proposed project in detail, including the characteristics, objectives, and the structural and technical elements of the proposed action. Chapter 4, Environmental Analysis. Organized into Chapters 4.1 through 4.18 corresponding to the environmental resource categories identified in CEQA Guidelines Appendix G, Environmental Checklist, these chapters provide a description of the physical environmental conditions in the vicinity of the
3 CEQA Guidelines Section 15093.
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proposed project as they existed at the time the Notice of Preparation was published, from both a local and regional perspective. Additionally, this chapter provides an analysis of the potential environmental impacts of the proposed project, and recommended mitigation measures, if required, to reduce the impacts to less than significant where possible, and to reduce their magnitude or significance when impacts cannot be reduced to a less-than-significant level. The environmental setting included in each chapter provides baseline physical conditions, which provides a context that the lead agency uses to determine the significance of environmental impacts resulting from the proposed project. Each chapter also includes a description of the thresholds used to determine if a significant impact would occur, the methodology to identify and evaluate the potential impacts of the proposed project, and the potential cumulative impacts associated with the proposed project. Chapter 5, Alternatives to the Proposed Project. Considers alternatives to the proposed project, including the CEQA-required “No Project Alternative” and “Environmentally Superior Alternative.” Chapter 6, CEQA-Required Conclusions. Discusses growth inducement, unavoidable significant effects, and significant irreversible changes as a result of the proposed project. Chapter 7, Organizations and Persons Consulted. Lists the people and organizations that were contacted during the preparation of this EIR for the proposed project. Chapter 8, Acronyms and Abbreviations. Lists the common acronyms and abbreviations in this Draft EIR.
Appendices: The appendices for this document contain the following supporting documents:
Appendix A: Notice of Preparation and Scoping Comments Appendix B: Air Quality and Greenhouse Gas Emissions Data Appendix C: 2020 VMT Guidelines
Appendix D: Water Supply Assessment
2.1.2 TYPE AND PURPOSE OF THIS EIR
According to CEQA Guidelines Section 15121(a), the purpose of an EIR is to inform public agency decision makers and the public generally of the significant environmental effects of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project.
As described in the CEQA Guidelines, different types of EIRs are used for varying situations and intended uses. Because of the long-term planning horizon of the proposed project and the permitting, planning, and development actions that are related both geographically and as logical parts in the chain of contemplated actions for implementation, this EIR has been prepared as a program EIR for the proposed project, pursuant to CEQA Guidelines Section 15168.
Once a program EIR has been certified, subsequent activities within the program must be evaluated to determine whether additional CEQA review needs to be prepared. However, if the program EIR addresses the program’s effects as specifically and comprehensively as possible, subsequent activities could be found to be within the program EIR scope, and additional environmental review may not be required (CEQA Guidelines Section 15168[c]). When a program EIR is relied on for a subsequent activity, the lead agency must incorporate feasible mitigation measures and alternatives developed in the program EIR into SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
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the subsequent actions (CEQA Guidelines Section 15168[c][3]). If a subsequent activity would have effects that are not within the scope of a program EIR, the lead agency must prepare a new Initial Study leading to a Negative Declaration, a Mitigated Negative Declaration, or an EIR. For these subsequent environmental review documents, this Program EIR will serve as the first-tier environmental analysis.
2.2 SUMMARY OF PROPOSED PROJECT
The proposed project would replace the City’s existing General Plan with an updated General Plan. The existing General Plan was prepared in 2009 and included a horizon year of 2035. While this horizon year is still approximately 11 years away, in the years between 2009 and 2022, Santa Rosa has experienced low housing production and increased homelessness, the destruction of housing and displacement of residents by the Tubbs fire, the impact of cannabis business activity on industrial and commercial land, and the annexation of the Roseland community into the city limit. A number of State and federal laws guiding General Plan policies have also been updated during this time. As such, there is a need to take stock of the existing situation and plan for sustainable development in line with a vision. The proposed General Plan 2050 focuses on meeting current community requirements and future needs.
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, 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.
2.3 SUMMARY OF PROJECT ALTERNATIVES
This Draft EIR analyzes alternatives to the proposed project that are designed to reduce the significant environmental impacts of the proposed project and feasibly attain most of the proposed project objectives. There is no set methodology for comparing the alternatives or determining the environmentally superior alternative under CEQA. Identification of the environmentally superior alternative involves weighing and balancing all of the environmental resource areas by the City. The following alternatives to the proposed project were considered and analyzed in detail:
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Alternative A: No Project (Current General Plan). Consistent with CEQA Guidelines Section 15126.6(e)(2), Alternative A presents the No Project scenario. Accordingly, under this alternative, the proposed project would not be adopted or implemented, and further development in the city would continue to be subject to existing policies, regulations, development standards, and land use designations under the existing General Plan 2035, existing Zoning districts, and a new GHG Reduction Strategy would not be implemented.
Alternative B: Increased Density Alternative. Alternative B, like the proposed project, would focus future commercial and residential growth in Priority Development Areas (PDA) and/or Transit Priority Areas (TPA) and in 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 would occur 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 in Areas of Change that are in or adjacent to PDAs and/or TPAs would be redesignated as Medium High density residential.
Chapter 5, Alternatives to the Proposed Project, of this Draft EIR includes a complete discussion of these alternatives. As discussed in Chapter 5, Alternative B is the Environmentally Superior Alternative pursuant to CEQA Guidelines Section 15126.6.
2.4 ISSUES TO BE RESOLVED
Section 15123(b)(3) of the CEQA Guidelines requires that an EIR identify issues to be resolved, including the choice among alternatives and whether or how to mitigate significant impacts. With regard to the proposed project, the major issues to be resolved include decisions by the City of Santa Rosa, as lead agency, related to:
Whether this Draft EIR adequately describes the environmental impacts of the proposed project. Whether the benefits of the proposed project override those environmental impacts that cannot be feasibly avoided or mitigated to a level of insignificance. Whether the proposed land use changes are compatible with the character of the existing area. Whether the identified goals, policies, or mitigation measures should be adopted or modified. Whether there are other mitigation measures that should be applied to the proposed project besides those mitigation measures identified in the Draft EIR.
Whether there are any alternatives to the proposed project that would substantially lessen any of the significant impacts of the proposed project and achieve most of the basic objectives.
2.5 AREAS OF CONTROVERSY
The City issued a Notice of Preparation (NOP) on February 7, 2023. The CEQA-mandated scoping period for this EIR was between February 7, 2023, and March 8, 2023, during which time interested agencies and the public could submit comments about the potential environmental impacts of the proposed project.
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During this time, the City received comment letters from a variety of State and local agencies as well as several organizations and members of the public. Appendix A, Notice of Preparation and Scoping Comments, of this Draft EIR contains the NOP as well as the comments received by the City in response to the NOP .
The following is a discussion of issues that are likely to be of particular concern to agencies and interested members of the public during the environmental review process. Though every concern applicable to the CEQA process is addressed in this Draft EIR, this list is not necessarily exhaustive, but rather attempts to capture concerns that are likely to generate the greatest interest based on the input received during the scoping process.
Protection of biological resources
Adequacy of existing water supply and increased water demand Annexation of land into the city limit
Protection from radiofrequency radiation
2.6 SUMMARY OF SIGNIFICANT IMPACTS
Table 2-1, Summary of Significant Impacts and Mitigating Policies and Actions, summarizes the conclusions of the environmental analysis in this Draft EIR and presents a summary of the identified significant impacts and the proposed mitigating General Plan 2050 policies and actions. 4 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 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 this Draft 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 this 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 this Draft EIR
.
4 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.
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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.”
5 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.”
6 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.
Significant and
unavoidable
5 Public Resources Code, Section 21002.1(b).
6 Public Resources Code, Section 21061.1
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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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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 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 SANTA ROSA GENERAL PLAN 2050 DRAFT 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
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Mitigation
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 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
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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.
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: Require projects that exceed the Bay Area Air Quality Management District (BAAQMD) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level. *Action 3-6.32: Continue to implement the Bay Area Air Quality Management District (BAAQMD) Basic Control Measures included in the latest version of BAAQMD’s CEQA Air Quality Guidelines to control fugitive dust (i.e., particulate matter PM
2.5 and PM10) during demolition, ground-disturbing activities, and/or construction.
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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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 (NOX) and
particulate matter (PM2.5 and PM10).
General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-6.31: Require projects that exceed the Bay Area Air Quality Management District (BAAQMD) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level.
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 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.
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Mitigation
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 this Draft EIR.
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 this Draft EIR provides the San Joaquin Valley Air Pollution Control District’s amicus brief, and South Coast Air Quality Management District’s amicus brief).
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CITY OF SANTA ROSA
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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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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. 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 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.
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Impact AIR-3a: Construction activities
associated with potential future
development could expose nearby
receptors to substantial concentrations of
toxic air contaminants.
General Plan 2050 Chapter 6, Health, Equity, Environmental Justice, and Parks *Action 6-1.5: As recommended by the California Air Resources Board, 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 (BAAQMD) CEQA Guidelines that identifies mitigation measures and appropriate enforcement mechanisms capable of reducing potential cancer and non-cancer risks below the BAAQMD threshold.
Less than
significant
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: 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 BAAQMD. The operational HRA shall 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 incremental cancer risk exceeds 10 in a million, the noncancer hazard index of 1.0, or the thresholds as determined by BAAQMD, 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 SANTA ROSA GENERAL PLAN 2050 DRAFT 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
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they are capable of reducing potential cancer, noncancer risks, and PM2.5 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 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 PM
2.5 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: Require projects that exceed the Bay Area Air Quality Management District (BAAQMD) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level. *Action 3-6.32: Continue to implement the Bay Area Air Quality Management District (BAAQMD) Basic Control Measures included in the latest version of BAAQMD’s CEQA Air Quality Guidelines to control fugitive dust (i.e., particulate matter PM
2.5 and PM10) during demolition, ground-disturbing activities, and/or construction.
Significant and
unavoidable
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General Plan 2050 Chapter 6, Health, Equity, Environmental Justice, and Parks *Action 6-1.5: As recommended by the California Air Resources Board, 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 (BAAQMD) CEQA Guidelines that identifies mitigation measures and appropriate enforcement mechanisms capable of reducing potential cancer and non-cancer risks below the BAAQMD threshold. *Action 6-1.6: 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 BAAQMD. The operational HRA shall 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 incremental cancer risk exceeds 10 in a million, the noncancer hazard index of 1.0, or the thresholds as determined by BAAQMD, 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: Continue to consult with the California Department of Fish and Wildlife 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 UGB.
Less than
significant
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*Action 3-5.10: 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. *Action 3-5.11: Require a qualified biologist to prepare a biological resource assessment 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. *Action 3-5.12: Require that construction or other ground-disturbing activities avoid nests of native birds when in active use by implementing protection measures 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.
*Action 3-5.13: Develop and adopt a bird-safe design ordinance to provide specific criteria and refined guidelines as part of design review 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.
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.
General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-5.7: Continue to consult with the California Department of Fish and Wildlife 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 UGB.
*Action 3-5.10: 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. *Action 3-5.11: Require a qualified biologist to prepare a biological resource assessment 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. *Action 3-5.19: Require 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.
Less than
significant
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*Action 3-5.20: Require new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans 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: 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. *Action 3-5.11: Require a qualified biologist to prepare a biological resource assessment 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.
Less than
significant
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: Follow the Secretary of the Interior Standards for Preservation, Rehabilitation, Restoration, and Reconstruction for the treatment of historic properties. *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
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CITY OF SANTA ROSA
EXECUTIVE SUMMARY
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*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: Require 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. *Action 3-5.20: Require new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans 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: Continue to review proposed developments in conjunction with the California Historical Resources Information System, Northwest Information Center, at Sonoma State University to determine whether project areas contain known 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: Work in good faith with interested communities to evaluate proposed development sites for the presence of subsurface historic, archaeological, 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.
*Action 4-2.3: Continue to require that project areas found to contain significant archaeological resources be examined by a qualified consulting archaeologist with recommendations for protection and preservation. *Action 4-2.4: If tribal cultural resources are encountered during development, halt work 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 animals, structures, landscapes, or plants—and determined suitable mitigation measures.
Less than
significant
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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: Ensure that new development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards.
*Action 5-1.1: Prior to new development approval, ensure geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable hazard conditions.
*Action 5-1.2: Restrict development in areas where adverse impacts 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.
General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Policy 5-1.1: Ensure that new development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards.
*Action 5-1.1: Prior to new development approval, ensure geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable hazard conditions.
*Action 5-1.2: Restrict development in areas where adverse impacts 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-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: Ensure that new development, redevelopment, and major remodels shall avoid or adequately mitigate seismic and geologic hazards.
*Action 5-1.1: Prior to new development approval, ensure geologic studies and analyses are deemed acceptable by a California Certified Engineering Geologist and/or Geotechnical Engineer for applicable hazard conditions.
*Action 5-1.2: Restrict development in areas where adverse impacts 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
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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HYDROLOGY (HYD)
Impact HYD-1: Impacts to water quality
could occur from implementation of the
proposed project.
General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-5.10: 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.
*Action 3-5.12: Require a qualified biologist to prepare a biological resource assessment 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.
*Action 3-5.19: Require 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. *Action 3-5.20: Require new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans to meet restoration and enhancement goals.
General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-2.14: 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. *Action 5-2.15: Ensure creek-side paths and trails are consistent with the Citywide Creek Master Plan and Bicycle and Pedestrian Master Plan and are incorporated into stormwater improvement projects along creek corridors.
*Action 5-2.17: Require 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: 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.
Less than
significant
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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: Continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: 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: Update the Noise Ordinance to incorporate construction best management practices to minimize construction noise.
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.
General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-7.1: Continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: 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.
Significant and
unavoidable
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*Action 5-7.3: Require conditions of approval or mitigation 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: Work 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 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 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 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: Continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.3: Require conditions of approval or mitigation 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 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 205 0 DRAFT EIR
CITY OF SANTA ROSA
EXECUTIVE SUMMARY
2-24 OCTOBER 2024
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.
General Plan 2050 Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities *Action 5-7.1: Continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: 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: Update the Noise Ordinance to incorporate construction best management practices to minimize construction noise.
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: Continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: 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 5-7.9: 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.
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: Continue to require acoustical studies prepared by qualified acoustical consultants in accordance with Municipal Code standards.
*Action 5-7.2: 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 5-7.3: Require conditions of approval or mitigation 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: Work 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 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.
Significant and
unavoidable
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
EXECUTIVE SUMMARY
PLACEWORKS 2-25
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 5-7.10: Update the Noise Ordinance to incorporate construction best management practices to minimize construction noise.
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: Require an analysis of projected VMT and mitigation, as necessary, as part of the project review process for projects with the potential to increase VMT.
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 an analysis of project VMT 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 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 SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
EXECUTIVE SUMMARY
2-26 OCTOBER 2024
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
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.
General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-1.1: Require an analysis of projected VMT and mitigation, as necessary, as part of the project review process for projects with the potential to increase VMT.
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 PDA, amongst other to reduce VMT generated by all development.
Specifically, proposed *Action 3-1.1 requires an analysis of project VMT 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).
General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction *Action 3-1.1: Require an analysis of projected VMT and mitigation, as necessary, as part of the project review process for projects with the potential to increase 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.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
EXECUTIVE SUMMARY
PLACEWORKS 2-27
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: Require 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. *Action 3-5.20: Require new development to maintain an adequate setback from channelized waterways to recognize the 100-year flood elevation, with setbacks in the Zoning Code as minimums and larger setbacks encouraged in accordance with Restoration Concept Plans 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: Continue to review proposed developments in conjunction with the California Historical Resources Information System, Northwest Information Center, at Sonoma State University to determine whether project areas contain known 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: Work in good faith with interested communities to evaluate proposed development sites for the presence of subsurface historic, archaeological, 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.
*Action 4-2.4: If tribal cultural resources are encountered during development, halt work 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 animals, structures, landscapes, or plants—and determined suitable mitigation measures.
Less than
significant
WILDFIRE (WF)
Impact WF-1: Implementation of the
proposed General Plan 2050 could result
in inadequate evacuation access the
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: Require all new development projects to provide adequate access for fire and emergency response personnel.
*Action 5-5.15: Prohibit the creation of new single ingress/egress roadway conditions in the city. *Action 5-5.16: Retrofit existing single-access residential neighborhoods to include additional access routes or other provisions to increase evacuation safety.
Less than
significant
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
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EXECUTIVE SUMMARY
2-28 OCTOBER 2024
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 5-5.17: Analyze the capacity, viability, and safety of evacuation routes for hazard areas in the city (e.g., WUIFA) and incorporate the results into the City’s Emergency Operations Plan.
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: Require 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
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 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.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
EXECUTIVE SUMMARY
PLACEWORKS 2-29
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 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: Require 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 Chapter 4.1 through Chapter 4.18 of this Draft EIR for the regulatory framework for each environmental resource topic.
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
EXECUTIVE SUMMARY
2-30 OCTOBER 2024
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PLACEWORKS 3-1
Project Description
This chapter of the Draft Environmental Impact Report (EIR) describes the proposed update to the Santa Rosa General Plan (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), hereinafter referred to separately or together as the “proposed project.” This Draft EIR has been completed in accordance with the California Environmental Quality Act (CEQA). CEQA requires that State and local public agencies analyze proposed projects to determine potential impacts on the environment and disclose any such impacts.1 As described in more detail in Chapter 1, Introduction, of this Draft EIR, consistent with CEQA Guidelines Section 15168, this Draft EIR provides a programmatic analysis of the environmental impacts associated with implementation of the proposed project, including the projected buildout of the proposed General Plan 2050. This Draft EIR is also intended to be used for purposes of tiering, pursuant to CEQA Guidelines Section 15152 and other tiering and streamlining provisions of CEQA and the CEQA Guidelines. The City of Santa Rosa (City) is the lead agency for the environmental review of the proposed project. This chapter provides a detailed description of the proposed project, including the location, setting, and characteristics of the General Plan Planning Area; as well as the project objectives; the principal report components; and required permits and approvals.
3.1 BACKGROUND
Every city and county in California is required to have an adopted comprehensive long-range general plan for the physical development of the county or city and, in some cases, land outside the city or county boundaries.
2 It is the community’s overarching policy document that defines a vision for future change and sets the “ground rules” for: locating and designing new projects that enhance the character of the community, expanding the local economy, conserving and preserving environmental resources, improving public services and safety, minimizing hazards, and fostering community health. The General Plan, which includes a vision, guiding principles, goals, policies, and actions, functions as the City’s primary land use regulatory tool. It provides a basis for judging whether specific development proposals and public projects are in harmony with the General Plan. It is the constitution for future change in Santa Rosa. Pursuant to State law, a general plan must contain eight mandated elements: land use, circulation, housing, conservation, open space, noise, environmental justice, and safety. Typically, general plans cover a time frame or forecast of 15 to 20 years. However, general plan housing elements are required to be updated every eight years to comply with the Regional Housing Needs Allocation (RHNA).
1 CEQA Guidelines, Section 15002(a).
2 California Government Code Section 65300.
3. SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-2 OCTOBER 2024
The City’s General Plan Land Use Map is integrated with the City’s Zoning Map, which shows the parcel- specific delineation of the zoning districts throughout the city and depicts permitted and conditionally permitted uses. A parcel’s zoning district stems directly from its General Plan Land Use designation, with the zoning district acting to implement the General Plan by refining the specific uses and development standards for that parcel.
All specific plans, master plans, and zoning in the city must be consistent with the General Plan.3 Similarly, the General Plan must be used as the basis for all planning-related decisions made by City staff, the Planning Commission, and the City Council. Other decision-making bodies that rely on the General Plan to guide future decisions include, but are not limited to, the Art in Public Places Committee, Bicycle and Pedestrian Advisory Board, Cultural Heritage Board, Design Review Board, Transportation and Public Works Department, and the Recreation and Parks Department. The General Plan itself, however, does not approve or entitle any development project. Future project applicants have control over when they wish to propose a project, and final development approval decisions are made on a project-by-project basis by City staff, the Planning Commission, and/or the City Council.
3.2 OVERVIEW
The existing General Plan was adopted in 2009 and included a horizon year of 2035. While this horizon year is still approximately 11 years away, in the years between 2009 and 2022, Santa Rosa has experienced low housing production and increased homelessness, the destruction of housing and displacement of residents by wildfires between 2017 and 2020 (e.g., the Tubbs and Glass fires,) the impact of cannabis business activity on industrial and commercial land, and the annexation of the Roseland community into the city. A number of State and federal laws guiding general plan policies have also been updated during this time. As such, there is a need to take stock of the existing situation and plan for sustainable development in line with a vision. The proposed General Plan 2050 focuses on meeting current community requirements and future needs. 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.
The proposed General Plan 2050 guides the city’s economic and physical growth as well as preservation of natural and agricultural resources over an approximately 25-year buildout horizon and replaces the City’s existing General Plan, with the exception of the Housing Element. The City’s Housing Element (2023 to 2031) was adopted by the City Council in February 2023, certified by the State Housing and Community Development Department on April 7, 2023, and is incorporated into the proposed General Plan 2050 by
3 Government Code Section 65860.
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CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-3
reference. The Housing Element underwent a separate environmental review as part of its adoption process; however, the residential development that could occur under the Housing Element is incorporated into the residential development analyzed as part of this EIR.
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), 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 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.
3.3 LOCATION AND SETTING
Santa Rosa is approximately 55 miles north of San Francisco, in the south-central part of Sonoma County.
As the county seat and the largest city in Sonoma County, Santa Rosa is bordered by unincorporated communities of Sonoma County, including Fulton and Larkfield-Wikiup. Incorporated cities near Santa Rosa include Windsor, Healdsburg, Rohnert Park, Cotati, Sebastopol, Petaluma, and Sonoma, in Sonoma County, and Calistoga, and St. Helena in Napa County. Santa Rosa is generally bordered by regional and State parks, including Spring Lake Regional Park, Trione-Annadel State Park, Sugarloaf Ridge State Park, and North Sonoma Mountain Regional Park, to the east and Taylor Mountain Regional Park and Open Space Preserve to the south. See Figure 3-1, Regional and Vicinity Map. US Highway 101 and California State Route (SR) 12 each bisect the city, running north-south and east-west, respectively. SR 116 to the west also provides regional access to the city. Public transit in Santa Rosa is served by several transit providers, including the Sonoma-Marin Area Rail Transit (SMART), Golden Gate Transit, Sonoma County Transit, and the Santa Rosa CityBus. Santa Rosa residents and visitors also navigate the city by a variety of arterial, collector, and residential streets, as well as regional and local pedestrian and bicycle routes.
3.4 PLANNING BOUNDARIES AND EIR STUDY AREA
This section explains the planning boundaries referenced in the proposed General Plan 2050 and the relationship of those boundaries to the EIR Study Area. The State of California encourages cities to look beyond their borders when undertaking the sort of comprehensive planning required of a General Plan.
Under State law, the City can establish a Planning Area that consists of land in the city and, “any land outside its boundaries which, in the planning agency’s judgment, bears relation to its planning.”4 The
4 Government Code, Title 7, Planning and Land Use, Division 1, Planning and Zoning, Chapter 3, Local Planning, Article 5, Authority for and Scope of General Plans, Section 65300.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-4 OCTOBER 2024
Santa Rosa Planning Area encompasses approximately 31,555 acres (about 49 square miles), and includes the lands within the city limit, the Urban Growth Boundary (UGB), and the Sphere of Influence (SOI).
3.4.1 PLANNING BOUNDARIES
A description of these planning boundaries as proposed for General Plan 2050 is provided in the following sections and shown on Figure 3-2, General Plan 2050 Planning Boundaries and EIR Study Area.
CITY LIMIT
The city limit encloses the incorporated territory where the City currently has jurisdictional authority. The city limit encompasses approximately 26,500 acres (about 42 square miles). The city limit extends below Mark West Spring Road to the north, is generally bound by agricultural lands to the west and State Parks to the east and extends to Bellevue Avenue to the south. The land outside the city limit is unincorporated Sonoma County. Changes to the city limit are made when the City annexes land that is currently under the jurisdiction of Sonoma County. Annexations must go through a legal process that requires input from residents or property owners and are subject to Sonoma Local Agency Formation Commission (Sonoma LAFCO) review and approval. The proposed project has no changes to the city limit.
URBAN GROWTH BOUNDARY
The UGB is created and defined by the City, and like the SOI, represents land that the City anticipates for future annexation. The UGB separates urban areas from the surrounding natural and agricultural lands, or greenbelts, and limits how far out a city can expand. The purpose of the UGB is to direct growth in a focused, compact way to protect surrounding agricultural and open space land, and to create greenbelt buffers between cities. As shown on Figure 3-2, the SOI and UGB coincide. The UGB covers approximately 29,252 acres (about 45 square miles) and encompasses all incorporated city land plus some unincorporated land expected to be annexed to receive City services at some point in the future.
SPHERE OF INFLUENCE
The SOI, approximately 3,677 acres (about 6 square miles), is defined and determined by Sonoma LAFCO, although the City can propose the area that it would like its SOI to include. The current Santa Rosa SOI was approved by Sonoma LAFCO in May 2024. The SOI is considered the City’s ultimate potential area for future annexation and provision of City services. Establishment of this boundary is necessary to determine which governmental agencies can provide services in the most efficient way to the people and property in the area. For Santa Rosa, land in the SOI receives services from the city or may in the future. The Sonoma LAFCO identifies unincorporated neighborhoods north, northeast, south, and southwest of the city limits as within Santa Rosa’s SOI. If land in the City’s SOI is annexed by the City in the future, it would then be within the city limit and under the jurisdiction of Santa Rosa at that time.
3.4.1.1 3.4.1.2
3.4.1.3 Rohnert Park
Windsor
Santa Rosa
Sebastopol
Cotati
Petaluma
(/101
116 128
29 1
12 Figure 3-1
Regional and Vicinity Map
Source: City of Santa Rosa, 2020; ESRI, 2022; PlaceWorks, 2024. 0 2.5 51.25
Miles
County Boundaries
City Limit
Creeks and Waterways
Parks and Open Space
MENDOCINO
COUNTY
LAKE
COUNTY
YOLO
COUNTY
SONOMA
COUNTY
NAPA
COUNTY
SOLANO
COUNTY
MARIN
COUNTY
PROJECT DESCRIPTION
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R C I T
Y O F S A N T A R O S A
HoenAve
Olivet Rd
Mendocino A
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Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark WestSpringsR d
W
atertro
ugh Rd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood
Hwy
Brush C
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Su
mmerfieldRd
Fount ainGrovePky
Co
ffey Ln
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SpringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calisto
gaRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfiel d R
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Airport Blvd
(/101
12 12
116
Figure 3-2
General Plan 2050 Planning Boundaries and EIR Study Area Source: City of Santa Rosa, 2020; ESRI, 2022; PlaceWorks, 2024. 0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
EIR Study Area
PROJECT DESCRIPTION
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O
F S A N T A R O S A
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SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-7
3.4.2 EIR STUDY AREA
As shown in Table 3-1, EIR Study Area, the EIR
Study Area includes all land within the city limit,
planning area, UGB, and SOI. The EIR Study Area
is previously shown on Figure 3-2.
3.5 PLANNING PROCESS
The process to update the existing General Plan began in 2019 and is scheduled to be completed with the adoption of the proposed General Plan 2050 by the City Council in early 2025. To support the General Plan update process, the City formed two advisory bodies: a Community Advisory Committee (CAC) and a Technical Advisory Committee (TAC). The CAC was formed based on their collective ability to represent the full range of community interests, perspectives, and backgrounds of Santa Rosa. Roles of CAC members include serving as liaisons to their constituent groups, inviting input into the process, encouraging community participation throughout the planning process, and assisting the City with gaining a broader understanding of the needs and desires of the local community. The TAC was made up of technical experts from various City departments and partner agencies that provided feedback and ensured the plan concepts could be achieved. The City also created a General Plan website at www.santarosaforward.com to enhance and inform the public process. The website provides all of the documents, maps, and meeting agendas, which are available for public download. The website offers information in both English and Spanish and provides contact information for City staff so that members of the public can send their thoughts and questions about Santa Rosa and the General Plan update throughout the process.
The preparation process of the proposed General Plan 2050 was divided into five phases. During each of these phases, robust community engagement efforts were made, including presenting draft products to the community, Planning Commission, and City Council to gather their input. Depending on the phase and direction from the Planning Commission and City Council, revisions were made to finalize the product and/or move on to the next phase of work. Phase 1 was to develop a community involvement strategy that identifies numerous opportunities for the public, key civic and business leaders, as well as City staff and elected officials to be involved in the General Plan update process. Phase 2 involved preparation and publication of an existing conditions report detailing current conditions in the community. The Vision Statement was also crafted during this phase and serves as the guide for the proposed General Plan 2050.
Phase 3 developed three land use and circulation alternatives that aimed to implement the community vision, each offering a unique approach to distributing future housing and improving circulation. With feedback from the community, Phase 4 resulted in a Preferred Alternative that serves as the foundation of the proposed General Plan 2050. Phase 5 resulted in the preparation of the proposed General Plan 2050.
TABLE 3-1 EIR STUDY AREA
Planning Boundaries Acreage Square Miles
Planning Area 31,555 49
Urban Growth Boundary 29,252 45
City Limit 27,464 42
Sphere of Influence 3,677 6
Note: Square miles are rounded.
Source: City of Santa Rosa, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-8 OCTOBER 2024
3.6 PROJECT OBJECTIVES
Implementation of the proposed project is guided by the Santa Rosa Vision as a diverse, equitable, and sustainable community built on civic engagement that empowers everyone to provide and support equal and affordable opportunities to obtain housing, education, and jobs; to enjoy vibrant cultural events and arts; and to live healthy lives in resilient neighborhoods that adapt to social and environmental change.
The primary purpose of the proposed project is to plan for the growth and conservation of Santa Rosa over an approximately 25-year time horizon while achieving the vision. The project objectives to realize the Santa Rosa Vision are related specifically to growth in the 21 Areas of Change, the majority of which capitalize on infill opportunities in and around Priority Development Areas (PDAs) and Transit Priority Areas (TPAs). Development of infill sites near transit make the most of existing infrastructure and allow for the streamlining of future development in a manner that is consistent with the proposed General Plan 2050. Meeting the vision also includes making major improvements to the transportation network, which focus on bridging east and west and enhancing multimodal connectivity and safety citywide. Achieving the vision also entails creating complete streets and complete neighborhoods to activate the Areas of Change.
This requires extending the buildout horizon to year 2050 and updating goals, policies, and actions so that they meet current State requirements and community priorities. As part of this process, the City has identified the following, which build on the framework of the Santa Rosa Vision and reflect the community’s desires for the future of Santa Rosa and will serve as the project objectives for the Draft EIR.
1. Realize Santa Rosa’s Vision as a diverse, equitable, and sustainable community built on civic engagement that empowers everyone to provide and support equal and affordable opportunities to obtain housing, education and jobs; to enjoy vibrant cultural events and arts; and to live healthy lives in resilient neighborhoods that adapt to social and environmental change. The full Santa Rosa Vision, with all 13 ideals, is as follows and as depicted on the image. Just: Social and environmental justice are
achieved for everyone—all abilities, ages,
ethnicities, gender identities, immigration
status, income levels, language speakers,
races, religions, and sexual orientations and
identities—EVERYONE.
Sustainable: Natural resources are restored,
protected, and expanded to provide accessible
green space for everyone in all
neighborhoods, mitigate drought, and
minimize greenhouse gas emissions.
Inclusive: Everyone is welcome and actively
encouraged to join in neighborhood and
citywide decision making, and barriers to
participation are identified and eliminated.
Healthy: All neighborhoods have low pollution level and good air quality, are vibrant, connected, full-service communities, with the resources to be civically organized, and anchored by inclusive and accessible public outdoor spaces and buildings offering safe and welcoming places for everyone. Every person has the opportunity to attain their full health potential.
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-9
Resilient: All facets of the community, including housing, infrastructure, and social services are sustainable and resilient to hazards and economic changes. Prepared: The health and safety of everyone is supported by neighborhood, City, and county-wide efforts to prepare for natural and human-caused hazards, and roadways are optimized to support efficient evacuations.
Sheltered: A diverse mix of high-quality, safe, thoughtfully designed, efficiently planned, and well- served housing at all affordability levels is available throughout the community to accommodate everyone, including formerly homeless, immigrants, local workers, multigenerational households, seniors, students, and formerly incarcerated people.
Equitable: Everyone has what they need to enjoy long, fulfilling, healthy lives, including affordable access to meet their daily needs—including healthy food, recreation, education, childcare, employment opportunities, reliable internet, and physical and mental health services. Successful: Top employers gravitate; Black-, Latino/Latina-, and other minority-owned businesses are in all corners of the community; equitable investments are made in all neighborhoods; local shops, food and beverage establishments and food trucks, and entertainment spaces support a vibrant city; and meaningful work in a thriving economy is available for people of all ages and backgrounds.
Connected: High-quality, reliable, and safe transit service, bicycle and pedestrian facilities, and other forms of mobility connect all ages across the city and region at all times and support healthy lifestyles, clean air, equity, and resilience.
Safe: Streets are safe; public safety services are provided by caring and thoughtful community members who are representative of and familiar with the neighborhoods, groups, and individuals they serve; and everyone, including immigrants and people of color, can safely access these services.
Educated: Life-long education, enrichment, and supportive services and resources engage and empower young people, strengthen families (of any family structure), connect and activate seniors, and foster the success and well-being of everyone. Cultural: Art, cultural resources, and activities, historic assets, and live music thrive in every neighborhood, are accessible to everyone, and work to celebrate our diverse community, bring people from all areas of the city together, and support the local economy.
2. Ensure compliance with changes in State Law, including but not limited to, developing an Environmental Justice element, and a Safety Element that is correlated with the requirements of the Local Hazard Mitigation Plan.
3. Develop a plan that accommodates a level of growth that could reasonably occur over the next 2.5 decades, and that plans for both growth and conservation.
4. Create a city with an increasingly dense urban core. Streamline future development by focusing on infill sites near transit to make the most of existing infrastructure. Ensure strong connections between land use, transportation, utilities, and other infrastructure.
5. Focus development in the 21 Areas of Change, the majority of which capitalize on infill opportunities in and around Priority Development Areas and Transit Priority Areas. Activate Areas of Change by developing complete neighborhoods that are walkable/bikeable and increasingly protected from environmental hazards.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-10 OCTOBER 2024
6. Provide a range of housing types to meet the needs of all Santa Rosa residents, including multi-family structures, “missing middle” units (such as duplex, triplex, cottage court, multiplex and live/work), and single-family residences with accessory dwelling units, within neighborhoods that are increasingly walkable/bikeable.
7. Create a cross-sector approach to integrating greenhouse gas reduction into all parts of the general plan, so that implementing the plan supports the City in reaching its climate mandates.
8. Create new opportunities for a vital, thriving downtown and entertainment district.
9. Preserve community character and environmental, historic, and cultural resources, as the city develops and becomes denser . Creatively blend old and new development to create a cohesive urban fabric and public realm.
3.7 PROJECT COMPONENTS
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) consistent5 and the NSASP , DSASP , the SRCC, and GHG Reduction Strategy are consistent with the General Plan (also known as vertical consistency).6 The section provides a description of each project components.
3.7.1 GENERAL PLAN 2050
The proposed project updates the current General Plan 2035 goals, policies, and actions, and makes changes to land use designations on a limited number of parcels to reflect current conditions, issues, resources, and community perspectives. For example, changes are needed to address the evolving state of the city and region and to cover global issues such as climate change and emerging transportation technologies. The update also incorporates regional forecasts for 2050 that extend the planning horizon forward by 15 years from the current General Plan 2035 horizon. This section provides a summary of the major components of the proposed General Plan 2050.
CONTENTS AND ORGANIZATION
The proposed General Plan 2050 includes an introductory chapter, six separate chapters that identify the goals, policies, and actions, and two appendices. The chapters cover the elements required by California Government Code Section 65302 as well as other topics of particular interest to Santa Rosa. A brief explanation of each General Plan chapter and appendix is provided herein. Chapter 1, Introduction: Describes the required elements of the General Plan, its planning context, and provides an overview of the General Plan’s organization. This chapter also covers existing land use conditions and the policy framework; describes the General Plan update process; and presents the location, intensity, and type of future growth and development allowed in the city.
5 Government Code Section 65300.5 (internal consistency). 6 Government Code Section 65860 (vertical consistency).
3.7.1.1 SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-11
Chapter 2, Land Use and Economic Development: Provides overall land use and economic development policies for the city. The State-mandated land use content addresses the connection between land use and transportation, utilities, and other infrastructure. Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction: Satisfies the State law requirement that transportation be addressed by the General Plan and provides the general location and extent of existing and proposed major streets and other transportation facilities. This chapter correlates with the Land Use chapter to provide adequate pedestrian, bicycle, motor vehicle, transit, air, and water transportation to serve both new and existing land uses. Further, this chapter addresses the State law requirement for open space and conservation elements, relating to both the natural and built environment.
Chapter 4, Urban and Environmental Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture: Is made up entirely of optional topics for General Plans and includes goals, policies, and actions related to urban and environmental design, cultural and tribal cultural resources, historic preservation, and art and culture. Each of these components are considered essential to the character and future growth of the Santa Rosa community. Chapter 5, Safety, Noise, and Public Services and Facilities: Addresses State-required safety considerations. It provides information about risks in Santa Rosa due to natural and human-made hazards, and contains goals, policies, and actions designed to protect the community and property from hazards. It specifically addresses risks associated with flooding and storm drainage, geologic and seismic hazards, hazardous materials and waste, and wildland fires. This chapter also includes goals, policies, and actions addressing the legally required topic of noise as well as public services and facilities.
Chapter 6, Health, Equity, Environmental Justice, and Parks: Addresses the State-mandated Environmental Justice element, along with optional element topics of community health, equity, parks, and children and families. The optional elements complement the mandated element as each topic directly impacts environmental justice and considering them on their own supports more sustainable change.
Chapter 7, Housing. Identifies the housing needs of the city for all income levels and strategies and policies for providing housing to meet those needs. Since the Housing Element is updated more frequently than the other elements, as required by State law, it exists as its own document outside of the proposed General Plan 2050 and is therefore not part of the proposed project. The current Housing Element, adopted February 14, 2023, and certified by HCD on April 7, 2023, was updated by the City through a separate process. The current Housing Element addresses housing needs in Santa Rosa for the 2023 to 2031 planning period.
Chapter 8, Glossary: Provides users of the General Plan with a description of all the key terms and acronyms used throughout the document.
Appendix A, Greenhouse Gas Reduction Strategy: Includes the GHG Reduction Strategy that will serve as the strategic plan for how the City will reduce GHG emissions and foster a sustainable community through 2050 and beyond.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-12 OCTOBER 2024
Appendix B, Climate Change Vulnerability Assessment Report: Includes an assessment of climate change vulnerability and addresses climate change adaptation and resilience to enable the community to prepare for, respond to, withstand, and recover from disruptions exacerbated or caused by climate change. It describes the regulatory framework and method for integrating adaptation and resilience into City policies; the climate change hazards affecting the resilience of Santa Rosa; the specific populations and assets included in the assessment; and provides a summary of the results.
GOALS, POLICIES, AND ACTIONS
Each chapter of the proposed General Plan 2050 contains background information and a series of goals, policies, and actions. Policies and actions are at the same level of importance and are both intended to support goals. In most cases, goals have both policies and actions. However, it is also possible for a goal to be supported exclusively by policies or actions. 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. The following provides a description of goals, policies, and actions and explains the relationship between them:
A goal is a description of the general desired result that the City seeks to create through the implementation of its General Plan.
A policy is a specific statement that regulates activities in the city, guides decision making, and directs ongoing efforts as the City works to achieve a goal. A policy is ongoing and requires no further implementation. The General Plan’s policies establish the standards that will be used by City staff and the other decision makers in their review of land development projects and in decision making about City actions.
An action is a measure, procedure, or technique intended to help reach a specified goal. An action may be ongoing or something that can be completed in a discrete timeframe. The City must take additional steps to implement each action in the General Plan.
LAND USE DESIGNATIONS
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 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
3.7.1.2 3.7.1.3
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-13
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.
Residential
Very Low Density (0.2-2.0 units/gross acre). This land use designation accommodates rural and hillside developments within the UGB and is intended for single-family detached units, but clustered single- family attached and multifamily may be permitted.
Low Density /Open Space (2.0-8.0 units/gross acre). This land use designation permits single-family residential development at a density assumed at only 80 percent of each site due to wetlands constraints. This classification is mainly intended for detached single-family dwellings but attached single-family and multifamily units may be permitted.
Low Density (2.0-8.0 units/ gross acre). This land use designation is mainly intended for detached single-family dwellings but attached single family and multifamily units may be permitted. Medium Low Density (8.0-13.0 units/gross acre). This land use designation is intended for attached single-family residential development (such as townhomes), but single-family detached housing and multifamily development may be permitted. Development at the mid-point of the density range is encouraged but not required.
Medium Density (8.0-18.0 units/gross acre). This land use designation permits a range of housing types, including single-family attached and multifamily developments, and is intended for specific areas where higher density is appropriate. Missing Middle Housing types, including Duplex-Triplex, Fourplex, and Cottage Court, are also compatible. New single-family detached housing is not permitted except in historic neighborhoods where single-family detached units are allowed. Medium High Density (18.0-30.0 units/gross acre). This land use designation permits a range of housing types, including single-family attached and multifamily developments, and is intended for specific areas where higher density is appropriate. Missing Middle Housing types, including Multiplex (small and large), Courtyard buildings, Townhomes, and Live/Work units, are also compatible. Single- family detached housing is not permitted.
Mobile Home Parks (4.0-18.0 units/gross acre). This land use designation permits residential mobile home development of two or more mobile home units. Mobile homes and manufactured homes are the only allowed housing type.
Mixed Use
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.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-14 OCTOBER 2024
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. Core Mixed Use. This land use designation is intended to foster a vital mix of residential, retail, office, governmental, entertainment, cultural, educational, and hotel uses to activate the greater Courthouse Square area and key transit corridors. The principal objectives of this land use designation are to strengthen the role of this area as a business, governmental, retail, and entertainment hub for the region, and accommodate significant new residential development that will extend the hours of activity and create a built-in market for retail, service, and entertainment uses. High-rise development in all-residential or mixed-use buildings is envisioned in a walkable, bikeable environment with civic spaces such as plazas, courtyards, or parks and easy access to public transit. The Core Mixed Use designation has a maximum FAR range of 3.0 to 8.0 except for 12 contributor properties on B, 7th, and 10th Streets, to which height and density maximums apply. Station Mixed Use. This land use designation is intended to provide for a range of visitor-serving uses, including retail, restaurants, entertainment, cultural amenities, and hotels in proximity to the Downtown SMART station. While commercial uses are emphasized, new multifamily housing will also be allowed to support daytime and evening vitality in the Downtown Station Area. New development will be required to respect the historic character of the Railroad Square area, adding to the mix of uses and enhancing the walkable, pedestrian-oriented streets and public spaces that attract local residents, SMART train riders, and visitors from the wider region. The Station Mixed Use designation has a maximum FAR range of 3.0 to 6.0.
Maker Mixed Use. This land use designation emphasizes a balanced mix of residential, creative, and maker-oriented uses, including artisan shops, studios, media production, printing and publishing, distilleries and micro-breweries, cannabis, tech start-ups, research and development facilities, limited light industrial uses, and home-based businesses. Multifamily residential units are encouraged in all- residential or mixed-use buildings, as are Live/Work units. Supportive uses that contribute to a vibrant village atmosphere, such as bodegas, specialty food stores, cafes, coffee shops, performing arts venues, theatres, restaurants, schools, and educational facilities are also permitted. The Maker Mixed Use designation has a maximum FAR range of 3.0 to 6.0.
Neighborhood Mixed Use. This land use designation allows for new multifamily residential development in all-residential or mixed-use buildings, together with a broad mix of uses that primarily serve local residents, including professional office, retail, entertainment, service, and other neighborhood-scale supporting uses. Housing development will include low- and mid-rise apartments and condominiums, as well as small-lot single-family attached dwellings (e.g., duplexes, triplexes, townhomes). Missing Middle Housing, including Live/Work spaces and maker-oriented uses, are permitted subject to performance standards. Street design that integrates Complete Streets concepts for accommodating all roadway users and incorporates traffic-calming features will be required with on-street parking where appropriate. FAR for the Neighborhood Mixed Use designation varies downtown.
SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-15
Commercial
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.
Office
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.
Industrial
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. 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, SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-16 OCTOBER 2024
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.
Other
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. Parks and Recreation. This land use designation permits neighborhood, community, trail and open space parks, special purpose parks and recreational facilities, and civic spaces. Open Space. This land use designation features special environmental conditions or significance, may be subject to wildfire, flood, or geologic hazards, or contain watershed lands or important wildlife or biotic habitat. Where otherwise not excluded by noise, aircraft safety, or other environmental standards, residential development is generally permitted at a density of 1.0 unit per 40 acres. Agriculture (0.5 units/gross acre). This land use designation is applied only to a limited number of sites outside the UGB in the southwestern portions of the Planning Area and includes orchards and cropland, grasslands, livestock, and related processing and distribution facilities. Residential density may not exceed one housing unit per 20 acres, provided that one housing unit is allowed on each existing parcel. Agriculture is permitted with fewer restrictions on keeping animals than in the residential classifications.
LAND USE AND ZONING MAP REVISIONS
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 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.
3.7.1.4 (/101
12 12
116
Figure 3-3
Proposed General Plan 2050 Land Use Map
Source: ESRI, 2022; City of Santa Rosa, 2023; PlaceWorks, 2024. 0 1 20.5
Miles
Land Use
Designations
Very Low Density
Residential
Low Density
Residential/Open
Space
Low Density
Residential
Medium Low
Densit
y
Residential
Medium Density
Residential
Medium High
Densit
y
Residential
Mobile Homes
Retail and
Business S
ervices
Retail/Medium
Residential Mix
ed
Use
Office/High
Residential Mix
ed
Use
Office/Medium
Residential Mix
ed
Use
Public/
Insti
tutional/
Medium
Residential Mixed
Use
Office
Transit Village
Mixed Use
Transit Village
Medium
Station Mixed Use
Core Mixed Use
Neighborhood
Mixed Use
Maker Mixed Use
Business Park
Light Industry
General Industry
Public/
Insti
tutional
Parks and
Recr
eation
Open Space
Agriculture
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
PROJECT DESCRIPTION
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O
F S A N T A R O S A
-
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-18
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
7 180-520-099 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
9 010-091-001 Neighborhood 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/Institutional Transit Village Mixed Use North Station Area Combining District (PI-SA) Transit Village-Mixed 0 17 17 13 041-043-057 Public/Institutional Transit Village Mixed Use North Station Area Combining District (PI-SA) Transit Village-Mixed 0 42 42 14 010-091-007 Neighborhood 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
8 3
9 5
13 14
4 12
11 210
1 H oen A
ve
Olivet Rd
Mendocino A
ve
Grange Rd
Benn
ett Valley Rd
W Steele Ln
W College Ave
Sebastopol Rd
Kennedy Rd
Guerneville Rd
Petaluma Hill Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
MarkWest S prings
Rd
W
atertrough
Rd
Millbrae Ave
Blo omfie
ld R
d
Old
RedwoodHwy
Saint Helena Rd
Su
mmerfiel
dRd
Fountain
Grove Pky
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marl
owRd
Faught Rd
WarmSpringsRd
River Rd
Cal
istoga
Rd
Arnold
Dr
Dutton Ave
Westside Rd
Llano
Rd
S Wright Rd
Hearn Ave
Montgomery Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Ba rnett
Valley Rd
Ea
stsideRd
Airport Blvd
(/101
116
12 12
Figure 3-4
General Plan Land Use and Zoning Revisions
Source: ESRI, 2022; City of Santa Rosa, 2023; PlaceWorks, 2024.
PROJECT DESCRIPTION
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
Parcels to be
Redesignated
and/or
Rezoned
0 1 20.5
Miles
See Table 3-2 in Chapter 3 of the
Draft EIR f
or additional details
6 7
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O
F S A N T A R O S A
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-20 OCTOBER 2024
In addition to the parcels with General Plan land use and zoning amendments, the City has identified 14 parcels where revisions to the zoning district are recommended to better align with the vision of the proposed General Plan 2050. These revisions to the zoning districts only are shown in Table 3-3, Proposed Rezoning Sites, and on Figure 3-5, Proposed Rezoning Sites.
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
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.
As shown in Table 3-2 and Table 3-3, the proposed revisions to the land use designations and as required, zoning districts on 13 parcels would result in a net loss for the potential future development of 40 residential units, and the proposed revisions to the zoning districts on 14 parcels would result in a net gain of 116 residential units. Therefore, with these changes there would not be a loss in housing potential but rather would result in a net gain for the potential future development of 76 residential units.
H oen A
ve
Olivet Rd
Mendocino
Ave
Grange Rd
Benn
ett Valley Rd
W Steele Ln
W College Ave
Sebastopol Rd
Guerneville Rd
Petaluma Hill Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark
WestSprings R d
Wat
ertrough R
d
Millbrae Ave
Blo omfi
eld
Rd
Old Re
dwoo
dHwy
Saint Helena Rd
Su
mmerfiel
dRd
Fountain
Grove Pky
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marl
owRd
WarmSpringsRd
River Rd
Calisto
gaRd
Arnold
Dr
Dutton Ave
Pleasa
ntHill Rd
Westside Rd
Llano
Rd
S Wright Rd
Hearn Ave
Montgomery Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Ba rnett
Valley Rd
Ea
stsideRd
Airport Blvd
(/101
116
12 12
Figure 3-5
Proposed Rezoning Sites
Source: ESRI, 2022; City of Santa Rosa, 2023; PlaceWorks, 2024.
PROJECT DESCRIPTION
Parcels to be Rezoned
Proposed Zoning
General Commercial (CG)
Multi-Family Residential, up
to 10 units/acr
e (R-3-10)
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
0 1 20.5
Miles
1 2
3 4
5 6
7 8 9
10 Hearn Ave
1112
13 144th St
12 See Table 3-3 in Chapter 3 of the
Draft EIR f
or additional details
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O
F S A N T A R O S A
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I
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-22 OCTOBER 2024
TRANSPORTATION AND INFRASTRUCTURE IMPROVEMENTS
The proposed project includes new and improved circulation infrastructure. Many of the circulation modifications reflected in the proposed General Plan 2050 are also identified in the recent Moving Forward 2050 Sonoma County Comprehensive Transportation Plan.7 A summary of the improvements reflected in the technical modeling and analysis discussed in Chapter
4.15, Transportation, of this Draft EIR, is shown in Table 3-4, Major Planned Roadway Circulation Improvements, and Table 3-5, Major Planned Multimodal Circulation Improvements.
TABLE 3-4 MAJOR PLANNED ROADWAY CIRCULATION IMPROVEMENTS Improvement Description
Freeway Interchanges and Overcrossings
Baker Ave Overpass widening including pedestrian and bicycle improvements Bellevue Ave* New US Highway 101 overcrossing connecting Corby Avenue to Santa Rosa Avenue Fulton Road* New freeway interchange at SR 12 including pedestrian and bicycle facilities Hearn Ave* Upgraded interchange and overpass widening including pedestrian and bicycle improvements Mendocino Ave
overcrossing* Widening including the addition of turn lanes, bike lanes, and sidewalks Roadway Improvements
B Street-Healdsburg Ave Remove one southbound lane between Tenth Street and Seventh Street Bellevue Ave* Stony Point Road to Santa Rosa Avenue - add center turn lane, sidewalks, bike lanes (including US Highway 101 overcrossing)
Chanate Rd* Resiliency corridor - Mendocino Avenue to Parker Hill Road Cleveland Ave Remove one through lane in each direction and add bike lanes - Piner Road to Guerneville Road
College Ave Widen westbound direction to the west of Stony Point Road to Halyard Drive; includes pedestrian and bicycle improvements
Dutton Ave Remove one through lane in each direction, adding bike lanes - south of College Avenue to north of West Third Street
Dutton Ave Extension* Roadway extension filling gap south of Hearn Avenue; includes pedestrian and bike improvements
Dutton Meadow* Realign and extend to Dutton Avenue extension, including sidewalks and bike lanes Evacuation Route Upgrades* Primarily on arterials within wildland-urban interface, including Fountaingrove Parkway and Montgomery Drive
Farmers Ln Extension* Bennett Valley Road to Petaluma Hill Road - sidewalks, bike lanes, transit route, and evacuation routes
Fourth St Remove one through lane each direction, adding bike lanes - Brookwood Avenue to Bryden Lane
Fresno Ave* Extension from Northpoint Parkway to Ludwig Avenue including sidewalk and bike lanes Fulton Rd Widen to two lanes in both directions between Piner Road and Guerneville Road Hearn Ave Widen between Dutton Avenue and Santa Rosa Avenue including pedestrian and bicycle improvements
SR 12 Widen to two lanes each direction between Melita Road and Pythian Road Kawana Springs Rd* Widen with turn lanes, sidewalks, and bike lanes
7 Sonoma County Transit Authority, 2021, Moving Forward 2050 Sonoma County Comprehensive Transportation Plan.
3.7.1.5 SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-23
TABLE 3-4 MAJOR PLANNED ROADWAY CIRCULATION IMPROVEMENTS Improvement Description
Mendocino Ave Remove one northbound lane and add bike lanes - College Avenue to Fourth Street Northpoint Parkway
extension*
Western extension to South Wright Road and eastern extension to Hearn Avenue, including sidewalks and bike lanes
Petaluma Hill Rd* Improvements including turn lanes, sidewalks, and bike lanes Piner Rd* Widening to four lanes between Fulton Road and Marlow Road including sidewalks and bike lanes
Santa Rosa Ave Remove one through lane each direction, adding bike lanes - Third Street to Maple Avenue Sebastopol Rd* Improvements including turn lanes, sidewalks, and bike lanes from Dutton Avenue to Olive Street
Sebastopol Rd Widen to two lanes each direction including pedestrian and bicycle improvements between Lombard Lane and Fulton Road
Stony Point Rd* Widening to four lanes between Hearn Avenue and south city limit including sidewalks and bike lanes
West College Ave Remove one lane in each direction, filling gaps in sidewalk and bike lane networks - Fulton Road to Halyard Drive
West Ave* Reconstruction including sidewalks and bike lanes Yolanda Ave* Widening to two westbound and one eastbound lane with center turn lane, sidewalks, and bike lanes
Note: *Projects identified in the Moving Forward 2050 Sonoma County Comprehensive Transportation Plan (Sonoma County Transit Authority, 2021).
Source: City of Santa Rosa, Sonoma County Transit Authority, and W-Trans, 2023.
TABLE 3-5 MAJOR PLANNED MULTIMODAL CIRCULATION IMPROVEMENTS Improvement Description
Bicycle and Pedestrian Improvements
Bicycle and Pedestrian High
Priority Improvements*
Fourth Street/College Avenue improvements, Stony Point Road improvements, Northeast connection improvements, and Roseland Creek trail
East-West Bicycle and
Pedestrian Connections*
New bicycle and pedestrian overcrossing of US Highway 101 near Santa Rosa Junior College Campus, construction of a bike and pedestrian grade crossing of the SMART corridor at Jennings Avenue, and installation of bike lanes on Steele Lane/Guerneville Road corridor Southeast Greenway
Multiuse Path and
Crossings*
Provide non-motorized transportation connections from Spring Lake Regional Park to Farmers Lane and links to downtown Santa Rosa, surrounding neighborhoods and schools, and the regional trail system
Climate Adaptation
Technology Innovation
Transport Initiatives*
Improve transit corridor efficiency, implement technologies to improve traffic flow and adapt to autonomous vehicles, upgraded signal controllers; implement short-term goals identified in the 2018 Bicycle and Pedestrian Master Plan (BPMP), such as Vision Zero, safe routes to school, first- and last-mile connections to transit and rail, regional bike share, bike and pedestrian safety, and education activities
Farmers Lane Extension
Multiuse Pathway*
Construct multiuse pathway along Farmers Lane Extension between Bennett Valley Road and Petaluma Hill Road
Santa Rosa Bicycle and
Pedestrian Master Plan
Implementation of remaining projects in the 2018 BPMP (including future updates to the 2018 BPMP) Note, the 2018 BPMP is updated approximately every 5 to 8 years. The City of Santa Rosa began an update to the 2018 BPMP in 2023. As part of the update, the BPMP is proposed to be renamed “Active Transportation Plan.” Anticipated adoption is March 2025.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-24 OCTOBER 2024
TABLE 3-5 MAJOR PLANNED MULTIMODAL CIRCULATION IMPROVEMENTS Improvement Description
Transit Improvements
Enhanced core CityBus
network* 50 percent increases in service hours and 15-minute service on core corridors CityBus infrastructure
improvements*
Expansions of Transit Mall and Coddingtown Transit hubs, Southside Transit Center, improved connectivity to SMART stations, park-and-ride improvements CityBus new mobility
projects*
Projects may include mobility on demand, shared mobility, or mobility as service applications and potentially autonomous vehicle technologies
CityBus Rapid Bus* Planning efforts supporting future implementation of Rapid Bus on key corridors CityBus Fare Programs* Scalable programs oriented toward fare-free transit and paratransit services CityBus Short Range Transit
Plan (SRTP)
Implement projects and programs identified in the current Short Range Transit Plan (including future updates to the SRTP)
Note: * Projects identified in the Moving Forward 2050 Sonoma County Comprehensive Transportation Plan (Sonoma County Transit Authority, 2021).
Source: City of Santa Rosa, Sonoma County Transit Authority, and W-Trans, 2023.
3.7.2 SPECIFIC PLAN AMENDMENTS
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. The proposed project would update the NSASP and DSASP 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.
3.7.3 SANTA ROSA CITY CODE AMENDMENTS
The SRCC is a collection of laws, or ordinances, that are passed by the City of Santa Rosa. These laws are the primary code of the municipality. The SRCC is organized by title, chapter, and section and in some cases, articles. The proposed project includes the modifications to SRCC Title 19, Subdivisions, and Title 20, Zoning, described herein.
TITLE 19: SUBDIVISIONS
Pursuant to SRCC Section 19-04.020, Purpose, the provisions of Title 19 are to regulate and control the division of land within the City and to supplement the provisions of the Subdivision Map Act concerning the design, improvement, and survey data of subdivisions, the form and content of all required maps provided by the Subdivision Map Act, and the procedure to be followed in securing the official approval of the City regarding the maps. To accomplish this purpose, the regulations contained in this title are determined to be necessary to preserve the public health, safety and general welfare; to promote orderly growth and development and to promote open space, conservation, protection, and proper use of land; and to ensure provision for adequate traffic circulation, utilities, and other services in the city.
3.7.3.1 SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-25
SRCC Chapter 19-70, Park and Recreation Land and Fees, as described in Section 19-70.010, Authority, General Purpose and Definitions, is adopted pursuant to the California Government Code Section 66477 (Quimby Act) and California Government Code Sections 66000 through 66025 (Mitigation Fee Act) and the general police power of the City, for the purpose of executing and implementing the General Plan of the City of Santa Rosa. It is the purpose of this chapter to provide for: (1) the acquisition of park land for neighborhood and community parks through dedication of land; and (2) the acquisition of park land for neighborhood and community parks and development of park and recreation facilities by imposition of fees in connection with the development of new dwelling units. The proposed project would specifically amend SRCC Section 19-70.030, Park Acreage Standard, to clarify how parkland requirements would be satisfied and would remove school recreational land as a means to satisfy acreage.
TITLE 20: ZONING CODE
New Zoning District: Missing Middle Housing
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. The proposed Missing Middle Housing combining district would be denoted as “-MMH” and could be combined with any residential or mixed-use primary zoning district 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.
Existing Zoning District Amendments
As listed, several sections of SRCC Title 20 would be revised to align with the proposed General Plan 2050, some of which are directed by proposed General Plan 2050 actions. Underlined text represents language that has been added to the SRCC; text with strikethrough represents language that has been deleted from the SRCC.
SRCC Section 20-16.040, Temporary Structures and Activities. B.2a. Temporary Use Permits issued pursuant to Section 20-52.040.D.3, Events, shall be eligible for up to 21 consecutive days, or 36 weekend days, within a 12-month period when conducted on nonresidential properties. Events considered under this subsection include, but are not limited to, arts and crafts exhibits, carnivals, circuses, concerts, fairs, farmers' markets, festivals, flea markets, food events, outdoor entertainment/sporting events, rodeos, rummage sales, second hand sales, and swap meets. (Revised pursuant to proposed General Plan 2050 Action 2-9.2: Update the Zoning Code to allow mobile food and crafts vendors, farmers markets, art and artisan pop-ups, and community gathering events in all nonresidential zoning districts.)
3.7.3.2 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-26 OCTOBER 2024
SRCC Section 20-20.020, Zoning Map and Zoning Districts. Table 2-1, Zoning Districts, would be revised to indicate that the General Plan land use designations for Retail and Business Services and Neighborhood Shopping Center would be implemented by the Neighborhood Commercial Zoning District.
SRCC Section 20-22.030, Residential District Land Uses and Permit Requirements. Table 2-2, Allowed Land Uses and Permit Requirements for Residential Zoning Districts, would be revised to reflect permitted uses in the Neighborhood Mixed Use Zoning District to be consistent with the General Plan land use designation for Neighborhood Mixed Use.
SRCC Section 20-22.040, Residential district subdivision and density standards. D. Development in all R-3 and TV-R districts shall provide at least the midpoint of the allowed density, unless topography, parcel configuration, heritage trees, historic preservation, or utility constraints make the midpoint impossible to achieve. (Revised pursuant to proposed General Plan 2050 Action 2-3.4: Require development at the midpoint or higher of the density range in the Medium and Medium High Density Residential land use designations, unless topography, parcel configuration, heritage trees, historic preservation, or utility constraints make achieving the midpoint infeasible.)
SRCC Section 20-23.030, Commercial District Land Use and Permit Requirements. Table 2-6, Allowed Land uses and Permit Requirements for Commercial Zoning Districts, in the Retail Trade land use designation change to ‘P’ for Artisan Shop and Sales and add a Farmers Markets row with ‘P’ in all districts. (Revised pursuant to proposed General Plan 2050 Action 2-9.2: Update the Zoning Code to allow mobile food and crafts vendors, farmers markets, art and artisan pop-ups, and community gathering events in all nonresidential zoning districts.) SRCC Section 20-24.030, Industrial District Land Use and Permit Requirements. Table 2-10, Allowed Land Uses and Permit Requirements for Industrial Districts, in the Retail Trade land use designation, add rows for Artisan Sales and Farmers Markets with ‘P’ in all districts. (Revised pursuant to proposed General Plan 2050 Action 2-9.2: Update the Zoning Code to allow mobile food and crafts vendors, farmers markets, art and artisan pop-ups, and community gathering events in all nonresidential zoning districts.)
SRCC Section 20-30.090, Performance Standards.
M. Biological Resource Assessment. Any development proposed on a site with natural habitat conditions that may support special-status species, sensitive natural communities, important wildlife corridors, or regulated wetlands and waters shall provide a biological resource assessment from a qualified biologist. (Revised pursuant to proposed General Plan 2050 Action 3-5.11:
Require a qualified biologist to prepare a biological resource assessment 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 for protecting the resource and surrounding habitat.) N. Health Impact Assessment. Any nonresidential development proposals of 100,000 square feet or more in an Equity Priority Area (as mapped in the General Plan) shall include health impact assessment that address any potential negative health implications of the project. (Revised pursuant to proposed General Plan 2050 Action 6-1.11: Update the Zoning Code to require health impact assessments for nonresidential projects of 100,000 square feet or more in Equity Priority Areas to identify and address any potential negative health implications of the project.) SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-27
Zoning Map and General Plan Land Use Map Conformance
As previously described, under State law the Zoning district for each parcel is required to be consistent with the General Plan land use designation.8 Accordingly, the proposed project includes amendments to the Zoning Map to bring consistency between the General Plan land use designation and Zoning district for each parcel that is not currently consistent with the General Plan land use designation. Because these amendments are being made to reflect what is currently allowed on the property under the General Plan, these amendments would not result in new development potential at these locations.
3.7.4 GREENHOUSE GAS REDUCTION STRATEGY
Concurrent with the proposed General Plan 2050, the proposed Community-wide GHG Reduction Strategy is an update to and replacement of the City’s 2012 CCAP . The proposed GHG Reduction Strategy will serve as the strategic plan for how the City will reduce GHG emissions and foster a sustainable community through 2050 and beyond. Through the qualified GHG Reduction Strategy, Santa Rosa Forward will (1) accelerate reductions in GHG emissions from community-wide sources in an equitable and sustainable manner, (2) provide a comprehensive set of goals, policies, and actions to reduce community emission sources through 2050, (3) meet State requirements related to GHG emissions reduction, (4) leverage work of the Regional Climate Protection Authority, and (5) integrate climate and GHG reductions throughout the General Plan. The proposed GHG Reduction Strategy includes an inventory and forecast of GHG emissions within the city limit and planning area, mandates for future GHG emissions, strategies to reduce GHG emissions, and an implementation plan. The proposed GHG Reduction Strategy is made up of three sections: (1) Introduction, (2) Community-wide Greenhouse Gas Emissions, and (3) GHG Emissions- Reduction Measures and Programs. A complete copy of the proposed GHG Reduction Strategy is included in Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR. It is also included in Appendix A,
Greenhouse Gas Reduction Strategy, of the proposed General Plan 2050.
The proposed GHG Reduction Strategy incorporates many of the proposed goals, policies, and actions of the proposed General Plan 2050 and consolidates these items into a set of measures and implementation programs and presents detailed quantification and other details consistent with CEQA Guidelines Section 15183.5, to support ongoing reductions through 2050. The proposed GHG Reduction Strategy’s GHG emissions-reduction measures and programs include both pre-existing measures that have already started to be implemented, and new measures that are being introduced for the first time as part of this GHG Reduction Strategy. Projected emissions reductions within the city limits are presented for the years 2030, 2045, and 2050 for both new and pre-existing measures. The proposed GHG Reduction Strategy provides a clear roadmap to meeting the per-capita GHG emissions target consistent with State guidance as well as demonstrates the path to achieving the State’s mandate of carbon neutrality by 2045 required by Executive Order B-55-18. See Chapter 4.0, Environmental Analysis, of this Draft EIR under subheading “Greenhouse Gas Reduction Strategy” for a description of how the proposed GHG Reduction Strategy is a Qualified GHG Reduction Strategy pursuant to CEQA and how development projects that are consistent with the local qualified reduction strategy would not result in a cumulatively considerable GHG emissions impact, reducing the need for additional analyses or mitigation measures.
8 Government Code Section 65860 (vertical consistency).
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
3-28 OCTOBER 2024
3.8 2050 DEVELOPMENT PROJECTIONS
This Draft EIR analyzes the potential for growth to 2050, which represents an approximately 25-year buildout horizon. Under CEQA Guidelines Section 15126.6(3)(A), when a project consists of the revision of a plan or policy, the project’s impacts are assessed against existing conditions, and future conditions under the existing plan are treated as the “No Project” alternative.
Under Section 15064(d) of the CEQA Guidelines, “In evaluating the significance of the environmental effect of a project, the lead agency shall consider direct physical changes in the environment which may be caused by the project and reasonably foreseeable indirect physical changes in the environment which may be caused by the project.” The projections represent the City’s estimation of all “reasonably foreseeable” development, including the application of current and future density bonuses, the proposed Missing Middle Housing Bonus described in Section 3.7.3.2, Title 20: Zoning Code, and other development incentives, that could occur over the next 25 years. These projections are used as the basis for the EIR’s environmental assessment that rely on quantitative analysis. See Chapter 4.0, Environmental Analysis, for a description of environmental analysis scenarios for this EIR. The projections do not presume that every parcel is developed to the maximum level allowed under the proposed General Plan 2050. Rather, they recognize regional demographic and economic forecasts, and the probable share of regional growth that would be captured by Santa Rosa given its policies and land use regulations. Horizon year (2050) projections in the EIR Study Area are shown in Table 3-6, Proposed 2050 Buildout Projections in the EIR Study Area.
TABLE 3-6 PROPOSED 2050 BUILDOUT PROJECTIONS IN THE EIR STUDY AREA Category
Existing Conditions
(2019)
Projected Growth 2019-2050
(Proposed Project)
Buildout Estimates
(2050)
Housing Units 75,850 24,090 99,940
Total Population 197,980 65,760 263,740
Jobs 77,590 14,090 91,680
Notes: Numbers are rounded from original sources.
Source: City of Santa Rosa, PlaceWorks, Sonoma County Transportation Authority, and W-Trans, 2023, Santa Rosa General Plan 2050 Travel Demand Model.
Through the 2050 buildout horizon, implementation of the proposed project is estimated to result in the following net growth by land uses:
2,128,000 square feet of office space
727,000 square feet of institutional space
945,000 square feet of retail space
71 acres of recreation-based uses
69 hotel rooms
800,000 square feet of industrial space
700,000 square feet of warehouse space
Areas of Change
The expansion of the city into surrounding lands is no longer a focus of City planning efforts. Growth and change in the city will be tailored to support maintenance and development of complete neighborhoods, particularly in Areas of Change. These are places where the City will focus efforts to address housing, SANTA ROSA GENERAL PLAN 205 0 DRAFT EIR
CITY OF SANTA ROSA
PROJECT DESCRIPTION
PLACEWORKS 3-29
services, connectivity, and/or infrastructure needs and help provide complete neighborhoods with goods and services that are easily available. The proposed General Plan 2050 identifies 21 Areas of Change, as shown on Figure 3-6, Proposed General Plan 2050 Areas of Change. Eleven Areas of Change are located within or directly adjacent to a PDAs and/or TPAs. See Chapter 4.0, Environmental Analysis, for more discussion on the Areas of Change and PDAs and TPAs.
3.9 INTENDED USES OF THE 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 over the buildout horizon. Each specific future project would conduct separate environmental review, as required by CEQA, to secure the necessary discretionary development permits. 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 proposed project and this EIR. Projects successive to this EIR include, but are not limited to, the following:
Approval and funding of major public projects and capital improvements Updates to the utility infrastructure master plans, such as the Water, Wastewater, and Stormwater Master Plans
Updates or amendments to the City’s Zoning Code
Issuance of permits and other approvals necessary for implementation of the proposed project Annexation of land into the city limit
Property rezoning consistent with the proposed General Plan 2050 Development plan approvals, such as tentative maps, variances, conditional use permits, and other land use permits
Permit issuance and other approvals necessary for public and private development projects Development agreement processes and approvals
3.10 REQUIRED PERMITS AND APPROVALS
The proposed project would require adoption by the Santa Rosa City Council. The Planning Commission will review the proposed project and make recommendations to the City Council. While other agencies may be consulted during the General Plan update process, their approval is not required for the adoption of the proposed General Plan 2050. However, subsequent development under the proposed General Plan 2050 may require approval of State, federal, responsible, and trustee agencies that may rely on the programmatic EIR for decisions in their areas of permitting HoenAve
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Proposed General Plan 2050 Areas of Change
Source: ESRI, 2022; City of Santa Rosa, 2023; PlaceWorks, 2024. 0 1 20.5
Miles
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Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
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PROJECT DESCRIPTION
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3. Rosewood Village
4. Marlow Center and Lance
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5. Coddingtown
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15. Bennet Valley
16. Santa Rosa Marketplace/
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17. Hearn Corridor
18. Roseland
19. Stony Point Circle
20. Oakmont
21. Southeast Greenway
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Environmental Analysis
This chapter describes the organization of the environmental analysis section of this Draft Environmental Impact Report (EIR) and the assumptions and methodology of the impact analysis and the cumulative impact setting.
CHAPTER ORGANIZATION
The Draft EIR is made up of 18 chapters that evaluate the direct, indirect, and cumulative environmental impacts of the proposed project. In accordance with Appendix F , Energy Conservation, and Appendix G, Environmental Checklist Form, of the California Environmental Quality Act (CEQA) Guidelines, the potential environmental effects of the proposed project are analyzed for potential significant impacts in the following environmental issue areas, which are organized with the listed abbreviations:
4.1 Aesthetics (AES)
4.2 Agricultural Resources (AG)
4.3 Air Quality (AIR)
4.4 Biological Resources (BIO)
4.5 Cultural Resources (CUL)
4.6 Energy (ENE)
4.7 Geology and Soils (GEO)
4.8 Greenhouse Gas Emissions (GHG)
4.9 Hazards and Hazardous Materials (HAZ)
4.10 Hydrology and Water Quality (HYD)
4.11 Land Use and Planning (LU)
4.12 Noise (NOI)
4.13 Population and Housing (POP)
4.14 Public Services, Parks, and Recreation (PS)
4.15 Transportation (TRAN)
4.16 Tribal Cultural Resources (TCR)
4.17 Utilities and Service Systems (USS)
4.18 Wildfire (WF)
Each chapter is organized into the following sections:
Environmental Setting offers an overview of federal, state, regional, and local laws and regulations relevant to each environmental issue, and a description of the existing environmental conditions, providing a baseline against which the impacts of the proposed project can be compared. Standards of Significance refer to the quantitative or qualitative standards, performance levels, or criteria used to evaluate the existing setting with and without the proposed project to determine whether the impact is significant. These thresholds are based primarily on the CEQA Guidelines, and also may reflect established health standards, ecological tolerance standards, public service capacity standards, or guidelines established by agencies or experts. Impact Discussion gives an overview of the potential impacts of the proposed project and explains why impacts are found to be significant or less than significant prior to mitigation. This subsection also includes a discussion of cumulative impacts related to the proposed project. Impacts and mitigation measures are numbered consecutively within each topical analysis and begin with an acronym or abbreviated reference to the impact section.
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STANDARDS OF SIGNIFICANCE
As stated, significance criteria are identified before the impact discussion subsection, under the subsection, “Standards of Significance.” For each impact identified, a level of significance is determined using the following classifications:
No impact. A no impact conclusion describes circumstances where there is no adverse effect on the environment.
Less than significant. A less-than-significant impact includes effects that are noticeable, but do not exceed established or defined thresholds, or can be mitigated below such thresholds. Significant. A significant impact includes a description of the circumstances where an established or defined threshold would be exceeded.
Significant and unavoidable. For each impact identified as being significant, the EIR identifies mitigation measures to reduce, eliminate, or avoid the adverse effect. If one or more mitigation measure would reduce the impact to a less-than-significant level successfully, this is stated in the EIR.
Significant and unavoidable impacts are described where mitigation measures would not diminish these effects to less-than-significant levels. The identification of a program-level significant and unavoidable impact does not preclude the finding of less-than-significant impacts for subsequent projects that comply with the applicable regulations and meet applicable thresholds of significance.
EVALUATION METHODOLOGY
Under CEQA, the decision as to whether an environmental effect should be considered significant is reserved to the discretion of the City of Santa Rosa, acting as the lead agency, based on substantial evidence in the record as a whole, including 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 based on the setting. The analysis in the Draft EIR is based on scientific and factual data that has been reviewed by the lead agency and represents the lead agency’s independent judgment and conclusions. 1 This section
describes the methodology for the program-level evaluation in Chapters 4.1 through 4.18 with respect to the horizon year, the baseline, the application of the proposed General Plan 2050 policies, amendments to the Zoning Map, the strategies to reduce GHG emissions, potential future projects in a priority development area (PDA) or a transit priority area (TPA), parking impacts, effects of the environment on the project, and cumulative impacts.
2050 HORIZON DEVELOPMENT POTENTIAL
The proposed project is made up of long-range policy documents (General Plan 2050, Zoning Map, and GHG Reduction Strategy) that do not directly result in development without additional approvals. Before any development can occur in the EIR Study Area, it must be analyzed for consistency with the adopted
1 California Code of Regulations, Title 14, Division 6, Chapter 3, Section 15064(b).
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General Plan, zoning requirements, and other applicable local and State requirements; comply with the requirements of CEQA as applicable; and obtain all necessary clearances and permits from regulatory agencies. The environmental analysis in this EIR discusses the potential for adverse impacts to occur from extending the buildout potential in the EIR Study Area to horizon year 2050; increasing the buildout potential in the EIR Study Area; new and modified General Plan goals, policies, and actions; amending the Zoning Map for consistency with the General Plan, and the new strategies to reduce GHG emissions.
The 2050 horizon development potential under the proposed project includes the net increase of realistic development potential for the city, including the application of current and future density bonuses, the proposed Missing Middle Housing Bonus described in Section 3.7.3.2, Title 20: Zoning Code, of Chapter 3, Project Description, of this Draft EIR, and other development incentives, that could occur over the next 25 years. Buildout methodology focused on vacant and underutilized lands and pipeline development projects in the city of Santa Rosa. Various unit per acre density factors and developable lot coverage were applied for each parcel based on zoning code requirements, total parcel size, site location, and possible constraints. Constraints included existing structures, fire hazard zones, and/or lands within 500 feet of select highway right of way. Opportunity sites within the Areas of Change were also closely analyzed to determine total growth capacity and investigate rezoning opportunities to meet the development goals for each growth area.
As shown in Table 3-6, Proposed 2050 Buildout Projections in the EIR Study Area, in Chapter 3 of this Draft EIR, this combined projected new growth in the entire EIR Study Area for the 2050 horizon year includes approximately 24,090 new residential units; 65,760 new residents; and 14,090 new jobs. Because the proposed project consists of long-term policy documents (i.e., General Plan 2050, Zoning Ordinance, and GHG Reduction Strategy) that are intended to guide future development activities and City actions, and because no specific development projects are proposed as part of the project, it is reasonable to assume that future development would occur incrementally or gradually over the approximately 25-year buildout horizon (e.g., 2025 to 2050). However, while this assumption describes the long-range nature of the proposed project, it does not prohibit or restrict when development can occur over the horizon period.
BASELINE
This EIR evaluates the impacts of the proposed project relative to existing conditions of the EIR Study Area, as required by CEQA Guidelines Section 15126.2. As described in Chapter 3, Project Description, of this Draft EIR, the EIR Study Area includes all land within the city limit, planning area, Urban Growth Boundary and Sphere of Influence (see Figure 3-2, General Plan 2050 Planning Boundaries and EIR Study Area, in Chapter 3 of this Draft EIR). The baseline represents the existing conditions on the ground (“physical conditions”) at the time that the Notice of Preparation (NOP) was issued (February 7, 2023).
However, some baseline conditions apply 2019 data.
As described in Chapter 3 of this Draft EIR, the process to update the existing General Plan 2035 began in 2019 and the collection of data was initially hindered by the disruptions created by the coronavirus disease 2019 (COVID-19) pandemic. The COVID-19 pandemic introduced a substantial amount of uncertainty in human lives. It directly affected human behavior, by initially requiring people to shelter in place, implement social/physical distancing, and make other changes to the way they live. Indirectly, it affected the economy, resulting in reduced consumer spending, business closures, and widespread SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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unemployment. Though some of these trends were considered short term and, in some cases, have reversed, some permanent changes in the ways humans live and behave have occurred in the post- pandemic world. Because the NOP was issued in early 2023, where feasible, baseline data has been applied that reflects the 2023 NOP . However, transportation data, which, in addition to the transportation analysis, is relevant to air quality, energy, greenhouse gas emissions, and noise, relies on the Sonoma County Transportation Authority (SCTA) Sonoma County Travel Model (SCTM19, revised December 2021).
The SCTA updates the SCTM on an approximately five-year cycle. Each major revision includes updates to existing land use inventories for all jurisdictions in the County, as well as calibration to both reflect current travel patterns within the County and align with the inputs and projections produced by the nine-County regional travel demand model maintained by the Metropolitan Transportation Commission (MTC). The SCTA travel demand model used in the analysis for this EIR is keyed to a 2019 base year and remains the model version used in Sonoma County to establish baseline VMT values. The next revision of the SCTM model is anticipated to be released by SCTA in 2025.
As discussed in Chapter 3 of this Draft EIR and shown in Table 3-6, Proposed 2050 Buildout Projections in the EIR Study Area, the baseline for the EIR Study Area includes the following existing conditions:
Housing Units: 75,850
Population: 197,980
Jobs: 77,590
GENERAL PLAN 2050 GOALS, POLICIES, AND ACTIONS
As discussed in Chapter 3, Project Description, of this Draft EIR, the proposed General Plan 2050 goals, policies, and actions aim to reduce vehicle miles traveled (VMT), GHG emissions, air and water pollutants, wasteful energy consumption, and solid waste generation, and improve water use efficiency by promoting infill development; increase opportunities for alternative modes of transportation, pedestrian and bicycle access and connectivity, and local jobs; protect open space; conserve natural resources; and require adherence to green building practices. The proposed General Plan 2050 goals, policies, and actions aim to avoid hazardous conditions and facilitate a healthy and safe environment for residents and visitors to Santa Rosa. In addition, General Plan policies aim to protect cultural resources, including historic buildings, and ensure new development and redevelopment is compatible with neighboring land uses.
While the proposed General Plan 2050 policies and actions aim to reduce environmental impact, the EIR process provides an additional opportunity to modify the policies and programs to ensure they adequately reduce impacts from potential future projects in Santa Rosa.
For each significant impact, the EIR must identify one or more feasible mitigation measures or explain why no feasible mitigation measures are available. CEQA Guidelines Section 15370 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; or (5) compensating for the impact by replacing or providing substitute resources or environments. An EIR SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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should focus on mitigation measures that are feasible,2 practical, and effective. Pursuant to CEQA Guidelines Section 12156.4(a)(1)(B), it is ordinarily not appropriate to defer the formulation of mitigation measures 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.
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 required as means to mitigate environmental impacts under CEQA. These policies and actions are fully enforceable at the discretion of the decision-maker and use the imperative “shall,” and in all 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.
Additionally, the EIR considers the potential for environmental impacts from the implementation of General Plan policies and actions. Amended and new policies collectively reflect the changes to the current General Plan 2035. Substantive General Plan policy and action changes include the addition, removal, or functional revisions (i.e., not purely semantic) to the text in ways that have the potential to result in a physical impact on the environment. Nonsubstantive changes include the renumbering of policies and actions or minor text revisions, which do not have the potential to result in a physical change to the environment. The content of the proposed General Plan 2050 policies and actions is directly integrated with and reflective of the proposed project as a whole. Therefore, impact discussions for the effects of the proposed project necessarily encompass analysis of the effects of the substantive policy changes as a whole, and those with relevance to CEQA topics are discussed in the appropriate chapters.
ASSOCIATED SPECIFIC PLAN AND CODE AMENDMENTS
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), the Santa Rosa City Code (SRCC), and GHG Reduction Strategy are consistent with the General Plan (also known as vertical consistency).4 The impacts from the proposed amendments to the NSASP , DSASP , and SRCC are therefore analyzed concurrently with the impacts of the proposed General Plan 2050.
2 Pursuant to CEQA Section 21061.1, the term “feasible” is defined 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.” 3 Government Code Section 65300.5 (internal consistency). 4 Government Code Section 65860 (vertical consistency).
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GREENHOUSE GAS REDUCTION STRATEGY
As described in Chapter 3, Project Description, of this Draft EIR the proposed GHG Reduction Strategy is an update to and replacement of the City’s 2012 Community-wide Climate Action Plan and would serve as the strategic plan for how the City will reduce GHG emissions and foster a sustainable community through 2045 and beyond. The proposed GHG Reduction Strategy provides a framework for reducing GHG emissions through recommended community-wide GHG reduction strategies. The proposed GHG Reduction Strategy provides a clear roadmap to meeting the per-capita GHG emissions target consistent with State guidance as well as demonstrating the path to the goal of carbon neutrality by 2045 mandated by Executive Order (EO) B-55-18.
Under CEQA Guidelines Section 15183.5, Tiering and Streamlining the Analysis of Greenhouse Gas Emissions, local strategic plans to reduce GHG emissions can help with the environmental review process for new development proposals defined as projects under CEQA. Plans that may be used this way are referred to as Qualified GHG Reduction Strategies or Plans and must satisfy the following criteria:
Quantify emissions, both existing and projected over a specified period, resulting from activities within a designed geographic area.
Establish a level, based on substantial evidence, below which the contribution to GHG emissions from an activity covered by the plan would not be cumulatively considerable. Identify and analyze the emissions resulting from specific actions or categories of actions anticipated within the geographic area.
Specify GHG reduction strategies or a group of strategies, including performance standards that, if implemented on a project-by-project basis, substantial evidence demonstrates they would collectively achieve the specified emissions level.
Establish a mechanism to monitor the plan’s progress toward achieving specific levels and to require amendment if the plan is not achieving those levels.
Include an environmental review of the plan.
If these plans meet the State criteria as determined by the City as the lead agency, potential future development projects that are consistent with the local qualified reduction strategy would not result in a cumulatively considerable GHG emissions impact, reducing the need for additional analyses or mitigation measures. Additionally, the GHG Reduction Strategy must identify measures and performance standards that can be clearly shown to achieve this determination. As a result, a GHG Reduction Strategy seeking to be a “Qualified” GHG Reduction Strategy must have a GHG emission-reduction target or targets that substantially reduce GHG emissions, can also be feasibly achieved, and reasonably tracked and reported over time.
As a component of the proposed project, the implementation of the proposed GHG Reduction Strategy, including potential new development associated with the new reduction measures and programs, will be analyzed at a programmatic level as part of this EIR. Following certification of this EIR, this would allow the proposed GHG Reduction Strategy to support and streamline environmental review of GHG emissions for future development projects in the city pursuant to CEQA Guidelines Section 15183.5.
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The proposed GHG Reduction Strategy includes the strategies that are required to reduce GHG emissions.
Like the proposed General Plan 2050 policies, the proposed GHG Reduction Strategy aims to reduce community-wide GHG emissions. The GHG emission-reduction strategies include a mix of education and outreach programs to encourage GHG emission-reduction activities, rebates, and other enticements to incentivize GHG emissions reductions, and mandates to require GHG emissions-reduction efforts. The GHG emission-reduction strategies also support broader sustainability initiatives.
Additionally, the proposed GHG Reduction Strategy implementation would not result in changes to the land use plan under the proposed General Plan 2050. Thus, because there is no specific land use component associated with the proposed GHG Reduction Strategy, its implementation would not directly result in the generation of GHG emissions. The proposed General Plan 2050 references the proposed GHG Reduction Strategy, recognizing that the City’s climate action planning efforts must be updated more regularly to be responsive to the changing regulations, guidance, technology, best practices, and science.
PRIORITY DEVELOPMENT AND TRANSIT PRIORITY AREAS
The Metropolitan Transportation Commission (MTC) and Association of Bay Area Government (ABAG) Plan Bay Area is the San Francisco Bay Area’s Regional Transportation Plan/Sustainable Community Strategy. Plan Bay Area is the long-range integrated transportation and land use/housing strategy through 2050 for the Bay Area, pursuant to the Sustainable Communities and Climate Protection Act (Senate Bill [SB] 375). MTC and ABAG adopted the current version of Plan Bay Area on October 21, 2021.5 Plan Bay Area 2050 is a limited and focused update to the Plan Bay Area 2040, with updated planning assumptions that incorporate key economic, demographic, and financial trends from the last several years.6 As part of the implementing framework for Plan Bay Area, PDAs and TPAs are identified as areas where concentrated development can have beneficial environmental effects and reduce adverse environmental impacts. Additional details about PDAs and TPAs are provided in the sections that follow.
PRIORITY DEVELOPMENT AREAS
A PDA is a place that has convenient public transit service, often referred to as “transit-oriented,” that is prioritized by local governments, such as Santa Rosa, for housing, jobs, and services within existing communities. All PDAs are created and planned by local governments, which nominate eligible areas to ABAG for adoption. The PDAs identified throughout the Bay Area in Plan Bay Area 2050 were projected to accommodate 72 percent (or 985,000 units) of new housing and 48 percent (or 679,000) of new jobs in the region from the 2015 baseline.
7 Development in PDAs leverage existing infrastructure and therefore can minimize development in green field (undeveloped) areas and maximize growth in transit-rich
5 Association of Bay Area Governments and Metropolitan Transportation Commission, October 2021, Plan Bay Area 2050, https://www.planbayarea.org/sites/default/files/documents/Plan_Bay_Area_2050_October_2021.pdf, accessed July 21, 2023. 6 Metropolitan Transportation Commission and Association of Bay Area Governments, October 2021, Plan Bay Area 2050, https://www.planbayarea.org/sites/default/files/documents/Plan_Bay_Area_2050_October_2021.pdf, accessed February 27, 2023.
7 Metropolitan Transportation Commission and Association of Bay Area Governments, October 2021, Plan Bay Area 2050, https://www.planbayarea.org/sites/default/files/documents/Plan_Bay_Area_2050_October_2021.pdf, accessed February 27, 2023.
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communities to help lower VMT and consequently reduce GHG emissions, air quality pollutants, and noise from vehicles with internal combustion engines dependent on fossil fuels and reduce wasteful, inefficient, or unnecessary consumption of energy resources. Additionally, due to the location, infill development in PDAs result in fewer impacts related to agricultural, forestry, mineral, archaeological, and biological resources, energy, geology and soils, hydrology and water quality, and wildfire. Impacts related to concentrated development in the PDAs is discussed throughout this Draft EIR, and specific quantified impacts are described in Chapter 4.3, Air Quality, Chapter 4.8, Greenhouse Gas Emissions, and Chapter
4.15, Transportation, of this Draft EIR.
Certain potential future residential or mixed-use residential projects and projects in PDAs that meet defined criteria in the CEQA Guidelines may be eligible for CEQA streamlining. For example, while not exclusive to PDAs, due to their urban setting, development in a PDA is more likely to qualify for a CEQA Guidelines Section 15332, Infill Development Projects, Class 32 Categorical Exemption.
TRANSIT PRIORITY AREAS
Plan Bay Area 2050 also identifies TPAs, referred to as Transit-Rich PDAs.8 These are areas within 0.5 miles of a major transit stop (i.e., a stop with service frequency of 15 minutes or less) that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon of a Transportation Improvement Program adopted pursuant to Section 450.216 or Section 450.322 of Title 23 of the Code of Federal Regulations. TPAs generally include existing neighborhoods served by transit and contain a wide range of housing options along with jobs, schools, and amenities. Certain potential future residential or mixed-use residential projects and projects
9 in TPAs that meet defined criteria in the CEQA Guidelines may be eligible for CEQA streamlining. Like development in PDAs, developing in TPAs also minimizes development in green field (undeveloped) areas and maximizes growth in transit-rich communities to help lower VMT and consequently reduce GHG emissions, air quality pollutants, and noise from vehicles with internal combustion engines dependent on fossil fuels and reduce wasteful, inefficient, or unnecessary consumption of energy resources.
With respect to potential future development in a TPA, SB 743, which became effective on January 1, 2014, amended CEQA by adding PRC Section 21099 regarding analysis of transportation, aesthetics, and parking impacts for urban infill projects, among other provisions.
SB 743 required the Governor’s Office of Planning and Research (OPR) to identify new metrics for identifying and mitigating transportation impacts under CEQA, shifting from a congestion-based (level of service or LOS) standard to a VMT standard. With the passage of SB 743 and the subsequent adoption of revised CEQA Guidelines (December 2018), level of service can no longer be used as a criterion for identifying significant transportation impacts for projects regardless of their location. Transportation impacts are discussed in Chapter 4.15, Transportation, of this Draft EIR.
8 Association of Bay Area Governments and Metropolitan Transportation Commission, 2021, Plan Bay Area 2050: Regional Growth Framework Update – Overview of Existing and Updated Geographies, https://www.planbayarea.org/sites/default/files/pdfs_referenced/2019_Regional_Growth_Framework_Update_- _Whats_Changed_1.pdf, accessed June 5, 2023.
9 A project in a transit priority area is referred to as a transit priority project (TPP).
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With respect to aesthetics and parking, CEQA Section 21099(d)(1), states, “Aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site located within a TPA shall not be considered significant impacts on the environment.” Accordingly, these topics are no longer to be considered in determining significant environmental effects for projects that meet all three of the following criteria:
Is located on an infill site that is defined as “a lot located within an urban area that has been previously developed or on a vacant site where at least 75 percent of the perimeter of the site adjoins or is separated only by an improved public right-of-way from parcels that are developed with qualified urban uses.”
Is a residential, mixed-use residential, or an employment-center project. Is in a transit priority area, as defined above.
Accordingly, in compliance with SB 743, no significant aesthetic or parking impacts can be made in the environmental analysis for potential future qualifying development in the TPAs in the EIR Study Area as they exist today or are modified over the buildout horizon.
EIR STUDY AREA PRIORITY DEVELOPMENT AND TRANSIT PRIORITY AREAS The EIR Study Area includes six PDAs and three TPAs, which are listed below and shown on Figure 4-1, Priority Development Areas and Transit Priority Areas.
Mendocino Avenue/Santa Rosa Avenue Corridor PDA. This PDA stretches north to south the length of the city along Mendocino Avenue south to Santa Rosa Avenue. It shares a border with all the other PDAs in the city. This PDA is designated as a “mixed-use corridor .” North Santa Rosa Station PDA and TPA. This PDA/TPA surrounds the North Santa Rosa Sonoma-Marin Area Rail Transit (SMART) station in northwest Santa Rosa and the PDA shares a border with the Mendocino Avenue/Santa Rosa Avenue Corridor and Downtown Station Area PDAs. The North Santa Rosa State PDA is designated as a “suburban center .”
Downtown Station Area PDA and TPA. This PDA/TPA encompasses the Downtown SMART station in Downtown Santa Rosa. The PDA shares a border with the Mendocino Avenue/Santa Rosa Avenue Corridor, North Santa Rosa Station, and Sebastopol Road Corridor PDAs. The Downtown Station Area PDA is designated as a “city center.” The Downtown Station TPA overlaps the Santa Rosa Transit Mall TPA.
Sebastopol Road Corridor PDA. This PDA stretches east to west along Sebastopol Road in west Santa Rosa and shares a border with the Mendocino Avenue/Santa Rosa Avenue Corridor, Downtown Station Area, and Roseland PDAs. This PDA is designated as a “mixed-use corridor.” Roseland PDA. This PDA is bordered by the Sebastopol Road Corridor PDA to the north, US Highway 101 to the east, Bellevue Avenue to the south, and Stony Point Road to the east. The Roseland PDA also shares a border with the Mendocino Avenue/Santa Rosa Avenue Corridor PDA. The Roseland PDA is designated as a “transit neighborhood.”
Santa Rosa Avenue PDA. This PDA stretches north to south along Santa Rosa Avenue, just south of the city limit and shares a border with the Mendocino Avenue/Santa Rosa Avenue Corridor PDA.
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Priority Development Areas and Transit Priority Areas
Source: City of Santa Rosa, 2020; MTC/ABAG, 2021; ESRI, 2022; PlaceWorks, 2024. 0 1 20.5
Miles
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Santa Rosa Transit Mall TPA. This TPA surrounds the Santa Rosa Transit Mall, which is a major transfer point for several bus routes serving the city.
AREAS OF CHANGE
The proposed General Plan 2050 identifies 21 Areas of Change where the City will focus on housing, services, connectivity, and/or infrastructure needed to make complete neighborhoods. Potential future development in the EIR Study Area is projected to occur primarily in the proposed General Plan 2050 Areas of Change in the form of infill/intensification on sites already developed or underutilized, and/or in close proximity to existing development and infrastructure. Complementing the Areas of Change are major improvements to the transportation network, which focus on bridging east and west and enhancing multimodal connectivity and safety citywide. Table 4-1, Proposed General Plan 2050 Areas of Change by PDA/TPA, shows the 11 Areas of Change that are within or directly adjacent to a PDA and/or TPA.
TABLE 4-1 PROPOSED GENERAL PLAN 2050 AREAS OF CHANGE BY PDA/TPA Area of Change No. and Name PDA/TPA
1. Fountaingrove/Mendocino Interchange Mendocino Avenue/Santa Rosa Avenue Corridor PDA
4. Marlow Center and Lance Drive Annexation North Santa Rosa Station PDA and TPA
5. Coddingtown North Santa Rosa Station PDA and TPA
6. West College Neighborhood Center North Santa Rosa Station PDA
7. Downtown Station Area Downtown Station Area PDA and TPA
8. Mendocino Corridor Mendocino Avenue/Santa Rosa Avenue Corridor PDA
9. 4th Street Corridor Downtown Station Area PDA and TPA (adjacent to)
16. Santa Rosa Marketplace/South Park Mendocino Avenue/Santa Rosa Avenue Corridor PDA
17. Hearn Corridor Roseland PDA
18. Roseland Sebastopol Road Corridor PDA
19. Stony Point Circle Sebastopol Road Corridor PDA
Notes: PDA = Priority Development Area; TPA = Transit Priority Area. See Figure 3-6, Proposed General Plan 2050 Areas of Change, in Chapter 3, Project Description, of this Draft EIR and Figure 2-5, Areas of Change, in Chapter 2, Land Use and Economic Development, of the proposed General Plan 2050.
Sources: City of Santa Rosa, 2020; Metropolitan Transportation Commission/Association of Bay Area Government, 2021; PlaceWorks, 2023.
PARKING
Effective in 2010, parking inadequacy as a significant environmental impact was eliminated from the CEQA Guidelines by OPR, which is the entity charged with drafting guidelines to help agencies implement CEQA.
Accordingly, parking adequacy in the EIR Study Area is not discussed further in this Draft EIR.
POTENTIAL EFFECTS OF THE ENVIRONMENT ON THE PROJECT
The California Supreme Court concluded in the California Building Industry Association vs. Bay Area Air Quality Management District (CBIA vs. BAAQMD) case that “CEQA generally does not require an analysis of how existing environmental conditions will impact a project’s future users or residents.” The CBIA vs.
BAAQMD ruling provided for several exceptions to the general rule where an analysis of the project on the environment is warranted: (1) if the project would exacerbate existing environmental hazards (such as exposing hazardous waste that is currently buried); (2) if the project qualifies for certain specific specified SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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exemptions (certain housing projects and transportation priority projects pursuant to PRC Sections 21159.21 (f) and (h), 21159.22 (a) and (b)(3), 21159.23 (a)(2)(A), 21159.24 (a)(1) and (3), or 21155.1 (a)(4) and (6)); (3) if the project is exposed to potential noise and safety impacts on projects due to proximity to an airport (pursuant to PRC Section 21096); and (4) school projects require specific assessment of certain environmental hazards (pursuant to PRC Section 21151.8). Therefore, the evaluation of the significance of project impacts under CEQA focuses on the potential impacts of the proposed project on the environment, including whether the proposed project may exacerbate any existing environmental hazards. Existing potential environmental hazards in Santa Rosa include seismic hazards, flooding, and wildfire. Therefore, while the effects of these hazards on the proposed project are not subject to CEQA review following the CBIA vs. BAAQMD case, 10 the City recognizes that seismic,
flooding, and wildfire hazards are issues of local concern. Therefore, a discussion of the project’s potential to exacerbate these hazardous conditions is provided in Chapter 4.7, Geology and Soils; Chapter 4.10, Hydrology and Water Quality; and Chapter 4.18, Wildfire, of this Draft EIR.
CUMULATIVE IMPACT ANALYSIS
A cumulative impact consists of an impact created as a result of the combination of the project evaluated in the EIR, together with other reasonably foreseeable projects causing related impacts. Section 15130 of the CEQA Guidelines requires an EIR to discuss cumulative impacts of a project when the project’s incremental effect is “cumulatively considerable.” Used in this context, cumulatively considerable means that the incremental effects of an individual project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.
In the case of a long-range plan such as the General Plan 2050, cumulative effects occur when future development under the long-range plan is combined with development in the surrounding areas, or in some instances, in the entire region.
Where the incremental effect of a project is not “cumulatively considerable,” a lead agency need not consider that effect significant but must briefly describe its basis for concluding that the incremental effect is not cumulatively considerable. The CEQA Guidelines state that a lead agency has discretion to determine if a project’s contribution to a significant cumulative impact is cumulatively considerable.
The cumulative discussions in Chapters 4.1 through 4.18 of this Draft EIR explain the geographic scope of the area affected by each cumulative effect (e.g., immediate project vicinity, county, watershed, or air basin). The geographic area considered for each cumulative impact depends on the impact that is being analyzed. For example, in assessing macro-scale air quality impacts, all development within the air basin contributes to regional emissions of criteria pollutants, and basinwide projections of emissions are the best tool for determining the cumulative impact. In assessing aesthetic impacts, on the other hand, only development within the local area of change would contribute to a cumulative visual effect since the area of change is only visible in its vicinity.
10 California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369.
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CEQA Guidelines Section 15130 permits two different methodologies for the cumulative impact analysis:
The “list” approach permits the use of a list of past, present, and probable future projects producing related or cumulative impacts, including projects both within and outside the city. The “projections” approach allows the use of a summary of projections in an adopted plan or related planning document, such as an RTP, or in an EIR prepared for such a plan. The projections may be supplemented with additional information such as regional modeling.
The cumulative impact analysis in this Draft EIR relies on a projections approach and takes into account growth from the proposed project in the EIR Study Area in combination with impacts from projected growth in the rest of Sonoma County and the surrounding region, as forecast by the Plan Bay Area. The following provides a summary of the cumulative impact setting for each impact area:
Aesthetics: The cumulative setting for visual impacts includes potential future development under the proposed project combined with effects of development on lands adjacent to the city in unincorporated Sonoma County.
Agricultural Resources: The geographic scope of the cumulative analysis for agricultural resources considers those agriculture resources deemed to be resources of statewide importance in the surrounding incorporated and unincorporated lands, the region, and the state. Air Quality: Cumulative air quality impacts could occur from a combination of the proposed project with regional growth in the San Francisco Bay Area Air Basin. Biological Resources: The geographic scope of the cumulative analysis for biological resources considers the surrounding incorporated and unincorporated lands and the region. Cultural Resources: Cumulative impacts to cultural resources could occur from projected growth in the surrounding region.
Energy: Cumulative impacts to energy resources could occur from the estimated growth in the service area for the two energy providers, Sonoma Clean Power and Pacific Gas and Electric Company. Geology and Soils: Potential cumulative geological impacts could arise from future growth in the immediate vicinity of Sonoma County.
Greenhouse Gas Emissions: The cumulative impact analyses for GHG emissions are related to the entire region. Because GHG emissions are not confined to a particular air basin but are dispersed worldwide, the cumulative impact analysis focuses on the global impacts and thus, is by its nature cumulative.
Hazards and Hazardous Materials: The cumulative analysis considers the effects of growth in the rest of Sonoma County and surrounding region.
Hydrology and Water Quality: The geographic context used for the cumulative assessment of hydrology and water quality impacts, including the potential to exacerbate the potential for flooding, considers the watersheds that encompass Santa Rosa.
Land Use and Planning: The geographic context for the cumulative land use and planning effects considers impacts from projected growth in the rest of Sonoma County and the surrounding region, as forecast in the Plan Bay Area.
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Noise: The traffic noise levels are based on cumulative traffic conditions that take into account cumulative development in the Sonoma County region.
Population and Housing: Impacts from cumulative growth are considered in the context of their consistency with regional planning efforts in the Sonoma County region. Public Services and Recreation: Cumulative impacts are considered in the context of projected growth in the rest of Sonoma County and the surrounding region, as forecast by the Plan Bay Area, and contiguous with the service area boundaries of the service providers evaluated in this section. Transportation: The analysis of the proposed project addresses cumulative impacts to the transportation network in the surrounding area.
Tribal Cultural Resources: Cumulative impacts to tribal cultural resources could occur from projected growth in the surrounding region.
Utilities and Service Systems: Cumulative impacts are considered in the context of the estimated growth in each utility’s service area.
Wildfire: The analysis of the proposed project includes a discussion of how cumulative development in the region may exacerbate wildfire risk in Santa Rosa and the surrounding area.
.
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4.1 AESTHETICS
This chapter of the Draft Environmental Impact Report (EIR) describes the potential aesthetics impacts associated with the adoption and implementation of the proposed project. This chapter describes the regulatory framework and existing conditions, identifies criteria used to determine impact significance, provides an analysis of the potential aesthetics impacts, and identifies proposed General Plan 2050 goals, policies, and actions
that would minimize any potentially significant impacts.
4.1.1 ENVIRONMENTAL SETTING
REGULATORY FRAMEWORK
State Regulations
California State Scenic Highways Program
California's Scenic Highway Program was created by the State legislature in 1963. Its purpose is to protect and enhance the natural scenic beauty of California highways and adjacent corridors through special conservation treatment. The State laws governing the Scenic Highways Program are found in the Streets and Highways Code, Sections 260 through 263.
When a city or county nominates an eligible scenic highway for official designation, it must identify and define the scenic corridor of the highway. Scenic corridors consist of land that is visible from the highway right-of-way and is composed primarily of scenic and natural features. Topography, vegetation, viewing distance, and/or jurisdictional lines determine the corridor boundaries. The city or county must also adopt ordinances, zoning, and/or planning policies to preserve the scenic quality of the corridor or document such regulations that already exist in various portions of local codes. These ordinances and/or policies make up the Corridor Protection Program. The status of a proposed State scenic highway changes from “eligible” to “officially designated” when the local governing body applies to the California Department of Transportation (Caltrans) for scenic highway approval, adopts a Corridor Protection Program, and receives notification that the highway has been officially designated a Scenic Highway.
California Building Code
The State of California provides a minimum standard for building design through the California Code of Regulations, Title 24, Part 2, commonly referred to as the California Building Code (CBC). All of Title 24, including the CBC, is updated on a three-year cycle. The CBC is effective statewide, but a local jurisdiction may adopt more restrictive standards based on local conditions under specific amendment rules prescribed by the State Building Standards Commission. The CBC includes standards for outdoor lighting that are intended to reduce light pollution and glare by regulating light power and brightness, shielding, and sensor controls.
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California Building Code: CALGreen
The California Building Standards Commission adopted the California Green Building Standards Code as Part 11 of Title 24, also known as CALGreen. CALGreen establishes building standards aimed at enhancing the design and construction of buildings through the use of building concepts that reduce negative impacts and increase positive environmental impacts by encouraging sustainable construction practices.
Specifically, Section 5.106.8, Light Pollution Reduction, establishes backlight, uplight, and glare ratings to minimize the effects of light pollution for nonresidential development. The local building permit process enforces the mandatory provisions of CALGreen.
Public Resources Code Section 21099
As described in Chapter 4.0, Environmental Analysis, of this Draft EIR, PRC Section 21099, commonly referred to as its legislative bill number Senate Bill 743, passed in 2013, made changes to the California Environmental Quality Act (CEQA) for projects located in transit-oriented development areas. Among these changes are that a project’s aesthetics impacts are no longer considered significant impacts on the environment if the project is a residential, mixed-use residential, or employment center project and if the project is located on an infill site within a transit priority area (TPA). 1 This was implemented to help the
State achieve greenhouse gas reductions while prioritizing jobs and housing. As described in Chapter 4.0, and shown on Figure 4-1, Priority Development Areas and Transit Priority Areas, of this Draft EIR, portions of the EIR Study Area are located in three TPAs surrounding the North Santa Rosa Sonoma-Marin Area Rail Transit (SMART) station, the Downtown SMART station, and the Santa Rosa Transit Mall as identified in Plan Bay Area,2 the guiding framework for transportation and land use planning throughout the San Francisco Bay Area, coordinated by the regional planning agencies, the Association of Bay Area Governments and the Metropolitan Transportation Commission. Therefore, within these areas where projects are infill and also a residential, mixed-use residential, or employment center project, pursuant to PRC Section 21099(d), aesthetics impacts shall not be considered significant environmental impacts.
Local Regulations
Santa Rosa City Code
The Santa Rosa City Code (SRCC) includes various directives to minimize adverse impacts to visual resources in Santa Rosa. The SRCC is organized by title, chapter, and section, and in some cases, articles.
Most provisions related to aesthetics and visual resources are in Title 13, Streets, Sidewalks, and Public Places; Title 17, Environmental Protection; Title 18, Buildings and Construction; and Title 20, Zoning, as follows:
Title 13, Streets, Sidewalks, and Public Places. Title 13 of the SRCC includes regulations that govern street encroachments, utilities, parks, and setback lines. Chapter 13-12, Underground Utilities, includes regulations related to aesthetics which prohibit the above-ground suspension of any wires or
1 California Legislative Information, 2013, Senate Bill No. 743, Chapter 386, http://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201320140SB743&search_keywords=, accessed July 9, 2020. 2 Metropolitan Transportation Commission, 2021, Transit Priority Areas, https://www.arcgis.com/apps/mapviewer/index.html?layers=370de9dc4d65402d992a769bf6ac8ef5, accessed March 2, 2023.
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any poles designed to carry telephone, telegraph, or electric conduit. Chapter 13-28, Setback Lines, includes development standards related to aesthetics which authorize the City Council to determine the minimum setback distance of the street line for the erection of buildings or structures along any portion of any street in the city.
Chapter 17-22, Historic and Cultural Preservation. The City adopted the Historic and Cultural Preservation Ordinance in 1988. This chapter outlines the methods that items can be identified and protected as cultural and historical resources.
Title 18, Buildings and Construction. As described under State Regulations, the California Building Code (Title 24, Part 2) and CALGreen (Title 24, Part 11), both include outdoor lighting standards to regulate light pollution. The City of Santa Rosa has adopted all sections of the CBC Title 24, Part 2, in Chapter 18-16, California Building Code, and Chapter 18-42, Citation of California Green Building Standards Code, of the SRCC.
Title 20, Zoning. The Santa Rosa Zoning Code implements the goals and policies of the General Plan by classifying and regulating the uses of land and structures within the city. In addition, the Zoning Code is adopted to protect and to promote the public health, safety, and general welfare of residents, and preserve and enhance the aesthetic quality of the city. The following provisions of the Zoning Code help minimize the visual impacts of new development projects in Santa Rosa:
Section 20-28.050, Scenic Road (-SR) Combining District. This section of the Zoning Code aims to preserve the natural and constructed features that contribute to the character of scenic roads.
This district may be combined with any primary zoning district, provided that the standards of Section 20-28.050 shall apply only to the portions of parcels within 125 feet or less from the edge of the pavement of the designated scenic road. Portions over 125 feet in length from the edge of the pavement of the designated scenic road shall be regulated by the standards of the primary zoning district. Proposed development and new land uses shall comply with the standards, as applicable. In the event of any conflict between the standards and those of the primary zoning district, the most restrictive shall apply. The standards in this section outline ten roads in Santa Rosa and their minimum setback distances, as well as more specific requirements for each road. Chapter 20-30, Standards for all Development and Land Uses. This chapter of the Zoning Code sets forth standards to address the details of site planning and project design to ensure that all development within Santa Rosa creates an environment of desirable character, is compatible with existing and future development, and protects the use and enjoyment of neighboring properties consistent with the General Plan. Section 20-30.040, Creekside development, requires minimum setbacks from waterways for new structures and states that these developments are required to comply with Section 4.4, Creeks, Riparian Corridors, and Storm Drainage, of the City’ Design Guidelines. Section 20-30.080, Outdoor lighting, establishes maximum height standards for outdoor lighting on private property and requires the use of energy-efficient fixtures. In addition, new development is required to shield and direct lighting fixtures downward and away from adjoining properties to reduce spill-over lighting and light pollution. Chapter 20-32, Hillside Development Standards. This chapter of the Zoning Code aims to preserve and enhance Santa Rosa’ scenic character, conserve open spaces and significant natural features, respect natural features in the design and construction of hillside development, and design hillside development to be sensitive to existing terrain, views, and significant landforms and SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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features. Section 20-32.050, Site planning and development standards, requires each structure shall be located in the most accessible, least visually prominent, most geologically stable, portion or portions of the site, and at the lowest feasible elevation. Structures shall also be aligned with the natural contours of the site to the maximum extent feasible. Section 20-32.060, Hillside development permit, outlines the review process for the City to consider the appropriateness of proposed development on hillside parcels, to ensure that a proposed project minimizes its visual and environmental impact.
Chapter 20-34, Landscaping Standards. This chapter of the Zoning Code establishes landscape standards to mitigate the effects of urbanization on the environment and to provide for an aesthetically pleasing urban setting. This chapter is also intended to encourage optimum use of drought-tolerant plant materials in conjunction with water-conserving automatic irrigation systems. Section 20-34.050, Landscape standards, outlines the standards that landscaped areas are required to comply with, including height limits, landscape design, and plant materials.
Section 20-34.070, Post-installation requirements, includes provisions for landscaping maintenance.
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.
Chapter 20-39, Objective Design Standards for By-Right Housing. This chapter of the Zoning Code establishes objective residential design standards that are sourced from the City’s Design Guidelines. This chapter applies to all residential projects which, upon applicant request and demonstration of eligibility, qualify for streamlined and ministerial processing.
Section 20-52.030, Design Review. This section of the Zoning Code establishes procedures for the City’s review of the design aspects of proposed development in compliance with the adopted Santa Rosa Design Guidelines. Proposed development requiring a building permit and/or resulting in exterior physical changes to existing structures are subject to the City’s design review process.
The design review authority charged with reviewing proposed development projects varies depending on the scale of the project. Projects that involve minor improvements such as a new door or window are reviewed by the Director of Planning and Economic Development.
Development projects with up to 10,000 square feet of total floor area that are not located within a historic district are reviewed by the Zoning Administrator . Development projects with 10,000 square feet or more of total floor area that are not located within a historic district or projects with 5,000 square feet or more that are located within a historic district are reviewed by the Design Review Board (DRB). The designated design review authority reviews project features such SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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as building design, landscaping, site planning, and signage. The criteria for design review are as follows:
1. The design and layout of the proposed development is of superior quality, and is consistent with the General Plan, any applicable specific plan, applicable Zoning Code standards and requirements, the City’s Design Guidelines, architectural criteria for special areas, and other applicable City requirements (e.g., City policy statements and development plans);
2. The design is appropriate for the use and location of the proposed development and achieves the goals, review criteria, and findings for approval as set forth in the framework of Design Review (Design Guidelines, Introduction, subsection C);
3. The design and layout of the proposed development will not interfere with the use and enjoyment of neighboring existing or future developments;
4. The architectural design of the proposed development is compatible with the character of the surrounding neighborhood;
5. The design of the proposed development will provide a desirable environment for its occupants, visiting public, and its neighbors through the appropriate use of materials, texture, and color, and would remain aesthetically appealing and be appropriately maintained;
6. The proposed development will not be detrimental to the public health, safety, or welfare or materially injurious to the properties or improvements in the vicinity; and
7. The project has been reviewed in compliance with CEQA.
Santa Rosa Design Guidelines
The Santa Rosa Design Guidelines (Design Guidelines), adopted in 2002, supplement and enhance design concepts that promote “superior design” by exhibiting thoughtful relationships in the natural and built environment with respect to architecture, landscaping, placemaking and livability, and sustainability. The Design Guidelines provide a clear set of design policies to project sponsors such as developers, property owners, architects, designers, and public agencies and establish criteria for project review. The Design Guidelines apply to all projects that require design review, including most new buildings, subdivisions, infill development, and public improvements. The Design Guidelines represent the city’s design and development pattern preferences and facilitate the city’s transition to prioritize infill development and increased development in the urban core. The guidelines are organized into four sections:
Neighborhood Design. Focuses on neighborhood-scale design issues. Downtown Station Area. Identifies key components to support a vibrant, pedestrian-oriented downtown and ways to encourage development.
Residential, Commercial, and Industrial Beyond the Core Area. Provides goals, site planning guidelines, and building design guidelines for single-family residential, multifamily residential, retail centers and commercial districts, and business and light industrial parks and buildings. Special Design Considerations. Addresses considerations, including streetscape, historic factors, hillside development, and infill projects.
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Processing Review Procedures for Owners of Historic Properties Adopted in 2001, the Cultural Heritage Board created the Processing Review Procedures for Owners of Historic Properties to assist owners, designers, and citizens in the preservation of Santa Rosa’s historic resources. These procedures are referenced in the Design Guidelines and apply to all historic properties in the city. The report includes background on design review including historic preservation and landmarks, the Cultural Heritage Board, CEQA compliance, and the step-by-step procedures applicants need to follow in preparing and submitting their applications for design review. 3 It also provides the design guidelines
and review procedures for historic properties.
Citywide Creek Master Plan
The Citywide Creek Master Plan, adopted in 2007 and updated in 2013, provides guidelines for the care, management, restoration, and enhancement of the network of creeks and waterways that flow through Santa Rosa, which affect the visual setting.
4 The plan is organized into six chapters: Introduction; Goals, Objectives, and Policies; Plan Concepts; Watershed-Specific Recommendations; Implementation Strategy; and References. Each chapter provides guidelines to aid the City’s decision-making when planning creek enhancement and restoration activities, coordinating and expanding creekside trail systems, making broader land use planning decisions concerning creeks, and in the development approval process for projects proposed adjacent to waterways.
Sebastopol Road Urban Vision and Corridor Plan
The Sebastopol Road Urban Vision Plan, adopted in 2007 after intensive community outreach, envisions development along the stretch of Sebastopol Road between Dutton Avenue and Stony Point Road in the Roseland community. The plan establishes guidelines for land use concepts, urban design criteria, streetscape elements, and a neighborhood center concept for Roseland Village Shopping Center and Dutton Plaza. It rearranges land uses to stimulate economic revitalization with additional opportunities for commercial and residential uses; provides more green spaces; facilitates pleasant and safer pedestrian connectivity; aims to decongest traffic with new alternative routes; and provides public spaces for socializing and a large community gathering space for special events.
Street Light Design Standards
Adopted in November 2011, the Street Light Design Standards establish uniform standards in accordance with City standards and policies for streetlights on public streets. 5 All street lighting projects are subject to
approval by the City Engineer . The Street Light Design Standards includes requirements for lateral light distribution based on location.
3 Santa Rosa Cultural Heritage Board, 2001, Processing Review Procedures, accessed on May 30, 2023, https://www.srcity.org/DocumentCenter/View/3259/Processing-Review-Procedures-for-Owners-of-Historic-Properties--- PDF?bidId=.
4 City of Santa Rosa, County of Sonoma, and Sonoma County Water Agency, August 2013, Santa Rosa Citywide Creek Master Plan, accessed April 5, 2023, https://www.srcity.org/DocumentCenter/View/13792/Santa-Rosa-Citywide-Creek-Master-Plan-PDF. 5 City of Santa Rosa, November 15, 2011, Street Light Design Standards, https://www.srcity.org/DocumentCenter/View/9814/Street-Light-Standards, accessed April 7, 2023.
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EXISTING CONDITIONS
Visual Character
The city of Santa Rosa is a visually and culturally rich community situated in central Sonoma County on the Santa Rosa Plain. The downtown area serves as the city’s primary activity node and consists of mixed office and retail uses. Local attractions such as the Old Courthouse; Santa Rosa Plaza, an indoor mall; and Railroad Square, a retail and hotel hub, are in the downtown area. Surrounding the downtown area are several historic districts, whose structures lend a sense of historic character to the city. The city’s residential neighborhoods are diverse, ranging from the traditional grid street patterns and moderately high densities to low density hillside neighborhoods.
Scenic Vistas, Corridors, and Roads
Scenic corridors are considered an enclosed area of landscape, viewed as a single entity that includes the total field of vision visible from a specific point, or series of points along a linear transportation route.
Public view corridors are areas in which short-range, medium-range, and long-range views are available from publicly accessible viewpoints, such as from city streets. However, scenic vistas are generally interpreted as long-range views of a specific scenic feature (e.g., open space lands, mountain ridges, bay, or ocean views). The city is bounded by the foothills of the Sonoma Mountains to the east and Laguna de Santa Rosa to the west. Long-range views of the Sonoma Mountains are predominantly visible from locations in the flatland areas of the city. Views of the natural hillsides and natural ridgelines such as Taylor Mountain and Bennet Mountain are important scenic vistas in the EIR Study Area. While there are no officially designated scenic vistas in the EIR Study Area, the City has officially designated the listed roadways in Santa Rosa as scenic roads in the General Plan. A scenic road is defined as a highway, road, drive, or street that provides opportunities for the enjoyment of natural and human-made scenic resources, in addition to its transportation function. Scenic roads direct views to areas of exceptional beauty, natural resources or landmarks, or historic or cultural interest.
1. Melita Road
2. Los Alamos Road
3. Calistoga Road (north of Badger Road)
4. Highway 12 (from Highway 101 west to
Fulton Road)
5. Highway 12 (from Farmers Lane to Calistoga
Road)
6. Highway 12 (from Calistoga Road to
Oakmont)
7. Montecito Avenue (north of Norte Way to
Chanate)
8. Brush Creek and Wallace Roads
9. Fountaingrove Parkway
10. Bennett Valley Road (south of Farmers Lane)
11. Montgomery Drive (from Mission Boulevard
to Melita Road)
12. Chanate Road (from Mendocino Avenue to
Fountaingrove Parkway)
13. Petaluma Hill Road (from Colgan Avenue to
the Urban Growth Boundary)
14. Highway 101 (contiguous from northern to
southern city limit)
15. Los Olivos Road
16. Manzanita Avenue
17. Newanga Avenue
18. Francisco Avenue
19. Channel Drive
20. Wright Road South
21. Ludwig Avenue
22. Burbank Avenue (from the northerly
boundary of Roseland Creek Community
Park to Hearn Avenue)
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State Scenic Highway
Caltrans has designated the section of State Route (SR) 12 within the EIR Study Area as “eligible” for a State Scenic Highway designation.6 A portion of SR 12 has also been “officially designated” as a State Scenic Highway, starting from Danielli Avenue in eastern Santa Rosa, to London Way near Agua Caliente.
Approximately 2.5 miles of the officially designated State Scenic Highway are within the EIR Study Area.
Light and Glare
Light pollution refers to all forms of unwanted light in the night sky around and above developed urban areas, including glare, light trespass, sky glow, and can also be visually disruptive to humans and nocturnal animal species, and often reflects an over lighting. Views of the night sky are an important part of the natural environment. Light pollution has the potential to become an issue of increasing concern as new development contributes additional outdoor lighting installed for safety and other reasons.
The EIR Study Area includes several urbanized areas with a variety of residential, commercial, and public uses. Existing sources of light and glare in the EIR Study Area are similar to those that would be found in any urbanized area, and include streetlamps, parking lot lighting, storefront and signage lighting, car headlamps, and interior lighting visible through windows. Light pollution is primarily limited to urban areas of the EIR Study Area and is restricted primarily to street lighting along major arterial streets, US Highway 101, SR 12, and to night-time illumination of commercial buildings, shopping centers, and industrial buildings. Light spillage from residential areas, particularly older neighborhoods, is mostly well screened by trees.
Transit Priority Areas
As described in Section 4.1.1.1, Regulatory Framework, the TPAs surrounding the North Santa Rosa SMART station, the Downtown SMART station, and the Santa Rosa Transit Mall are areas where no aesthetic impact findings can be made for future environmental analysis where projects are infill and also a residential, mixed-use residential, or employment center project, pursuant to PRC Section 21099(d).
4.1.2 STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in a significant aesthetic impact if it would:
1. Have a substantial adverse effect on a scenic vista.
2. Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
6 California State Scenic Highways Map,
https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa, accessed October 14, 2022.
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3. If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
4. Create a new source of substantial light or glare that would adversely affect day or nighttime views in the area.
5. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to aesthetics.
With respect to standard number three, the complete question in the CEQA Guidelines is “In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?” PRC (CEQA) Section 21071, Urbanized Area Definition, has several metrics by which a city can be defined as an urban area. CEQA Section 21071(a)(1) states that a city can be classified as an urban area if the city has a population of at least 100,000 people. According to the State of California Department of Finance, the population of Santa Rosa in 2019 was 174,885. 7 Therefore,
Santa Rosa is considered an urban area under CEQA Guidelines Section 21071, and impact discussion AES-3 as shown in the list of standards is based on the second part of the question.
4.1.3 IMPACT DISCUSSION
This section analyzes the proposed project’s potential impacts to aesthetics. The evaluation of aesthetics and aesthetic impacts is highly subjective. It requires the application of a process that objectively identifies the visual features of the environment and their importance. Aesthetic description involves identifying existing visual character, including visual resources and scenic vistas unique to Santa Rosa (see Section 4.1.1.2, Existing Conditions). Changes to aesthetic resources due to implementation of the proposed project are identified and qualitatively evaluated based on the proposed modifications to the existing setting and the viewer’s sensitivity. Project-related aesthetic impacts are determined using the threshold criteria discussed in Section 4.1.2, Standards of Significance.
AES-
1 Implementation of the proposed project would not have a substantial adverse effect on a scenic vista.
Future development under the proposed project would have the potential to affect scenic vistas/ corridors if new or intensified development blocked views of areas that provide or contribute to such visual resources. Potential effects could include blocking views of a scenic vista/corridor from specific, publicly accessible vantage points or the alteration of the overall scenic vista/corridor itself. Such alterations could be positive or negative, depending on the characteristics of individual future developments and the subjective perception of observers.
7 State of California, Department of Finance, May 2021, E-5 Population and Housing Estimates for Cities, Counties and the State: 2011-2020 with 2010 Census Benchmark, https://dof.ca.gov/forecasting/demographics/estimates/estimates-e5-2010- 2020/, accessed March 10, 2023.
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For the purposes of this analysis, the scenic vistas and corridors are limited to those listed in Section
4.1.1.2, Existing Conditions, under the subheading “Scenic Vistas and Corridors” and considers the sections of SR 12 that are officially designated and eligible for listing as an official scenic highway. Long- range views of the scenic vistas are generally seen from the flatland areas of the city, and the vistas would be affected if views of these resources were blocked by potential future development. Another effect that could occur is if potential future development altered areas surrounding the officially designated scenic roads. Such alterations could be positive or negative, depending on the characteristics of individual future developments and the subjective perception of observers.
As discussed in Chapter 3, Project Description, of this Draft EIR, potential future development from implementation of the proposed project is expected to occur in the proposed General Plan 2050 Areas of Change and would be concentrated in the form of infill/intensification on sites either already developed and/or underutilized, and/or in close proximity to existing development, where future development would have a lesser impact on scenic vistas and corridors. The proposed General Plan 2050 reinforces existing uses, heights, and densities in most locations, with allowances for greater intensity at locations that support the goal of a more sustainable, less auto-oriented city. Specifically, areas of concentrated growth would occur in areas such as the Mendocino Avenue/Santa Rosa Avenue Corridor Priority Development Areas (PDA), North Santa Rosa SMART station PDA and TPA, Downtown Station Area PDA and TPA, Sebastopol Road Corridor PDA, Roseland PDA, and Santa Rosa Transit Mall TPA. As shown on Figure 3-3, Proposed General Plan 2050 Land Use Map, and Figure 3-6, Proposed General Plan 2050 Areas of Change, in Chapter 3 of this Draft EIR, land uses that could generate denser and potentially taller buildings are primarily limited to the existing built environment where buildings of a variety of heights partially obstruct views from the public viewing locations that are at the pedestrian-level. In addition, as described in Chapter 3 of the Draft EIR, nearly all of the land use designations would remain unchanged under the proposed project. Therefore, similar views would continue to be visible between elements of the built environment and over lower-intensity areas, and no new impacts to views of the existing scenic resources described in Section 4.1.1.1 under subheading “Scenic Vistas and Corridors” would occur under the proposed General Plan 2050.
All potential future development in Santa Rosa that is subject to discretionary approval within the city limits would be required to comply with SRCC regulations described in Section 4.1.1.1, Regulatory Framework. Specifically, the SRCC includes a Scenic Road Combining District to preserve the natural and constructed features that contribute to the character of scenic roads. The Santa Rosa Design Guidelines would also apply to all projects that require design review, including most new buildings, subdivisions, infill development, and public improvements. Potential future development in the city would also be subject to the various planning documents that govern scenic quality in the city, as described in Section
4.1.1.1. These include the Citywide Creek Master Plan, Sebastopol Road Urban Vision and Corridor Plan, and Street Light Design Standards. The environmental and design review process for project-specific development serves to preserve and enhance views from other buildings and public property, thereby reducing the risk of potential future development blocking public views of significant visual resources.
Furthermore, 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, of the proposed General Plan 2050 contain goals, policies, and actions that require local planning and SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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development decisions to consider aesthetic impacts to scenic resources. The following goals, policies, and actions would serve to minimize impacts related to scenic vistas and/or corridors:
Goal 3-2: Provide a safe and accessible active and public transportation network that emphasizes active transportation connections and service to Equity Priority Areas and Areas of Change. Policy 3-2.4: Identify, preserve, and enhance City-designated scenic roads throughout Santa Rosa in both rural and developed areas, to encourage bicycle commuting and recreation. Action 3-2.25: Provide bicycle lanes along scenic roads where right-of-way exists. Action 3-2.26: Discourage on-street parking along scenic roads; bus stops or scenic overlooks may be provided at appropriate intervals
Action 3-2.27: Ensure that the size, amount, and placement of signage along scenic roads does not detract from the area’s scenic character .
Action 3-2.28: Update the Zoning Code to develop standards for scenic roadways identified in the General Plan that do not have corresponding development standards in the Zoning Code, including:
Highway 12 (from Highway 101
west to Fulton Road)
Highway 12 (from Farmers Lane to
Calistoga Road)
Fountaingrove Parkway
Bennett Valley Road (south of
Farmers Lane)
Montgomery Drive (from Mission
Boulevard to Melita Road)
Chanate Road (from
Mendocino Avenue to
Fountaingrove Parkway)
Petaluma Hill Road (from Colgan
Avenue to the Urban Growth
Boundary [UGB])
Highway 101 (contiguous from
northern to southern city limit)
Newanga Avenue
Channel Drive
Wright Road South
Ludwig Avenue
Burbank Avenue
Goal 4-1: Preserve and enhance Santa Rosa’s community character through attractive urban and environmental design and intentional development.
Policy 4-1.1: Preserve and enhance the visual beauty and value of the city’s natural waterways, hillsides, historic districts, buildings, structures, and landscapes. Action 4-1.1: Maintain view corridors from public vantage points to natural ridgelines and natural landmarks, such as Taylor Mountain and Bennett Mountain. Policy 4-1.2: Strengthen and emphasize community focal points, visual landmarks, and features that contribute to the identity of Santa Rosa by applying the design concepts and standards of the Zoning Code, Design Guidelines, Historic Combining Districts, Bicycle and Pedestrian Plan, and the Citywide Creek Master Plan.
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Action 4-1.3: Update the City’s Design Guidelines, Objective Design Standards, and/or Zoning Code, as appropriate, to:
Expand and refine objective design standards for residential development in compliance with State requirements and to create objective measures that relate to site context and promote livable environments.
Require landscape design to relate to the natural setting. Minimize grading for new development and revegetate graded areas around structures with native plants, as fire resistance allows.
Require structures in new developments to step with the slope of the site and its topography through use of split-level designs.
Policy 4-1.3: Enhance and strengthen the visual quality of major entry routes into the city and major corridors that link neighborhoods with downtown.
Action 4-1.4: Develop and implement a strategy for gateways, depicted in Figure 4-2, that enhances their visual quality and supports placemaking, economic development, active transportation, and other, complementary City goals.
Action 4-1.7: Require landscape screening for all development, redevelopment, and rehabilitation of properties along Highway 101 to create a visual buffer between the highway and other uses.
Proposed General Plan 2050 Action 3-2.28 requires the City to update the Zoning Code to develop standards for scenic roadways identified in the General Plan that do not have corresponding development standards in the Zoning Code, and Action 4-1.3 requires the City to update the City’s Design Guidelines, Objective Design Standards, and/or Zoning Code to ensure that design standards relate to site context and the natural setting, including the slope, which would ensure scenic vistas and/or corridors would not be adversely impacted by potential future development over the course of the General Plan 2050.
In summary, the location of more intense development combined with the established design review procedures for potential future development would limit the significant adverse impact that potential future development could have on a scenic vista or corridor . Implementation of the proposed General Plan 2050 goals, policies, and actions identified above would further ensure views of scenic vistas and/or corridors would be protected. Therefore, impacts to scenic vistas from implementation of the proposed project would be less than significant.
Significance without Mitigation: Less than significant.
AES-2 Implementation of the proposed project would not substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway.
As described in Section 4.1.1.2, Existing Conditions, Caltrans has designated the section of SR 12 within the EIR Study Area as “eligible” for a State Scenic Highway designation and a portion of SR 12 has been “officially designated” as a State Scenic Highway, starting from Danielli Avenue, in eastern Santa Rosa, to London Way, near Agua Caliente. Approximately 2.5 miles of the officially designated State Scenic Highway SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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are within the EIR Study Area. Implementation of the proposed project would damage scenic resources along these sections of SR 12 if views of the scenic resources were blocked by development from the proposed project.
Impacts to state scenic highway SR 12 in the EIR Study Area are described under impact discussion AES-1 along with the City’s locally designated scenic roadways. Because scenic roads, including SR 12, carry vehicles through areas of notable beauty and/or with natural resources, landmarks, historic features, or cultural interest points, the City has regulations in place to protect and enhance the aesthetic values of scenic routes by governing the development of property and placement of outdoor advertising. As described under impact discussion AES-1, 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, of the proposed General Plan 2050 contains goals, policies, and actions that require local planning and development decisions to consider aesthetic impacts to scenic resources along the sections of SR 12 that are officially designated and eligible to be designated as a state scenic highway. Specifically, proposed Action 3-2.28 requires the City to update the Zoning Code to include development standards for scenic roadways identified in the General Plan that do not have corresponding development standards in the Zoning Code, which includes a section of SR 12 from Farmers Lane to Calistoga Road that is designated as an “eligible” state scenic highway. Accordingly, compliance with SRCC regulations and Design Review requirements along with implementation of the proposed General Plan 2050 goals, policies, and actions, would ensure any impacts to scenic roads and/or state designated scenic highways would be less than significant.
Significance without Mitigation: Less than significant.
AES-3 Implementation of the proposed project would not conflict with applicable zoning and other regulations governing scenic quality.
The proposed General Plan 2050 is the primary planning document for the City of Santa Rosa. The proposed update is intended to ensure consistency between the General Plan, Zoning Code, and State law. Because the proposed General Plan 2050 is the overriding planning document for the City, and because the proposed General Plan 2050 involves amending the General Plan 2035 and the Zoning Code to improve consistency, adoption and implementation of the proposed project would have no impact with respect to being inconsistent with policies or regulations governing scenic quality.
As described under impact discussion AES-1, potential future development that is subject to design review would be required to adhere to the standards and guidelines of the Design Guidelines, which apply to all projects that require design review, including most new buildings, subdivisions, infill development, and public improvements.
Furthermore, as described under impact discussion AES-1, Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture, of the proposed General Plan 2050 includes a goal, policies, and actions that require local planning and development decisions to consider impacts to aesthetic impacts, including consistency with applicable zoning and other regulations governing scenic quality. Specifically, proposed Action 3-2.28 and Action 4-1.3 direct the City to update the Zoning Code, SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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City’s Design Guidelines, and/or Objective Design Standards, as appropriate, to be consistent with the goals and policies of the proposed General Plan 2050.
While development resulting from implementation of the proposed project could potentially impact visual character or quality of public views in the EIR Study Area, such development would be required to adhere to existing regulations, along with the proposed General Plan 2050 goals, policies, and actions.
Accordingly, implementation of the proposed project would not conflict with applicable zoning or other regulations governing scenic quality and impacts would be less than significant.
Significance without Mitigation: Less than significant.
AES-4 Implementation of the proposed project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area.
Nighttime illumination and glare impacts are the effects of a development’s exterior lighting on adjoining uses and areas. Nighttime uses associated with potential future development may increase light intensity levels and may have the potential to affect existing and future nearby sensitive receptors. If lighting in new development is not designed to reduce upwardly directed light, nighttime lighting could obscure views of the night sky or intrude into neighboring properties. Potential future development would also incrementally increase glare due to exterior glazing (e.g., windows and doors) of new building surfaces, parked cars, and solar photovoltaic panels and site planning (i.e., landscaping and solar photovoltaic panel placement) are not carefully considered. Light and glare impacts are determined through a comparison of the existing light sources with the lighting plans or policies incorporated in development proposals.
Currently, the EIR Study Area contains many existing sources of nighttime illumination. These include street and parking area lights, building-mounted lights, illuminated signage, security lighting, and interior and exterior lighting on existing residential, commercial, and institutional buildings. Glare is primarily from building materials, solar photovoltaic panels, and parked cars. Additional on-site light and glare is caused by surrounding land uses and traffic on SR 12 and US Highway 101.
Future development and activities under the proposed project could intensify lighting sources throughout the EIR Study Area. Future lighting would involve uses similar to the existing land uses in the EIR Study Area and sources of light and glare associated with these uses would be similar in intensity and nature to the existing source of light and glare. In addition to new lighting for buildings, security, and parking areas, the proposed General Plan 2050 encourages the use of solar photovoltaic panels through proposed Action 3-7.13 and Action 3-7.16 in Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction. The potential for glare impacts as a result of solar photovoltaic panels would depend on the placement and angle of the panels, and the materials with which the panels are composed.
Nighttime uses associated with potential future development may increase light intensity levels in development areas and may have the potential to affect existing and future nearby sensitive receptors. If lighting from new development is not designed to reduce upwardly directed light, nighttime lighting could obscure views of the night sky or intrude into neighboring properties. Potential future development would SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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also incrementally increase glare from new building surfaces, parked cars, and solar panel if exterior glazing (i.e., windows and doors), and site planning (i.e., landscaping and solar panel placement) are not carefully considered.
As described in Section 4.1.1.1, Regulatory Framework, in addition to general best management practices that require lighting that is context sensitive in style and intensity required under CALGreen, potential future development, including the installation of solar photovoltaic panels, would have to comply with the City’s lighting standards as outlined in the SRCC, Street Light Design Standards, and other adopted plans (e.g., Citywide Creek Master Plan, Sebastopol Road Urban Vision and Corridor Plan). Potential future development would be reviewed for consistency with the lighting standards regarding the appropriate use of lighting and avoidance of glare from lighting and other sources.
Compliance with these standards to reduce light spill and glare would ensure potential future development does not generate excessive light levels or glare. Therefore, the lighting and glare from implementation of the proposed project would not substantially increase nighttime light or glare within the EIR Study Area or its surroundings. Impacts would be less than significant.
Significance without Mitigation: Less than significant.
AES-5 Implementation of the proposed project, in combination with past, present, and reasonably foreseeable projects, would not result in less- than-significant cumulative impacts with respect to aesthetics.
As discussed in Chapter 4.0, Environmental Analysis, of this Draft EIR, the cumulative setting includes growth within the EIR Study Area in combination with projected growth in the rest of Sonoma County and the surrounding region. The cumulative setting for visual impacts includes potential future development under the proposed project, combined with effects of development on lands adjacent to the EIR Study Area. Significant impacts, including those associated with scenic resources, visual character, and increased light and glare, would generally be site specific and would not contribute to cumulative impacts after implementation of the General Plan 2050 goals, policies, and actions.
Compliance with the SRCC regulations, Santa Rosa Design Guidelines, along with implementation of the proposed General Plan 2050 goals, policies, and actions, would ensure any impacts to scenic vistas and/or corridors would be less than significant. Potential future development within 125 feet or less from the edge of the pavement of a designated scenic road would be required to comply with the regulations of the Scenic Road Combining District as outlined in the SRCC as well as the Sonoma County General Plan and Design Review requirements. The proposed project is intended to ensure consistency between the General Plan, Zoning Code, and State law; therefore, implementation of the proposed project would not conflict with applicable zoning or other regulations governing scenic quality. Light and glare from potential future development under the proposed project would be regulated through the City’s lighting standards in the SRCC, the Santa Rosa Design Guidelines, and other adopted plans.
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With adherence to existing local and regional regulations, potential future development under the proposed project would not create substantial impacts to visual resources in Santa Rosa or the surrounding communities. Therefore, the proposed project would not result in a cumulatively considerable impact to aesthetic resources and cumulative impacts would be less than significant.
Significance without Mitigation: Less than significant.
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4.2 AGRICULTURAL RESOURCES
This chapter of the Draft Environmental Impact Report (EIR) describes the potential impacts to agricultural resources associated with the adoption and implementation of the proposed project. This chapter describes the regulatory framework and existing conditions, identifies criteria used to determine impact significance, provides an analysis of the potential impacts to agricultural resources, and identifies proposed General Plan 2050 goals, actions, and policies, as well as feasible mitigation measures, that would minimize any potentially significant impacts. As described in Section 4.2.2, Standards of Significance, there is no qualifying forest land or timberland production in the EIR Study Area, and therefore, no evaluation of forestry resources is required.
4.2.1 ENVIRONMENTAL SETTING
REGULATORY FRAMEWORK
State Regulations
Farmland Mapping and Monitoring Program
Within the California Natural Resources Agency, the State Department of Conservation provides technical services and information to promote informed land use decisions and sound management of the state’s natural resources. As part of this duty, the Department of Conservation manages the Farmland Mapping and Monitoring Program (FMMP), which supports agriculture throughout California by developing maps and statistical data for analyzing land use impacts to farmland. The FMMP publishes a field report for each county about every two years. The FMMP categorizes land by agricultural production potential according to the following classifications:
1 Prime Farmland has the best combination of physical and chemical features able to sustain long-term agricultural production. Prime farmland has the soil quality, growing season, and moisture supply needed to produce sustained high yields. Land must have been used for irrigated agriculture production at some time during the four years prior to the mapping date. Farmland of Statewide Importance is similar to Prime Farmland, but with minor shortcomings, such as steeper slopes or less ability to store soil moisture. Land must have been used for irrigated agricultural production at some time during the four years prior to the mapping date. Unique Farmland consists of lesser quality soils used for the production of the State’s leading agricultural crops. This land is usually irrigated but may include non-irrigated orchards or vineyards as found in some climatic zones in California. Land must have been farmed at some time during the four years prior to the mapping date.
1 State of California Department of Conservation, 2022, Important Farmland Categories, https://www.conservation.ca.gov/dlrp/fmmp/Pages/Important-Farmland-Categories.aspx, accessed April 5, 2022.
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Farmland of Local Importance consists of all farmable land not meeting the definitions of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland. This includes land that is or has been used for irrigated pasture, dryland farming, confined livestock or dairy facilities, aquaculture, poultry facilities, and dry grazing. It also includes soils previously designated by soil characteristics as prime farmland, farmland of statewide importance, and unique farmland that has since become idle. Grazing Land is the land on which the existing vegetation is suited to the grazing of livestock.
Williamson Act
The California Land Conservation Act of 1965, better known as the Williamson Act, conserves agricultural and open space lands through property tax incentives and voluntary restrictive land use contracts administered by local governments under State regulations. Private landowners voluntarily restrict their land to agricultural and compatible open space uses under minimum 10-year rolling term contracts, with counties and cities also acting voluntarily. In return, restricted parcels are assessed for property tax purposes at a rate consistent with their actual use rather than potential market value.
Regional Regulations
Sonoma County General Plan
Sonoma County has a significant agricultural economy and upbringing, with agriculture as one of its leading sectors, boasting a total production value of over 8 million dollars in 2021.2 The 2020 Sonoma County General Plan, adopted in 2008, is a comprehensive long-range guide for land in the unincorporated portions of the county, including land directly in the surrounding periphery of the Santa Rosa city limit. While the land within the Santa Rosa city limit is regulated by the City’s General Plan, the unincorporated areas outside of the city limit are governed by the County’s General Plan. While there are no agricultural land use designations in the Sphere of Influence (SOI), the southern portion of the EIR Study Area outside the SOI and within the Urban Growth Boundary has a diverse agriculture land use designation. The following are relevant goals from the Sonoma County General Plan Agricultural Resources (AR) Element regarding agricultural resources:
3 Goal AR-2: Maintain for the timeframe of this plan agricultural production on farmlands at the edges but beyond the Urban Service Areas, to minimize the influence of speculative land transactions on the price of farmland and to provide incentives for long term agricultural use. Goal AG-3: Maintain the maximum amount of land in parcel sizes that a farmer would be willing to lease or buy for agricultural purposes.
2 Sonoma County Department of Agriculture/Weights & Measurements, 2022, 2021 Sonoma County Crop Report, https://sonomacounty.ca.gov/Main%20County%20Site/Natural%20Resources/Agricultural%2C%20Weights %20%26%20Measures/Documents/Crop%20Reports/2021-Sonoma-County-Crop-Report.pdf, accessed November 9, 2022. 3 Sonoma County, amended August 2, 2016, Sonoma County General Plan 2020, Agricultural Resources Element, https://permitsonoma.org/Microsites/Permit%20Sonoma/Documents/Archive/Department %20Information/Cannabis%20Program/_Documents/General-Plan-Agricultural-Resources-Element.pdf, accessed October 18, 2022.
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Sonoma LAFCO Agricultural Policies
The Sonoma Local Agency Formation Commission (LAFCO) is an independent agency created by the State to promote the wise use of land resources while providing for the present and future needs of a community. As part of this charge, Sonoma LAFCO establishes agricultural policies and provides guidance to property owners with LAFCO applications who propose the conversion of prime agricultural lands (as defined by LAFCO) into non-agricultural uses. Sonoma LAFCO’s main objectives are: (1) To encourage the orderly formation of local government agencies and promote the efficient provision of public services; (2) To preserve agricultural land and open-space resources; and (3) To promote orderly growth and discourage urban sprawl.
Ultimately, Sonoma LAFCO is responsible for determining any changes to a city’s boundaries and or a city’s SOI. Objective I.A of the Sonoma LAFCO policies is that prime agricultural land is protected and conserved while ensuring there are adequate areas for efficient and orderly growth. Policies under this objective include the following:
Agricultural Lands. In addition to considering the policies and priorities set forth in Government Code Section 56377, Sonoma LAFCO shall conform to the following policies in reviewing and approving or disapproving proposals that may result in the conversion of agricultural land to non-agricultural uses:4
1. Agricultural significance of the subject territory and adjacent areas relative to other agricultural lands in the region.
2. Use of the subject territory and adjacent areas.
3. Whether public facilities for proposed development would be a) sized or situated so as to facilitate conversion of adjacent or nearby agricultural land, or b) extended through agricultural lands that lie between the project site and existing facilities.
4. Whether uses incompatible with adjacent agricultural uses are expected to result from the proposal and whether natural or man-made barriers would buffer adjacent or nearby agricultural lands from the effects of proposed development or other incompatible uses.
5. Whether the subject territory is located within the sphere of influence of a city or district providing sewer and/or water service or within an “Urban Service Boundary” designation of the Sonoma County General Plan.
6. Provisions of applicable general plan open space and land use elements, growth management policies, or other statutory provisions designed to protect agriculture.
The Sonoma LAFCO shall discourage proposals which would likely convert to urban uses those lands identified by the County General Plan as suitable for long-term agricultural or open space use or identified by the Sonoma County Agricultural Preservation and Open Space District Acquisition Plan as a priority for acquisition or protection in cooperation with willing landowners.
4 Sonoma Local Agency Formation Commission, amended June 5, 2013, Policy: Agricultural Lands, https://sonomalafco.org/about-the-commission/procedures-and-guidelines/policies-and-guidelines/ policy-agricultural-lands, accessed on October 18, 2022.
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Territory Subject to Williamson Act Agricultural Preserve Contract. Proposals establishing or amending spheres of influence and/or annexations for territory to a or city or district providing sewers or nonagricultural water or cities, with an existing Williamson Act Agricultural Preserve Contract shall be prohibited, unless these facilities or services benefit land uses that are allowed under the contract and the landowner consents.
5 Pursuant to Government Code Section 56426.5, Sonoma LAFCO may approve the inclusion of territory subject to the Agricultural Preserve Contract within the sphere of influence of a city or special district able to provide sewers or nonagricultural water if it complies with all of the following criteria:
1. Territory that is subject to a contract for which a notice of nonrenewal has been served pursuant to Section 51245 and has less than five (5) years remaining in the term of the contract.
2. Territory that is subject to a contract for which a tentative cancellation has been approved pursuant to Section 51282 and has less than five (5) years remaining in the term of the contract.
Territory for which the governing body of the county or city administering the contract has given its written approval to the change and the landowner consents to the change and has less than five (5) years remaining in the term of the contract.
Local Regulations
Santa Rosa City Code
The Santa Rosa City Code (SRCC) includes various directives to minimize adverse impacts to agricultural resources in Santa Rosa. The SRCC is organized by title, chapter, and section, and in some cases, articles.
Most provisions related to agricultural resources are in Title 20, Zoning, as follows:
Chapter 20-26, Special Purpose Zoning Districts. This chapter of the Zoning Code lists the land uses that may be allowed within the Special Purpose zoning districts. Special Purpose Zoning Districts include Open Space–Recreation (OSR), Open Space–Conservation (OSC), Public and Institutional (PI), and Planned Development (PD) districts. The OSC zoning district is applied to important open space areas of the City including agricultural land. Section 20-26.030, Special purpose district land uses and permit requirements, allows for agricultural-based uses in the OSR and OSC zoning districts through conditional use permits.
EXISTING CONDITIONS
Regional Agriculture
Agricultural commodities in Sonoma County grossed over $800 million in 2021, a 19 percent increase from 2020. Wine grapes has been the top-valued agricultural commodity in the county for many years, with a 2021 value of over $540 million. Other top-valued crops in Sonoma County, in order of value, are
5 Sonoma Local Agency Formation Commission, amended May 2013, Policy: Territory Subject to Williamson Act Agricultural Preserve Contract, https://sonomalafco.org/about-the-commission/procedures-and-guidelines/policies-and-guidelines/policy- territory-subject-to-williamson-act-agricultural-preserve-contract, accessed on October 18, 2022.
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milk, nursey plants, miscellaneous livestock and poultry products, cattle and calves, vegetables, cut flowers, bedding plants, and sheep and lambs.6 The growing population in the EIR Study Area and in greater Sonoma County has increased the rate of agricultural land conversion since the 1980s. As indicated in Table 4.2-1, Sonoma County Agricultural Land Conversion 1984 to 2018, the acreages for Prime Farmland and Farmland of Local Importance have decreased by 11 and 29 percent, respectively.
TABLE 4.2-1 SONOMA COUNTY AGRICULTURAL LAND CONVERSION 1984 TO 2018 Land Use Category 1984 Acreage 2018 Acreage
1984 to 2020 Net
Acreage Changed
Percentage
Change
Prime Farmland 33,930 30,339 -3,591 -11%
Farmland of Statewide Importance 11,318 17,782 6,464 57% Unique Farmland 15,797 34,455 18,658 118%
Farmland of Local Importance 112,094 79,226 -32,869 -29% Grazing Land 454,851 414,992 -39,859 9%
Source: California Department of Conservation, 2023, Historic Land Use Conversion, https://www.conservation.ca.gov/dlrp/fmmp/Pages/Sonoma.aspx, accessed May 15, 2023.
Important Farmland
While the majority of land within the city limit is urban and built-up land, land use for agricultural purposes is in the EIR Study Area. The EIR Study Area includes a variety of California Important Farmland, including Prime Farmland, Farmland of Statewide Importance, Farmland of Local Importance, and Unique Farmland, as classified by the Department of Conservation and shown on Figure 4.2-1, Important Farmlands and Williamson Act Contracts. Table 4.2-2, Important Farmland by Acreage in the EIR Study Area, lists the number of acres associated with each farmland classification. Most of the Important Farmlands in the EIR Study Area are Grazing Land and Farmland of Local Importance.
TABLE 4.2-2 IMPORTANT FARMLAND BY ACREAGE IN THE EIR STUDY AREA Acres
City Limit
Sphere of Influence/Urban
Growth Boundary EIR Study Area Total a
Prime Farmland 41 0 43
Farmland of Statewide Importance 627 8 660
Farmland of Local Importance 1,455 613 2,194
Unique Farmland 2 5 54
Grazing Land 1,421 500 2,051
Total Acres 3,587 1,070 5,002
Source: Department of Conservation, Farmland Mapping and Monitoring Program GIS data, 2018. a. Totals may not match City Limit + Sphere of Influence as the EIR Study Area includes the Planning Area, which is not entirely encompassed by the City Limit and Sphere of Influence.
6 Sonoma County Department of Agriculture/Weights & Measurements, 2021 Sonoma County Crop Report, https://sonomacounty.ca.gov/Main%20County%20Site/Natural%20Resources/Agricultural %2C%20Weights%20%26%20Measures/Documents/Crop%20Reports/2021-Sonoma-County-Crop-Report.pdf, accessed November 9, 2022.
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Figure 4.2-1
Important Farmland and Williamson Act Contracts
Source: DOC, 2018; City of Santa Rosa, 2020; ESRI, 2022; PlaceWorks, 2024. 0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Williamson Act Contracts
Important Farmland
Urban or Developed Land
Grazing Land
Farmland of Local Importance
Prime Farmland
Farmland of Statewide
Importance
Unique Farmland
Other Land
AGRICULTURAL RESOURCES
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
PLACEWORKS 4.2-7
Sonoma County Agricultural Preservation and Open Space District Sonoma County Agricultural Preservation and Open Space District (District) is a community-created, taxpayer-funded agency that works to permanently protect Sonoma County’s diverse agricultural lands, natural resources, and scenic open space for future generations.7 The District’s primary tool is the conservation easement, a legal agreement between a willing landowner and the agency that permanently limits uses of the land to protect its conservation values. Approximately 1,558 acres of land in the EIR Study Area is protected by the District. The District will consider a proposal for a mitigation-related activity on lands protected with a District-held easement according to the permitted use request review process as described in the Board-adopted District Stewardship Manual.8 The District is also eligible to receive funding through public agency grant programs for planning, acquisition, and stewardship of easement or District-owned properties, or other District projects.
Williamson Act Contracts
A Williamson Act contract is an agreement between the property owner and the county that provides the property owner with reduced property taxes in exchange for maintaining the land in commercial agricultural use for a period of 10 years.9 There are two types of Williamson Act contracts: Type I for prime agricultural land planted in permanent crops such as grapes, apples, olives, or pears; and Type II for nonprime grazing or open-space lands. The contract is binding on all subsequent property owners. As shown on Figure 4.2-1, there are no active Williamson Act contracts within the city limit but there are a few within the SOI. These are Type II contracts for prime agricultural or open space lands that are primarily used for grazing, hay farming, horse breeding, timber production, open space, or any combination of agricultural and open space uses, including permanent crops. The land under Williamson Act contract in the southeastern portion of the EIR Study Area has a Phase-Out Status. There is a total of 97 acres of land that are under Williamson Act contracts within the EIR Study Area.
Forestry Resources
There are no portions of the EIR Study Area that contain forest or timber resources or are zoned as such.
No further discussion of this topic is required.
7 Sonoma County Agricultural Preservation and Open Space District, 2023, Land for Life, https://www.sonomaopenspace.org/wp-content/uploads/Brochure_PDF_For_Web.pdf, accessed May 15, 2023. 8 Sonoma County Agricultural Preservation and Open Space District, July 18, 2017, Mitigation Policy for District-Protected Lands, https://www.sonomaopenspace.org/wp-content/uploads/Final-District-Mitigation -Policy_20170718.pdf, accessed May 15, 2023.
9 Sonoma County, updated May 20, 2018, Frequently Asked Questions (FAQs) Agricultural Preserves Phase Out of Substandard Parcels, https://permitsonoma.org/regulationsandinitiatives/agriculturaluses/faqsagriculturalpreservesphaseout, accessed March 3, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
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4.2-8 OCTOBER 2024
4.2.2 STANDARDS OF SIGNIFICANCE
The Santa Rosa Zoning Code does not contain a zoning district for forest land or timberland production.
Further, there are no State or national forest lands in the EIR Study Area. Consequently, there would be no impacts to forestry resources, and the following standards are not discussed further in this Draft EIR:
The project would conflict with existing zoning for, or cause rezoning of, forestland (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g)).
The project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of forest land to non-forest use.
Implementation of the proposed project would result in a significant impact to agricultural resources if it would:
1. Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use.
2. Conflict with existing zoning for agricultural use, or a Williamson Act contract.
3. Involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use.
4. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to agricultural resources.
4.2.3 IMPACT DISCUSSION
AG-1 Implementation of the proposed project could convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance, as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use.
As shown in Table 4.2-2, the EIR Study Area contains 43 acres of Prime Farmland, 660 acres of Farmland of Statewide Importance, and 54 acres of Unique Farmland. As shown in Table 4.2-3, Qualifying Farmland Potentially Converted to Other Uses at General Plan Buildout, with buildout of the proposed project, there could be a reduction of 94 acres of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non-agricultural uses.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
PLACEWORKS 4.2-9
TABLE 4.2-3 QUALIFYING FARMLAND POTENTIALLY CONVERTED TO OTHER USES AT GENERAL PLAN BUILDOUT Farmland Classification
Existing Acres Future Acres
EIR Study Area
Potential to be
Converted
Total Acres Remaining at
Buildout
Prime Farmland 43 23 20
Farmland of Statewide Importance 660 19 641
Unique Farmland 54 52 2
Total 757 94 663
Source: Department of Conservation, Farmland Mapping and Monitoring Program GIS data, 2018.
The proposed General Plan 2050 would retain approximately 1,520 acres of land designated for agricultural use within the EIR Study Area, as well as 245 acres of land designated for open space. This land consists of approximately 20 acres of Prime Farmland, 641 acres of Farmland of Statewide Importance, and 2 acres of Unique Farmland that would not be developed over the buildout horizon of the proposed project. Therefore, for the purposes of this analysis, it is assumed that the remaining 94 acres of qualified farmland within the EIR Study Area could be converted to nonagricultural uses by 2050, as shown in Table 4.2-3. Because the standard of significance is the loss of any qualifying farmlands (Prime Farmland, Unique Farmland, or Farmland of Statewide Importance), any conversion of the 94 acres or qualifying farmlands to non-agricultural lands would constitute a significant impact under the California Environmental Quality Act (CEQA). Figure 4.2-2, CEQA Important Farmland, depicts areas where qualifying farmlands would have the potential to be converted under the proposed projects and areas of remaining qualifying farmlands would at buildout.
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 agricultural resources. The following goal, policies, and actions would serve to minimize impacts related to the loss of Prime Farmland, Farmland of Statewide Importance, and Unique Farmland:
Goal 3-6: Use nature- and science-based strategies to preserve and create environments that provide ecosystem benefits.
Policy 3-6.6: Conserve agricultural land and soils.
Action 3-6.16: Discourage the conversion of agricultural land to non-agricultural uses. Action 3-6.17: Promote restorative agricultural and landscaping techniques that incorporate cover crops, mulching, compost application, field borders, alley cropping, conservation crop rotation, prescribed grazing, and reduced tillage to promote healthy soils and soil conservation.
Action 3-6.19: 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 in Santa Rosa.
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Fulton Rd
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Stony Point Rd
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illRd
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Bodega Hwy
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wRd
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listoga
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ntHill Rd
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Figure 4.2-2
CEQA Important Farmland
Source: DOC, 2018; City of Santa Rosa, 2020; ESRI, 2022; PlaceWorks, 2024. 0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
CEQA Important Farmland
Potential to be Converted
Remaining at Buildout
Farmland Type
Prime Farmland
Farmland of Statewide
Importance
Unique Farmland
AGRICULTURAL RESOURCES
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
PLACEWORKS 4.2-11
Policy 3-6.7: Support Sonoma County efforts to preserve unincorporated lands adjacent to and near the Santa Rosa UGB as viable agricultural resources and to support the agriculture economy and environmental quality, scenic resources, and a buffer providing greater resilience against hazards.
Policy 3-6.8: Capture and sequester more carbon in soils and plants citywide. Action 3-6.28: Ensure that agricultural easements have standards for best management practices and prioritize conservation of agricultural properties that use or agree to implement regenerative agriculture practices.
While the proposed General Plan 2050 goal, policies, and actions identified above would reduce potential impacts related to the conversion of farmland, they would not reduce the amount of acreage converted under buildout of the proposed project since it would designate 94 acres of Prime Farmland, Unique Farmland, and Farmland of Statewide Importance to nonagricultural uses; therefore, a significant impact would result.
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.”
10 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.”
11 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
10 Public Resources Code, Section 21002.1(b).
11 Public Resources Code, Section 21061.1
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
4.2-12 OCTOBER 2024
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 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.
Significance without Mitigation: Significant and unavoidable. 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 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
PLACEWORKS 4.2-13
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 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.
AG-
2 Implementation of the proposed project could conflict with existing zoning for agricultural use, or a Williamson Act contract.
There are a total of 97 acres of land that are under ongoing Williamson Act contracts in the EIR Study Area. As described in impact discussion AG-1, conversion of agricultural land uses through implementation of the proposed project would affect the majority of agricultural lands within the EIR Study Area. The proposed project would potentially convert approximately 68 acres of the Williamson Act lands in the northeastern portion of the EIR Study Area to non-agricultural uses. As described under impact discussion AG-1, 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 agricultural resources. While the proposed General Plan 2050 goal, policies, and actions listed in impact discussion AG-1 would reduce potential impacts related to the conversion of land under the Williamson Act, since the proposed General Plan 2050 would designate a majority of these lands to nonagricultural uses, a significant impact would result.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
4.2-14 OCTOBER 2024
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 in 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.
Significance without Mitigation: Significant and unavoidable. As described in 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.
AG-3 Implementation of the proposed project would not involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use.
Implementation of the proposed project could result in potentially incompatible urban uses next to farms or ranches, creating circumstances that impair the productivity and profitability of agricultural operation, and could eventually lead farmers to take their land out of production. For example, this could manifest as complaints from new residents about noise, dust, and chemical use from agricultural operations.
Concerns of farmers and ranchers about increased vandalism, traffic, access difficulties, and the introduction of domestic animals can lower productivity. Adjacent urban development may also increase land values, increasing the property tax burden for farmland not protected by Williamson Act contracts or permanent agricultural conservation easements.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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AGRICULTURAL RESOURCES
PLACEWORKS 4.2-15
The proposed project recognizes that the agricultural history of Santa Rosa contributes to its sense of place and seeks to preserve active agricultural lands. As described under impact discussion AG-1, Chapter 3, Circulation, Open Space Conservation, and Greenhouse Gas Reduction, of the proposed General Plan 2050 contains a goal, policies, and actions that require local planning and development decisions to consider impacts that development could have on agricultural resources. The same proposed General Plan 2050 goal, policies, and actions listed under impact discussion AG-1 would serve to minimize potential adverse impacts of adjacent land uses on farmland. Thus, a less-than-significant impact would result.
Significance without Mitigation: Less than significant.
AG-4 Implementation of the proposed project, in combination with past, present, and reasonably foreseeable projects, could result in cumulative impacts with respect to agricultural resources.
As described in Chapter 3, Project Description, and throughout this Draft EIR, the proposed General Plan 2050 includes a buildout projection and population growth that would increase the urbanization of the city. To accommodate anticipated growth and achieve City goals, the proposed project plans for the conversion of agricultural land to various types of residential and job-generating development. With implementation of the proposed project in combination with agricultural impacts identified throughout Sonoma County, the proposed project would contribute to cumulative impacts to agricultural resources.
As described in impact discussions AG-1 and AG-2, implementation of the proposed project would result in significant impacts related to the conversion of farmland of concern under CEQA and of farmland under Williamson Act contracts. As such, the proposed project would contribute to the cumulative impacts of overall conversion of these lands in the region. Although the policies and actions in the proposed General Plan 2050 would reduce and partially offset regional agricultural impacts, the proposed project would contribute to cumulatively significant agricultural impacts in the region and a cumulative significant impact would occur .
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.
Significance without Mitigation: Significant and unavoidable. 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 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AGRICULTURAL RESOURCES
4.2-16 OCTOBER 2024
regarding conversion of agricultural land are outside the control of the City of Santa Rosa. Therefore, this cumulative impact would be significant and unavoidable.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
PLACEWORKS 4.3-1
4.3 AIR QUALITY
This chapter of the Draft Environmental Impact Report (EIR) describes the potential air quality impacts associated with the adoption and implementation of the proposed project. This chapter describes the regulatory framework and existing conditions, identifies criteria used to determine impact significance, provides an analysis of the potential air quality impacts, and identifies proposed General Plan 2050 goals, policies, and actions, as well as feasible mitigation measures, that would minimize any potentially significant impacts. This evaluation is based on the methodology recommended by the Bay Area Air Quality Management District (BAAQMD). The analysis focuses on air pollution from regional emissions and localized pollutant concentrations. Criteria air pollutant emissions modeling is included in Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR. Transportation-sector impacts are based on trip generation and vehicle miles traveled (VMT) provided W-Trans. Cumulative impacts related to air quality are based on the regional boundaries of the San Francisco Bay Area Air Basin (SFBAAB).
4.3.1 ENVIRONMENTAL SETTING
TERMINOLOGY
The following are definitions for terms used throughout this section:
AAQS: Ambient Air Quality Standards.
CES: CalEnviroScreen is a mapping tool that helps identify the California communities most affected by sources of pollution and where people are often especially vulnerable to pollution’s effects. Concentrations: Refers to the amount of pollutant material per volumetric unit of air . Concentrations are measured in parts per million (ppm), parts per billion (ppb), or micrograms per cubic meter (µg/m
3).
Criteria Air Pollutants: Those air pollutants specifically identified for control under the federal Clean Air Act (currently seven—carbon monoxide, nitrogen oxides, lead, sulfur oxides, ozone, and coarse and fine particulates).
DPM: Diesel particulate matter .
Emissions: Refers to the actual quantity of pollutant, measured in tons per year . Overburdened Community: As defined by BAAQMD, an area located within a census tract identified by CES, Version 4, having an overall CES score at or above the 70th percentile, or located within 1,000 feet of any such census tract.
ppm: Parts per million.
Sensitive receptor: Land uses that are considered more sensitive to air pollution than others due to the types of population groups or activities involved. These land uses include residential, retirement facilities, hospitals, and schools.
TAC: Toxic air contaminant.
VMT: Vehicle miles traveled.
4.3.1.1 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
4.3-2 OCTOBER 2024
AIR POLLUTANTS OF CONCERN
Criteria Air Pollutants
The pollutants emitted into the ambient air by stationary and mobile sources are categorized as primary and/or secondary pollutants. Primary air pollutants are emitted directly from sources. Carbon monoxide (CO), volatile organic compounds (VOC) or reactive organic gases (ROG), nitrogen oxides (NO x), sulfur
dioxide (SO2), coarse inhalable particulate matter (PM10), fine inhalable particulate matter (PM2.5), and lead (Pb) are primary air pollutants. Of these, CO, SO2, nitrogen dioxide (NO2), coarse inhalable particulate matter (PM10), and fine inhalable particulate matter (PM2.5) are “criteria air pollutants,” which means that ambient air quality standards (AAQS) have been established for them. ROG and NOx are criteria pollutant precursors that form secondary criteria air pollutants through chemical and photochemical reactions in the atmosphere. Ozone (O
3) and nitrogen dioxide (NO2) are the principal secondary pollutants. Table 4.3- 1, Criteria Air Pollutant Health Effects Summary, summarizes the potential health effects associated with the criteria air pollutants.
TABLE 4.3-1 CRITERIA AIR POLLUTANT HEALTH EFFECTS SUMMARY Pollutant Health Effects Examples of Sources
Carbon
Monoxide
(CO)
Chest pain in heart patients
Headaches, nausea
Reduced mental alertness
Death at very high levels
Any source that burns fuel such as cars, trucks,
construction and farming equipment, and
residential heaters and stoves
Ozone (O3) Cough, chest tightness
Difficulty taking a deep breath
Worsened asthma symptoms
Lung inflammation
Atmospheric reaction of organic gases with
nitrogen oxides in sunlight
Nitrogen
Dioxide (NO
2)
Increased response to allergens
Aggravation of respiratory illness
Same as carbon monoxide sources
Particulate
Matter (PM
10 and PM2.5)
Hospitalizations for worsened heart diseases
Emergency room visits for asthma
Premature death
Cars and trucks (particularly diesels)
Fireplaces and woodstoves
Windblown dust from overlays, agriculture,
and construction
Sulfur Dioxide
(SO
2)
Aggravation of respiratory disease (e.g., asthma
and emphysema)
Reduced lung function
Combustion of sulfur-containing fossil fuels,
smelting of sulfur-bearing metal ores, and
industrial processes
Lead (Pb) Behavioral and learning disabilities in children Nervous system impairment
Contaminated soil
Sources: California Air Resources Board, 2023, Common Air Pollutants: Air Pollution and Health, https://ww2.arb.ca.gov/resources/common-air- pollutants, accessed July 21, 2023; South Coast Air Quality Management District, 2005, Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, http://www.aqmd.gov/docs/default-source/planning/air-quality-guidance/complete-guidance-document.pdf, accessed July 21, 2023.
4.3.1.2 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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A description of each of the primary and secondary criteria air pollutants and its known health effects is presented herein.
Carbon Monoxide (CO) is a colorless, odorless gas produced by incomplete combustion of carbon substances, such as gasoline or diesel fuel. CO is a primary criteria air pollutant. CO concentrations tend to be the highest during winter mornings with little to no wind, when surface-based inversions trap the pollutant at ground levels. The highest ambient CO concentrations are generally found near traffic-congested corridors and intersections. When inhaled at high concentrations, CO combines with hemoglobin in the blood and reduces its oxygen-carrying capacity. This results in reduced oxygen reaching the brain, heart, and other body tissues. This condition is especially critical for people with cardiovascular diseases, chronic lung disease, or anemia, as well as for fetuses. Even healthy people exposed to high CO concentrations can experience headaches, dizziness, fatigue, unconsciousness, and even death.
1 Volatile Organic Compounds (VOCs) / Reactive Organic Gases (ROGs) are compounds composed primarily of hydrogen and carbon atoms. Internal combustion associated with motor vehicle usage is the major source of ROGs. Other sources of ROGs include evaporative emissions from paints and solvents, the application of asphalt paving, and the use of household consumer products such as aerosols. Adverse effects on human health are not caused directly by ROGs, but rather by reactions of ROGs to form secondary pollutants such as O
3. There are no AAQS established for ROGs. However,
because they contribute to the formation of O3, BAAQMD has established a significance threshold for this pollutant.2
Nitrogen Oxides (NOx) are a by-product of fuel combustion and contribute to the formation of ground- level O3, PM10, and PM2.5. The two major forms of NOx are nitric oxide (NO) and nitrogen dioxide (NO2). NO is a colorless, odorless gas formed from atmospheric nitrogen and oxygen when combustion takes place under high temperature and/or high pressure. The principal form of NOx produced by combustion is NO, but NO reacts quickly with oxygen to form NO2, creating the mixture of NO and NO2 commonly called NOx. NO2 is an acute irritant and more injurious than NO in equal concentrations. At atmospheric concentrations, however, NO2 is only potentially irritating. NO2 absorbs blue light; the result is a brownish-red cast to the atmosphere and reduced visibility. NO is a colorless, odorless gas formed from atmospheric nitrogen and oxygen when combustion takes place under high temperature and/or high pressure. NO
2 acts as an acute irritant and in equal
concentrations is more injurious than NO. At atmospheric concentrations, however, NO2 is only potentially irritating. There is some indication of a relationship between NO2 and chronic pulmonary fibrosis. Some increase in bronchitis in children (2 and 3 years old) has also been observed at concentrations below 0.3 ppm.3
1 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
2 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
3 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
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Sulfur Dioxide (SO2) is a colorless, pungent, irritating gas formed by the combustion of sulfurous fossil fuels. It enters the atmosphere as a result of burning high-sulfur-content fuel oils and coal and from chemical processes at chemical plants and refineries. Gasoline and natural gas have very low sulfur content and do not release significant quantities of SO2. When sulfur dioxide forms sulfates (SO4) in the atmosphere, together these pollutants are referred to as sulfur oxides (SOX). Thus, SO2 is both a primary and secondary criteria air pollutant. At sufficiently high concentrations, SO2 may irritate the upper respiratory tract. Current scientific evidence links short-term exposures to SO2, ranging from 5 minutes to 24 hours, with an array of adverse respiratory effects including bronchoconstriction and increased asthma symptoms. These effects are particularly important for asthmatics at elevated ventilation rates (e.g., while exercising or playing) at lower concentrations and when combined with particulates, SO2 may do greater harm by injuring lung tissue.4 Suspended Particulate Matter (PM10) consists of finely divided solids or liquids such as soot, dust, aerosols, fumes, and mists. In the SFBAAB, most particulate matter is caused by combustion, factories, construction, grading, demolition, agricultural activities, and motor vehicles. Inhalable coarse particles, or PM
10, include the particulate matter with an aerodynamic diameter of 10 microns (i.e., 10 millionths of a meter or 0.0004 inch) or less.
Extended exposure to particulate matter can increase the risk of chronic respiratory disease. PM10 bypasses the body’s natural filtration system more easily than larger particles and can lodge deep in the lungs. These health effects include premature death in people with heart or lung disease, nonfatal heart attacks, irregular heartbeat, aggravated asthma, decreased lung function, and increased respiratory symptoms (e.g., irritation of the airways, coughing, or difficulty breathing). Motor vehicles are currently responsible for about half of particulates in the SFBAAB. Wood burning in fireplaces and stoves is another large source of fine particulates.
5 Suspended Particulate Matter (PM2.5) is another form of fine particulate matter that has an aerodynamic diameter of 2.5 microns or less (i.e., 2.5 millionths of a meter or 0.0001 inch). Fine particulate matter originates from a variety of sources, including fossil fuel combustion, residential wood burning and cooking, and natural sources, such as wildfires and dust. As mentioned above, extended exposure to particulate matter can cause negative effects on the respiratory system, such as triggering asthma attacks, aggravating bronchitis, and diminishing lung function. PM
2.5 studies have
also found harm to the cardiovascular system and impacts on the brain, such as reduced cognitive function.
Local jurisdictions have the option of developing community risk reduction plans (CRRPs) to cumulatively reduce community wide PM
2.5 concentrations by following a comprehensive plan.
Stationary source screening maps contain all the facilities in the Bay Area where a permit has been issued and that emit one or more TACs. These stationary source screening maps can be used as a basis for community baseline conditions and to evaluate screening-level health risk impacts using the
4 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
5 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
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cavity effects equation. An alternative screening methodology is to use the California Air Resources Board’s (CARB) gas station screening tool to estimate cancer risk and chronic/acute hazards from gas station emissions.
6 Ozone (O3) is a key ingredient of “smog” and is a gas that is formed when ROGs and NOx, both by- products of internal combustion engine exhaust, undergo photochemical reactions in sunlight. O3 is a secondary criteria air pollutant. O3 concentrations are generally highest during the summer months when direct sunlight, light winds, and warm temperatures create favorable conditions for its formation. O
3 poses a health threat to those who already suffer from respiratory diseases as well as to healthy people. Breathing O3 can trigger a variety of health problems, including chest pain, coughing, throat irritation, and congestion. It can worsen bronchitis, emphysema, and asthma; reduce lung function; and inflame the linings of the lungs. Besides causing shortness of breath, it can aggravate existing respiratory diseases such as asthma, bronchitis, and emphysema. Chronic exposure to high ozone levels can permanently damage lung tissue. O
3 can also damage plants and trees and materials
such as rubber and fabrics.7
Lead (Pb) is a metal found naturally in the environment as well as in manufactured products. The major sources of lead emissions have historically been mobile and industrial sources. As a result of the phasing out of leaded gasoline, metal processing is currently the primary source of lead emissions.
The highest levels of lead in air are generally found near lead smelters. Other stationary sources are waste incinerators, utilities, and lead-acid battery manufacturers. Because emissions of lead are found only in projects that are permitted by BAAQMD, lead is not an air quality of concern for the proposed project.
8 Toxic Air Contaminants
People exposed to toxic air contaminants (TAC) at sufficient concentrations and durations may have an increased chance of getting cancer or experiencing other serious health effects. These health effects can include damage to the immune system, as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory, and other health problems.
9 At the time of the last update to the TAC list in
December 1999, CARB had designated 244 compounds as TACs.10 Additionally, CARB has implemented control measures for a number of compounds that pose high risks and show potential for effective control. There are no air quality standards for TACs. Instead, TAC impacts are evaluated by calculating the health risks associated with a given exposure. The majority of the estimated health risks from TACs can be
6 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
7 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
8 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
9 United States Environmental Protection Agency, last updated 2023, Health and Environmental Effects of Hazardous Air Pollutants. https://www.epa.gov/haps/health-and-environmental-effects-hazardous-air-pollutants, accessed August 30, 2023. 10 California Air Resources Board, 1999, Final Staff Report: Update to the Toxic Air Contaminant List.
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attributed to relatively few compounds, the most relevant to the proposed project being particulate matter from diesel-fueled engines.
Diesel Particulate Matter
In 1998, CARB identified DPM as a TAC. Previously, the individual chemical compounds in diesel exhaust were considered TACs. Almost all diesel exhaust particles are 10 microns or less in diameter . Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lungs. Long-term (chronic) inhalation of DPM is likely a lung cancer risk. Short-term (i.e., acute) exposure can cause irritation and inflammatory symptoms and may exacerbate existing allergies and asthma symptoms.
11 Placement of New Sensitive Receptors
Because placement of sensitive land uses falls outside CARB’s jurisdiction, CARB developed and approved the Air Quality and Land Use Handbook: A Community Health Perspective in 2005 to address the compatibility and associated health risks of siting sensitive land uses f in the vicinity of freeways, distribution centers, rail yards, ports, refineries, chrome-plating facilities, dry cleaners, and gasoline- dispensing facilities.
CARB’s recommendations on the siting of new sensitive land uses, identified in Table 4.3-2, CARB Recommendations for Siting New Sensitive Land Uses, were based on a compilation of recent studies that evaluated data on the adverse health effects from proximity to air pollution sources.
TABLE 4.3-2 CARB RECOMMENDATIONS FOR SITING NEW SENSITIVE LAND USES Source/Category Advisory Recommendations
Freeways and
High-Traffic Roads
Avoid siting new sensitive land uses within 500 feet of a freeway, urban roads with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day.
Distribution Centers
Avoid siting new sensitive land uses within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units [TRUs] per day, or where TRU unit operations exceed 300 hours per week).
Take into account the configuration of existing distribution centers and avoid locating residences and other sensitive land uses near entry and exit points.
Rail Yards Avoid siting new sensitive land uses within 1,000 feet of a major service and maintenance rail yard. Within one mile of a rail yard, consider possible siting limitations and mitigation approaches.
Ports
Avoid siting of new sensitive land uses immediately downwind of ports in the most heavily impacted zones. Consult local air districts or CARB on the status of pending analyses of health risks.
Refineries Avoid siting new sensitive land uses immediately downwind of petroleum refineries. Consult with local air districts and other local agencies to determine an appropriate separation.
11 United States Environmental Protection Agency, May 2002, Health Assessment Document for Diesel Engine Exhaust, EPA/600/8-90/057F, prepared by the National Center for Environmental Assessment, Washington, DC, for the Office of Transportation and Air Quality.
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TABLE 4.3-2 CARB RECOMMENDATIONS FOR SITING NEW SENSITIVE LAND USES Source/Category Advisory Recommendations
Chrome Platers Avoid siting new sensitive land uses within 1,000 feet of a chrome plater.
Dry Cleaners Using
Perchloroethylene
Avoid siting new sensitive land uses within 300 feet of any dry cleaning operation. For operations with two or more machines, provide 500 feet. For operations with three or more machines, consult with the local air district. Do not site new sensitive land uses in the same building with perchloroethylene dry cleaning operations.
Gasoline Dispensing Facilities
Avoid siting new sensitive land uses within 300 feet of a large gas station (defined as a facility with a throughput of 3.6 million gallons per year or greater). A 50-foot separation is recommended for typical gas dispensing facilities.
Source: California Air Resources Board, May 2005, Air Quality and Land Use Handbook: A Community Health Perspective, http://www.aqmd.gov/docs/default-source/ceqa/handbook/california-air-resources-board-air-quality-and-land-use-handbook-a-community-health -perspective.pdf, accessed August 30, 2023.
The key observation in these studies is that proximity to air pollution sources substantially increases both exposure and the potential for adverse health effects. There are three carcinogenic TACs that constitute the majority of the known health risks from motor vehicle traffic: DPM from trucks and benzene and 1,3- butadiene from passenger vehicles.
In 2017, CARB provided a supplemental technical advisory to the handbook for near-roadway air pollution exposure, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways. Strategies include practices and technologies that reduce traffic emissions, increase dispersion of traffic pollution (or the dilution of pollution in the air), or remove pollution from the air . 12 REGULATORY FRAMEWORK
Federal, state, and local air districts have passed laws and regulations intended to control and enhance air quality. Land use in the city is subject to the rules and regulations imposed by BAAQMD, CARB, and the United States Environmental Protection Agency (USEPA). The regulatory framework that is potentially applicable to the proposed project is also summarized below.
Federal and State Regulations
AAQS have been adopted at federal and state levels for criteria air pollutants. In addition, both the federal and state governments regulate the release of TACs. Santa Rosa in the SFBAAB and is subject to the rules and regulations imposed by BAAQMD, the National AAQS adopted by the USEPA, and the California AAQS adopted by CARB. Federal, state, regional, and local laws, regulations, plans, or guidelines that are potentially applicable to the proposed project are summarized below.
12 California Air Resources Board, April 2017, Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways, https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf, accessed August 30, 2023.
4.3.1 .3
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Ambient Air Quality Standards for Criteria Air Pollutants The Clean Air Act (CAA) was passed in 1963 by the United States Congress and has been amended several times. The 1970 CAA amendments strengthened previous legislation and laid the foundation for the regulatory scheme of the 1970s and 1980s. In 1977, Congress again added several provisions, including nonattainment requirements for areas not meeting National AAQS and the Prevention of Significant Deterioration program. The 1990 amendments represent the latest in a series of federal efforts to regulate the protection of air quality in the United States. The CAA allows states to adopt more stringent standards or to include other pollutants. The California CAA, signed into law in 1988, requires all areas of the state to achieve and maintain the California AAQS by the earliest practical date. The California AAQS tend to be more restrictive than the National AAQS.
The National and California AAQS are the levels of air quality considered to provide a margin of safety in the protection of the public health and welfare. They are designed to protect “sensitive receptors” most susceptible to further respiratory distress, such as asthmatics, the elderly, very young children, people already weakened by other disease or illness, and people engaged in strenuous work or exercise. Healthy adults can tolerate occasional exposure to air pollutant concentrations considerably above these minimum standards before adverse effects are observed.
Both California and the federal government have established health-based AAQS for seven air pollutants, as shown in Table 4.3-3, Ambient Air Quality Standards for Criteria Pollutants. These pollutants are ozone (O
3), nitrogen dioxide (NO2), carbon monoxide (CO), sulfur dioxide (SO2), coarse inhalable particulate matter (PM10), fine inhalable particulate matter (PM2.5), and lead (Pb). Additionally, the State has set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. These standards are designed to protect the health and welfare of the populace with a reasonable margin of safety.
TABLE 4.3-3 AMBIENT AIR QUALITY STANDARDS FOR CRITERIA POLLUTANTS Pollutant
Averaging
Time
California
Standard a
Federal Primary
Standard b Major Pollutant Sources
Ozone (O3) c
1 hour 0.09 ppm *
Motor vehicles, paints, coatings, and solvents.
8 hours 0.070 ppm 0.070 ppm
Carbon
Monoxide (CO)
1 hour 20.0 ppm 35.0 ppm Internal combustion engines, primarily gasoline- powered motor vehicles.
8 hours 9.0 ppm 9.0 ppm
Nitrogen Dioxide
(NO2)
Annual Average 0.030 ppm 0.053 ppm Motor vehicles, petroleum-refining operations, industrial sources, aircraft, ships, and railroads. 1 hour 0.18 ppm 0.100 ppm Sulfur
Dioxide (SO2)
Annual Arithmetic
Mean * 0.030 ppm
Fuel combustion, chemical plants, sulfur recovery
plants, and metal processing. 1 hour 0.25 ppm 0.075 ppm 24 hours 0.04 ppm 0.14 ppm
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TABLE 4.3-3 AMBIENT AIR QUALITY STANDARDS FOR CRITERIA POLLUTANTS Pollutant
Averaging
Time
California
Standard a
Federal Primary
Standard b Major Pollutant Sources
Respirable
Particulate
Matter
(PM10) d
Annual Arithmetic
Mean 20.0 µg/m3 * Dust and fume-producing construction, industrial, and agricultural operations, combustion,
atmospheric photochemical reactions, and
natural activities (e.g., wind-raised dust and ocean
sprays).
24 hours 50.0 µg/m3 150.0 µg/m3
Respirable
Particulate
Matter
(PM
2.5 )
Annual Arithmetic
Mean 12.0 µg/m3 12.0 µg/m3 Dust and fume-producing construction, industrial, and agricultural operations, combustion,
atmospheric photochemical reactions, and
natural activities (e.g., wind-raised dust and ocean
sprays).
24 hours * 35.0 µg/m3
Lead (Pb)
30-Day Average 1.5 µg/m3 *
Present source: lead smelters, battery
manufacturing & recycling facilities. Past source:
combustion of leaded gasoline.
Calendar Quarterly * 1.5 µg/m3
Rolling 3-Month
Average * 0.15 µg/m3
Sulfates (SO4) e 24 hours 25 µg/m3 * Industrial processes.
Visibility
Reducing
Particles
8 hours
ExCof =0.23/km
visibility of 10≥
miles
No Federal
Standard
Visibility-reducing particles consist of suspended
particulate matter, which is a complex mixture of
tiny particles that consists of dry solid fragments,
solid cores with liquid coatings, and small droplets
of liquid. These particles vary greatly in shape,
size, and chemical composition, and can be made
up of many different materials such as metals,
soot, soil, dust, and salt.
Hydrogen Sulfide 1 hour 0.03 ppm No Federal
Standard
Hydrogen sulfide (H2S) is a colorless gas with the
odor of rotten eggs. It is formed during bacterial
decomposition of sulfur-containing organic
substances. Also, it can be present in sewer gas
and some natural gas, and can be emitted as the
result of geothermal energy exploitation.
Vinyl Chloride 24 hour 0.01 ppm No Federal
Standard
Vinyl chloride (chloroethene), a chlorinated
hydrocarbon, is a colorless gas with a mild, sweet
odor. Most vinyl chloride is used to make
polyvinyl chloride (PVC) plastic and vinyl products.
Vinyl chloride has been detected near landfills,
sewage plants, and hazardous waste sites, due to
microbial breakdown of chlorinated solvents.
Notes: ppm: parts per million; μg/m3: micrograms per cubic meter * Standard has not been established for this pollutant/duration by this entity. a. California standards for O3, CO (except 8-hour Lake Tahoe), SO2 (1 and 24 hour), NO2, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. b. National standards (other than O3, PM, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The O3 standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 µg/m3 is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard.
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TABLE 4.3-3 AMBIENT AIR QUALITY STANDARDS FOR CRITERIA POLLUTANTS Pollutant
Averaging
Time
California
Standard a
Federal Primary
Standard b Major Pollutant Sources
c. On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. d. On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 µg/m3. The existing national 24-hour PM2.5 standards (primary and secondary) were retained at 35 µg/m3, as was the annual secondary standard of 15 µg/m3. The existing 24-hour PM10 standards (primary and secondary) of 150 µg/m3 also were retained. The form of the annual primary and secondary standards is the annual mean, averaged over 3 years.
e. On June 2, 2010, a new 1-hour SO2 standard was established, and the existing 24-hour and annual arithmetic mean standards were revoked.
Source: California Air Resources Board, 2016, Ambient Air Quality Standards, https://ww2.arb.ca.gov/resources/documents/ambient-air-quality- standards-0, accessed July 21, 2023.
California has also adopted a host of other regulations that reduce criteria pollutant emissions, including:
Assembly Bill (AB) 1493: Pavley Fuel Efficiency Standards Heavy-Duty (Tractor-Trailer) Greenhouse Gas (GHG) Regulation Advanced Clean Cars Regulation
Advanced Clean Fleets Regulation
Senate Bill (SB) 1078 and SB 107: Renewables Portfolio Standards California Code of Regulations (CCR) Title 20: Appliance Energy Efficiency Standards 24 CCR Part 6: Building Energy Efficiency Standards
24 CCR Part 11: Green Building Standards Code
Tanner Air Toxics Act and Air Toxics “Hot Spot” Information and Assessment Act Public exposure to TACs is a significant environmental health issue in California. In 1983, the California Legislature enacted a program to identify the health effects of TACs and to reduce exposure to these contaminants to protect the public health. The California Health and Safety Code defines a TAC as “an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health.” A substance that is listed as a hazardous air pollutant pursuant to Section 112(b) of the federal CAA (42 US Code Section 7412[b]) is a TAC. Under State law, the California Environmental Protection Agency (CalEPA), acting through CARB, is authorized to identify a substance as a TAC if it is an air pollutant that may cause or contribute to an increase in mortality or serious illness, or may pose a present or potential hazard to human health. California regulates TACs primarily through AB 1807 (Tanner Air Toxics Act) and AB 2588 (Air Toxics “Hot Spot” Information and Assessment Act of 1987). The Tanner Air Toxics Act sets up a formal procedure for CARB to designate substances as TACs. Once a TAC is identified, CARB adopts an “airborne toxics control measure” for sources that emit designated TACs. If there is a safe threshold for a substance (i.e., a point below which there is no toxic effect), the control measure must reduce exposure to below that threshold.
If there is no safe threshold, the measure must incorporate toxics best available control technology to minimize emissions. To date, CARB has established formal control measures for 11 TACs that are identified as having no safe threshold. Under AB 2588, TAC emissions from individual facilities are quantified and prioritized by the air quality management district or air pollution control district. High-priority facilities are required to perform a health risk assessment, and if specific thresholds are exceeded, are required to communicate the results to the public through notices and public meetings.
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CARB has promulgated the following specific rules to limit TAC emissions:
13 CCR Chapter 10 Section 2485: Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling. This generally restricts on-road diesel-powered commercial motor vehicles with a gross vehicle weight rating of greater than 10,000 pounds from idling more than five minutes. 13 CCR Chapter 10 Section 2480: Airborne Toxic Control Measure to Limit School Bus Idling and Idling at Schools. This generally restricts a school bus or transit bus from idling for more than five minutes when within 100 feet of a school.
13 CCR Section 2477 and Article 8: Airborne Toxic Control Measure for In-Use Diesel-Fueled Transport Refrigeration Units (TRU) and TRU Generator Sets and Facilities Where TRUs Operate. Regulations established to control emissions associated with diesel-powered TRUs.
Regional Regulations
Bay Area Air Quality Management District
BAAQMD is the agency responsible for ensuring that the National and California AAQS are attained and maintained in the SFBAAB. Air quality conditions in the SFBAAB have improved significantly since BAAQMD was created in 1955. BAAQMD prepares air quality management plans (AQMP) to attain AAQS in the SFBAAB. BAAQMD prepares ozone attainment plans for the National O 3 standard and clean air plans
for the California O3 standard. BAAQMD prepares these AQMPs in coordination with Association of Bay Area Governments (ABAG) and the Metropolitan Transportation Commission (MTC) to ensure consistent assumptions about regional growth.
BAAQMD 2017 Clean Air Plan
BAAQMD adopted the 2017 Clean Air Plan: Spare the Air, Cool the Climate (2017 Clean Air Plan) on April 19, 2017, making it the most recently adopted comprehensive plan. The 2017 Clean Air Plan incorporates significant new scientific data, primarily in the form of updated emissions inventories, ambient measurements, new meteorological episodes, and new air quality modeling tools. The 2017 Clean Air Plan serves as an update to the adopted Bay Area 2010 Clean Air Plan and continues to provide the framework for SFBAAB to achieve attainment of the National and California AAQS. The 2017 Clean Air Plan updates the Bay Area’s ozone plan, which is based on the “all feasible measures” approach to meet the requirements of the California CAA. It sets a goal of reducing health risk impacts to local communities by 20 percent between 2015 and 2020 and lays the groundwork for reducing GHG emissions in the Bay Area to meet the State’s 2030 GHG reduction target and 2050 GHG reduction goal. It also includes a vision for the Bay Area in a post-carbon year 2050 that encompasses the following:
Construct buildings that are energy efficient and powered by renewable energy. Walk, bicycle, and use public transit for the majority of trips and use electric-powered autonomous public transit fleets.
Incubate and produce clean energy technologies.
Live a low-carbon lifestyle by purchasing low-carbon foods and goods in addition to recycling and putting organic waste to productive use.
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A comprehensive multipollutant control strategy has been developed to be implemented in the next three to five years to address public health and climate change and to set a pathway to achieve the 2050 vision.
The control strategy includes 85 control measures to reduce emissions of ozone, particulate matter, TACs, and GHGs from a full range of emission sources. These control measures cover the following sectors: 1) stationary (industrial) sources; 2) transportation; 3) energy; 4) agriculture; 5) natural and working lands; 6) waste management; 7) water; 8) super-GHG pollutants; and 9) buildings.
Overall, the proposed control strategy is based on the following key priorities:
Reduce emissions of criteria air pollutants and toxic air contaminants from all key sources. Reduce emissions of “super-GHGs” such as methane, black carbon, and fluorinated gases. Decrease demand for fossil fuels (gasoline, diesel, and natural gas). Increase efficiency of the energy and transportation systems. Reduce demand for vehicle travel, and high-carbon goods and services. Decarbonize the energy system.
Make the electricity supply carbon-free.
Electrify the transportation and building sectors.13
BAAQMD Community Air Risk Evaluation Program
The BAAQMD’s Community Air Risk Evaluation (CARE) program was initiated in 2004 to evaluate and reduce health risks associated with exposure to outdoor TACs in the Bay Area. Based on findings of the latest report, DPM was found to account for approximately 85 percent of the cancer risk from airborne toxics. Carcinogenic compounds from gasoline-powered cars and light duty trucks were also identified as significant contributors: 1,3-butadiene contributed 4 percent of the cancer risk-weighted emissions, and benzene contributed 3 percent. Collectively, five compounds—diesel PM, 1,3-butadiene, benzene, formaldehyde, and acetaldehyde—were found to be responsible for more than 90 percent of the cancer risk attributed to emissions. The most important sources of cancer risk-weighted emissions were combustion-related sources of DPM, including on-road mobile sources (31 percent), construction equipment (29 percent), and ships and harbor craft (13 percent). Overall, cancer risk from TAC dropped by more than 50 percent between 2005 and 2015, when emissions inputs accounted for State diesel regulations and other reductions.
The major contributor to acute and chronic non-cancer health effects in the SFBBAB is acrolein (C 3H4O).
Major sources of acrolein are on-road mobile sources and aircraft near freeways and commercial and military airports.14 Currently, CARB does not have certified emission factors or an analytical test method
13 Bay Area Air Quality Management District, April 19, 2017, Final 2018 Clean Air Plan, Spare the Air Cool the Climate, A Blueprint for Clean Air And Climate Protection in the Bay Area, http://www.baaqmd.gov/research-and- https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_-proposed-final-cap- vol-1-pdf.pdf, accessed August 30, 2023.
14 Bay Area Air Quality Management District, 2006, Community Air Risk Evaluation Program, Phase I Findings and Policy Recommendations Related to Toxic Air Contaminants in the San Francisco Bay Area, https://www.baaqmd.gov/Divisions/Planning-and-Research/Planning-Programs-and- Initiatives/~/media/54D434A0EB8348B78A71C4DE32831544.ashx, accessed August 30, 2023.
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for acrolein. Since the appropriate tools needed to implement and enforce acrolein emission limits are not available, BAAQMD does not conduct health risk screening analysis for acrolein emissions.15 Assembly Bill 617 Community Action Plans
AB 617 (Chapter 136, Statues of 2017) was signed into law in July 2017 to develop a new community- focused program to reduce exposure more effectively to air pollution and preserve public health in environmental justice communities. AB 617 directs CARB and all local air districts to take measures to protect communities disproportionally impacted by air pollution through monitoring and implementing air pollution control strategies.
On September 27, 2018, CARB approved BAAQMD’s recommended communities for monitoring and emission reduction planning. The State approved communities for year 1 of the program as well as communities that would move forward over the next five years. Bay Area recommendations included all the Community Air Risk Evaluation areas, areas with large sources of air pollution (e.g., refineries, seaports, and airports), areas identified via statewide screening tools as having pollution and/or health burden vulnerability, and areas with low life expectancy. 16 Year 1 Communities:
West Oakland. The West Oakland community was selected for BAAQMD's first Community Action Plan. In 2017, cancer risk from sources in West Oakland (local sources) was 204 in a million. The primary sources of air pollution in West Oakland include heavy trucks and cars, port and rail sources, large industries, and to a lesser extent other sources such as residential sources (i.e., wood burning). The majority (over 90 percent) of cancer risk is from DPM. 17 Richmond. Richmond was selected for a community monitoring plan in year 1 of the AB 617 program. The Richmond area is in western Contra Costa County and includes most of Richmond and portions of El Cerrito. It also includes communities just north and east of Richmond, such as San Pablo and several unincorporated communities, including North Richmond. The primary goals of the Richmond monitoring effort are to leverage historical and current monitoring studies, better characterize the area’s mix of sources, and more fully understand the associated air quality and pollution impact.
18 15 Bay Area Air Quality Management District, 2016, Air Toxics NSR Program, Health Risk Screening Analysis Guidelines, https://www.baaqmd.gov/~/media/files/planning-and-research/permit-modeling/hra_guidelines_12_7_2016_clean- pdf.pdf?la=en, accessed August 30, 2023.
16 Bay Area Air Quality Management District, April 19, 2019, AB 617 Fact Sheet: San Francisco Bay Area Community Health Protection Program, https://www.baaqmd.gov/~/media/files/ab617-community-health/2019_0325_ab617onepager- pdf.pdf?la=en&rev=9f6dcd6de8854fd9853ff0498c6bbdff, accessed August 30, 2023. 17 Bay Area Air Quality Management District, October 2, 2019, West Oakland Community Action Plan, https://www.baaqmd.gov/community-health/community-health-protection-program/west-oakland-community-action-plan, accessed August 30, 2023.
18 Bay Area Air Quality Management District, April 19, 2019, AB 617 Fact Sheet: San Francisco Bay Area Community Health Protection Program, https://www.baaqmd.gov/~/media/files/ab617-community-health/2019_0325_ab617onepager- pdf.pdf?la=en&rev=9f6dcd6de8854fd9853ff0498c6bbdff, accessed August 30, 2023.
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Year 2 to 5 Communities: East Oakland/San Leandro, Eastern San Francisco, the Pittsburg-Bay Point area, San Jose, Tri-Valley, and Vallejo are slated for action in years 2 to 5 of the AB 617 program.19 Planning Healthy Places
BAAQMD adopted Planning Healthy Places in 2016 to provide a list of best practices that should be applied when placing sensitive uses in areas with high levels of air pollution or in close proximity to local sources of air pollution. The goal of Planning Healthy Places is to support and encourage infill development while promoting clean, healthy air for residents. The key observation in BAAQMD’s Planning Healthy Places is that proximity to air pollution sources substantially increases exposure and the potential for adverse health effects. There are three carcinogenic TACs that constitute the majority of the known health risks from motor vehicle traffic: DPM from trucks, and benzene and 1,3-butadiene from passenger vehicles. Planning Healthy Places provides a list of “Best Practices to Reduce Exposure to Local Air Pollution” that BAAQMD recommends lead agencies require for projects that introduce new receptors in specific screening distances. These include practices that reduce local traffic emissions, increase site buffering between receptors and emission sources, or alter the design of proposed projects to remove receptors from locations expected to experience the highest pollutant concentrations. 20 BAAQMD Rules and Regulations
Regulation 7, Odorous Substances
Sources of objectionable odors may occur within the City. BAAQMD’s Regulation 7, Odorous Substances, places general limitations on odorous substances and specific emission limitations on certain odorous compounds. Odors are also regulated under BAAQMD Regulation 1, Rule 1-301, Public Nuisance, which states that “no person shall discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or the public; or which endangers the comfort, repose, health or safety of any such persons or the public, or which causes, or has a natural tendency to cause, injury or damage to business or property.” Under BAAQMD’s Rule 1-301, a facility that receives three or more violation notices within a 30-day period can be declared a public nuisance.
Other BAAQMD Regulations
In addition to the plans and programs described above, BAAQMD administers a number of specific regulations on various sources of pollutant emissions that would apply to individual development projects in the EIR Study Area, including:
19 Bay Area Air Quality Management District, April 19, 2019, AB 617 Fact Sheet: San Francisco Bay Area Community Health Protection Program, https://www.baaqmd.gov/~/media/files/ab617-community-health/ 2019_0325_ab617onepager-pdf.pdf?la=en&rev=9f6dcd6de8854fd9853ff0498c6bbdff, accessed August 30, 2023. 20 Bay Area Air Quality Management District, May 2016, Planning Healthy Places: A Guidebook for Addressing Local Sources of Air Pollutants in Community Planning, https://www.baaqmd.gov/~/media/files/planning-and -research/planning-healthy-places/php_may20_2016-pdf.pdf?la=en, accessed May 25, 2023.
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BAAQMD, Regulation 2, Rule 2, New Source Review
BAAQMD, Regulation 2, Rule 5, New Source Review of Toxic Air Contaminants BAAQMD Regulation 6, Rule 1, General Requirements
BAAQMD Regulation 6, Rule 2, Commercial Cooking Equipment BAAQMD Regulation 8, Rule 3, Architectural Coatings
BAAQMD Regulation 8, Rule 4, General Solvent and Surface Coatings Operations BAAQMD Regulation 8, Rule 7, Gasoline Dispensing Facilities BAAQMD Regulation 11, Rule 2, Asbestos, Demolition, Renovation and Manufacturing Sonoma County Transportation Authority
The Sonoma County Transportation Authority (SCTA) is the congestion management agency for Sonoma County. SCTA is tasked with developing a comprehensive transportation improvement program among local jurisdictions that will reduce traffic congestion and improve land use decision-making and air quality.
SCTA’s latest congestion management program is the 2016 Comprehensive Transportation Plan (CTP).
SCTA’s countywide transportation model must be consistent with the regional transportation model developed by the MTC with ABAG data. The countywide transportation model is used to help evaluate cumulative transportation impacts of local land use decisions on the congestion management program system. In addition, SCTA’s updated CTP includes multi-modal performance standards and trip reduction and transportation demand management (TDM) strategies consistent with the goals of reducing regional VMT in accordance with the Sustainable Communities and Climate Protection Act, commonly known by its legislative bill number SB 375.
As part of the implementing framework for the CTP, communities in Sonoma County have identified Priority Development Areas (PDA) to focus future population and employment growth. Increased density in PDAs is intended to locate more people near jobs and services in an effort to reduce travel and transportation related GHG emissions.
21 Furthermore, shifting travel to active transportation modes (such as walking, biking, or riding transit) would help improve neighborhood air quality conditions and overall community health.
Plan Bay Area
As described in Chapter 4.0, Environmental Analysis, of this Draft EIR, MTC and ABAG adopted Plan Bay Area 2050 on October 21, 2021.
22 Plan Bay Area provides transportation and environmental strategies to continue to meet the regional transportation-related GHG reduction goals of the Sustainable Communities and Climate Protection Act (SB 375). Strategies to reduce GHG emissions include focusing housing and commercial construction in walkable, transit-accessible places; investing in transit and active transportation; and shifting the location of jobs to encourage shorter commutes.
21 Sonoma County Transportation Authority, September 2016, Moving Forward 2040: Sonoma County’s Comprehensive Transportation Plan, https://scta.ca.gov/wp-content/uploads/2016/09/CTP16_090616.pdf, accessed August 30, 2023. 22 Association of Bay Area Governments and Metropolitan Transportation Commission, October 2021, Plan Bay Area 2050, https://www.planbayarea.org/sites/default/files/documents/Plan_Bay_Area_2050_October_2021.pdf, accessed July 21, 2023.
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Similar to the County’s CTP , local governments have identified PDAs23 and Transit Priority Areas (TPAs)24 to focus growth within the Bay Area region. As shown on Figure 4-1, Priority Development Areas and Transit Priority Areas, in Chapter 4.0 of this Draft EIR, the EIR Study Area has six PDAs and three TPAs—the Mendocino Avenue/Santa Rosa Avenue Corridor PDA, North Santa Rosa Station PDA and TPA, Downtown Station Area PDA and TPA, Sebastopol Road Corridor PDA, Roseland PDA, Santa Rosa Avenue PDA, and Santa Rosa Transit Mall TPA.
Local Regulations
Santa Rosa City Code
The Santa Rosa City Code (SRCC) includes directives to minimize adverse impacts to air quality in Santa Rosa. The SRCC is organized by title, chapter, and section and in some cases, articles. Most provisions related to air quality are in Title 9, Health and Safety, and Title 17, Environmental Protection, as follows:
Chapter 9-20, Smoking Regulations. This chapter provides regulations to protect the public health, safety, and general welfare by providing a smoke-free and vapor-free environment in public and private places where nonsmokers may be exposed to secondhand smoke and vapor . Chapter 17-30, Trip Reduction Program. The purpose of this chapter is to reduce traffic and improve air quality within the City of Santa Rosa by promoting the development of trip reduction programs at existing and future work sites.
Average vehicle ridership is established to measure progress toward achieving an increase in the use of commute alternatives and reducing peak hour vehicle trips.
Section 17-30.060, Employer responsibilities, list the provisions for employers to implement and Section 17-30.070, City participation, outlines the City’s roles in the trip reduction program. Chapter 17-35, Installation of Wood Burning Appliances, Removal, and Operation of Noncertified Wood Heaters. This chapter aims to improve air quality by educating the public with regard to the impacts of burning wood and the various types of wood burning appliances, regulating the type of wood burning appliances that may be installed and maintained within the city, and banning the use of noncertified wood burning appliances after June 1, 2004.
EXISTING CONDITIONS
San Francisco Bay Area Air Basin
California is divided geographically into air basins for the purpose of managing the air resources of the State on a regional basis. An air basin generally has similar meteorological and geographic conditions throughout. The State is divided into 15 air basins. As previously stated, Santa Rosa is in the SFBAAB. The discussion below identifies the natural factors in the SFBAAB that affect air pollution. Air pollutants of concern are criteria air pollutants and TACs. Federal, State, and local air districts have adopted laws and regulations intended to control and improve air quality. BAAQMD is the regional air quality agency for the SFBAAB, which comprises all of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, and Santa
23 PDAs are transit-oriented, infill development opportunity areas within existing communities. 24 TPAs are half-mile buffers surrounding major transit stops or terminals.
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Clara Counties; the southern portion of Sonoma County; and the southwestern portion of Solano County.
Air quality in this area is determined by such natural factors as topography, meteorology, and climate, in addition to the presence of existing air pollution sources and ambient conditions:
25 Meteorology: The SFBAAB is characterized by complex terrain, consisting of coastal mountain ranges, inland valleys, and bays, which distort normal wind flow patterns. The Coast Range26 splits in the Bay Area, creating a western coast gap, the Golden Gate, and an eastern coast gap, the Carquinez Strait, which allows air to flow in and out of the Bay Area and the Central Valley. The climate is dominated by the strength and location of a semi-permanent, subtropical high-pressure cell. During the summer, the Pacific high-pressure cell is centered over the northeastern Pacific Ocean, resulting in stable meteorological conditions and a steady northwesterly wind flow. Upwelling of cold ocean water from below the surface because of the northwesterly flow produces a band of cold water off the California coast. The cool and moisture-laden air approaching the coast from the Pacific Ocean is further cooled by the presence of the cold water band, resulting in condensation and the presence of fog and stratus clouds along the Northern California coast. In the winter, the Pacific high-pressure cell weakens and shifts southward, resulting in wind flow offshore, the absence of upwelling, and the occurrence of storms. Weak inversions coupled with moderate winds result in a low air pollution potential. Wind Patterns: During the summer, winds flowing from the northwest are drawn inland through the Golden Gate and over the lower portions of the San Francisco Peninsula. Immediately south of Mount Tamalpais in Marin County, the northwesterly winds accelerate considerably and come more directly from the west as they stream through the Golden Gate. This channeling of wind through the Golden Gate produces a jet that sweeps eastward and splits off to the northwest toward Richmond and to the southwest toward San Jose when it meets the East Bay hills. Wind speeds may be strong locally in areas where air is channeled through a narrow opening, such as the Carquinez Strait, the Golden Gate, or the San Bruno gap. For example, the average wind speed at San Francisco International Airport in July is about 17 knots (from 3:00 to 4:00 p.m.), compared with only 7 knots at San Jose and less than 6 knots at the Farallon Islands. The air flowing in from the coast to the Central Valley, called the sea breeze, begins developing at or near ground level along the coast in late morning or early afternoon. As the day progresses, the sea breeze layer deepens and increases in velocity while spreading inland. The depth of the sea breeze depends in large part upon the height and strength of the inversion. Under normal atmospheric conditions, the air in the lower atmosphere is warmer than the air above it. An inversion is a change in the normal conditions that causes the temperature gradient to be reversed or inverted. If the inversion is low and strong, and hence stable, the flow of the sea breeze will be inhibited, and stagnant conditions are likely to result. In the winter, the SFBAAB frequently experiences stormy conditions with moderate to strong winds, as well as periods of stagnation with very light winds. Winter stagnation episodes (i.e., conditions where there is little mixing, which occurs when there is a lack of or little wind) are characterized by nighttime drainage flows in coastal valleys. Drainage is a reversal of the usual daytime air-flow patterns; air moves from
25 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed August 30, 2023.
26 The Coast Ranges traverse California’s west coast from Humboldt County to Santa Barbara County.
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the Central Valley toward the coast and back down toward the Bay from the smaller valleys within the SFBAAB.
Temperature: Summertime temperatures in the SFBAAB are determined in large part by the effect of differential heating between land and water surfaces. Because land tends to heat up and cool off more quickly than water, a large-scale gradient (differential) in temperature is often created between the coast and the Central Valley, and small-scale local gradients are often produced along the shorelines of the ocean and bays. The temperature gradient near the ocean is also exaggerated, especially in summer, because of the upwelling of cold water from the ocean bottom along the coast.
On summer afternoons, the temperatures at the coast can be 35 degrees Fahrenheit cooler than temperatures 15 to 20 miles inland; at night, this contrast usually decreases to less than 10 degrees Fahrenheit. In the winter, the relationship of minimum and maximum temperatures is reversed.
During the daytime the temperature contrast between the coast and inland areas is small, whereas at night the variation in temperature is large.
Precipitation: The SFBAAB is characterized by moderately wet winters and dry summers. Winter rains (November through March) account for about 75 percent of the average annual rainfall. The amount of annual precipitation can vary greatly from one part of the SFBAAB to another, even within short distances. In general, total annual rainfall can reach 40 inches in the mountains, but it is often less than 16 inches in sheltered valleys. During rainy periods, ventilation (rapid horizontal movement of air and injection of cleaner air) and vertical mixing (an upward and downward movement of air) are usually high, and thus pollution levels tend to be low (i.e., air pollutants are dispersed more readily into the atmosphere rather than accumulate under stagnant conditions). However, during the winter, frequent dry periods do occur, where mixing and ventilation are low and pollutant levels build up. Wind Circulation: Low wind speed contributes to the buildup of air pollution because it allows more pollutants to be emitted into the air mass per unit of time. Light winds occur most frequently during periods of low sun (fall and winter, and early morning) and at night. These are also periods when air pollutant emissions from some sources are at their peak, namely, commuter traffic (early morning) and wood-burning appliances (nighttime). The problem can be compounded in valleys, when weak flows carry the pollutants up-valley during the day, and cold air drainage flows move the air mass down-valley at night. Such restricted movement of trapped air provides little opportunity for ventilation and leads to buildup of pollutants to potentially unhealthful levels. Inversions: As described above, an inversion is a layer of warmer air over a layer of cooler air .
Inversions affect air quality conditions significantly because they influence the mixing depth (i.e., the vertical depth in the atmosphere available for diluting air contaminants near the ground). There are two types of inversions that occur regularly in the SFBAAB. Elevation inversions are when the air blows over elevated areas, it is heated as it is compressed into the side of the hill/mountain. When that warm air comes over the top, it is warmer than the cooler air of the valley. These are more common in the summer and fall. Radiation inversions occur during the night when the ground cools off, radiating the heat to the sky, and are more common during the winter . The highest air pollutant concentrations in the SFBAAB generally occur during inversions.
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SFBAAB Area Designations
The AQMP provides the framework for air quality basins to achieve attainment of National and California AAQS through the State Implementation Plan. Areas that meet AAQS are classified attainment areas, and areas that do not meet these standards are classified nonattainment areas. Severity classifications for O3 range from marginal, moderate, and serious to severe and extreme. Unclassified: A pollutant is designated unclassified if the data are incomplete and do not support a designation of attainment or nonattainment.
Attainment: A pollutant is in attainment if the AAQS for that pollutant was not violated at any site in the area during a three-year period.
Nonattainment: A pollutant is in nonattainment if there was at least one violation of an AAQS for that pollutant in the area.
Nonattainment/Transitional: A subcategory of the nonattainment designation. An area is designated nonattainment/transitional to signify that the area is close to attaining the AAQS for that pollutant.
The attainment status for the SFBBAB is shown in Table 4.3-4, Attainment Status of Criteria Air Pollutants in the San Francisco Bay Area Basin. The SFBBAB is currently designated a nonattainment area for California and National O3, California and National PM2.5, and California PM10 AAQS.
TABLE 4.3-4 ATTAINMENT STATUS OF CRITERIA POLLUTANTS IN THE SAN FRANCISCO BAY AREA AIR BASIN Pollutant State Federal
Ozone – 1-hour Nonattainment Classification revoked (2005) Ozone – 8-hour Nonattainment (serious) Nonattainment (marginal) a PM10 Nonattainment Unclassified/Attainment b
PM2.5 Nonattainment Unclassified/Attainment
CO Attainment Attainment
NO2 Attainment Unclassified
SO2 Attainment Attainment
Lead Attainment Attainment
Sulfates Attainment Unclassified/Attainment
All others Unclassified/Attainment Unclassified/Attainment Notes:
a. Severity classification current as of February 13, 2017. b. In December 2014, USEPA issued final area designations for the 2012 primary annual PM2.5 national AAQS. Areas designated “unclassifiable/attainment” must continue to take steps to prevent their air quality from deteriorating to unhealthy levels. The effective date of this standard is April 15, 2015.
Source: California Air Resources Board, 2023, Maps of State and Federal Area Designations, https://ww2.arb.ca.gov/resources/documents/maps-state- and-federal-area-designations, accessed July 21, 2023.
Existing Ambient Air Quality
Existing levels of ambient air quality and historical trends and projections in the vicinity of Santa Rosa have been documented and measured by BAAQMD. BAAQMD has 24 permanent monitoring stations located around the Bay Area, and data from the nearest station, Sebastopol-103 Morris Street in Sebastopol was used. The station closest to the EIR Study Area with data for PM 10 was the Napa-Valley College Monitoring
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Station. Data from these stations are summarized in Table 4.3-5, Ambient Air Quality Monitoring Summary. The data show occasional violations of the federal PM2.5 and state PM10 standards.
TABLE 4.3-5 AMBIENT AIR QUALITY MONITORING SUMMARY
Pollutant/Standard
Number of Days Threshold Were Exceeded and
Maximum Levels During Such Violations
2019 2020 2021
Ozone (O3) a
State 1-Hour ≥ 0.09 ppm
State & Federal 8-hour ≥ 0.07 ppm
Maximum 1-Hour Conc. (ppm)
Maximum 8-Hour Conc. (ppm)
0 0
0.070
0.060
0 0
0.068
0.059
0 0
0.071
0.063
Nitrogen Dioxide (NO2)
State 1-Hour ≥ 0.18 (ppm)
Maximum 1-Hour Conc. (ppb)
0 0.0319
0 0.0363
0 0.0263
Coarse Particulates (PM10) a
State 24-Hour > 50 µg/m3
Federal 24-Hour > 150 µg/m3
Maximum 24-Hour Conc. (µg/ m3)
0 0
37.5 2
0 122.9
0 0
22.9 Fine Particulates (PM2.5)
Federal 24-Hour > 35 µg/m3
Maximum 24-Hour Conc. (µg/m3)
0 28.0
7 124.3
0 29.5
Notes: ppm = parts per million; ppb = parts per billion; µg/m3 = micrograms per cubic meter; * = insufficient data/not available a. Data obtained from the Napa-Valley College Monitoring Station for PM10.
Source: California Air Resources Board, 2023, Air Pollution Data Monitoring Cards (2019, 2020, and 2021), https://www.arb.ca.gov/adam/topfour/topfour1.php, accessed July 21, 2023.
Sensitive Receptors
Some land uses are considered more sensitive to air pollution than others due to the types of population groups or activities involved. Sensitive population groups include children, the elderly, the acutely ill, and the chronically ill, especially those with cardiorespiratory diseases. Disadvantaged communities (i.e., environmental justice communities) identified by CalEnviroScreen 4.0 (CES4) may be disproportionately affected by and vulnerable to poor air quality.
27, 28 The CES cumulative score is a cumulative measure of overall environmental justice burden based on 24 indicators, including pollution, social, and health indicators, four of which are specifically related to air quality or air pollution.
Residential areas are also considered sensitive receptors to air pollution because residents (including children and the elderly) tend to be at home for extended periods of time, resulting in sustained exposure to any pollutants present. Other sensitive receptors include retirement facilities, hospitals, and schools.
Recreational land uses are considered moderately sensitive to air pollution. Although exposure periods are generally short, exercise places a high demand on respiratory functions, which can be impaired by air pollution. In addition, noticeable air pollution can detract from the enjoyment of recreation. Industrial,
27 Under SB 535, disadvantaged communities are defined as the top 25 percent scoring areas from CES along with other areas with high amounts of pollution and low populations. 28 CES4 Indicator Maps can be found at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40.
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commercial, retail, and office areas are considered the least sensitive to air pollution. Exposure periods are relatively short and intermittent, as the majority of the workers tend to stay indoors most of the time.
In addition, the working population is generally the healthiest segment of the public.
Environmental Justice Communities
Disadvantaged communities identified by CES (i.e., environmental justice communities) may be disproportionately affected by and vulnerable to poor air quality. 29, 30 The CES cumulative score is a
cumulative measure of overall environmental justice burden based on 24 indicators, including pollution, social, and health indicators, four of which specifically relate to air quality or air pollution (see Figure 4.3- 1, CES4 Indicator: Cumulative Score by Percentile).
Within Sonoma County, there are the following identified sensitive community types, which are areas that are disproportionately burdened by pollution, both of which are based on CES4:
BAAQMD’s Overburdened Communities. Figure 4.3-2, BAAQMD Overburdened Communities, shows the areas that, according to BAAQMD, are disproportionately burdened by pollution. These Overburdened Communities were mapped using the CES4, a tool advocated for by community groups and developed by the State Office of Environmental Health Hazard Assessment (OEHHA) on behalf of the CalEPA.
Santa Rosa Equity Priority Areas (EPAs).31 The City’s proposed General Plan 2050 identifies communities that suffer most from economic, health, and environmental burdens based on SB 1000 “disadvantaged communities” definition. These communities disproportionately burdened by pollution and health impacts in Santa Rosa are called Equity Priority Areas (see Figure 4.3-3, Santa Rosa Equity Priority Areas). EPAs were identified using the CES4 tool, which applies a formula to each census tract in the state to generate a score that ranks the level of cumulative impacts in each area relative to the rest of the census tracts in the state. In general, the higher the score, the more impacted a community is. Census tracts in the highest quartile of scores (i.e., 75 to 100 percent [75 percentile]) are considered EPAs. Additional EPAs were also identified pursuant to SB 535, which encourages cities to work with community members and stakeholders to refine the boundaries of these communities and identify additional communities.
CalEnviroScreen Air Quality Indicators
CES identifies California communities most affected by sources of pollution and where people are vulnerable to pollution’s effects. People in environmental justice areas identified by CES4 by BAAQMD’s Overburdened Communities, may be disproportionately affected by and vulnerable to poor air quality.
CES’s “pollution burden” map identifies communities exposed to pollution from human activities, such as air pollution (ozone, PM
2.5, DPM), water pollution (drinking water contaminants), and hazardous materials (pesticide use, children’s lead exposure, toxic releases), and traffic density. Figure 4.3-4, CES4 Indicator:
29 Under SB 535, disadvantaged communities are defined as the top 25 percent scoring areas from CES along with other areas with high amounts of pollution and low populations. 30 CES4 Indicator maps can be found at: https://oehha.ca.gov/calenviroscreen/report/calenviroscreen-40. 31 Synonymous with Disadvantaged Communities under SB 1000.
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Pollution Burden by Percentile, shows the pollution burden in the EIR Study Area relative to the rest of the state. In CES, the pollution burden score considers the disproportionate effect of pollution on environmental justice communities, because the score weighs socioeconomic factors (e.g., educational attainment and poverty) and sensitivity of the population (e.g., asthma rates and cardiovascular disease).
Though the causes of asthma are poorly understood, it is established that exposure to traffic and outdoor air pollutants can trigger asthma attacks. Previous research has shown that children, the elderly, racial and ethnic minorities, and low-income Californians suffer disproportionately from asthma attacks and asthma- like symptoms.
32 Figure 4.3-5, CES4 Indicator: Asthma by Percentile, maps the percentile of spatially modeled, age-adjusted rate of emergency department visits for asthma per 10,000 (averaged over 2015 to 2017) relative to the rest of the state.33
Placement of New Sensitive Receptors
As previously described in Section 4.3.1.3, Regulatory Framework, BAAQMD adopted Planning Healthy Places to provide a list of best practices that should be applied when placing sensitive uses in areas with high levels of air pollution or in close proximity to local sources of air pollution. Figure 4.3-6, BAAQMD Siting Recommendations, identifies stationary sources (BAAQMD-permitted) in the EIR Study Area and major roadways where BAAQMD recommends either implementation of best practices to reduce risk or preparation of site-specific analysis (e.g., health risk assessments) to ensure air quality compatibility. 34 Existing Emissions
Table 4.3-6, Existing EIR Study Area Regional Criteria Air Pollutant Emissions Inventory, identifies the existing criteria air pollutant emissions inventory using emission rates for year 2019 (baseline conditions).
The inventories are based on existing land uses in the EIR Study Area. The Year 2019 inventory represents the projected emissions currently generated by existing land uses using the baseline year 2019 emission factors for on-road vehicles.
32 California Air Resources Board, October 2013, “Higher ‘asthma burden’ among minorities, low-income groups tied to increased exposure to air pollution,” https://ww2.arb.ca.gov/news/higher-asthma-burden-among -minorities-low-income-groups-tied-increased-exposure-air-pollution, accessed May 25, 2023. 33 Office of Environmental Health Hazard Assessment, May 1, 2023, CalEnviroScreen (CES) 4.0 Indicator Map, https://experience.arcgis.com/experience/ed5953d89038431dbf4f22ab9abfe40d/, accessed August 30, 2023. 34 Bay Area Air Quality Management District, May 2016, Planning Healthy Places: A Guidebook for Addressing Local Sources of Air Pollutants in Community Planning, https://www.baaqmd.gov/~/media/files/planning-and -research/planning-healthy-places/php_may20_2016-pdf.pdf?la=en, accessed May 25, 2023.
HoenAve
Olivet Rd
Mendocino A
ve
Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark WestSpringsR d
W
atertro
ugh Rd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood
Hwy
Brush C
reek Rd
Su
mmerfieldRd
Fount ainGrovePky
Co
ffey Ln
Warm
SpringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calisto
gaRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfiel d R
d
Airport Blvd
(/101
12 12
116
Figure 4.3-1
CES4 Indicator - Cumulative Score by Percentile
Source: OEHHA, 2021; ESRI, 2022; PlaceWorks, 2024.
0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Cumulative Score by Census Tract
<=10 (Lowest Score)
10 - 20
20 - 30
30 - 40
40 - 50
50 - 60
60 - 70
70 - 80
80 - 90
90 - 100 (Highest Score)
AIR QUALITY
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
---------
D
·- - -· D
D
HoenAve
Olivet Rd
Mendocino A
ve
Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark WestSpringsR d
W
atertro
ugh Rd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood
Hwy
Brush C
reek Rd
Su
mmerfieldRd
Fount ainGrovePky
Co
ffey Ln
Warm
SpringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calisto
gaRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfiel d R
d
Airport Blvd
(/101
12 12
116
Figure 4.3-2
BAAQMD Overburdened Communities
Source: ESRI, 2022; BAAQMD, 2023; PlaceWorks, 2024.
0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
BAAQMD Overburdened
Census Tr
acts
AIR QUALITY
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
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Hoen Ave
Olivet Rd
Mendocino Av
e
Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark W
estSpri ngs R d
Wa
tertro
ughRd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood Hwy
Brush C
reek Rd
Su
mmerfieldRd
Fount ain
GrovePky
Co
ffey Ln
Warm S
pringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calistog
aRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfield R
d
Airport Blvd
(/101
12 12
116
Figure 4.3-3
Santa Rosa Equity Priority Areas
Source: ESRI, 2022; City of Santa Rosa, 2023; PlaceWorks, 2024. 0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
Equity Priority Areas
AIR QUALITY
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
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HoenAve
Olivet Rd
Mendocino A
ve
Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark WestSpringsR d
W
atertro
ugh Rd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood
Hwy
Brush C
reek Rd
Su
mmerfieldRd
Fount ainGrovePky
Co
ffey Ln
Warm
SpringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calisto
gaRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfiel d R
d
Airport Blvd
(/101
12 12
116
Figure 4.3-4
CES4 Indicator - Pollution Burden by Percentile
Source: OEHHA, 2021; ESRI, 2022; PlaceWorks, 2024.
0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Pollution Percentile by Census Tract
<=10 (Lowest Score)
10 - 20
20 - 30
30 - 40
40 - 50
50 - 60
60 - 70
70 - 80
80 - 90
90 - 100 (Highest Score)
AIR QUALITY
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
-------
r.· : . :!
HoenAve
Olivet Rd
Mendocino A
ve
Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark WestSpringsR d
W
atertro
ugh Rd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood
Hwy
Brush C
reek Rd
Su
mmerfieldRd
Fount ainGrovePky
Co
ffey Ln
Warm
SpringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calisto
gaRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfiel d R
d
Airport Blvd
(/101
12 12
116
Figure 4.3-5
CES4 Indicator - Asthma by Percentile
Source: OEHHA, 2021; ESRI, 2022; PlaceWorks, 2024.
0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Asthma Percentile by Census Tract
<= 10 (Lowest Score)
10 - 20
20 - 30
30 - 40
40 - 50
50 - 60
60 - 70
70 - 80
80 - 90
90 - 100 (Highest Score)
AIR QUALITY
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
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HoenAve
Olivet Rd
Mendocino A
ve
Grange Rd
Ben
net t Valley Rd
W Steele Ln
W College Ave Sonoma Ave
Sebastopol Rd
Guerneville Rd
College Ave
Fulton Rd
Crane Canyon Rd
Stony Point Rd
Mark WestSpringsR d
W
atertro
ugh Rd
Millbrae Ave
Petalu
maHill Rd
OldRed
wood
Hwy
Brush C
reek Rd
Su
mmerfieldRd
Fount ainGrovePky
Co
ffey Ln
Warm
SpringsRd
Piner Rd
4th
St
Todd Rd
Bodega Hwy
Marlo
wRd
River Rd Calisto
gaRd
Dutton Ave
Pleasa
ntHill Rd
Llano Rd
S Wright Rd
Hearn Ave
Montgome
ry Dr
Santa Rosa Ave
Occidental Rd
Slusser Rd
Blo omfiel d R
d
Airport Blvd
(/101
12 12
116
Figure 4.3-6
BAAQMD Siting Recommendations
Source: ESRI, 2022; BAAQMD, 2023; PlaceWorks, 2024.
0 1 20.5
Miles
Planning Area
Urban Growth Boundary
Sphere of Influence
City Limit
Creeks and Waterways
Parks and Open Space
# BAAQMD Permitted
Stationary Sources
Implement Best Practices
Conduct Further Study
AIR QUALITY
S A N T A R O S A G E N E R A L P L A N 2 0 5 0 D R A F T E I R
C I T Y O F S A N T A R O S A
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SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
PLACEWORKS 4.3-29
TABLE 4.3-6 EXISTING EIR STUDY AREA REGIONAL CRITERIA AIR POLLUTANT EMISSIONS INVENTORY Pollutant/Standard
Tons per year
ROG NOX PM10 PM2.5
Transportation a 46 376 22 7
Energy b 11 209 16 16
Off-road Equipment c 143 173 9 8
Consumer Products d 529 ― ― ―
Total 729 758 47 30
Notes:
a. On-road transportation VMT is provided by VMT and modeled with EMFAC2021. VMT for the proposed project is based on the “project’s effect” of VMT in the EIR Study Area.
b. Building electricity and natural gas are based on data provided by the City for the GHG emissions inventory conducted for their GHG Reduction Strategy from PG&E, SCP, and CalEEMod User’s Guide for natural gas criteria air pollutant emissions. The electricity rates were adjusted to reflect the increase in housing units and employment within the EIR Study Area. c. On-road vehicles and equipment are based on the OFFROAD2021 emissions inventory and include construction equipment and commercial equipment.
d. Based on CalEEMod User’s Guide methodology to calculate ROG emissions from use of household consumer cleaning products.
Source: PlaceWorks, 2023.
Stationary Sources
Stationary sources of air pollution—including complex sources such as metal smelting, wastewater treatment plants, and refineries as well as smaller facilities such as diesel generators, gasoline dispensing facilities (GDFs or gas stations), and boilers—are regulated and subject to permit conditions established by BAAQMD.35 Stationary sources in the EIR Study Area are shown on Figure 4.3-2.
Odors
Santa Rosa has a wastewater treatment plant that has the potential to generate odors. Odors are also associated with certain manufacturing processes and with some commercial operations (restaurants, etc.) that may be located near residential uses. Nuisance odors are regulated under BAAQMD Regulation 7, Odorous Substances, and Regulation 1, Rule 1-301, Public Nuisance. Under BAAQMD’s Rule 1-301, a facility that receives three or more violation notices within a 30-day period can be declared a public nuisance.
4.3.2 STANDARDS OF SIGNIFICANCE
Implementation of the proposed project would result in significant impacts to air quality if it would:
1. Conflict with or obstruct implementation of the applicable air quality plan.
2. Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard.
3. Expose sensitive receptors to substantial pollutant concentrations.
35 Permitted facilities are mapped by BAAQMD and can be found at:
https://baaqmd.maps.arcgis.com/apps/webappviewer/index.html?id=2387ae674013413f987b1071715daa65.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
4.3-30 OCTOBER 2024
4. Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
5. In combination with past, present, and reasonably foreseeable projects, result in a cumulative impact with respect to air quality.
BAAQMD PLAN-LEVEL THRESHOLDS
The BAAQMD CEQA Air Quality Guidelines (BAAQMD CEQA Guidelines) were prepared to assist in the evaluation of air quality impacts of projects and plans proposed within the Bay Area. The BAAQMD CEQA Guidelines provide recommended procedures for evaluating potential air impacts during the environmental review process, consistent with California Environmental Quality Act (CEQA) requirements, and include recommended thresholds of significance, mitigation measures, and background air quality information. The BAAQMD CEQA Guidelines also include recommended assessment methodologies for air toxics, odors, GHG emissions, and environmental justice.
In June 2010, BAAQMD’s Board of Directors adopted CEQA thresholds of significance and an update of the BAAQMD CEQA Guidelines. These thresholds are designed to establish the level at which the BAAQMD believed air pollution emissions would cause significant environmental impacts under CEQA. BAAQMD published a new version of the BAAQMD CEQA Guidelines in April 2023, which was the version used to prepare the analysis in this EIR.
36 Clean Air Plan Consistency
Under its plan-level review criteria, which apply to long-range plans such as the proposed project, BAAQMD recommends a consistency evaluation of the plan with its current AQMP control measures.
BAAQMD considers a plan to be consistent with the applicable AQMP , which is currently the 2017 Clean Air Plan, if it is consistent with below considerations:
Does the plan support the primary goals of the AQMP?
Does the plan include applicable control measures from the AQMP? Does the plan disrupt or hinder implementation of any AQMP control measure? Does the plan result in VMT growth that is equal to or less than the projected population growth? Criteria Air Pollutant Emissions and Precursors
Regional Significance Criteria
BAAQMD’s regional significance criteria for projects that exceed the screening thresholds are shown in Table 4.3-7, BAAQMD Regional (Mass Emissions) Criteria Air Pollutant Significance Thresholds. Criteria for both the construction and operational phases of the proposed project are shown.
36 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
4.3.2.1 SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
PLACEWORKS 4.3-31
TABLE 4.3-7 BAAQMD REGIONAL (MASS EMISSIONS) CRITERIA AIR POLLUTANT SIGNIFICANCE THRESHOLDS Air Pollutant
Construction Phase Operational Phase
Average Daily Emissions (lbs/day) Average Daily Emissions (lbs/day)
Maximum Annual Emissions
(Tons/year)
Project-Level
ROG 54 54 10
NOX 54 54 10
PM10 82 (Exhaust) 82 15
PM2.5 54 (Exhaust) 54 10
PM10 and PM2.5 Fugitive Dust Best Management Practices None None Plan-Level
All Criteria Air Pollutants No Net Increase
Source: Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/updated-ceqa-guidelines, accessed July 21, 2023.
While the proposed General Plan 2050 is a local long-range plan, the land use pattern it envisions has regional implications, such as interjurisdictional transportation behavior and jobs-to-housing ratios; therefore, it would have a less-than-significant impact related to air quality if it demonstrates “no net increase” in criteria air pollutants and risks and hazards. To demonstrate no net increase, BAAQMD’s Guidelines require two comparative analyses for the projected future emissions:
Scenario 1: Project to Existing Conditions (base-to-future-year comparison). Compare the existing (base year) emissions with projected future year emissions plus the regional plan’s emissions (base year/regional plan comparison).
Scenario 2: Project to Future No Project Conditions (future baseline comparison). Compare projected future year emissions with projected future year emissions plus the regional plan’s emissions (no regional plan/regional plan comparison). This scenario isolates changes in emissions due solely to the project since both the scenarios consider emissions reductions from federal and state regulations.
If both comparative analyses demonstrate no net increase in emissions, the air quality impacts of the proposed General Plan 2050 would be less than significant.
Health Effects of Criteria Air Pollutants
If projects exceed the emissions in Table 4.3-7, emissions would cumulatively contribute to the nonattainment status and would contribute to elevating health effects associated with these criteria air pollutants. Known health effects related to ozone include worsening of bronchitis, asthma, and emphysema and a decrease in lung function. Health effects associated with particulate matter include premature death of people with heart or lung disease, nonfatal heart attacks, irregular heartbeat, decreased lung function, and increased respiratory symptoms. Reducing emissions would further contribute to reducing possible health effects related to criteria air pollutants.
However, for projects that exceed the emissions in Table 4.3-7, it is speculative to determine how exceeding the regional thresholds would affect the number of days the region is in nonattainment since mass emissions are not correlated with concentrations of emissions or how many additional individuals in SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
4.3-32 OCTOBER 2024
the SFBAAB would be affected by the health effects cited above. BAAQMD is the primary agency responsible for ensuring the health and welfare of sensitive individuals to elevated concentrations of air quality in the SFBAAB; at the present time, it has not provided methodology to assess the specific correlation between mass emissions generated and the effect on health in order to address the issue raised in Sierra Club v. County of Fresno (Friant Ranch, L.P .) (2018) 6 Cal.5th 502, Case No. S21978 (Friant Ranch).
Ozone concentrations are dependent upon 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. 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. To achieve the health-based standards established by the EPA, the air districts prepare air quality management plans that detail regional programs to attain the AAQS. However, if a project within the EIR Study Area exceeds the regional significance thresholds, the project could contribute to an increase in health effects in the basin until such time the attainment standards are met in the SFBAAB.
Receptor Exposure to Pollutant Concentrations
Local Carbon Monoxide Hotspots
Congested intersections have the potential to create elevated concentrations of CO, referred to as CO hotspots. The significance criteria for CO hotspots are based on the California AAQS for CO, which are
9.0 ppm (8-hour average) and 20.0 ppm (1-hour average). Under a plan-level review, BAAQMD does not require an evaluation of CO hotspots. With the turnover of older vehicles, introduction of cleaner fuels, and implementation of control technology, the SFBAAB is in attainment of the National and California AAQS for CO emissions, and CO concentrations in the SFBAAB have steadily declined. Because CO concentrations have improved, BAAQMD does not require a CO hotspot analysis if the following criteria are met:
37 A project is consistent with an applicable congestion management program established by the County Congestion Management Agency for designated roads or highways, the regional transportation plan, and local congestion management agency plans.
A project would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour .
A project traffic would not increase traffic volumes at affected intersection to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade roadway).
37 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
CITY OF SANTA ROSA
AIR QUALITY
PLACEWORKS 4.3-33
Community Risk and Hazards
BAAQMD’s significance thresholds for local community risk and hazard impacts apply to both the siting of a new source and to the siting of a new receptor . Local community risk and hazard impacts are associated with TACs and PM
2.5 because emissions of these pollutants can have significant health impacts at the local level. The proposed project would generate TACs and PM2.5 during construction activities that could elevate concentrations of air pollutants at the nearby receptors. The thresholds for construction-related local community risk and hazard impacts are the same as for project operations. BAAQMD has adopted screening tables for air toxics evaluation during construction. Construction-related TAC and PM
2.5 impacts
should be addressed on a case-by-case basis, taking into consideration the specific construction-related characteristics of each project and proximity to off-site and on-site receptors, as applicable.38, 39 Community Risk and Hazards: Project
Project-level emissions of TACs or PM2.5 from individual sources that exceed any of the thresholds listed below are considered a potentially significant community health risk in the absence of a qualified community risk reduction plan:
An excess (i.e., increased) cancer risk level of more than 10 in one million. Noncancer (i.e., chronic or acute) hazard index greater than 1.0. An incremental increase of greater than 0.3 micrograms per cubic meter (µg/m3) annual average PM2.5.40
Community Risk and Hazards: Cumulative
Cumulative sources represent the combined total risk values of each of the individual sources within the 1,000-foot evaluation zone. A project would have a cumulatively considerable impact if the aggregate total of all past, present, and foreseeable future sources within a 1,000-foot radius from the fence line of a source or location of a receptor, plus the contribution from the project, exceeds any of the following in the absence of a qualified community risk reduction plan:
41 An excess cancer risk level of more than 100 in one million (from all sources). Chronic noncancer hazard index (from all local sources) greater than 10.0. 0.8 µg/m3 annual average PM2.5 (from all local sources).
38 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
39 Bay Area Air Quality Management District, January 5, 2017, Air Quality Standards and Attainment Status, http://www.baaqmd.gov/research-and-data/air-quality-standards-and-attainment-status#thirteen, accessed July 21, 2023. 40 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
41 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
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In February 2015, OEHHA adopted new health risk assessment guidance that includes several efforts to be more protective of children’s health. These updated procedures include the use of age sensitivity factors to account for the higher sensitivity of infants and young children to cancer-causing chemicals, and age- specific breathing rates.
42 Odor Impacts
BAAQMD’s thresholds for odors are qualitative based on BAAQMD’s Regulation 7, Odorous Substances.
This rule places general limitations on odorous substances and specific emission limitations on certain odorous compounds. In addition, odors are also regulated under BAAQMD Regulation 1, Rule 1-301, Public Nuisance, which states that no person shall discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance or annoyance to any considerable number of persons or the public; or which endangers the comfort, repose, health or safety of any such persons or the public, or which causes, or has a natural tendency to cause, injury or damage to business or property. Under BAAQMD’s Rule 1-301, a facility that receives three or more violation notices within a 30-day period can be declared a public nuisance. BAAQMD has established odor screening thresholds for land uses that have the potential to generate substantial odor complaints, including wastewater treatment plants, landfills or transfer stations, composting facilities, confined animal facilities, food manufacturing, and chemical plants.
43 For a plan-level analysis, BAAQMD requires:
Potential existing and planned locations of odor sources to be identified. Policies to reduce odors.
METHODOLOGY
Emissions Quantification
This air quality evaluation was prepared in accordance with the requirements of CEQA to determine if significant air quality impacts are likely to occur in conjunction with future development that would be accommodated by the proposed project. BAAQMD has published CEQA Guidelines that provide local governments with guidance for analyzing and mitigating air quality impacts and were used in this analysis.
The EIR Study Area’s criteria air pollutant emissions inventory includes the following sectors:
Transportation: Transportation emissions forecasts were modeled using emission rates from CARB’s EMFAC2021, version 1.0.2 web database. Model runs were based on Origin Destination (OD) Method using VMT data provided by W-Trans, calendar year 2019, and 2050 emission rates (see Chapter 4.15, Transportation, of this Draft EIR). VMT that have an origin or destination in the EIR Study Area use a transportation origin-destination methodology. Accounting of VMT is based on the recommendations
42 California Office of Environmental Health Hazard Assessment, February 2015, Air Toxics Hot Spots Program Risk Assessment Guidelines, https://oehha.ca.gov/media/downloads/crnr/2015guidancemanual.pdf, accessed July 21, 2023. 43 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
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of CARB’s Regional Targets Advisory Committee (RTAC) created under SB 375. For accounting purposes, there are three types of trips:
Internal-Internal. Vehicle trips that originated and terminated within the EIR Study Area (Internal- Internal, I-I). Using the accounting rules established by RTAC, 100 percent of the length of these trips and their emissions are attributed to the EIR Study Area. Internal-External/External-Internal. Vehicle trips that either originated or terminated (but not both) in the EIR Study Area (Internal-External or External-Internal, I-X and X-I). Using the accounting rules established by RTAC, 50 percent of the trip length for these trips is attributed to the EIR Study Area.
External-External. Vehicle trips that neither originated nor terminated in the EIR Study Area.
These trips are commonly called pass-through trips (External-External, X-X). Using the accounting rules established by RTAC, these trips are not counted toward the EIR Study Area's VMT or emissions.
Energy: Energy use for residential and nonresidential land uses in the EIR Study Area were modeled using natural gas data provided by PG&E and Sonoma Clean Power as part of the GHG Reduction Strategy (Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR and Appendix A, Greenhouse Gas Reduction Strategy, of the proposed General Plan 2050). Residential energy and non-residential energy forecasts are adjusted for increases in population and based on State actions energy forecasts conducted for the GHG Reduction Strategy. Off-Road Equipment: Emission rates from CARB’s OFFROAD2021, version 1.0.4, web database were used to estimate criteria air pollutant emissions from light commercial and construction equipment in the EIR Study Area. OFFROAD2021 is a database of equipment use and associated emissions for each county compiled by CARB. Emissions were compiled using OFFROAD2021 for the County of Sonoma for year 2019 and forecast based on the increase in agricultural acreage, housing permits, employment, and housing units as a percentage of Sonoma County. Area Sources: Area sources are based on the emission factors from the CalEEMod Users Guide for emissions generated from use of household consumer products and cleaning supplies.
IMPACTS OF THE ENVIRONMENT ON A PROJECT
BAAQMD’s CEQA Guidelines include methodology for jurisdictions wanting to evaluate the potential quantitative impacts from placing sensitive receptors proximate to major air pollutant sources as part of individual projects. For assessing community risk and hazards for siting a new receptor, sources within a 1,000-foot radius of a project site are typically considered. Sources are defined as freeways, high volume roadways, large distribution centers, and permitted sources. For plan-level impact determination such as this EIR, the analysis is limited to whether the plan has policies or overlay zones to reduce impacts. 44 44 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed July 21, 2023.
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Buildout under the proposed project could result in siting sensitive uses (e.g., residential) near sources of emissions (e.g., freeways, industrial uses, etc.). Developing new sensitive land uses near sources of emissions could expose people to potential air quality-related impacts. However, the purpose of this environmental evaluation is to identify the significant effects of the proposed project on the environment, not the significant effects of the environment on the proposed project, as determined by the California Supreme Court in California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369 (Case No. S213478). Thus, CEQA does not require analysis of the potential environmental effects from siting sensitive receptors near existing sources, and this type of analysis is not provided in the impact discussion below.
While it is generally not within the purview of CEQA to analyze impacts of the environment on a project, the proposed General Plan 2050 includes policy guidance which would ensure priority of the health of the city’s residents through enforcement of the municipal code and incorporation of design features to minimize air quality impacts and to achieve appropriate health standards. Chapter 2, Land Use and Economic Development, Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, and Chapter 6, Health, Equity, Environmental Justice, and Parks, of the proposed General Plan 2050 include the following goals, policies, and actions that would serve to protect sensitive receptors from poor air quality in the EIR Study Area:
Goal 2-1: Ensure that growth and change serve community needs, protect the environment, improve the City’s fiscal stability, and enhance quality of life for all members of the community. Policy 2-1.1: Ensure that growth and change serve community needs, protect the environment, improve the City’s fiscal stability, and enhance quality of life for all members of the community. Action 2-1.2: Work with developers to ensure new development respects the integrity and character of surrounding uses, especially when nonresidential uses are proposed adjacent to residential areas. Consider use of buffers, landscaping, and other types of screening to minimize noise, light, glare, and odor .
Goal 2-5: Create a business-friendly, diverse, and sustainable economy through the attraction of new business, and the expansion, retention, and support of existing business. Policy 2-5.1: Create a business-friendly, diverse, and sustainable economy through the attraction of new business, and the expansion, retention, and support of existing business. 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, focusing on areas away from sensitive receptors.
Goal 2-9: Create a business-friendly, diverse, and sustainable economy through the attraction of new business, and the expansion, retention, and support of existing business. Policy 2-9.3: Protect industrial land supply and ensure compatibility between industrial development and surrounding neighborhoods.
Action 2-9.4: Require industrial development adjacent to residential areas to provide buffers and institute setback, landscaping, and screening requirements intended to minimize noise, light, glare, and other impacts.
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Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.6: Identify and work with partners to address impacts from groundwater threats and solid waste.
Action 5-9.41: Identify solid waste and hazardous waste facilities that do not comply with standards for preventing contamination of air, water, and soil with hazardous waste, and work with owners to upgrade those facilities to meet those standards, prioritizing facilities in Equity Priority Areas.
Goal 6-1: Improve health and well-being for all community members by emphasizing community health in all City policies, programs, actions, and activities. Policy 6-1.1: Promote efforts to improve community health outcomes and ensure that City investments support community health goals.
Action 6-1.3: Collaborate with health service organizations, including Sonoma County Health and Human Services, to identify environmental risk factors for asthma, especially in Equity Priority Areas and areas where more than 10 percent of adults have asthma. *Action 6-1.5: As recommended by the California Air Resources Board, 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 (BAAQMD) CEQA Guidelines that identifies mitigation measures and appropriate enforcement mechanisms capable of reducing potential cancer and non-cancer risks below the BAAQMD threshold. *Action 6-1.6: 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 BAAQMD. The operational HRA shall 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 incremental cancer risk exceeds 10 in a million, the noncancer hazard index of 1.0, or the thresholds as determined by BAAQMD, 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.
Action 6-1.7: Require applicants for residential and/or other sensitive land use projects (e.g., hospitals, nursing homes, day care centers) to implement the best practices identified in the BAAQMD Planning Healthy Places Guidebook (Guidebook) where the site is located within the recommended screening distance of the Guidebook.
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Action 6-1.11: Update the Zoning Code to require health impact assessments for nonresidential projects of 100,000 square feet or more in Equity Priority Areas to identify and address any potential negative health implications of the project. Goal 6-2: Advance health equity by understanding and addressing key social determinants of health. Policy 6-2.4: Address conditions contributing to risk of asthma and adverse air quality. Action 6-2.11: Consult with Sonoma County Public Health Division as appropriate to reduce risk of asthma through land use planning and community programs.
4.3.3 IMPACT DISCUSSION
As described in Chapter 4.0, Environmental Analysis, of this Draft EIR, some proposed General Plan 2050 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 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.
AIR
-1 Implementation of the proposed project would not conflict with or obstruct implementation of the BAAQMD Clean Air Plan.
BAAQMD 2017 Clean Air Plan
The proposed project plays an important role in local agency project review by linking local planning and individual projects to the 2017 Clean Air Plan. It fulfills the CEQA goal of informing decision makers of the environmental efforts of the project under consideration at an early enough stage to ensure that air quality concerns are fully addressed. It also provides the local agency with ongoing information as to whether they are contributing to clean air goals in the Bay Area. As discussed in Section 4.3.2.1, BAAQMD Plan-Level Thresholds, BAAQMD requires a consistency evaluation of a proposed plan with the current AQMP control measures. In addition, proposed long-range plans must demonstrate if the project VMT or vehicle trip increase is less than or equal to the projected population increase.
The primary goals of the 2017 Clean Air Plan are to attain the National and California AAQS, reduce population exposure and protect public health in the Bay Area, and reduce GHG emissions and protect the climate. Furthermore, the 2017 Clean Air Plan lays the groundwork for reducing GHG emissions in the Bay Area to meet the State’s 2030 GHG reduction target and the long-term GHG reduction goals.
Attain Air Quality Standards
BAAQMD’s 2017 Clean Air Plan strategy is based on regional population and employment projections in the Bay Area compiled by ABAG, which are based in part on cities’ general plan land use designations.
These demographic projections are incorporated into Plan Bay Area. Demographic trends incorporated into Plan Bay Area determine VMT in the Bay Area, which BAAQMD uses to forecast future air quality SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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trends. The 2017 Clean Air Plan is based on data used in Plan Bay Area 2050. The SFBAAB is currently designated a nonattainment area for O3, PM2.5, and PM10 (California AAQS only).
As discussed in Chapter 4.13, Population and Housing, of this Draft EIR, the expected buildout under the proposed project would be able to accommodate the next three Regional Housing Needs Allocation (or RHNA) cycles and would not induce a substantial amount of unplanned population growth or growth for which inadequate planning has occurred. Additionally, the proposed project would result in an overall decrease in total VMT per service population compared to existing conditions (see Table 4.15-4, Daily VMT Performance Metrics for the EIR Study Area, in Chapter 4.15, Transportation, of this Draft EIR).
Chapter 2, Land Use and Economic Development, of the proposed General Plan 2050 also provides goals, policies, and actions that would serve to minimize potential adverse impacts related to growth in the EIR Study Area (see impact discussion POP-1 in Chapter 4.13 of this Draft EIR). Therefore, implementation of the proposed project would not introduce a substantial unplanned growth in population in the EIR Study Area and all potential future development would be required to comply with any required site-specific infrastructure improvements and to pay any project-specific impact fees.
As discussed in greater detail under impact discussion AIR-2, potential future development projects from implementation of the proposed project would be required to undergo their own project-specific CEQA environmental review. In determining whether an individual development project would be considered a project under CEQA that would have potentially significant impacts on local and regional air quality, including consideration of an individual development project’s contribution to an existing or forecasted air quality violation, BAAQMD recommends project-level significance thresholds for criteria pollutants and ozone precursors. Therefore, the population projections of the proposed project would be consistent with regional projections. The emissions resulting from potential future development associated with the proposed project are included in the BAAQMD projections, and future development accommodated under the proposed project would not hinder BAAQMD’s ability to attain the National or California AAQS.
Accordingly, this impact would be less than significant.
Reduce Population Exposure and Protect Public Health
Potential future development and activities from implementation of the proposed project could result in new sources of TACs and PM
2.5. Stationary sources, including smaller stationary sources associated with residential development (e.g., emergency generators and boilers), are subject to review by BAAQMD as part of the permitting process. Adherence to the BAAQMD permitting regulations would ensure that new stationary sources of TACs do not expose populations to significant health risk. Mobile sources of air toxics (e.g., truck idling) are not regulated directly by BAAQMD. However, residential development associated with the proposed project would not generate substantial truck traffic or idling. Furthermore, individual development projects would be required to achieve the project-level risk thresholds established by BAAQMD to ensure the sensitive receptor impact resulting from the subject development project would be less than significant.
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Reduce GHG Emissions and Protect the Climate
Consistency of the proposed project with State, regional, and local plans adopted for the purpose of reducing GHG emissions are discussed in Chapter 4.8, Greenhouse Gas Emissions, of this Draft EIR.
Potential future development under the proposed project would be required to adhere to statewide measures that have been adopted to achieve the GHG reduction targets of SB 32 and AB 1279, as outlined in the GHG Reduction Strategy (see Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR and Appendix A, Greenhouse Gas Reduction Strategy, of the proposed General Plan 2050), which updates the City’s Climate Action Plan. The proposed project is consistent with regional strategies for infill development identified in Plan Bay Area. Moreover, as discussed under impact discussion GHG-1 in Chapter 4.8 of this Draft EIR, the proposed project would meet legislative GHG emission reduction targets established under SB 32 and AB 1279 with implementation of the proposed GHG Reduction Strategy.
Therefore, the proposed project is consistent with the goal of the 2017 Clean Air Plan to reduce GHG emissions and protect the climate, and the impact would be less than significant. 2017 Clean Air Plan Control Measures
Table 4.3-8, Control Measures from the BAAQMD 2017 Clean Air Plan, identifies the control measures included in the 2017 Clean Air Plan that are required by BAAQMD to reduce emissions for a wide range of both stationary and mobile sources.
TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
Stationary
Source Control
Measures
SS 1 – Fluid Catalytic Cracking in
Refineries
SS 2 – Equipment Leaks
SS 3 – Cooling Towers
SS 4 – Refinery Flares
SS 5 – Sulfur Recovery Units
SS 6 – Refinery Fuel Gas
SS 7 – Sulfuric Acid Plants
SS 8 – Sulfur Dioxide from Coke
Calcining
SS 9 – Enhanced NSR Enforcement
for Changes in Crude Slate
SS 10 – Petroleum Refining
Emissions Tracking
SS 11 – Petroleum Refining Facility-
Wide Emission Limits
SS 12 – Petroleum Refining Climate
Impacts Limit
SS 13 – Oil and Gas Production,
Processing and Storage
SS 14 – Methane from Capped Wells
SS 15 – Natural Gas Processing and
Distribution
SS 16 – Basin-Wide Methane
Strategy
SS 17 – GHG BACT Threshold
SS 18 – Basin-Wide Combustion
Strategy
Stationary and area sources are regulated directly by
BAAQMD; therefore, as the implementing agency, new
stationary and area sources in the EIR Study Area would be required to comply with BAAQMD regulations. BAAQMD
routinely adopts/revises rules or regulations to implement the stationary source (SS) control measures to reduce stationary source emissions. Based on the new development
under the
proposed project, implementation of the proposed project would not hinder the ability of BAAQMD to implement these SS control measures. Major stationary sources are more
commonly associated with industrial manufacturing or
warehousing. However, BAAQMD and the City have existing regulations in place to ensure potential future development under the proposed project would not conflict with the
applicable SS control measures. Nonresidential land uses may generate small quantities of stationary source emissions during project operation (e.g., emergency generators, dry cleaners, and gasoline dispensing facilities); however, these small- quantity generators would require review by BAAQMD for
permitted sources of air toxics, which would ensure
consistency with the 2017 Clean Air Plan.
The proposed project involves residential and commercial uses that would not include major stationary sources of emissions.
Boilers and emergency generators for multifamily residential products would be required to follow BAAQMD’s permitting requirements.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
SS 19 – Portland Cement
SS 20 – Air Toxics Risk Cap and
Reduction from Existing Facilities
SS 21 – New Source Review for
Toxics
SS 22 – Stationary Gas Turbines
SS 23 – Biogas Flares
SS 24 – Sulfur Content Limits of
Liquid Fuels
SS 25 – Coatings, Solvents,
Lubricants, Sealants and Adhesives
SS 26 – Surface Prep and Cleaning
Solvent
SS 27 – Digital Printing
SS 28 – LPG, Propane, Butane
SS 29 – Asphaltic Concrete
SS 30 – Residential Fan Type
Furnaces
SS 31 – General Particulate Matter
Emission Limitation
SS 32 – Emergency Backup
Generators
SS 33 – Commercial Cooking
Equipment
SS 34 – Wood Smoke
SS 35 – PM from Bulk Material
Storage, Handling and Transport,
Including Coke and Coal
SS 36 – PM from Trackout
SS 37 – PM from Asphalt Operations
SS 38 – Fugitive Dust
SS 39 – Enhanced Air Quality
Monitoring
SS 40 – Odors
Transportation
Control
Measures
TR 1 – Clean Air Teleworking
Initiative
TR 2 – Trip Reduction Programs
TR 3 – Local and Regional Bus
Service
TR 4 – Local and Regional Rail
Service
TR 5 – Transit Efficiency and Use
TR 6 – Freeway and Arterial
Operations
TR 7 – Safe Routes to Schools and
Safe Routes to Transit
TR 8 – Ridesharing, Last-Mile
Connection
TR 9 – Bicycle and Pedestrian Access
and Facilities
TR 10 – Land Use Strategies
TR 11 – Value Pricing
TR 12 – Smart Driving
Transportation (TR) control measures are strategies to reduce vehicle trips, vehicle use, VMT, vehicle idling, and traffic congestion for the purpose of reducing motor vehicle
emissions. Although most of the TR control measures are implemented at the regional level—that is, by MTC or
Caltrans—the 2017 Clean Air Plan relies on local communities to assist with implementation of some measures.
Potential future development over the buildout horizon of the proposed project would be reviewed based on the goals,
policies, and actions of the proposed General Plan 2050.
Chapter 3, Circulation, Open Space, Conservation, and
Greenhouse Gas Reduction, contains the following goals, policies, and actions to expand the pedestrian and bicycle network:
Goal 3-1: Provide an integrated land use and transportation system with safe and efficient movement of people and
goods for all modes of travel that prioritizes reduction of VMT and transportation-related GHG emissions.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
TR 13 – Parking Policies
TR 14 – Cars and Light Trucks
TR 15 – Public Outreach and
Education
TR 16 – Indirect Source Review
TR 17 – Planes
TR 18 – Goods Movement
TR 19 – Medium and Heavy-Duty
Trucks
TR 20 – Ocean Going Vessels
TR 21 – Commercial Harbor Craft
TR 22 – Construction, Freight and
Farming Equipment
TR 23 – Lawn and Garden
Equipment
Policy 3-1.2: Promote a citywide mode shift away from single-occupancy vehicles to support ambitious VMT
and GHG reduction goals.
Action 3-1.5: Develop a process that invests in and
prioritizes non-automobile modes of transportation in
capital improvement projects to reduce VMT and
GHGs, prioritizing, in order:
Active transportation modes, including walking,
bicycling, and rolling.
Public transportation, including inter-city and
regional systems.
Other shared vehicles such as carpool, vanpool,
and rideshare/transportation network companies.
Action 3-1.11: Update the Zoning Code to discourage
cul-de-sac design and require any new developments
with cul-de-sacs or other limited street connectivity
layouts to provide enhanced connectivity for
pedestrians and bicyclists to sites adjacent to or
behind the new developments.
Action 3-1.13: Work with developers in the beginning
phases of project conception to install Class I and
Class IV bicycle lanes, wherever feasible.
Goal 3-2: Provide a safe and accessible active and public transportation network that emphasizes active
transportation connections and service to Equity Priority Areas and Areas of Change.
Policy 3-2.1: Ensure that the active transportation
network remains in good condition by maintaining
facilities, tracking the state of infrastructure, and
managing the network in a way that serves all users.
Action 3-2.2: Use mapping to identify gaps in the
active transportation network, and complete those
gaps, except where it may be infeasible due to lack of
City right-of way.
Action 3-2.4: Improve connections in the active
transportation network to ensure that all who choose
to walk, roll, or ride have adequate access to public
transportation amenities, especially in Equity Priority Areas and Areas of Change.
Action 3-2.6: Ensure that major arterials have active transportation infrastructure that accommodates all
road users and does not present a barrier to regional
travel for any mode.
Action 3-2.7: Improve active transportation crossings of major transportation barriers, such as the SMART
rail lines, Highway 101, and Highway 12.
Policy 3-2.2: Continue to expand and improve the active transportation network toward completing a safe,
continuous, convenient, and attractive network of
designated routes that connect all neighborhoods and
that is equitably accessible for all ages and abilities.
1. 2.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
Action 3-2.12: Identify and analyze arterial corridors and improve them by preparing and implementing
corridor plans to address all transportation modes,
specifically active transportation, focusing on
separated or protected facilities for all ages and
abilities.
Action 3-2.13: Ensure that there are no physical
barriers to bicyclists or pedestrians as they cross high traffic roadways at intersections of Class I or Class IV facilities through improvements such as crosswalks
and beacon lights.
Action 3-2.18: Prioritize addressing active
transportation deficiencies in Equity Priority Areas.
Energy and
Climate
Control
Measures
EN 1 – Decarbonize Electricity
Production
EN 2 – Renewable Energy Decrease
Electricity Demand
The energy and climate (EN) control measures are intended to reduce energy use as a means to reducing adverse air quality emissions. Potential future
development over the buildout
horizon of the proposed project would be reviewed based on the goals, policies, and actions of the proposed General Plan 2050. The proposed Chapter 2, Land Use and Economic
Development, and Chapter 3, Circulation, Open Space,
Conservation, and Greenhouse Gas Reduction, contain the following goal, policies, and actions that align with the City’s goals to reduce energy use:
Goal 3-7: Strive to achieve net carbon neutrality no later than 2045.
Policy 3-7.2: Reduce energy use and increase energy
efficiency in existing and new residential, commercial, industrial, and public structures.
Action 3-7.11: Use education and incentives to
promote and sustain energy-conserving design and
practices.
Policy 3-7.3: Increase the use of renewable, carbon-free, and distributed energy resources throughout the city.
Action 3-7.14: Participate in State and local efforts to develop appropriate policies and review procedures
for the installation of photovoltaic solar and other
forms of distributed energy generation.
Action 3-7.15: Continue to participate in utility-
sponsored renewable energy programs that allow the
city to receive a significant portion of energy from
renewable sources.
Action 3-7.16: Seek and identify resources to assist
low-income homeowners and small business owners
with identifying financing options for installation of
rooftop solar energy systems, energy storage, and
electrification of existing buildings.
Action 3-7.17: Support the development of local-
serving renewable energy projects that expand the
availability of local renewable energy, provide
sustainable local jobs, and support local and regional
housing, economic development, and sustainability
goals and initiatives.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
Furthermore, new developments accommodated under the
proposed project would be built to comply with the latest Building Energy Efficiency Standards and CALGreen standards.
Therefore, implementation of the proposed project would not conflict with these EN control measures.
Buildings
Control
Measures
BL 1 – Green Buildings
BL 2 – Decarbonize Buildings
BL 3 – Market-Based Solutions
BL 4 – Urban Heat Island Mitigation
The buildings (BL) control measures focus on working with local governments to facilitate adoption of best GHG emissions control practices and policies. Potential future
development
over the buildout horizon of the proposed project would be reviewed based on the goals, policies, and actions of the proposed General Plan 2050. Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, and
Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, contain the following goals, policies, and actions to promote energy efficiency and sustainability:
Goal 3-7: Strive to achieve net carbon neutrality no later than 2045.
Policy 3-7.2: Reduce energy use and increase energy
efficiency in existing and new residential, commercial, industrial, and public structures.
Action 3-7.5: Require regular energy audits of existing City-owned and operated structures, identifying
levels of existing energy use and potential
conservation and efficiency measures.
Action 3-7.7: Provide information on the cost-savings potential and other benefits of energy audits and
energy-efficient retrofits to encourage their
preparation for buildings throughout the city.
Action 3-7.8: Guide project applicants toward site
planning, solar orientation, cool roofs, and
landscaping that decrease summer cooling and
winter heating needs.
Action 3-7.9: Identify incentives to encourage new
buildings to exceed State energy efficiency
requirements and/or meet or exceed the U.S. Green
Building Council’s LEED (Leadership in Energy and
Environmental Design) Program or equivalent
standards.
Policy 3-7.3: Reduce the use of fossil fuels as an energy source in new and existing buildings.
Action 3-7.18: Encourage the establishment of
neighborhood renewable energy microgrids to
support resilience.
Action 3-7.19: Support State and utility efforts to
improve grid resilience and capacity.
Policy 3-7.4: Reduce the use of fossil fuels as an energy source in new and existing buildings.
Action 3-7.21: Evaluate and adopt changes to the
building code or other municipal codes and policies
to decarbonize the building stock while also
maximizing energy efficiency.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
Action 3-7.22: Amend the building or energy code to
incentivize building owners to upgrade residential
appliances, including water and space heaters, to
increase energy efficiency and reduce GHG
emissions.
Action 3-7.23: Develop new and retrofit existing City facilities to be zero net energy.
Action 3-7.24: Continue to update the Building Code,
consistent with State law, to increase the use of low-
carbon construction materials.
Policy 3.7-5: Continue the City’s role as a leader in sustainability and climate action.
Action 3-7.27: Continue using 100 percent renewable
electricity for all City buildings.
Goal 5-6: Ensure Santa Rosa is a resilient city able to adapt to, recover from, and thrive under changing climate
conditions.
Policy 5-6.4: Encourage collaboration among City
departments and with nonprofit organizations to create
a network of equitably located resilience centers
throughout the city.
Action 5-6.10: Seek funding to upgrade existing
warming and cooling centers to offer refuge from
extreme heat events and poor air quality due to
regional wildfire smoke and be equipped with
renewable energy generation and backup power
supplies.
Action 5-6.11: Continue to provide backup power and
emergency supplies at critical City facilities,
emergency shelters, community resilience centers,
and cooling centers in case of power and water
outages. Transition to carbon-free backup power
sources as available and appropriate.
In addition, as stated, potential development over the buildout horizon of the proposed project would be built to comply with the latest Building Energy Efficiency Standards and CALGreen standards. Thus, the proposed project would not conflict with these BL control measures.
Agriculture
Control
Measures
AG 1 – Agricultural Guidance and
Leadership
AG 2 – Dairy Digesters
AG 3 – Enteric Fermentation
AG 4 – Livestock Waste
Agricultural practices in the Bay Area account for a small portion, roughly 1.5 percent, of the Bay Area GHG emissions inventory. The GHGs from agriculture include methane and nitrous oxide, in addition to carbon dioxide. While the Agriculture (AG) control measures target larger scale farming practices that are not included in
the proposed project, the
potential development under the proposed project does not constitute any sites that currently host commercial agricultural operations. Therefore, implementation of the proposed
project would not conflict with these AG control measures.
Natural and
Working Lands
Control
Measures
NW 1 – Carbon Sequestration in
Rangelands
NW 2 – Urban Tree Planting
NW 3 – Carbon Sequestration in
Wetlands
The control measures for the natural and working lands sector focus on increasing carbon sequestration on rangelands and wetlands. Potential future
development over the buildout
horizon of the proposed project would be reviewed based on the goals, policies, and actions of the proposed General Plan SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
2050. Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, and Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, contain the following goals, policies, and actions to promote carbon sequestration:
Goal 3-5: Protect, expand, maintain, and restore natural resources, open space, and the limited remaining
agricultural land.
Policy 3-5.1: Maximize the benefits of open space,
including by supporting passive recreation and
conservation.
Action 3-5.1: Give priority to multi-benefit
recreational projects that maximize pollution
reduction and adaptation, carbon sequestration,
heat-island reduction, stormwater capture that
increases infiltration, habitat protection and
biodiversity, and/or community health
improvements.
Policy 3-5.3: Conserve and protect creeks, wetlands,
vernal pools, wildlife ecosystems, rare plant habitats, and waterways from development.
Action 3-4.5: 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 restoration or
creation.
Action 3-5.6: Protect high-quality wetlands and
vernal pools from development and other activities.
Action 3-5.8: Inventory wetlands, floodplains,
marshlands, and adjacent lands that could potentially
support climate adaptation (e.g., through flood
management, filtration, or other beneficial
ecosystem services) and mitigation (e.g., carbon
sequestration).
*Action 3-5.10: 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
Policy 3-5.4: Use existing (and/or restore historical) natural features and ecosystem processes for
conservation, preservation, or sustainable management
of open space, including, but not limited to, aquatic or terrestrial vegetated open space, systems that provide
clean water, conserve ecosystem values and functions,
and provide a wide array of benefits to people and
wildlife.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
*Action 3-5.11: Require a qualified biologist to
prepare a biological resource assessment 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.
Goal 3-6: Use nature- and science-based strategies to preserve and create environments that provide ecosystem benefits.
Policy 3-6.8: Capture and sequester more carbon in soils and plants citywide.
Action 3-6.21: Conduct a carbon sequestration
feasibility study of City-owned open space, parks,
agricultural lands, and conservation lands, and
implement the recommendations as feasible.
Action 3-6.22: Conduct carbon sequestration farming
pilot projects and research as part of ongoing
ecological restoration of degraded habitats.
Action 3-6.23: Work with the County to support the
implementation of forest management practices that
protect existing carbon stocks by reducing the risk of
catastrophic wildfire. At the same time, support
activities such as mulching in place, prescribed fire,
conservation burns, and off-site uses, including
compost and mulch production.
Action 3-6.24: Work with regional partners on
strategic land protection and stewardship actions
that increase carbon sequestration, minimize
conversion to land uses that have a lower capacity to
sequester carbon, and preserve contiguous open
space areas to better protect ecosystems that are
under pressure from a changing climate, allowing
greater mobility of species.
Action 3-6.27: Coordinate with the County and
private landowners to support local agricultural
producers to plan, implement, and scale natural
carbon sequestration.
Action 3-6.29: Amend the composting ordinance to
advance compost infrastructure and support soil
carbon sequestration activities.
Goal 5-6: Ensure Santa Rosa is a resilient city able to adapt to, recover from, and thrive under changing climate
conditions.
Policy 5-6.5: Support the preservation and restoration of natural landscapes to reduce the heat island effect,
improve air quality, and improve community health.
Action 5-6.15: Increase the city’s urban tree canopy, starting with Equity Priority Areas, and expand urban
greening throughout the city to reduce the heat
Island effect.
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Action 5-6.16: Seek resources to conduct a
community-wide tree canopy assessment to quantify
how much of the City’s land area is covered by trees,
including streets with street tree canopy cover;
identify the location of those trees; and identify
opportunities to plant trees.
Action 5-6.18: Work with the Water Team and
Master Gardeners to refine guidelines on specific
tree species and management procedures that
integrate carbon sequestration, ecosystems services,
and biodiversity.
Action 5-6.23: Seek resources to create and regularly update an Urban Greening Plan to increase the urban
tree canopy, open spaces, and green roofs to reduce
the heat island effect, giving priority to areas of the city with vulnerable populations.
Action 5-6.24: Explore incentives for shading
features, such as large eaves and cantilevers on
south- and west-facing walls to reduce air
conditioning requirements and heat island effects
that contribute to the entire community's reduced
quality of life, but especially those living in high-
density, low-income neighborhoods.
Water Control
Measures
WR 1 – Limit GHGs from publicly
owned treatment works (POTWs)
WR 2 – Support Water Conservation
The 2017 Clean Air Plan includes measures to reduce water use. Potential future development over the buildout horizon of the proposed project would be reviewed based on the goals, policies, and actions of the proposed General Plan 2050.
Chapter 5, Safety, Climate Resilience, Noise, and Public Services and Facilities, contains the following goal, policies, and actions to increase plumbing water efficiency and reduce landscape water use:
Goal 5-9: Provide adequate and high-quality city services for water, wastewater, recycled water, stormwater, and solid waste.
Policy 5-9.1: Ensure water quality, water service delivery, and wastewater treatment are sufficient to meet the
needs of current and future residents.
Action 5-8.3: Maintain water, wastewater, and
recycled water system integrity and capacity by
continuing to prioritize maintenance and preserve
funding for maintenance, rehabilitation, and
replacement of existing infrastructure.
Action 5-8.4: Evaluate cost and other implications of new initiatives to avoid impacting funding and
resources needed for proper management of existing
infrastructure.
Action 5-8.5: Ensure that new programs and
infrastructure do not impact funding of existing
infrastructure maintenance, rehabilitation, and
replacement.
Policy 5-9.2: Maintain water quality and encourage Santa Rosa Water customers to save water.
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TABLE 4.3-8 CONTROL MEASURES FROM THE BAAQMD 2017 CLEAN AIR PLAN Type Measure Number / Title Consistency
Action 5-9.13: Require new development projects to
provide water-efficient landscaping in accordance
with the City’s Water Efficient Landscape Ordinance.
Action 5-9.14: Continue to comply with statewide
regulations for long- term urban water use efficiency.
Action 5-9.15: Promote water efficiency through
public education, incentives, rebates, technical
assistance, customer programs, and information
about indoor and outdoor water use efficiency
measures.
Action 5-9.16: Provide information and explore
incentive opportunities to encourage property
owners to install catchment, graywater systems, and
other water recycling systems; remove paving; and
install low-impact development features, such as
permeable pavers, bioswales, and other green
infrastructure components.
Super-GHG
Control
Measures
SL 1 – Short-Lived Climate Pollutants
SL 2 – Guidance for Local Planners
SL 3 – GHG Monitoring and
Emissions Measurements Network
Super-GHGs include methane, black carbon, and fluorinated gases. The compounds are sometimes referred to as short- lived climate pollutants because their lifetime in the
atmosphere is generally fairly short. Measures to reduce super GHGs are addressed on a sector-by-sector basis in the 2017 Clean Air Plan.
Through ongoing implementation of the City’s
GHG Reduction Strategy, the City will continue to reduce local GHG emissions and meet State, regional, and local reduction targets, which would ensure implementation of the proposed project would not conflict with these SL control measures.
Potential future development over the buildout horizon of the proposed project would be reviewed based on the goals,
policies, and actions of the proposed General Plan 2050.
Chapter 2, Land Use and Economic Development, and Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, contains the following goals, policies, and actions for encouraging use of renewable energy:
Goal 2-3: Create dense and varied housing types near
transit to reduce greenhouse gas emissions and promote
livability.
Goal 3-7: Strive to achieve net carbon neutrality no later than 2045.
Policy 3-7.1: Significantly reduce community- wide and municipal GHG emissions, achieving at least an 85
percent reduction of GHG emissions from community
sources below 1990 levels by no later than 2045 with a
commitment to accelerate reductions, as feasible, in
support of the City’s and State’s carbon neutrality goals.
Action 3-7.2: Implement the actions in the GHG
Reduction Strategy to achieve the City’s GHG
reduction goals.
Action 3-7.3: Continue regular inventories of
community-wide and municipal GHG emissions, at
least every five years, consistent with the GHG
Reduction Strategy and this General Plan.
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Action 3-7.4: Provide public information to educate
residents and businesses on the GHG Reduction
Strategy and to support individual changes in energy
and water use, transportation mode choices, material
use, and waste reduction.
Policy 3.7-5: Continue the City’s role as a leader in sustainability and climate action.
Action 3-7.25: Continue to enhance the City’s ability to optimize energy use, minimize energy costs,
prepare for emergencies, and power provider
outages, protect public health, sustain natural
resources, and reduce municipal GHG emissions
Action 3-7.26: Enhance efforts to reduce GHG
emissions in municipal operations after
understanding the scope, effectiveness, and resource
commitments of existing GHG reduction initiatives.
Action 3-7.28: Integrate GHG emissions reduction
and climate resilience into all municipal projects,
policies, and procedures as applicable.
Further Study
Control
Measures
FSM SS 1 – Internal Combustion
Engines
FSM SS 2 – Boilers, Steam Generator
and Process Heaters
FSM SS 3 – GHG Reductions from
Non Cap-and Trade Sources
FSM SS 4 – Methane Exemptions
from Wastewater Regulation
FSM SS 5 – Controlling start-up,
shutdown, maintenance, and
malfunction (SSMM) Emissions
FSM SS 6 – Carbon Pollution Fee
FSM SS 7 – Vanishing Oils and Rust
Inhibitors
FSM SS 8 – Dryers, Ovens and Kilns
FSM SS 9 – Omnibus Rulemaking to
Achieve Continuous Improvement
FSM BL 1 – Space Heating
FSM AG 1 – Wineries
The majority of the further study control measures apply to sources regulated directly by BAAQMD. Because BAAQMD is the implementing agency, new and existing sources of
stationary and area sources in the EIR Study Area
would be
required to comply with these additional further study control measures in the 2017 Clean Air Plan.
Source: Bay Area Air Quality Management District, April 19, 2017, Final 2017 Clean Air Plan, Spare the Air, Cool the Climate: A Blueprint for Clean Air and Climate Protection in the Bay Area, https://www.baaqmd.gov/~/media/files/planning-and-research/plans/2017-clean-air-plan/attachment-a_- proposed-final-cap-vol-1-pdf.pdf?la=en, accessed July 21, 2023.
As shown in Table 4.3-8, the proposed project would not conflict with the 2017 Clean Air Plan and would not hinder BAAQMD from implementing the control measures in the 2017 Clean Air Plan. Accordingly, this impact would be less than significant.
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Regional Growth Projections for VMT and Population
As previously discussed, one of the criteria for determining consistent with the current AQMP is comparing the proposed project’s VMT growth with its population growth over the same planning horizon. Consistency with BAAQMD’s AQMP requires that the VMT increase by less than or equal to the projected population increase from the proposed project (e.g., generate the same or less VMT per population). However, because the proposed project accommodates both residential and nonresidential growth, a better indicator of how efficiently the city is growing can be made by comparing the increase in VMT to the increase in service population (e.g., generate the same or less VMT per service population).
This approach is similar to the efficiency metrics for GHG emissions, which consider the total service population when calculating project efficiency.
VMT for the proposed project was evaluated to estimate the weekday citywide VMT generation for the proposed project in the Baseline Year (2019) No Project and Cumulative Year (2050) with Project scenarios (see Chapter 4.15, Transportation, of this Draft EIR for a more detailed VMT discussion). Table 4.3-9, Comparison of the Change in Population and Daily VMT in the EIR Study Area, displays the Baseline Year (2019) No Project and Cumulative Year (2050) with Project estimates.
TABLE 4.3-9 COMPARISON OF THE CHANGE IN POPULATION AND DAILY VMT IN THE EIR STUDY AREA Category
Base Year
(2019)
Cumulative Year
(2050)
Change from Existing
Change Percent
Service Population a 275,569 355,425 79,856 29%
Daily VMT b 2,229,977 2,745,678 515,701 23%
VMT/Service Population c 8.1 7.7 -0.4 -5%
Notes:
a. Service Population accounts for total population and jobs. See Table 3-6, Proposed 2050 Buildout Projections in the EIR Study Area, in Chapter 3, Project Description, of this Draft EIR.
b. W-Trans, 2023. VMT modeled by W-Trans is conservative because it assumed slightly higher population and employees. VMT identified in this table is consistent with the accounting recommendations of CARB’s RTAC created under SB 375 (see Methodology above) and is not the same as accounting for VMT under SB 74.
c. Daily per Capita VMT estimates are identified by dividing the Daily VMT estimates by the City Population for the corresponding year. It should be noted that the Daily per capita VMT estimates above do not necessarily reflect VMT by each resident as the total Daily VMT estimates include nonresidential VMT.
Source: W-Trans, 2023; PlaceWorks, 2023.
VMT estimates based on data provided by W-Trans were calculated for the EIR Study Area. As shown in Table 4.3-9, implementation of the proposed project would result in an increase for daily VMT by 515,701 vehicle miles per day45 in the EIR Study Area (about 23 percent increase) but lead to a lower VMT per service population than existing conditions (approximately 5 percent decrease). Thus, the proposed project would be consistent with the goals of the 2017 Clean Air Plan and this impact would be less than significant.
45 VMT identified in this table is consistent with the accounting recommendations of CARB’s RTAC created under SB 375 (see Methodology above) and is not the same as accounting for VMT under SB 743.
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Environmental Justice
BAAQMD’s CEQA Air Quality Guidelines also require an analysis of consistency of the proposed project with applicable Community Emission Reduction Plans and local environmental justice policies.
Environmentally overburdened, underserved, and economically distressed communities may be subject to a higher risk of pollutant-related health effects than the general population because they may be exposed to higher pollutant concentrations; they may experience a larger health impact at a given pollutant concentration; or they may be adversely affected by lower pollutant concentrations than the general population. The most critical air pollutant affecting health in the SFBAAB is PM
2.5, which includes DPM.
The burden of breathing unhealthy air is often disproportionately borne by low-income communities and communities of color, many of which are situated closer to busy highways, ports, factories, and other pollution sources.
46 Chapter 6, Health, Equity, Environmental Justice, and Parks, of the proposed General Plan 2050 integrates goals, policies, and actions to lessen the environmental burden on disadvantaged populations. The process to develop environmental justice policy guidance involved extensive discussions and many meetings with community members and other stakeholders who live in, work in, or engage with communities that are most impacted by environmental justice issues to ensure the plan directly responds to the specific needs of EPAs. Furthermore, the City has launched work with an equity and organizational development consulting team (Seed Collaborative) that will collaborate directly with City staff to develop a comprehensive work plan to establish a lasting culture of equity and belonging. 47 The proposed General Plan 2050 Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, Chapter 4, Urban Design, Cultural and Tribal Cultural Resources, Historic Preservation, and Art and Culture, and Chapter 6, Health, Equity, Environmental Justice, and Parks, include broad policy guidance for environmental justice that require local planning and development decisions to help address vulnerabilities in EPAs. In addition to the proposed General Plan 2050 goals, policies, and actions listed in Section 4.3.2.3, Impacts of the Environment on a Project, the following proposed goals, policies, and actions would serve to reduce and/or avoid environmental effects on vulnerable populations:
Goal 3-2: Provide a safe and accessible active and public transportation network that emphasizes active transportation connections and service to Equity Priority Areas and Areas of Change. Policy 3-2.1: Ensure that the active transportation network remains in good condition by maintaining facilities, tracking the state of infrastructure, and managing the network in a way that serves all users.
Action 3-2.4: Improve connections in the active transportation network to ensure that all who choose to walk, roll, or ride have adequate access to public transportation amenities, especially in Equity Priority Areas and Areas of Change.
46 Bay Area Air Quality Management District, 2022, Best Practices for Centering Environmental Justice, Health, and Equity, https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines-2022/ ceqa-guidelines-chapter-2-environmental-justicefinal-pdf.pdf?la=en, accessed June 1, 2023. 47 City of Santa Rosa, Equity SR, https://www.srcity.org/3610/Equity-SR, accessed July 27, 2023.
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Policy 3-2.2: Continue to expand and improve the active transportation network toward completing a safe, continuous, convenient, and attractive network of designated routes that connect all neighborhoods and that is equitably accessible for all ages and abilities. Action 3-2.18: Prioritize addressing active transportation deficiencies in Equity Priority Area. Goal 3-3: Transition away from single-occupancy vehicles. Policy 3-3.6: Ensure that the transit system serves all members of the community equitably, especially in Equity Priority Areas.
Goal 4-1: Preserve and enhance Santa Rosa’s community character through attractive urban and environmental design and intentional development.
Policy 4-1.5: Create public/civic spaces at the neighborhood, city, and regional scale to serve residents of all areas of the city, and particularly Equity Priority Areas where these spaces provide vital resources for vulnerable populations.
Goal 6-1: Improve health and well-being for all community members by emphasizing community health in all City policies, programs, actions, and activities. Policy 6-1.1: Promote efforts to improve community health outcomes and ensure that City investments support community health goals.
Action 6-1.9: Provide training for City staff and officials about how the built environment and transportation choices affect health equity, economic opportunity, well-being, and quality of life.
Action 6-1.10: Create healthy development guidelines or checklists to track and monitor how new developments are incorporating health-promoting features such as opportunities for physical activity, healthy food, drinking water, urban farming, affordable housing, and sustainable design.
Goal 6-2: Advance health equity by understanding and addressing key social determinants of health. Policy 6-2.1: Promote awareness of the role of social determinants of health and health inequities, and ensure that City policies, services, and programs can improve the lives and well- being of everyone in the community, especially in Equity Priority Areas and among Equity Priority Populations at a higher risk for health inequities.
The proposed project includes measures to reduce emissions and improve community health within Overburdened Communities consistent with BAAQMD’s environmental justice goals. Thus, the proposed project would be consistent with BAAQMD’s environmental justice goals, and the impact would be less than significant.
Significance without Mitigation: Less than significant.
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AIR-2 Implementation of the proposed project could result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard.
The proposed General Plan 2050 guides growth within the EIR Study Area by designating land uses and implementing goals, policies, and actions. New development would increase air pollutant emissions in the EIR Study Area and contribute to the overall emissions inventory in the SFBAAB. A discussion of health effects associated with air pollutant emissions generated by operational activities is included in Section
4.3.1.2, Air Pollutants of Concern.
Construction
The proposed project would not directly result in construction of any development or infrastructure; however, future development under the proposed project would result in short-term construction-related criteria pollutant emissions that have the potential to have an adverse effect on air quality. Short-term criteria pollutant emissions would occur during demolition, site preparation, grading, building construction, paving, and architectural coating activities associated with individual development projects.
ROG and NO
X emissions are primarily associated with gasoline and diesel equipment exhaust and the application of architectural coatings. Fugitive dust emissions (PM10 and PM2.5) are primarily associated with site preparation and vary as a function of such parameters as soil silt content, soil moisture, wind speed, acreage of disturbance area, and VMT by construction vehicles on- and off-site. Typical construction equipment associated with development and redevelopment projects includes dozers, graders, excavators, loaders, and trucks.
Although the exact coverage, location, or duration of future construction projects is unknown at the time of preparation of this program-level EIR, future development activities would generally entail demolition, site preparation, grading, building construction, paving, and painting. As discussed in Chapter 3, Project Description, of this Draft EIR, potential future development from implementation of the proposed project is expected to occur in the proposed General Plan 2050 Areas of Change and would be concentrated in the form of infill/intensification on sites either already developed and/or underutilized and/or in close proximity to existing development. Accordingly, many new projects in the EIR Study Area will likely require the demolition of existing structures to make room for newer ones. Fugitive dust emissions would typically be greatest during building demolition, site preparation, and grading activities due to the disturbance of soils and transport of material. NO
X emissions would also result from the combustion of
diesel fuels used to power off-road heavy-duty vehicles and equipment (e.g., backhoes, bulldozers, excavators). The types and quantities of equipment as well as duration of construction activities would be dependent on project-specific conditions. Larger developments would require more equipment over a longer time frame than that required for redevelopment of a single, residential home.
BAAQMD does not recommend plan-level thresholds of significance for construction emissions; however, BAAQMD does maintain and recommend project-level thresholds of significance for construction emissions that future development projects facilitated by the proposed project would be subject to. In addition, BAAQMD’s CEQA Air Quality Guidelines identify and recommend a series of “Basic” measures to SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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control and reduce construction-related fugitive dust emissions. For all project, BAAQMD recommends implementation of Basic Construction Measures to reduce construction fugitive dust and determines a project’s fugitive dust impacts during construction to be less than significant if the Basic Construction Measures are incorporated into project construction. BAAQMD Basic Control Measures for fugitive dust control48 include:
Water all active construction areas at least twice daily, or as often as needed to control dust emissions. Watering should be sufficient to prevent airborne dust from leaving the site. Increased watering frequency may be necessary whenever wind speeds exceed 15 miles per hour . Reclaimed water should be used whenever possible.
Pave, apply water twice daily or as often as necessary to control dust, or apply (nontoxic) soil stabilizers on all unpaved access roads, parking areas, and staging areas at construction sites. Cover all trucks hauling soil, sand, and other loose materials or require all trucks to maintain at least 2 feet of freeboard (i.e., the minimum required space between the top of the load and the top of the trailer).
Sweep daily (with water sweepers using reclaimed water if possible) or as often as needed all paved access roads, parking areas, and staging areas at the construction site to control dust. Sweep public streets daily (with water sweepers using reclaimed water if possible) in the vicinity of the project site, or as often as needed, to keep streets free of visible soil material. Hydroseed or apply nontoxic soil stabilizers to inactive construction areas. Enclose, cover, water twice daily, or apply nontoxic soil binders to exposed stockpiles (dirt, sand, etc.). Limit vehicle traffic speeds on unpaved roads to 15 miles per hour . Replant vegetation in disturbed areas as quickly as possible.
Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, of the proposed General Plan 2050 includes goals, policies, and actions that require local planning and development decisions to consider impacts from emissions and to reduce those emissions. The following goal, policy, and actions would ensure compliance with BAAQMD requirements:
Goal 3-6: Use nature- and science-based strategies to preserve and create environments that provide ecosystem benefits.
Policy 3-6.9: Achieve and maintain ambient air quality standards. *Action 3-6.31: Require projects that exceed the Bay Area Air Quality Management District (BAAQMD) screening sizes to evaluate project-specific operation and construction emissions in conformance with the BAAQMD methodology and if operation or construction-related criteria air pollutants exceed the BAAQMD thresholds of significance, require the project applicant to mitigate the impacts to an acceptable level.
48 BAAQMD’s current CEQA Guidelines can be found on their website: https://www.baaqmd.gov/plans-and- climate/california-environmental-quality-act-ceqa
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*Action 3-6.32: Continue to implement the Bay Area Air Quality Management District (BAAQMD) Basic Control Measures included in the latest version of BAAQMD’s CEQA Air Quality Guidelines to control fugitive dust (i.e., particulate matter PM2.5 and PM10) during demolition, ground-disturbing activities, and/or construction.
As the SFBAAB is currently designated a nonattainment area for PM (fugitive dust emissions (PM10 and PM2.5), mitigation would be required to ensure that individual development projects facilitated by the proposed project would minimize construction fugitive dust impacts. Therefore, construction-related regional air quality impacts associated with implementation of the proposed project are considered potentially significant.
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.
Significance with Mitigation. Less than significant. Because the Bay Area Air Quality Management District (BAAQMD) considers all impacts related to fugitive dust emissions (PM2.5 and PM10) from construction from all development in their jurisdiction to be less than significant with implementation of BAAQMD’s best management practices (see Table 4.3-7, BAAQMD Regional (Mass Emissions) Criteria Air Pollutant Significance Thresholds), the ongoing implementation of BAAQMD’s requirements by the City pursuant to proposed General Plan 2050 *Action 3-6.31 and *Action 3-6.32 would ensure impacts would be less than significant.
Operation
Operational activities associated with potential future development over the buildout horizon of the proposed project could generate a substantial increase in long-term criteria air pollutant emissions from existing conditions that could exceed BAAQMD’s regional significance thresholds and cumulatively contribute to the nonattainment designations of the SFBAAB.
Implementation of the proposed project would result in direct and indirect criteria air pollutant emissions from transportation, energy (e.g., natural gas use), and area sources (e.g., aerosols and landscaping equipment). Mobile-source criteria air pollutant emissions are based on the traffic analysis conducted by W-Trans for this EIR. The emissions forecast for the EIR Study Area under the proposed project compared to existing conditions (with 2050 emissions rates) is shown in Table 4.3-10, Proposed Project Criteria Air Pollutant Emissions Forecast (Scenario 1, Comparison to Existing Conditions). This is “Scenario 1” as required by BAAQMD and explained under the “BAAQMD Significance Criteria” subheading in Section
4.3.2, Standards of Significance.
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As shown in Table 4.3-11, Net Change in Regional Criteria Air Pollutant Emissions Forecast (Scenario 2, Comparison to Future No Project Conditions), compared to existing baseline year conditions, emissions of NOX are projected to decrease from current levels despite growth associated with the proposed project.
However, operational (long-term) emissions associated with the future no project conditions would also remain above the BAAQMD significance thresholds.
TABLE 4.3-10 PROPOSED PROJECT CRITERIA AIR POLLUTANT EMISSIONS FORECAST (SCENARIO 1, COMPARISON TO
EXISTING CONDITIONS)
Year
Criteria Air Pollutants (Tons/Year)
ROG NOX PM10 PM2.5
Existing Land Uses – Year 2050
On-Road Transportation 6 42 19 6
Energy 11 209 16 16
Off-road Equipment 143 173 9 8
Consumer Products 529 ― ― ―
Total Existing Land Uses (tons/year) 689 424 44 29
Proposed Land Use Plan – Year 2050 Total Buildout
On-Road Transportation 7 52 23 7
Energy 12 230 17 17
Off-road Equipment 178 181 10 8
Consumer Products 745 ― ― ―
Proposed Land Uses Total (tons/year) 942 463 50 32
Change in Emissions from Existing Land Uses (Year 2050) On-Road Transportation 1 10 4 1
Energy 1 21 2 2
Off-road Equipment 35 8 <1 <1
Consumer Products 216 ― ― ―
Net Change from Existing Land Uses (Year 2050) 253 39 6 3 BAAQMD Threshold (Tons/Year) 0 0 0 0
Exceeds BAAQMD Threshold? Yes Yes Yes Yes
Note: Numbers may not sum due to rounding.
Source: PlaceWorks, 2023. See Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR.
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Compliance with applicable policies and programs would contribute to minimizing long-term emissions.
However, implementation of the proposed project would still exceed the BAAQMD significance threshold for operation. Therefore, implementation of the proposed project could result in significant long-term regional air quality impacts.
Consistency with AQMP Control Measures
As previously mentioned, BAAQMD’s plan-level guidance does not require an emissions inventory of criteria air pollutants for plan-level analysis; however, BAAQMD recommends that one method used for determining plan-level impact significance is to analyze the proposed plan’s consistency with the current AQMP control measures. As discussed in Table 4.3-8, the proposed project would be consistent with the applicable 2017 Clean Air Plan control measures. As such, the proposed project would be consistent with the current AQMP control measures, and this impact would be less than significant.
TABLE 4.3-11 NET CHANGE IN REGIONAL CRITERIA AIR POLLUTANT EMISSIONS FORECAST (SCENARIO 2,
COMPARISON TO FUTURE NO PROJECT CONDITIONS)
Year
Criteria Air Pollutants (Tons/Year)
ROG NOX PM10 PM2.5
Existing Land Uses – Existing Baseline
On-Road Transportation 46 376 22 7
Energy 11 209 16 16
Off-road Equipment 143 173 9 8
Consumer Products 529 ― ― ―
Existing Baseline Land Uses Total 729 758 47 30
Proposed Land Use Plan – Year 2050 Total Buildout
On-Road Transportation 7 52 23 7
Energy 12 230 17 17
Off-road Equipment 178 181 10 8
Consumer Products 745 ― ― ―
Proposed Land Uses Total 942 463 50 32
Change in Emissions from Existing Baseline
On-Road Transportation -39 -324 1 <1
Energy 1 21 2 2
Off-road Equipment 35 8 <1 <1
Consumer Products 216 ― ― ―
Net Change from Existing Baseline 213 -295 3 2
BAAQMD Threshold (Tons/Year) 0 0 0 0
Exceeds BAAQMD Threshold? Yes No Yes Yes
Note: Numbers may not add up due to rounding.
Source: See Appendix B, Air Quality and Greenhouse Gas Emissions Data, of this Draft EIR.
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Proposed Plan VMT and Population Growth
As previously mentioned, BAAQMD’s plan-level guidance does not require an emissions inventory of criteria air pollutants for plan-level analysis; however, BAAQMD recommends that the second method for determining plan-level impact significance is to analyze the proposed plan’s projected VMT growth versus its projected population growth from existing conditions through its planning horizon year (2050). A significant impact could occur if a proposed plan’s projected VMT growth outpaces its projected population growth resulting in a cumulatively considerable net increase in criteria pollutants.
As discussed under impact discussion AIR-1, the daily VMT per service population would decrease from the city’s current levels. However, there would be an increase in the total magnitude at buildout. The reduction in citywide VMT per service population below existing levels is a positive indicator that the land use and circulation changes associated with the proposed project will, overall, reduce the amount of VMT generated by each person living or working in Santa Rosa. Therefore, the forecasted VMT growth would not outpace the forecasted population growth facilitated by the proposed project. As such, this impact would be less than significant.
While growth within the EIR Study Area would cumulatively contribute to operational (long-term) regional criteria air pollutant emissions, Chapter 3, Circulation, Open Space, Conservation, and Greenhouse Gas Reduction, of the proposed General Plan 2050 includes goals, policies, and actions that require local planning and development decisions to consider impacts from emissions and to reduce those emissions.
In addition to the proposed General Plan 2050 goals, policies, and actions listed in Section 4.3.2.3, Impacts of the Environment on a Project, the following goals, policies, and actions would serve to minimize potential adverse impacts related associated with buildout of the proposed project:
Goal 3-1: Provide an integrated land use and transportation system with safe and efficient movement of people and goods for all modes of travel that prioritizes reduction of VMT and transportation- related GHG emissions.
Policy 3-1.1: Work with partner agencies to reduce VMT using existing techniques and explore feasibility of new techniques as they arise.
Action 3-1.3: Continue to participate in discussions addressing regional through-traffic with SCTA, the County of Sonoma, MTC, and other municipalities, prioritizing investments that will reduce VMT and GHG emissions.
Policy 3-1.2: Promote a citywide mode shift away from single-occupancy vehicles to support ambitious VMT and GHG reduction goals.
Action 3-1.5: Develop a process that invests in and prioritizes non-automobile modes of transportation in capital improvement projects to reduce VMT and GHGs, prioritizing, in order:
1. Active transportation modes, including walking, bicycling, and rolling.
2. Public transportation, including inter-city and regional systems.
3. Other shared vehicles such as carpool, vanpool, and rideshare/transportation network companies.
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Goal 3-2: Provide a safe and accessible active and public transportation network that emphasizes active transportation connections and service to Equity Priority Areas and Areas of Change. Policy 3-2.5: Address traffic volumes and speeds in neighborhoods to reduce cut-through traffic and promote use of existing low-stress streets for active transportation travel. Action 3-2.33: Construct or require roundabouts in lieu of stop/signal-controlled intersections, where appropriate, to improve safety, reduce delay and idling time, and lower vehicle emissions.
Goal 3-3: Transition away from single-occupancy vehicles. Policy 3-3.1: Continue to offer and improve TDM programs that incentivize a shift away from single-occupancy vehicles.
Action 3-3.1: Work with local employers and existing residential and commercial development to expand TDM and related efforts to help meet employee transportation needs through modes that reduce VMT from single-occupancy automobile trips less than five miles, such as:
Unlimited free access to transit service (CityBus, Sonoma County Transit, and SMART). Funding for increased transit frequency.
Paid incentives to active transportation and micromobility users, including a transportation allowance and secure on-site bicycle parking, lockers, showers and other facilities that support bicycling commuting to and from work. Programs and incentives to expand carpooling, vanpooling, and car sharing. Staggered work shifts, flex time (e.g., 9/80 work schedule), and telecommuting. Paid-parking disincentives for single-occupant vehicles and/or parking cash-out incentives.
Action 3-3.2: Implement a TDM program for City employees—potentially in partnership with other local governments, public agencies, and transit providers—and promote the program as a model for larger local employers.
Policy 3-3.3: Encourage transit ridership to reduce GHG emissions and provide convenient and efficient public transportation to workplaces, shopping, and other destinations. Action 3-3.12: Continue to require transit-supportive TDM measures for new development, including CityBus/Sonoma County Transit/SMART pass products. Goal 3-6: Use nature- and science-based strategies to preserve and create environments that provide ecosystem benefits.
Policy 3-6.9: Achieve and maintain ambient air quality standards. Action 3-6.33: Require all new development to be electric vehicle charging ready at a minimum. Explore opportunities to amend the City’s municipal codes to require new development to install electric vehicle charging infrastructure beyond the minimum State requirements.
Action 3-6.35: Review and amend the City’s Building Code and Zoning Code to facilitate the installation of electric vehicle charging infrastructure.
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Action 3-6.37: Expand installation and operation of electric vehicle charging stations on City properties, including curbside in areas of the community where other options are limited. Action 3-6.38: Budget for clean fuel and zero-emission vehicles in the City’s long-range capital expenditure plans to transition the existing fleet of gasoline- and diesel- powered vehicles, and work to make the City’s fleet among the cleanest in the North Bay by:
Purchasing zero-emission vehicles whenever possible that meet or exceed requirements under the California Advanced Clean Fleets Regulation. If zero- emission vehicles are not available, purchase plug-in hybrids, or other vehicle types to minimize emissions. Using biodiesel and pollution- reducing fuel additives in the City’s diesel fuel vehicles. Action 3-6.39: Continue to implement the City’s Wood Burning Appliance Ordinance to reduce particulate matter emissions from wood-burning appliances.
While BAAQMD rules and the proposed General Plan 2050 goals, policies, and actions identified above may reduce operation-related regional air quality impacts of individual projects accommodated under the proposed project to a less-than-significant level, due to the magnitude of development allowed, the projected cumulative emissions associated with future development projects would exceed the threshold.
Therefore, implementation of the proposed project would significantly contribute to the nonattainment designations of the SFBAAB, resulting in a significant impact.
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 (NOX) and particulate matter (PM2.5 and PM10).
Significance with Mitigation: 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 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.
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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 this Draft EIR.
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 this Draft EIR provides the San Joaquin Valley Air SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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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. 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 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.
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AIR-3 Implementation of the proposed project could expose sensitive receptors to substantial pollutant concentrations.
Implementation of the proposed project would cause or contribute significantly to elevated pollutant concentration levels such that it would expose sensitive receptors to elevated pollutant concentrations.
Unlike regional emissions, localized emissions are typically evaluated in terms of air concentration rather than mass so they can be more readily correlated to potential health effects.
Construction Community Risk and Hazards
Future construction over the buildout horizon of the proposed project would temporarily elevate concentrations of TACs and DPM in the vicinity of sensitive land uses during construction activities. Since the details regarding future construction activities are not known at this time due to this analysis being conducted at a program level—including phasing of future individual projects, construction duration and phasing, and preliminary construction equipment—construction emissions are evaluated qualitatively in accordance with BAAQMD’s plan-level guidance. Subsequent environmental review of future development projects would be required to assess potential impacts under BAAQMD’s project-level thresholds. However, construction emissions associated with the proposed project could exceed BAAQMD’s project level and cumulative significance thresholds for community risk and hazards. As recommended by CARB, applicants for construction within 1,000 feet of residential and other sensitive land uses (e.g., hospitals, nursing homes, and day care centers), as measured from the property line of the project to the property line of the source/edge of the nearest travel lane, are required to prepare construction HRAs in accordance with policies and procedures of the OEHHA and BAAQMD to identify and mitigate health risk impacts from construction. The latest OEHHA guidelines are required to be applied for the analysis, including age sensitivity factors, breathing rates, and body weights appropriate for children ages 0 to 16 years. If the construction HRA shows that the incremental cancer risk exceeds the respective threshold established by BAAQMD—project-level risk of 10 in a million in all other areas, PM
2.5 emissions
that exceed 0.3 µg/m3, or the appropriate noncancer hazard index exceeds 1.0—the applicant would be required to identify and demonstrate that mitigation measures are capable of reducing potential cancer and non-cancer risks below the respective threshold, including appropriate enforcement mechanisms.
Measures to reduce risk may include, but are not limited to:
Use of construction equipment rated as United States Environmental Protection Agency Tier 4 Interim or higher for equipment of 50 horsepower or more.
Use of construction equipment fitted with Level 3 Diesel Particulate Filters for all equipment of 50 horsepower or more.
However, construction emissions associated with the proposed General Plan 2050 could exceed BAAQMD’s project level and cumulative significance thresholds for community risk and hazards.
Therefore, construction-related health risk impacts associated with the proposed General Plan 2050 are considered potentially significant.
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Impact AIR-3a: Construction activities associated with potential future development could expose nearby receptors to substantial concentrations of toxic air contaminants.
Significance with Mitigation. Less than significant. 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 6-1.5 would require projects that result in construction activities within 1,000 feet of residential and other land uses that are sensitive to toxic air contaminants to prepare a construction health risk assessment that identifies mitigation measures and appropriate enforcement mechanisms capable of reducing potential cancer and non-cancer risks below the Bay Area Air Quality Management District threshold. Therefore, with implementation of the proposed General Plan 2050 goals, policies, and actions, construction-related health risk impacts associated with the proposed project are considered less than significant.
Operation
Implementation of the proposed project could result in individual development projects that cause or contribute significantly to elevated pollutant concentration levels such that it would expose sensitive receptors to elevated pollutant concentrations. Unlike regional emissions, localized emissions are typically evaluated in terms of air concentration rather than mass so they can be more readily correlated to potential health effects. Types of land uses that typically generate substantial quantities of TACs and PM
2.5 include industrial and manufacturing (stationary sources) and warehousing land uses that have the potential to generate DPM from onsite equipment and mobile sources (trucks). While these types of land uses are not prevalent in the EIR Study Area, nor are they anticipated to be introduced as part of the planned land uses envisioned in the proposed General Plan 2050, commercial and retail uses that generate small- and medium-sized truck trips for deliveries could similarly generate localized substantial concentrations of TACs and PM
2.5. Additionally, operation of new land uses consistent with the proposed project could generate new sources of criteria air pollutants and TACs in the EIR Study Area associated with CO hotspots. The following describes potential localized operational air quality impacts from implementation of the proposed project.
Operational CO Hotspots
Areas of vehicle congestion have the potential to create pockets of CO called hotspots. These pockets have the potential to exceed the State 1-hour standard of 20 ppm or the 8-hour standard of 9.0 ppm.
Since CO is produced in the greatest quantities from vehicle combustion and does not readily disperse into the atmosphere, adherence to AAQS is typically demonstrated through an analysis of localized CO concentrations. Hotspots are typically produced at intersections, where traffic congestion is highest because vehicles queue for longer periods and are subject to reduced speeds.
An overarching goal of Plan Bay Area 2050 is to concentrate development in areas where there are existing services and infrastructure rather than allocate new growth in outlying areas where substantial transportation investments would be necessary to achieve the per capita passenger vehicle VMT and associated GHG emissions reductions. As described under impact discussion GHG-2 in Chapter 4.8, Greenhouse Gas Emissions, of this Draft EIR, the proposed project would be consistent with the overall SANTA ROSA GENERAL PLAN 2050 DRAFT EIR
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goals of Plan Bay Area 2050. Additionally, the proposed project would not hinder the capital improvements outlined in Plan Bay Area 2050. Thus, the proposed project would not conflict with Plan Bay Area 2050.
Pursuant to BAAQMD, under existing and future vehicle emission rates, a project would have to increase traffic volumes at a single intersection to more than 44,000 vehicles per hour—or 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited—to generate a significant CO impact.49 Implementation of the proposed project would not increase traffic volumes at affected intersections to more than BAAQMD screening criteria of 44,000 vehicles per hour or 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited. The highest intersection volumes in the city are:
50 Farmers Lane at Fourth Street-Highway 12: approximately 4,800 vehicles per hour Guerneville Road at US Highway 101 South Offramp: approximately 4,400 vehicles per hour Highway 12 at Fulton Road-Wright Road: approx. 4,300 vehicles per hour Moreover, the proposed General Plan 2050 includes land use designations, goals, policies, and actions that will help reduce VMT and therefore reduce emissions from automobiles (see Chapter 4.15, Transportation, of this Draft EIR for a complete list of these goals, policies, and actions). Therefore, the proposed project would not have the potential to substantially increase CO hotspots at intersections in the EIR Study Area and vicinity. Overall, these components of the proposed project would contribute to reducing congestion and associated emissions. Localized air quality impacts related to mobile-source emissions would be less than significant.
Operational Community Risk and Hazards
Common sources of TAC emissions are stationary sources (e.g., dry cleaners, diesel backup generators, and gasoline stations), which are subject to the BAAQMD permit requirements. Future development and activities under the proposed project could result in new sources of TACs and PM
2.5. Stationary sources,
including smaller stationary sources associated with residential development (e.g., emergency generators and boilers), are subject to review by BAAQMD as part of the permitting process. Adherence to the BAAQMD permitting regulations would ensure that new stationary sources of TACs do not expose populations to significant health risk. Mobile sources of air toxics (e.g., truck idling) are not regulated directly by BAAQMD. However, residential development associated with the proposed project would not generate substantial truck traffic or idling. Permitted stationary sources and nonpermitted sources are discussed in greater detail below.
49 Bay Area Air Quality Management District, April 2023, California Environmental Quality Act: Air Quality Guidelines, https://www.baaqmd.gov/plans-and-climate/california-environmental-quality-act-ceqa/ updated-ceqa-guidelines, accessed May 8, 2023.
50 W-Trans, 2023.
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Stationary (Permitted) Sources
Various industrial and commercial processes (e.g., manufacturing, dry cleaning) in the EIR Study Area from implementation of the proposed project would be expected to release TACs. TAC emissions generated by stationary and point sources of emissions within the SFBAAB are regulated and controlled by BAAQMD.
Land uses that would require a permit from BAAQMD for emissions of TACs include chemical processing facilities, chrome-plating facilities, dry cleaners, and gasoline-dispensing facilities. Emissions of TACs from stationary sources would be controlled by BAAQMD through permitting and would be subject to further study and health risk assessment prior to the issuance of any necessary air quality permits under Regulation 2, New Source Review, as well as Regulation 11, Rule 18, Reduction of Risk from Air Toxic Emissions at Existing Facilities.
Review under New Source Review ensures that stationary source emissions (permitted sources) would be reduced or mitigated below the BAAQMD community risk and hazards thresholds. Though these sources would incrementally contribute to emissions in the EIR Study Area individually, they would be mitigated to the BAAQMD standards. Moreover, the 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 minimize potential adverse impacts on air quality by requiring new development to follow standards to reduce health risks from stationary sources.
Though the proposed General Plan 2050 includes goals, policies, and actions to reduce exposure of sensitive receptors to pollution, and BAAQMD would ensure that emission achieve their permit thresholds on a project-by-project basis, emissions cannot be determined or modeled until specific development projects are proposed. Therefore, implementation of the proposed project may result in projects that emit TACs and PM
2.5 throughout the EIR Study Area and result in potentially significant localized air quality impacts.
Nonpermitted Sources
TACs and PM2.5 from mobile sources when operating at a property (e.g., truck idling) are regulated by statewide rules and regulations, not by BAAQMD, and have the potential to generate substantial concentrations of air pollutants. The primary mobile source of TACs within the EIR Study Area includes truck idling and use of off-road equipment.
New warehousing operations present the potential to generate substantial DPM and PM
2.5 emissions from
off-road cargo-handling equipment use and truck idling. In addition, some warehousing and industrial facilities may include use of transport refrigeration units (TRU) for cold storage. New land uses in the EIR Study Area that would be permitted under the proposed project that use trucks and TRUs could generate an increase in DPM that would contribute to cancer and noncancer health risk in the SFBAAB. Additionally, these types of facilities could also generate particulate matter (PM 10 and PM2.5) that may cause an
exceedance or contribute to the continuing exceedance of the National and California AAQS. These new land uses could be near existing sensitive receptors. In addition, trucks would travel on regional transportation routes through the Bay Area, contributing to near-roadway DPM concentrations.
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The proposed project would result in an increase of up to 1,415,095 square feet of industrial and warehouse land use. The proposed project could result in specific development projects that could emit localized concentrations of TACs and PM2.5. The emissions associated with these facilities cannot be determined or modeled until specific development projects are proposed. Therefore, implementation of the proposed project may result in projects that emit TACs and PM2.5 in the vicinity of EPAs and result in potentially significant localized air quality impacts without project-specific analysis of operational health risk impacts from nonpermitted sources associated with development of industrial and commercial land uses.
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 (PM2.5) concentrations and exceed the Bay Area Air Quality Management District’s (BAAQMD) project- level and cumulative significance thresholds.
Significance with Mitigation: Significant and unavoidable. Potential future development over the buildout horizon of the proposed project could result in new sources of TACs or PM2.5 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 PM2.5 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 2050 DRAFT EIR
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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 address 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.
AIR-
4 Implementation of the proposed project would not result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.
Construction
While odors could be generated during future construction activities associated with development and activities under the proposed project, the proposed project would not directly result in construction of any development project. Identification of potential impacts to odor receptors resulting from construction-generated odors, such as equipment exhaust, would require project-specific information for future individual land use development projects that is not currently known. Nonetheless, odors are regulated under BAAQMD Regulation 1, Rule 1-301, Public Nuisance. Compliance with BAAQMD Regulation 1 would ensure that odor impacts associated with the proposed project are minimized. As previously discussed, consistent with BAAQMD’s CEQA Air Quality Guidelines, a plan-level analysis must acknowledge odor sources within the EIR Study Area and identify policies, goals, and objectives aimed at reducing potential odor impacts to ensure that potential impacts would be less than significant.
Operation
According to BAAQMD’s 2022 CEQA Air Quality Guidelines, land uses associated with odor complaints typically include agricultural operations, wastewater treatment plants, landfills, and certain industrial operations such as chemical and other manufacturing. While odors do not themselves present a health risk, they are often considered a nuisance by people who live, work, or otherwise are located near outdoor odor sources. Future environmental review could be required for industrial projects listed in BAAQMD’s CEQA Guidelines Table 4, Project Screening Trigger Levels for Potential Odor Sources, to ensure that sensitive land uses are not exposed to nuisance odors. Consequently, review of projects using BAAQMD’s odor screening distances is necessary to ensure that odor impacts are minimized.
Increase in residential uses would not generate odors that would affect a substantial number of people.
During operation, residences could generate odors from cooking. However, odors from cooking are not substantial enough to be considered nuisance odors that would affect a substantial number of people.
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The proposed General Plan 2050 provides guidance for the development, management, and preservation of Santa Rosa’s natural, open space, and agricultural lands, including air quality. Specifically, proposed General Plan 2050 Policy 2-1.1, Action 2-1.2, Policy 5-9.6, and Action 5-9.41 listed in Section 4.3.2.3, Impacts of the Environment on a Project, would serve to minimize impacts related to potential adverse impacts related to odors. Therefore, compliance with proposed General Plan 2050 goals, policies, and actions, as well applicable BAAQMD rules and regulations, would prevent odor emissions from adversely affecting a substantial number of people in the EIR Study Area.
Furthermore, nuisance odors are regulated under BAAQMD Regulation 7, Odorous Substances, which requires abatement of any nuisance generating an odor complaint, and BAAQMD Regulation 1, Rule 1- 301, Public Nuisance. Compliance with BAAQMD Regulations would ensure that odor impacts associated with the proposed project are minimized. This impact would be less than significant.
Significance without Mitigation: Less than significant.
AIR-5 Implementation of the proposed project could, in combination with past, present, and reasonably foreseeable projects, result in cumulative air quality impacts in the area.
The cumulative area of analysis is the SFBAAB which is currently designated a nonattainment area for O3 and particulate matter (PM10 and PM2.5). As identified in Section 4.3.1, Environmental Setting, California is divided into air basins for the purpose of managing the air resources of the state on a regional basis based on meteorological and geographic conditions. Similar to GHG emissions impacts, air quality impacts are regional in nature as no single project generates enough emissions that would cause an air basin to be designated as a nonattainment area. Therefore, the impacts previously discussed are evaluated in the cumulative context and no additional cumulative analysis is needed.
Buildout of the proposed project would generate new sources of TAC 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 gasoline dispensing facilities) would ensure that health risks are minimized.
Implementation of proposed General Plan 2050 goals, policies, and actions would ensure that mobile sources of TACs not covered by BAAQMD permits are considered during subsequent project-level environmental review by the City. Individual development projects would be required to achieve the incremental risk thresholds established by BAAQMD. However, implementation of the proposed project would generate TACs that could contribute to elevated levels in the SFBAAB. While individual projects would achieve the project-level risk threshold of 10 per million, they would nonetheless contribute to the higher levels of cancer risk in the SFBAAB. Therefore, the cumulative contribution to health risk resulting from implementation of the proposed project is significant.
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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.
Significance with Mitigation: Significant and unavoidable. 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 in 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.
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4.4 BIOLOGICAL RESOURCES
This chapter describes existing biological resources within the Draft Environmental Impact Report (EIR) Study Area and evaluates the potential environmental consequences of future development that could occur by adopting and implementing the proposed project. A summary of the relevant regulatory framework and existing conditions is followed by an impact discussion of the proposed project and cumulative impacts.
This chapter is based on a review of available background information for the Santa Rosa vicinity, preparation of detailed mapping of known resources, and an assessment of potential impacts of the proposed project based on anticipated future development. Available background information included:
the Santa Rosa General Plan 20351 and EIR;2 the Santa Rosa Citywide Creek Master Plan;3 the occurrence data of special-status species and sensitive natural communities maintained by the California Natural Diversity Data Base (CNDDB) of the California Department of Fish and Wildlife (CDFW); the 2005 Santa Rosa Plain Conservation Strategy (SRPCS) overseen by the United States Fish and Wildlife Service (USFWS);
4 wetlands mapped as part of the National Wetlands Inventory maintained by the USFWS; and mapping of critical habitat for federally-listed species maintained by the USFWS. No detailed field surveys were conducted as part of this assessment or are considered necessary given the nature of the proposed project as a broad, long-term planning-level document rather than a site-specific development proposal.
4.4.1 ENVIRONMENTAL SETTING
REGULATORY FRAMEWORK
Federal Regulations
Federal Endangered Species Act
The USFWS has jurisdiction over federally listed threatened and endangered plant and animal species. The federal Endangered Species Act (FESA) and its implementing regulations prohibit the take of any fish or wildlife species that is federally listed as threatened or endangered without prior approval pursuant to either Section 7 or Section 10 of the FESA. FESA defines “take” as “harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such conduct.” Title 50, Wildlife and Fisheries, Part 17, Endangered and Threatened Wildlife and Plants, Section 17.3, Definitions, of the Code of Federal Regulations, defines the term “harass” as an intentional or negligent act that creates the likelihood of injuring wildlife by annoying it to such an extent as to significantly disrupt normal behavior patterns such as breeding, feeding, or sheltering. Furthermore, Section 17.3 defines “harm” as an act that either kills or injures a listed species. By definition, “harm” includes habitat modification or degradation
1 City of Santa Rosa, updated October 2020, Santa Rosa General Plan 2035. 2 Environmental Science Associates, March 2009, Draft Santa Rosa General Plan 2035 Environmental Impact Report. 3 City of Santa Rosa, May 2013, Santa Rosa Citywide Creek Master Plan. 4 Santa Rosa Plain Conservation Strategy Team, December 1, 2005, Santa Rosa Plain Conservation Strategy (Final).
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that actually kills or injures a listed species by significantly impairing essential behavior patterns such as breeding, spawning, rearing, migrating, feeding, or sheltering.
Section 10(a) of the FESA establishes a process for obtaining an incidental take permit that authorizes nonfederal entities to incidentally take federally listed wildlife or fish. Incidental take is defined by FESA as take that is “incidental to, and not the purpose of, the carrying out of an otherwise lawful activity.” Preparation of a habitat conservation plan (HCP) is required for all Section 10(a) permit applications. The USFWS and National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NOAA Fisheries Service) have joint authority under the FESA for administering the incidental take program.