Sunnyvale City Council
December 12, 2023

Initial Study/Proposed Negative Declaration
2023 – 2031 Housing Element Update
Prepared for:

City of Sunnyvale
456 W. Olive Avenue
Sunnyvale, CA 94086
October 2023
Attachment 3

Attachment 3

Initial Study/Proposed Negative Declaration
2023 – 2031 Housing Element Update
Prepared for:

City of Sunnyvale
456 W. Olive Avenue
Sunnyvale, CA 94086
Contact:

Ryan Dyson
Housing Specialist
408.730.7466
Prepared by:

Ascent Environmental
455 Capitol Mall, Suite 300
Sacramento, CA 95814
Contact:

Pat Angell
Principal-in-Charge
916.732-3324
October 2023
Attachment 3

Attachment 3

TABLE OF CONTENTS
Section Page
ACRONYMS AND ABBREVIATIONS ................................ ................................ ................................ ................................ ....................... iii NOTICE ON INTENT TO ADOPT A NEGATIVE DECLARATION ................................ ................................ ................................ ......... 1 1 INTRODUCTION ................................ ................................ ................................ ................................ ................................ ........ 1-1

1.1 Introduction and Regulatory Guidance ......................................................................................................................1-1

1.2 Why this Document? .........................................................................................................................................................1-1

1.3 Summary of Findings ....................................................................................................................................................... 1-2

1.4 Document Organization ................................................................................................................................................. 1-2 2 PROJECT DESCRIPTION ................................ ................................ ................................ ................................ ........................... 2-1

2.1 Project background .......................................................................................................................................................... 2-1

2.2 Project Location ................................................................................................................................................................ 2-3

2.3 Project Description ........................................................................................................................................................... 2-3

2.4 Required Actions .............................................................................................................................................................. 2-5 3 ENVIRONMENTAL CHECKLIST................................ ................................ ................................ ................................ ............... 3-1

3.1 Aesthetics ............................................................................................................................................................................ 3-6

3.2 Agriculture and Forest Resources ............................................................................................................................... 3-9

3.3 Air Quality .......................................................................................................................................................................... 3-11

3.4 Biological Resources ...................................................................................................................................................... 3-16

3.5 Cultural Resources ......................................................................................................................................................... 3-20

3.6 Energy................................................................................................................................................................................. 3-22

3.7 Geology and Soils .......................................................................................................................................................... 3-24

3.8 Greenhouse Gas Emissions ......................................................................................................................................... 3-28

3.9 Hazards and Hazardous Materials ........................................................................................................................... 3-31

3.10 Hydrology and Water Quality .................................................................................................................................... 3-36

3.11 Land Use and Planning ................................................................................................................................................. 3-40

3.12 Mineral Resources .......................................................................................................................................................... 3-42

3.13 Noise ................................................................................................................................................................................... 3-43

3.14 Population and Housing .............................................................................................................................................. 3-46

3.15 Public Services ................................................................................................................................................................. 3-48

3.16 Recreation ......................................................................................................................................................................... 3-51

3.17 Transportation ................................................................................................................................................................. 3-53

3.18 Tribal Cultural Resources ............................................................................................................................................. 3-58

3.19 Utilities and Service Systems ...................................................................................................................................... 3-61

3.20 Wildfire ............................................................................................................................................................................... 3-65

3.21 Mandatory Findings of Significance ......................................................................................................................... 3-67 4 REFERENCES ................................ ................................ ................................ ................................ ................................ .............. 4-1 5 REPORT PREPARERS ................................ ................................ ................................ ................................ ................................ .5-1

Attachment 3

Figures
Figure 2-1 City of Sunnyvale City Limits ........................................................................................................................................ 2-4

Tables
Table 2-1 City of Sunnyvale Regional Housing Needs Allocation for the 2023 – 2031 Housing Element Update ................................................................................................................................................................................... 2-1 Table 2-2 Anticipated 2023-2031 Housing Capacity With Adoption of Moffett Park Specific Plan ........................ 2-2 Table 3-1 National and California Ambient Air Quality Standards ................................................................................... 3-12 Table 3-2 Attainment Status Designations for Santa Clara County .................................................................................. 3-13

Attachment 3

ACRONYMS AND ABBREVIATIONS
AB Assembly Bill
ABAG Association of Bay Area Governments
AMI area median income
BAAQMD Bay Area Air Quality Management District
°C Celsius
CEQA California Environmental Quality Act
CLUP The Moffett Federal Airfield Comprehensive Land Use Plan CO Carbon monoxide
DSP Downtown Specific Plan
ECRSP El Camino Real Specific Plan
EIR Environmental Impact Report
EO Executive Order
GHG greenhouse gas
HCD State Department of Housing and Community Development HOV high occupancy vehicle
IS/Proposed ND Initial Study/Proposed Negative Declaration LOS level of service
LSAP Lawrence Station Area Plan
LUTE Land Use and Transportation Element Update
Mgd million gallons per day
MPP Miscellaneous Planning Permit
MPSP Moffett Park Specific Plan
MPSP Moffett Park Specific Plan
MTCO2e metric tons of carbon dioxide equivalent
NAHC Native American Heritage Commission
NO2 Nitrogen dioxide
OPR The Governor’s Office of Planning and Research
PG&E Pacific Gas and Electric Company
PM10 Respirable particulate matter
PM2.5 Fine particulate matter
RHNA Regional Housing Needs Allocation
SCVWD Santa Clara Valley Water District
SFBAAB San Francisco Bay Area Air Basin
Attachment 3

SFPUC San Francisco Public Utilities Commission
SO2 Sulfur dioxide
SR State Route
SVCE Silicon Valley Clean Energy
VMT vehicle miles traveled
WPCP Water Pollution Control Plant
Attachment 3

NOTICE ON INTENT TO ADOPT A NEGATIVE DECLARATION
The attached Initial Study/Proposed Negative Declaration (IS/Proposed ND) has been prepared for the City of Sunnyvale (City), as the lead agency, to evaluate potential environmental effects resulting from the proposed 2023- 2031 Housing Element Update. Under CEQA, the lead agency is the public agency with primary responsibility over approval of the project.

PROJECT DESCRIPTION
The proposed Housing Element Update is an update of the City of Sunnyvale’s current housing element. The proposed City of Sunnyvale 2023 – 2031 Housing Element Update would address City housing needs during the 2023-2031 planning period, from January 31, 2023, to January 31, 2031.

LOCATION
The project addressed is the entire City. The City of Sunnyvale is located in the northwestern region of Santa Clara County and is within the nine-county San Francisco Bay Area. Sunnyvale’s norther border is situated with U.S. Route 101.

The San Francisco Bay Area borders Sunnyvale to the north, the City of Mountain View to the northwest, the City of Los Altos to the southwest, the City of Cupertino to the south, and the City of Santa Clara to the east.

This includes potential housing sites that may be on the list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.

REVIEW AND APPROVAL
The purpose of the IS/Proposed ND is to present to decision-makers and the public information about the environmental consequences of implementing the project. This IS/Proposed ND will be available for a 30-day public review period from October 20, 2023 to November 20, 2023.

Supporting documentation referenced in this document is available for review at:

City of Sunnyvale Community Development Department
456 W. Olive Avenue
Sunnyvale, CA 94088
Comments should be addressed to:

Ryan Dyson
City of Sunnyvale Community Development Department
456 W. Olive Avenue
Sunnyvale, CA 94088
E-mail comments may be addressed to: [email protected] If you have questions regarding the IS/Proposed MND, please call Ryan Dyson at: 408.730.7466. If you wish to send written comments (including via e-mail), they must be postmarked by November 20, 2023.

After comments are received from the public and reviewing agencies, the City of Sunnyvale City Council may (1) adopt the ND and approve the project; (2) undertake additional environmental studies, potentially including preparation of an Environmental Impact Report; or (3) deny the project.

Attachment 3

PROPOSED FINDINGS
The City has reviewed and considered the proposed project and has determined that the project will not have a significant effect on the environment. The City hereby prepares and proposes to adopt a ND for this project.

PUBLIC HEARING INFORMATION
Public hearings on the project are scheduled for:
 Housing and Human Services Commission Hearing – November 21, 2023 at 7:00 p.m. in the Bay Conference Room (Room 145), City Hall, 456 West Olive Avenue, Sunnyvale and online at https://sunnyvale-ca- gov.zoom.us/j/92867949471.
 Planning Commission Hearing – November 27, 2023 at 7:00 p.m. in the Council Chambers, City Hall, 456 West Olive Avenue, Sunnyvale and online at https://sunnyvale-ca-gov.zoom.us/j/91827390357.  City Council Hearing – December 12, 2023 at 7:00 p.m. in the Council Chambers, City Hall, 456 West Olive Avenue, Sunnyvale and online at https://sunnyvale-ca-gov.zoom.us/j/96111580540.

Attachment 3

1 INTRODUCTION

1.1 INTRODUCTION AND REGULATORY GUIDANCE
This Initial Study/Proposed Negative Declaration (IS/Proposed ND) has been prepared by the City of Sunnyvale (City) to evaluate potential environmental effects resulting from proposed 2023-2031 Housing Element Update. Section 2 “Project Description” presents the detailed project information.

This document has been prepared in accordance with the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et seq.) and the State CEQA Guidelines (California Code of Regulations Section 15000 et seq.). An initial study is prepared by a lead agency to determine if a project may have a significant effect on the environment (State CEQA Guidelines Section 15063[a]), and thus to determine the appropriate environmental document. In accordance with State CEQA Guidelines Section 15070, a “public agency shall prepare…a proposed negative declaration or mitigated negative declaration…when: (a) The Initial Study shows that there is no substantial evidence…that the project may have a significant impact on the environment, or (b) The Initial Study identifies potentially significant effects but revisions to the project plans or proposal are agreed to by the applicant and such revisions would reduce potentially significant effects to a less-than-significant level.” In this circumstance, the lead agency prepares a written statement describing its reasons for concluding that the project would not have a significant effect on the environment and, therefore, does not require the preparation of an Environmental Impact Report (EIR). By contrast, an EIR is required when the project may have a significant environmental impact that cannot clearly be reduced to a less-than-significant effect by adoption of mitigation or by revisions in the project design.

1.2 WHY THIS DOCUMENT?
As described in the environmental checklist (Chapter 3), the project would not result in any unmitigated signifi cant environmental impacts that have not been addressed in the following EIRs as provided under State CEQA Guidelines Section 15063(c)(3)(D):
 Land Use and Transportation Element Update EIR, State Clearinghouse No. 2012032003 (LUTE EIR)  Downtown Specific Plan EIR, State Clearinghouse No. 1998110816 (DSP EIR)  Downtown Specific Plan Amendments and Specific Development Project EIR, State Clearinghouse No. 2018052020 (2020 DSP EIR)
 Lawrence Station Area Plan Update Subsequent EIR, State Clearinghouse No. 2019012022 (LSAP Update SEIR)  El Camino Real Specific Plan EIR, State Clearinghouse No. 2017102082 (ECRSP EIR)  Moffett Park Specific Plan EIR, State Clearinghouse No. 2021080338 (MPSP EIR) Therefore, an IS/Proposed ND is the appropriate document for compliance with the requirements of CEQA. This IS/Proposed ND conforms to these requirements and to the content requirements of State CEQA Guidelines Section 15071.

Under CEQA, the lead agency is the public agency with primary responsibility over approval of the proje ct. The City is the CEQA lead agency because they are responsible for adoption and subsequent implementation of the 2023 – 2031 Housing Element Update. The purpose of this document is to present to decision -makers and the public information about the environmental consequences of implementing the project. This disclosure document is being made available to the public for review and comment. This IS/Proposed ND will be available for a 30- day public review period from October 20, 2023 to November 20, 2023.

Attachment 3

Supporting documentation referenced in this document is available for review at:

City of Sunnyvale Community Development Department
456 W. Olive Avenue
Sunnyvale, CA 94088
Comments should be addressed to:

Ryan Dyson
City of Sunnyvale Community Development Department
456 W. Olive Avenue
Sunnyvale, CA 94088
E-mail comments may be addressed to: [email protected] If you have questions regarding the IS/Proposed MND, please call Ryan Dyson at: 408.730.7466. If you wish to send written comments (including via e-mail), they must be postmarked by November 20, 2023.

After comments are received from the public and reviewing agencies, the City may (1) adopt the ND and approve the project; (2) undertake additional environmental studies; or (3) deny the project.

1.3 SUMMARY OF FINDINGS
Chapter 3 of this document contains the analysis and discussion of potential environmental impacts of the project.

Based on the issues evaluated in that chapter, it was determined that the project would have either no impact or a less-than-significant impact related to the issue areas identified in the Environmental Checklist, included as Appendix G of the State CEQA Guidelines. Environmental Permits

1.4 DOCUMENT ORGANIZATION
This IS/Proposed ND is organized as follows:

Chapter 1: Introduction. This chapter provides an introduction to the environmental review process. It describes the purpose and organization of this document as well as presents a summary of findings.

Chapter 2: Project Description and Background. This chapter describes the purpose of and need for the proposed project, identifies project objectives, and provides a detailed description of the project.

Chapter 3: Environmental Checklist. This chapter presents an analysis of a range of environmental issues identified in the CEQA Environmental Checklist and determines if project actions would result in no impact, a less- than-significant impact, a less-than-significant impact with mitigation incorporated, or a potentially significant impact. If any impacts were determined to be potentially significant, an EIR would be required. For this project, however, none of the impacts were determined to be significant.

Chapter 4: References. This chapter lists the references used in preparation of this IS/Proposed ND.

Chapter 5: List of Preparers. This chapter identifies report preparers.

Attachment 3

2 PROJECT DESCRIPTION

2.1 PROJECT BACKGROUND
State law requires each city and county to adopt a general plan containing at least eight elements including a housing element. The housing element is the only element that is required by law to be updated every eight years and must be reviewed by the State Department of Housing and Community Development (HCD). This Housing Element Update is an update of the City of Sunnyvale’s current housing element. The proposed City of Sunnyvale 2023 – 2031 Housing Element Update would address City housing needs during the 2023-2031 planning period, from January 31, 2023, to January 31, 2031.

Housing element law requires local governments to adequately plan to meet the existing and projected housing needs of all economic segments of the community, including their share of the regional housing need. Housing element law is the State’s primary market-based strategy to increase housing supply, choice, and affordability. The law recognizes that in order for the private for-profit and non-profit sectors to adequately address housing needs and demand, local governments must adopt land use plans and regulatory requirements that provide opportunities for, and do not unduly constrain, housing development.

An important part of State housing element law is the determination of a city or county to accommodate forecasted housing demand for all income levels, known as the Regional Housing Needs Allocation (RHNA). The RHNA quantifies the need for housing in each region statewide and is determined by HCD. The Association of Bay Area Governments (ABAG) is responsible for allocating the RHNA to each city and county in its region, which includes the City of Sunnyvale. On December 16, 2021, ABAG adopted the 2023-2031 RHNA Plan. Through the RHNA Plan, ABAG allocates a “fair share” by income category based on projected housing needs for each jurisdiction. Each jurisdiction is required to report to HCD on how the fair share allocation can be accommodated within the planning period. It should be noted that the RHNA projection period is June 30, 2022 – December 15, 2030, which differs slightly from the Housing Element planning period of January 31, 2023 – January 31, 2031. The allocations are intended to be used by jurisdictions when updating their housing elements as the basis for assuring that adequate sites and zoning are available to accommodate at least the number of units allocated.

Table 2-1 shows the RHNA assigned to Sunnyvale for the 2023-2031 Housing Element. As shown in the table, ABAG allocated 11,966 new housing units to the City of Sunnyvale, which includes 2,968 very low-, 1,709 low-, 2,032 moderate-, and 5,257 above moderate-income units. State law also requires the City to identify the projected need for extremely low-income housing. The City assumes that 50 percent of the very low-income housing needs is equal to the extremely low-income housing needs. As such, there is a projected need for 1,484 extremely low-income housing units.

Table 2-1 City of Sunnyvale Regional Housing Needs Allocation for the 2023 – 2031 Housing Element Update
Very-Low-Income
Units Low-Income Units Moderate-Income
Units
Above-Moderate-
Income Units Total
RHNA 2,968 1,709 2,032 5,257 11,966
Percent of Total 24.8% 14.2% 16.9% 43.9% 100%
Source: Association of Bay Area Governments. 2021. Final Regional Housing Needs Allocation (RHNA) Plan: San Francisco Bay Area, 2023-2031 (Adopted December 2021).

As part of the Housing Element update, the City is obligated under State law to develop an inventory of vacant and underutilized land suitable for residential development that can accommodate the 11,966 housing units allocated through the RHNA which, includes 4,677 total lower-income units (includes very low- and low-income units). Based on the City’s residential sites inventory, the City has a shortfall of 1,535 lower-income units and a shortfall of 3,280 above moderate-income units. However, in 2022, the City prepared a comprehensive update to the Moffett Park Specific Plan (MPSP) that was approved on July 11, 2023, which involved the rezoning of land area that increased the Attachment 3

City’s housing capacity. The adoption of this specific plan implements proposed Housing Element Update Implementation Program H2 (Rezone Program).

The Moffett Park Specific Plan is an update to previous versions of the Moffett Park Specific Plan. The Moffett Park Specific Plan provides a vision and guiding principles, development standards, and design guidelines for future development within Moffett Park. As a result of the Moffett Park Specific Plan adoption and associated rezoning, there would be a net increase of 20,000 new residential units by 2040. With adoption of the Moffett Park Specific Plan, the City has a sufficient capacity to accommodate 17,158 residential units, accommodating the RHNA in all income categories. This includes capacity to accommodate 7,560 lower-, 2,413 moderate-, and 7,185 above- moderate-income units. The City will have a lower-income surplus of 2,883 units.

In addition to the Moffett Park Specific Plan, the City contains other specific plans/area plans that provide housing opportunities. These specific plans/area plans include the following:
 Downtown Specific Plan
 Lawrence Station Area Plan
 El Camino Real Specific Plan
 Peery Park Specific Plan
These Specific Plans/Area Plans are shown in Figure 2-2, along with available sites. Table 2-2 summarizes City housing capacity in comparison to the 2023-2031 RHNA allocation.

Table 2-2 Anticipated 2023-2031 Housing Capacity With Adoption of Moffett Park Specific Plan

Lower-Income
Moderate-
Income
Above
Moderate-
Income
Total Very Low
Income Low Income
2023-2031 RHNA 2,968 1,709 2,032 5,257 11,966
4,677
Planned and Approved Projects 220 100 522 999 1,842
Lawrence Station Area Plan 1,096 227 379 1,702
Downtown Specific Plan 126 48 50 224
El Camino Real Specific Plan 1,204 367 502 2,073
Village Centers 0 797 0 797
Additional Sites 299 316 6 621
Accessory Dwelling Units 14 82 136 41 273
Moffett Park Specific Plan 4,418 0 5,208 9,626
Total Capacity 7,560 2.413 7,185 17,158
Surplus 2,883 381 1,928 5,192
Source: Table 5-22 2023-2031 Housing Element Update.

The proposed 2023 – 2031 Housing Element Update includes a Housing Plan that identifies specific goals and actions to address housing needs and meet statutory requirements.

Attachment 3

The Housing Plan identified the following six goals that are supported by policy provisions and implementation programs:
 Goal 1: Provision of Adequate Housing Sites. Provide adequate sites for the development of new housing through appropriate land use and zoning to address the diverse needs of Sunnyvale’s residents and workforce.  Goal 2: Affordable Housing and Home Buyer Assistance. Assist in the provision of affordable housing to meet the diverse needs of Sunnyvale’s lower- and moderate-income households.  Goal 3: Housing Conservation and Maintenance. Maintain and enhance the condition and affordability of existing housing in Sunnyvale.
 Goal 4: Removal of Governmental Constraints. Minimize the impact of governmental constraints on the maintenance, improvement and development of housing.
 Goal 5: Equal Housing Opportunities and Special Needs. Promote equal housing opportunities for all residents, including Sunnyvale’s special needs populations, so that residents can reside in the housing of their choice.  Goal 6: Neighborhood Quality. Maintain sustainable neighborhoods with quality housing, infrastructure, and open space that fosters neighborhood character and the health of residents.

For each goal, the City developed a set of actions to carry out the goal. The actions specify objectives, primary responsibility, and an estimated timeframe for accomplishment. Some of these policies identify subsequent evaluations to provide or improve additional housing opportunities in the City’s designated Village Centers (Policy H-

1.3), El Camino Real Specific Plan area (Implementation Program H3), and in the East Sunnyvale Industrial to Residential area (Implementation Program H45).

2.2 PROJECT LOCATION
As shown in Figure 2-1, the City of Sunnyvale is located in the northwestern region of Santa Clara County and is within the nine-county San Francisco Bay Area. Sunnyvale’s norther border is situated with U.S. Route 101, which provides access to San Francisco, San Jose, Gilroy, and northern California. Sunnyvale is one of the major cities that compose the Silicon Valley. The San Francisco Bay Area borders Sunnyvale to the north, the City of Mountain View to the northwest, the City of Los Altos to the southwest, the City of Cupertino to the south, and the City of Santa Clara to the east.

2.3 PROJECT DESCRIPTION
The proposed City of Sunnyvale 2023-2031 Housing Element Update (hereafter referred to as the Housing Element Update or Project) would amend the City of Sunnyvale General Plan (General Plan) to update the Housing Element.

2.3.1 Project Objectives
The purpose of the Housing Element Update is to address the housing needs of the City and to meet the requirements of State law. Based on the goals of the project, the following objectives have been established for the purpose of this document:
 Provide adequate supply of land for housing;
 Reduce constraints to housing production, including through the promotion of accessory dwelling units;  Conserve and rehabilitate existing housing and neighborhoods;  Improve housing opportunities for special needs groups;  Preserve existing affordable housing stock and provision of affordable housing;  Promote the efficient use of energy in residences and improve the air quality of the City; and  Promote and affirmatively further fair housing opportunities for City residents.

Attachment 3

Source: Adapted by Ascent in 2023.

Figure 2-1 City of Sunnyvale City Limits
Attachment 3

2.4 REQUIRED ACTIONS
Implementation of the Housing Element Update would require the following discretionary actions by the Sunnyvale City Council:
 Adoption of the Initial Study/Negative Declaration for the Housing Element Update; and  Adoption of the Housing Element Update for the City of Sunnyvale through the General Plan amendment process.

In addition to adoption by the Sunnyvale City Council, the Housing Element Update will be submitted for review and certified by the California Department of Housing and Community Developmen t.

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3 ENVIRONMENTAL CHECKLIST

PROJECT INFORMATION

1. Project Title: City of Sunnyvale 2023 – 2031 Housing Element Update

2. Lead Agency Name and Address: City of Sunnyvale. 456 West Olive Avenue Sunnyvale, CA 94088-3707

3. Contact Person and Phone Number: Ryan Dyson, Housing Specialist, 408.730.7466

4. Project Location: Citywide, City of Sunnyvale

5. Project Sponsor’s Name and Address: N/A

6. General Plan Designation: various

7. Zoning: Various

8. Description of Project: The proposed City of Sunnyvale 2023-2031 Housing Element Update would amend the City of Sunnyvale General Plan to update the Housing Element. The proposed City of Sunnyvale 2023 – 2031 Housing Element Update would address City housing needs during the 2023 -2031 planning period, from January 31, 2023, to January 31, 2031.

9. Surrounding Land Uses and Setting:

The City of Sunnyvale is surrounded by the City of Mountain View to the northwest, the City of Los Altos to the southwest, the City of Cupertino to the south, and the City of Santa Clara to the east. All surrounding cities consist of urban land uses, such as residential, commercial, office, mixed use, public facilities, and industrial uses.

10. Other public agencies whose approval is required:

City of Sunnyvale and the California Department of Housing & Community Development (Housing Element certification)

11. Have California Native American tribes traditionally and culturally affiliated with the project area requested consultation pursuant to Public Resources Code section 21080.3.1? If so, is there a plan for consultation that includes, for example, the determination of significance of impacts to tribal cultural resources, procedures regarding confidentiality, etc.?
Pursuant to Public Resources Code section 21080.3.1, on June 7, 2023, the City of Sunnyvale contacted California Native American Tribes by sending an Assembly Bill (AB) 52 notification letters to tribes with an affiliation with the project area based on a list provided by the Native American Heritage Commission (NAHC). Under AB 52, Native American tribes have 30 days to respond and request further project information and request formal consultation. No requests for consultation were received by the City.

Attachment 3

ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:

The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a “Potentially Significant Impact” as indicated by the checklist on the following pages. Where noted below with a “Y” for yes, the topic with a potentially significant impact will be addressed in an environmental impact report. ☐ Aesthetics
☐ Agriculture and Forest Resources
☐ Air Quality
☐ Biological Resources
☐ Cultural Resources
☐ Energy
☐ Geology / Soils
☐ Greenhouse Gas Emissions
☐ Hazards / Hazardous Materials
☐ Hydrology / Water Quality
☐ Land Use / Planning
☐ Mineral Resources
☐ Noise
☐ Population / Housing
☐ Public Services
☐ Recreation
☐ Transportation
☐ Tribal Cultural Resources
☐ Utilities / Service Systems
☐ Wildfire
☐ Mandatory Findings of
Significance
☐ None
☐ None with Mitigation
Incorporated

Attachment 3

Ascent Environmental Checklist
City of Sunnyvale
2023 – 2031 Housing Element Update Initial Study 3-3
DETERMINATION (To be completed by the Lead Agency)
On the basis of this initial evaluation:

I find that the proposed project could not have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared.

Signature __________________________________________ Date ____ ___________________ Printed Name Ryan Dyson ________________________ Title _______Housing Specialist Agency City of Sunnyvale _________________________

10/16/2023
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EVALUATION OF ENVIRONMENTAL IMPACTS

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

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

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

4. “Negative Declaration: Less Than Significant With Mitigation Incorporated” applies where the incorporation of mitigation measures has reduced an effect from “Potentially Significant Impact” to a “Less Than Significant Impact.” The lead agency must describe the mitigation measures, and briefly explain how they reduce the effect to a less than significant level (mitigation measures from “Earlier Analyses,” as described in (5) below, may be cross-referenced).

5. Earlier analyses may be used where, pursuant to the tiering, program EIR, or other CEQA process, an effect has been adequately analyzed in an earlier EIR or negative declaration as allowed under CEQA Guidelines Section 15063(c)(3)(D).

Certified EIRs that address housing sites in 2023-2031 Housing Element Update include the following:
 Land Use and Transportation Element Update EIR, State Clearinghouse No. 2012032003 (LUTE EIR)  Downtown Specific Plan (DSP) EIR, State Clearinghouse No. 1998110816 (DSP EIR)  Downtown Specific Plan Amendments and Specific Development Project EIR, State Clearinghouse No. 2018052020 (2020 DSP EIR)
 Lawrence Station Area Plan (LSAP) Update Subsequent EIR, State Clearinghouse No. 2019012022 (LSAP Update SEIR)
 El Camino Real Specific Plan (ECRSP) EIR, State Clearinghouse No. 2017102082 (ECRSP EIR)  Moffett Park Specific Plan (MPSP) EIR, State Clearinghouse No. 2021080338 (MPSP EIR) In this case, a brief discussion should identify the following:
a) Earlier Analysis Used. Identify and state where they are available for review. b) Impacts Adequately Addressed. Identify which effects from the above checklist were within the scope of and adequately analyzed in an earlier document pursuant to applicable legal standards, and state whether such effects were addressed by mitigation measures based on the earlier analysis. c) Mitigation Measures. For effects that are “Less than Significant with Mitigation Measures Incorporated,” describe the mitigation measures which were incorporated or refined from the earlier document and the extent to which they address site-specific conditions for the project.

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

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

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8. This is only a suggested form, and lead agencies are free to use different formats; however, lead agencies should normally address the questions from this checklist that are relevant to a project’s environmental effects in whatever format is selected.

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

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3.1 AESTHETICS

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
I. Aesthetics.

Except as provided in Public Resources Code section
21099 (where aesthetic impacts shall not be considered
significant for qualifying residential, mixed-use residential, and employment centers), would the project:

a) Have a substantial adverse effect on a scenic vista? ☐ ☐ ☒ ☐ b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway?
☐ ☐ ☐ ☒
c) In non-urbanized areas, substantially degrade the
existing visual character or quality of public views of the site and its surroundings? (Public views are those
that are experienced from publicly accessible vantage
points.) If the project is in an urbanized area, would
the project conflict with applicable zoning and other
regulations governing scenic quality?
☐ ☐ ☒ ☐
d) Create a new source of substantial light or glare
which would adversely affect day or nighttime views
in the area?
☐ ☐ ☒ ☐

3.1.1 Environmental Setting
The Santa Clara Valley has a diversity of natural settings and landscapes that are unique in the San Francisco Bay Area. The valley is defined by San Francisco Bay to the north, the coastal mountain range to the west and south, and the Diablo Range to the east. San Francisco Bay and the mountain ranges that define the valley provide scenic views of lush evergreen forests, oak woodlands, bay lands, wetlands, and other natural features. The valley floor features a wide variety of settings, including high-technology employment centers, residential neighborhoods, and downtown settings, both large and small. There are also open space areas throughout the valley, including active and passive parks, golf courses, natural rivers, and stream corridors. Sunnyvale is almost entirely surrounded by the cities of Santa Clara, Cupertino, Los Altos, and Mountain View. Ninety-eight percent of Sunnyvale is built out. Continuing growth has resulted in diminishing vacant land in the city.

The most visible landmarks in Sunnyvale are the Moffett Federal Airfield dirigible hangars. These hangars are often difficult to see from within Sunnyvale but are visible throughout the Bay Area and orient air travelers flying into the region. Other landmarks in Sunnyvale include vertical landmarks such as the Libby Water Tower, historic landmarks such as the Murphy Avenue Commercial District, and horizontal landmarks such as the cherry orchards on Mathilda Avenue near El Camino Real. There are no designated scenic vistas, viewsheds, or scenic highway or roadway in the city.

The City regulates urban design through the Land Use and Transportation Element of the General Plan, Citywide Design Guidelines, City Municipal Code provisions, and design provisions of area plans .

Attachment 3

3.1.2 Discussion
a) Have a substantial adverse effect on a scenic vista? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to designated scenic vistas from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.12.1 (less than significant)
 DSP Draft EIR pages 5-16 through 5-21 (no impact)
 2020 DSP Draft EIR Impact AES-1 (less than significant)  LSAP Update Draft SEIR page 3.1-6 (no impact)
 ECRSP Draft EIR page 4-2 (no impact)
 MPSP Draft EIR Impact AES-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in physical changes affecting scenic vista s that would alter the conclusions of the above certified EIRs.
b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? No Impact. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to scenic resources within a state scenic highway (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.12.2 (no impact)
 DSP Draft EIR page 5-12 (no impact)
 2020 DSP Draft EIR Impact AES-1 (no impact)
 LSAP Update Draft SEIR page 3.1-6 (no impact)
 ECRSP Draft EIR page 4-2 (no impact)
 MPSP Draft EIR Impact AES-2 (no impact)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in physical changes affecting a scenic highway that would alter the conclusions of the above certified EIRs.
c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage points.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Attachment 3

Specific Plan, and the Moffett Specific Plan. Visual character and consistency with regulations governing scenic quality impacts from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.12.3 (less than significant)
 DSP Draft EIR Impact 5-1 and pages 5-15 through 5-21 (less than significant with mitigation)  2020 DSP Draft EIR Impact AES-1 (no impact)
 LSAP Update Draft SEIR Impact 3.1-1 (less than significant)  ECRSP Draft EIR Impact 3.1.1 (less than significant)
 MPSP Draft EIR Impact AES-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in physical changes affecting visual character or conflict with City urban design guidelines and standards that would alter the conclusions of the above certified EIRs. Subsequent housing development under proposed Housing Element Update would be subject area plan, specific plan, and City design standards that ensure urban design character is compatible with the area surrounding the housing. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations that would create new sources of nighttime light ing and glare.

Light and glare impacts from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.12.4 (less than significant)
 DSP Draft EIR Impact 5-2 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.1-2 (less than significant)  ECRSP Draft EIR Impact 3.1.2 (less than significant)
 MPSP Draft EIR Impact AES-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in physical changes affecting nighttime lighting and glare that would alter the conclusions of the above certified EIRs. Subsequent housing development under proposed Housing Element Update would be subject area plan, specific plan, and City light design and fixture standards that avoid glare and lighting impacts to adjoining land uses.

Attachment 3

3.2 AGRICULTURE AND FOREST RESOURCES

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
II. Agriculture and Forest Resources.

In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site
Assessment Model (1997, as updated) prepared by the
California Department of Conservation as an optional model to use in assessing impacts on agriculture and farmland.

In determining whether impacts to forest resources,
including timberland, are significant environmental effects, lead agencies may refer to information compiled by the
California Department of Forestry and Fire Protection
regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement
methodology provided in Forest Protocols adopted by the California Air Resources Board. Would the project:

a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural use?
☐ ☐ ☐ ☒
b) Conflict with existing zoning for agricultural use or a Williamson Act contract?
☐ ☐ ☐ ☒
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
☐ ☐ ☐ ☒
d) Result in the loss of forest land or conversion of
forest land to non-forest use?
☐ ☐ ☐ ☒
e) Involve other changes in the existing environment,
which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or
conversion of forest land to non-forest use?
☐ ☐ ☐ ☒

Attachment 3

3.2.1 Discussion
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use or a Williamson Act contract? c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Code section 4526), or timberland zoned Timberland Production (as defined by Government Code section 51104(g))?
d) Result in the loss of forest land or conversion of forest land to non-forest use? e) Involve other changes in the existing environment, which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forest land to non-forest use?
No Impact. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transpo rtation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to agriculture or forestry resources from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.1-10 (no impact)
 DSP Draft EIR page 17-3 (no impact)
 2020 DSP Draft EIR Impact AG-1 and AG-2 (no impact)
 LSAP Update Draft SEIR page 1-2 (no impact)
 ECRSP Draft EIR page 4-1 through 4-2 (no impact)
 MPSP Draft EIR impacts AG-1 through AG-5 (no impact)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts affecting agriculture and forestry resources as these resources do not exist in the City.

Attachment 3

3.3 AIR QUALITY

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
III. Air Quality.

Where available, the significance criteria established by the applicable air quality management district or air
pollution control district may be relied on to make the following determinations.

Are significance criteria established by the applicable air district available to rely on for significance
determinations? Would the project:

a) Conflict with or obstruct implementation of the
applicable air quality plan?
☐ ☐ ☒ ☐
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is
non-attainment under an applicable federal or state
ambient air quality standard?
☐ ☐ ☒ ☐
c) Expose sensitive receptors to substantial pollutant
concentrations?
☐ ☐ ☒ ☐
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
☐ ☐ ☒ ☐

3.3.1 Environmental Setting
The most recent air quality standards for NAAQS and the California Ambient Air Quality Standards (CAAQS) are summarized below in Table 5.3-1. Attainment status refers to whether the air quality for specific pollutants in a geographic area meets or is cleaner than adopted national and/or state standards. Areas that meet the national and/or state standards for those pollutants are called attainment areas, and those that do not meet the national and/or state standards are called nonattainment areas. Table 5.3-2 below summarizes the most recent attainment status of Santa Clara County.

Attachment 3

Table 3-1 National and California Ambient Air Quality Standards Pollutant Averaging Time CAAQSa,b NAAQSc Primaryb,d NAAQSc Secondaryb,e Ozone 1-hour 0.09 ppm (180 μg/m3) – Same as primary standard 8-hour 0.070 ppm (137 μg/m3) 0.070 ppm (147 μg/m3) Same as primary standard Carbon monoxide (CO) 1-hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) Same as primary standard 8-hour 9 ppmf (10 mg/m3) 9 ppm (10 mg/m3) Same as primary standard Nitrogen dioxide (NO2) Annual arithmetic mean 0.030 ppm (57 μg/m3) 53 ppb (100 μg/m3) Same as primary standard 1-hour 0.18 ppm (339 μg/m3) 100 ppb (188 μg/m3) —
24-hour 0.04 ppm (105 μg/m3) — —
Sulfur dioxide (SO2) 3-hour — — 0.5 ppm (1300 μg/m3) 1-hour 0.25 ppm (655 μg/m3) 75 ppb (196 μg/m3) —
Respirable particulate matter (PM10) Annual arithmetic mean 20 μg/m3 — Same as primary standard 24-hour 50 μg/m3 150 μg/m3 Same as primary standard
Fine particulate matter (PM2.5) Annual arithmetic mean 12 μg/m3 12.0 μg/m3 15.0 μg/m3 24-hour — 35 μg/m3 Same as primary standard
Lead f Calendar quarter — 1.5 μg/m3 Same as primary standard 30-Day average 1.5 μg/m3 — —
Rolling 3-Month Average – 0.15 μg/m3 Same as primary standard Hydrogen sulfide 1-hour 0.03 ppm (42 μg/m3) No national Standards No national Standards Sulfates 24-hour 25 μg/m3 No national Standards No national Standards Vinyl chloride f 24-hour 0.01 ppm (26 μg/m3) No national Standards No national Standards Visibility-reducing particulate
matter
8-hour Extinction of

0.23 per km No national Standards No national Standards Notes: CAAQS = California ambient air quality standards; NAAQS = national ambient air quality standards; µg/m = micrograms per cubic meter; km = kilometers; ppb = parts per billion; ppm = parts per million.

California standards for ozone, carbon monoxide, SO (1- and 24-hour), NO, particulate matter, 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.

Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based on a reference temperature of 25 degrees Celsius (°C) and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas.

National standards (other than ozone, particulate matter, and those based on annual averages or annual arithmetic means) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration in a year, averaged over three years, is equal to or less than the standard. The PM 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m is equal to or less than one. The PM 24-hour standard is attained when 98 percent of the daily concentrations, averaged over 3 years, are equal to or less than the standard. Contact the U.S. Environmental Protection Agency for further clarification and current federal policies.

National primary standards: The levels of air quality necessary, with an adequate margin of safety to protect public health.

National secondary standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.

The California Air Resources Board has identified lead and vinyl chloride as toxic air contaminants with no threshold of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

Source: EPA 2022a, CARB 2022a.

Attachment 3

Table 3-2 Attainment Status Designations for Santa Clara County Pollutant NAAQS CAAQS
Ozone Attainment (1-hour)1 Nonattainment (1-hour) Classification2 Nonattainment (8-hour)3 Classification –
Marginal Nonattainment (8-hour)
Nonattainment (8-hour)3 Classification –
Marginal Nonattainment (24-hour)
Respirable particulate matter
(PM10) Attainment (24-hour) Nonattainment (24-hour)
Attainment (24-hour) Nonattainment (Annual)
Fine particulate matter (PM2.5) Attainment (24-hour) (No State Standard for 24-Hour) Attainment (Annual) Nonattainment (Annual)
Carbon monoxide (CO) Attainment (Maintenance) (1-hour) Attainment (1-hour) Attainment (Maintenance) (8-hour) Attainment (8-hour)
Nitrogen dioxide (NO2) Attainment (Maintenance) (1-hour) Attainment (1-hour) Attainment (Maintenance) (Annual) Attainment (Annual)
Sulfur dioxide (SO2)4 Attainment (1-Hour) Attainment (1-hour) Attainment (3-month rolling avg.) Attainment (24-hour) Lead (Particulate) Attainment (3-month rolling avg.) Attainment (30-day average) Hydrogen Sulfide Unclassified (1-hour)
Sulfates No Federal Standard Attainment (24-hour)
Visibly Reducing Particles Unclassified (8-hour)
Vinyl Chloride Unclassified (24-hour)
Notes: NAAQS = national ambient air quality standards; CAAQS = California ambient air quality standards Air Quality meets federal 1-hour Ozone standard (77 FR 64036). EPA revoked this standard, but some associated requirements still apply.

Per Health and Safety Code Section 40921.5(c), the classification is based on 1989–1991 data, and therefore does not change. 2015 Standard.
2010 Standard.

Source: EPA 2022b; CARB 2022a; CARB 2022b.

The Bay Area Air Quality Management District (BAAQMD) maintains and manages air quality conditions in the San Francisco Bay Area Air Basin (SFBAAB), including Santa Clara County, through a comprehensive program of planning, regulation, enforcement, technical innovation, and promotion of the understanding of air quality issues. The clean air strategy of BAAQMD includes the preparation of plans and programs for the attainment of the NAAQS and CAAQS, adoption and enforcement of rules and regulations, and issuance of permits for stationary sources. BAAQMD also inspects stationary sources, responds to citizen complaints, monitors ambient air quality and meteorological conditions, and implements other programs and regulations required by the CAA and CCAA.

Projects located in the SFBAAB are subject to BAAQMD’s rules and regulations. B AAQMD also has 2022 CEQA
Guidelines. The Guidelines include nonbinding recommendations for how a lead agency can evaluate, measure, and mitigate air quality and climate impacts generated from land use construction and operational activities .

Attachment 3

3.3.2 Discussion
a) Conflict with or obstruct implementation of the applicable air quality plan? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict or obstruction to the air quality plan from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIR s:
 LUTE Draft EIR Impact 3.5.1 (less than significant)
 2020 DSP Draft EIR Impact AQ-1 (less than significant)  LSAP Update Draft SEIR page 3.2-15 through 3.2-18 (less than significant)  ECRSP Draft EIR Impact 3.2.1 (less than significant)
 MPSP Draft EIR Impact AIR-1 (less than significant)
The original DSP EIR did not address impacts related to the conflict or obstruction to air quality plans.

Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in the conflict or obstruction to the air quality plan that would alter the conclusions of the above certified EIRs.
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. The net increase of any criteria pollutant from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.5.2 and 3.5.3 (significant and unavoidable)  DSP Draft EIR pages 10-12 through 10-17 and Impact 10-2 (significant and unavoidable)  2020 DSP Draft EIR Impacts AQ-2 and AQ-3 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.2-1 (significant and unavoidable) and 3.2-2 (less than significant)  ECRSP Draft EIR Impact 3.2.2 (significant and unavoidable) and 3.2.3 (less than significant)  MPSP Draft EIR Impact AIR-2, AIR-3, and AIR-C (significant and unavoidable) Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in the cumulatively considerable net increase of any criteria pollutant that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address construction and operational air quality impacts.
c) Expose sensitive receptors to substantial pollutant concentrations? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. The exposure of sensitive receptors to substantial pollutant Attachment 3

concentrations from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.5.4, 3.5.5, and 3.5.6 (less than significant with mitigation)  DSP Draft EIR pages 10-9 through 10-17 and Impact 10-2 (significant and unavoidable)  2020 DSP EIR Impact AQ-4 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.2-3 and 3.2-4 (less than significant)  ECRSP Draft EIR Impact 3.2.4, 3.2.5, and 3.2.6 (less than significant with mitigation)  MPSP Draft EIR Impact AIR-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would expose sensitive receptors to substantial pollutant concentrations that would alter the conclusions of the above certified EIRs. Proposed Housing Element Update Policy H-5.15 would require the consideration of existing pollution burden levels when siting new affordable housing developments and encourage developers to provide mitigation measures to address the impact. d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts resulting in other emissions affecting a substantial number of people from development (including housing identified in the proposed Housing Element Update is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.5.7 (less than significant)
 2020 DSP Draft EIR Impact AIR-5 (less than significant)  LSAP Update Draft SEIR Impact 3.2-5 (less than significant)  ECRSP Draft EIR Impact 3.2.7 (less than significant)
 MPSP Draft EIR Impact AIR-5 (less than significant)
The original DSP EIR did not address odor impacts. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would adversely affect a substantial number of people that would alter the conclusions of the above certified EIRs.

Attachment 3

3.4 BIOLOGICAL RESOURCES

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IV. Biological Resources.

Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species
identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or
regulations, or by the California Department of Fish
and Wildlife or the U.S. Fish and Wildlife Service?
☐ ☐ ☒ ☐
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community
identified in local or regional plans, policies, or
regulations or by the California Department of Fish
and Wildlife or the U.S. Fish and Wildlife Service?
☐ ☐ ☒ ☐
c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
☐ ☐ ☒ ☐
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
☐ ☐ ☒ ☐
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree
preservation policy or ordinance?
☐ ☐ ☒ ☐
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state
habitat conservation plan?
☐ ☐ ☒ ☐

3.4.1 Environmental Setting
Sunnyvale is located along the southern San Francisco Bay. The interface of the city with the bay (east of Moffett Federal Airfield) provides some of the best natural areas in and around the city. Beyond this interstitial zone, Sunnyvale is built out, with few natural areas. Small patches of fresh emergent marsh occur, as well as segments of Stevens Creek, Calabazas Creek, and Moffett Channel.

Attachment 3

3.4.2 Discussion
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to special status species from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.9.1 (less than significant)
 DSP Draft EIR pages 14-5 through 14-6 (less than significant)  2020 DSP Draft EIR Impact BIO-1 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.4-1 (less than significant)  ECRSP Draft EIR Impact 3.3.1 (less than significant with mitigation)  MPSP Draft EIR Impact BIO-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would create impacts to special status species that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address special status species impacts. b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to riparian habitats or other sensitive natural communities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.9.2 (less than significant)
 DSP Draft EIR pages 14-5 through 14-6 (less than significant)  2020 DSP EIR Impact BIO-2 (less than significant)
 LSAP Update Draft SEIR page 3.4-15 (no impact)
 ECRSP Draft EIR page 4-3 (no impact)
 MPSP Draft EIR Impact BIO-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would create impacts to riparian habitats or other sensitive natural communities that would alter the conclusions of the above certified EIRs. These habitat conditions do not exist on the housing sites.

Attachment 3

c) Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to protected wetlands from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.9.2 (less than significant)
 DSP Draft EIR pages 14-5 through 14-6 (less than significant)  2020 DSP Draft EIR Impact BIO-2 (less than significant)  LSAP Update Draft SEIR page 3.4-15 (no impact)
 ECRSP Draft EIR page 4-3 (no impact)
 MPSP Draft EIR Impact BIO-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would create impacts to protected wetlands that would alter the conclusions of the above certified EIRs.

d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to the movement of resident or migratory wildlife from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.9.3 (less than significant)
 DSP Draft EIR pages 14-5 through 14-6 (less than significant)  2020 DSP Draft EIR Impact BIO-3 (less than significant)  LSAP Update Draft SEIR page 3.4-15 (no impact)
 ECRSP Draft EIR page 4-3 (no impact)
 MPSP Draft EIR Impact BIO-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would create impacts to the movement of resident or migratory wildlife that would alter the conclusions of the above certified EIRs. e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict or obstruction from local policies or ordinances protecting Attachment 3

biological resources from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.9.4 (less than significant)
 DSP Draft EIR page 14-6 (less than significant)
 2020 DSP Draft EIR Impact BIO-4 (less than significant)  LSAP Update Draft SEIR page 3.4-15 (no impact)
 ECRSP Draft EIR Impact 3.3.2 (less than significant with mitigation)  MPSP Draft EIR Impact BIO-5 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would conflict or obstruct local policies or ordinances protecting biological resources that would alter the conclusions of the above certified EIRs. f) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict with an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved conservation plan from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.9.4 (less than significant)
 DSP Draft EIR page 14-5 and 14-6 (less than significant)  2020 DSP Draft EIR BIO-5 (no impact)
 LSAP Update Draft SEIR page 3.4-15 (no impact)
 ECRSP Draft EIR page 4-3 (no impact)
 MPSP Draft EIR Impact BIO-6 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would conflict with an adopted h abitat conservation plan, natural community conservation plan, or other approved conservation plan that would alter the conclusions of the above certified EIRs. There are no adopted habitat conservation plans, natural community conservation plans, or other approved conservation plans that cover the City of Sunnyvale.

Attachment 3

3.5 CULTURAL RESOURCES

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
V. Cultural Resources.

Would the project:
a) Cause a substantial adverse change in the
significance of a historical resource pursuant to
Section 15064.5?
☐ ☐ ☒ ☐
b) Cause a substantial adverse change in the
significance of an archaeological resource pursuant
to Section 15064.5?
☐ ☐ ☒ ☐
c) Substantially disturb human remains, including those interred outside of formal cemeteries?
☐ ☐ ☒ ☐

3.5.1 Environmental Setting
The City of Sunnyvale maintains a Heritage Resources Inventory, containing landmarks, trees, residential and commercial districts, and individual structures of local importance. There are two main types of protected structures in Sunnyvale—heritage resources and local landmarks. A local landmark is the highest level of protection afforded by the City under its Code. Heritage resources have a somewhat lower level of protection.

3.5.2 Discussion
a) Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts that could cause a substantial adverse change in the significance of a historic resource from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.10.1 (significant and unavoidable)  DSP Draft EIR Impact 15-2 (less than significant with mitigation)  2020 DSP Draft EIR Impact CR-1 (significant and unavoidable)  LSAP Update Draft SEIR page 3.3-4 (no impact)
 ECRSP Draft EIR Impact 3.4.1 (less than significant with mitigation)  MPSP Draft EIR Impact CUL-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause a substantial adverse change in the significance of a historic resource or building that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address historic resource impacts.

Attachment 3

b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts that could cause a substantial adverse change in the significance of an archaeological resource from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.10.2 (less than significant)
 DSP Draft EIR Impact 15-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact CR-2 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.3-1 (less than significant)  ECRSP Draft EIR Impact 3.4.2 (less than significant with mitigation)  MPSP Draft EIR Impact CUL-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause a substantial adverse change in the significance of a n archaeological resource that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address archaeological resource impacts.

c) Substantially disturb human remains, including those interred outside of formal cemeteries?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts that could substantially disturb human remains from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.10.2 (less than significant)
 DSP Draft EIR Impact 15-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact CR-2 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.3-1 (less than significant)  ECRSP Draft EIR Impact 3.4.3 (less than significant)
 MPSP Draft EIR Impact CUL-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would substantially disturb human remains and alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address human remain impacts.

Attachment 3

3.6 ENERGY

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VI. Energy.

Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources, during project
construction or operation?
☐ ☐ ☒ ☐
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
☐ ☐ ☒ ☐

3.6.1 Environmental Setting
The City of Sunnyvale and the Cities of Campbell, Cupertino, Gilroy, Los Altos, Los Altos Hills, Los Gatos, Milpitas, Monte Sereno, Morgan Hill, Mountain View, and Saratoga, and unincorporated Santa Clara County are members of Silicon Valley Clean Energy (SVCE), which serves as the Community Choice Aggregation for its member communities.

SVCE works in partnership with the Pacific Gas and Electric Company (PG&E) to deliver direct, carbon free and renewable electricity to customers within its member jurisdictions. Consistent with state law, all electricity accounts in Sunnyvale were automatically enrolled in SVCE; however, customers can choose to opt out or remain with PG&E. In 2018 the State passed SB 100 in 2018 that requires 52 percent of electricity demand from renewables by 2027, 60 percent by 2030, and 100 percent by 2045. Since 2017, there have been two updates to Title 24, parts 6 and 11. Title 24, Part 6 has been updated to advance the onsite energy generation by encouraging electric heat pump technology and use, establishing electric-ready requirements when natural gas is installed, and expanding solar PV system and battery storage standards. Title 24, Part 11, also known as CALGreen, has been updated to include more stringent green building standards for statewide residential and nonresidential construction.

On August 13, 2019, the City adopted the Climate Action Playbook (Playbook), which builds upon the City’s previous Climate Action Plan (CAP 1.0) in 2014. The Playbook includes a Game Plan 2020, which contains the “next moves” for the City to demonstrate compliance with the state’s long-term climate change reduction goals including compliance with SB 32 and Executive Order [EO] S-3-05. According to the Sunnyvale Climate Action Plan Biennial Progress Report released in 2018, 98 percent of residential and commercial accounts received carbon-free electricity from SVCE (City of Sunnyvale 2018). Electricity is supplied to the city using infrastructure built and maintained by PG&E.

3.6.2 Discussion
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts resulting in wasteful, inefficient, or unnecessary consumption of energy resources from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:

Attachment 3

 LUTE Draft EIR Impact 3.11.4.1 (less than significant)  LSAP Update Draft SEIR Impact 3.5-1 (less than significant)  2020 DSP Draft EIR Impact EN-1 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.5.1 (less than significant)
 MPSP Draft EIR Impact EN-1 (less than significant)
The original DSP EIR does not address impacts related to energy. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in wasteful, inefficient, or unnecessary consumption of energy resources that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address energy impacts. b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict or obstruction with a state or local plan for renewable energy or energy efficiency from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LSAP Update Draft SEIR Impact 3.5-2 (less than significant)  2020 DSP Draft EIR Impact EN-2 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.5.2 (less than significant)
 MPSP Draft EIR Impact EN-2 (less than significant)
The original DSP EIR and LUTE EIR do not address impacts related to the conflict or obstruction with a state or local plan for renewable energy or energy efficiency. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would conflict or obstruct with a state or local plan for renewable energy or energy efficiency that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address energy impacts.

Attachment 3

3.7 GEOLOGY AND SOILS

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VII. Geology and Soils.

Would the project:
a) Directly or indirectly cause potential substantial
adverse effects, including the risk of loss, injury, or death involving:

i) Rupture of a known earthquake fault, as delineated
on the most recent Alquist-Priolo Earthquake Fault
Zoning Map issued by the State Geologist for the
area or based on other substantial evidence of a
known fault? (Refer to California Geological Survey
Special Publication 42.)
☐ ☐ ☒ ☐
ii) Strong seismic ground shaking? ☐ ☐ ☒ ☐
iii) Seismic-related ground failure, including
liquefaction?
☐ ☐ ☒ ☐
iv) Landslides? ☐ ☐ ☒ ☐
b) Result in substantial soil erosion or the loss of topsoil? ☐ ☐ ☒ ☐ c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the
project, and potentially result in on- or off-site
landslide, lateral spreading, subsidence, liquefaction, or collapse?
☐ ☐ ☒ ☐
d) Be located on expansive soil, as defined in Table 18-1- B of the Uniform Building Code (1994, as updated),
creating substantial direct or indirect risks to life or property?
☐ ☐ ☒ ☐
e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal
systems where sewers are not available for the
disposal of waste water?
☐ ☐ ☐ ☒
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
☐ ☐ ☒ ☐

3.7.1 Environmental Setting
Sunnyvale is located at the southern end of San Francisco Bay and is built atop the generally Holocene-age alluvial deposits that surround the margins of the bay. Near the immediate vicinity of San Francisco Bay (roughly 1,000 feet), Bay mud deposits are present. Generally, alluvial deposits increase in age toward the south where locally Late Pleistocene-age alluvial deposits occur. Sunnyvale’s topography is generally flat, gradually dropping in a northerly direction from an elevation of 300 feet to sea level.

Attachment 3

Three active faults are located near Sunnyvale: the Hayward fault (11.7 miles east), the San Andreas fault (7.5 miles west), and the Monte Vista-Shannon fault (4.3 miles west). There are also three potentially active faults in the city— the San Jose fault, the Stanford fault, and the Cascade fault.

The California Supreme Court decision (California Building Industry Association v. Bay Area Air Quality Management District (2015) 62 Cal.4th 369, 377) clarified CEQA with regard to the effects of existing environmental conditions on a project’s future users or residents. The effects of the environment on a project are generally outside the scope of CEQA unless the project would exacerbate these conditions. Changes to the CEQA Guidelines to reflect this decision have been adopted. Local agencies are not precluded from considering the impact of locating new development in areas subject to existing environmental hazards. However, CEQA cannot be used by a lead agency to require a developer or other agency to obtain an EIR or implement mitigation measures solely because the occupants or users of a new project would be subjected to the level of hazards specified. However, previous discussions of effects of the environment related to geology and soils is included herein for disclosure purposes.

3.7.2 Discussion
a) Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? (Refer to California Geological Survey Special Publication 42.)
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction? iv) Landslides?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to seismic hazards from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.7-14 and Impact 3.7.1 (less than significant)  DSP Draft EIR page 12-7 (less than significant)
 2020 DSP Draft EIR Impact GEO-1 (less than significant)  LSAP Update Draft SEIR page 3.6-2 (no impact)
 ECRSP Draft EIR pages 4-4 through 4-5 (no impact)
 MPSP Draft EIR Impact GEO-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in seismic hazards that would alter the conclusions of the above certified EIRs. Subsequent new housing development would be subject to California Building Code standards, as implemented by the City through Chapter 16.16 of the Municipal Code that address seismic hazards.

Attachment 3

b) Result in substantial soil erosion or the loss of topsoil? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to the increase in erosion and loss of topsoil from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.7.2 (less than significant)
 DSP Draft EIR Impact 12-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact GEO-2 (less than significant)  LSAP Update Draft SEIR page 3.6-2 (no impact)
 ECRSP Draft EIR Impact 3.6.2 (less than significant)
 MPSP Draft EIR Impact GEO-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in an increase in erosion and loss of topsoil that would alter the conclusions of the above certified EIRs. Subsequent housing development would be subject to City standards that water quality and soil erosion during construction activities as well as California Building Code Chapter 70 standards. c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. The development on unstable soils resulting in a seismic-related hazard from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.7.3 (less than significant)
 DSP Draft EIR Impact 12-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact GEO-3 (less than significant)  LSAP Update Draft SEIR page 3.6-2 (no impact)
 ECRSP Draft EIR Impact 3.6.3 (less than significant)
 MPSP Draft EIR Impact GEO-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would be located on unstable soils that would alter the conclusions of the above certified EIRs. The City requires preparation of geotechnical reports for all development projects. These geotechnical reports would include soil sampling and laboratory testing to determine the soil’s susceptibility to expansion and differential settlement and would provide recommendations for design and construction methods to reduce potential impacts, as necessary.
d) Be located on expansive soil, as defined in the current California Building Code, creating substantial direct or indirect risks to life or property? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, Attachment 3

and the Moffett Specific Plan. The development on expansive soils resulting in hazards to development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.7.3 (less than significant)
 DSP Draft EIR Impact 12-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact GEO-3 (less than significant)  LSAP Update Draft SEIR page 3.6-2 (no impact)
 ECRSP Draft EIR Impact 3.6.3 (less than significant)
 MPSP Draft EIR Impact GEO-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would be located on expansive soils that would alter the conclusions of the above certified EIRs. The City requires preparation of geotechnical reports for all development projects. These geotechnical reports would include soil sampling and laboratory testing to determine the soil’s susceptibility to expansion and differential settlement and would provide recommendations for design and construction methods to reduce potential impacts, as necessary.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
No Impact. All development in the City is served by a public wastewater conveyance and treatment system operated and maintained by the City of Sunnyvale. All future housing development would use public wastewater systems. f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to paleontological resources from development (including housing identified in the proposed Housing Element Update) is addressed in the followi ng EIRs:
 LUTE Draft EIR Impact 3.7.4 (less than significant)
 DSP Draft EIR pages 15-8 through 15-12 (less than significant)  LSAP Update Draft SEIR Impact 3.6-1 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.6.4 (less than significant with mitigation)  MPSP Draft EIR Impact GEO-6 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would have impacts related to paleontological resources that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address paleontological resource impacts.

Attachment 3

3.8 GREENHOUSE GAS EMISSIONS

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
VIII. Greenhouse Gas Emissions.

Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
☐ ☐ ☒ ☐
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
☐ ☐ ☒ ☐

3.8.1 Environmental Setting
On August 13, 2019, the City adopted the Climate Action Playbook (Playbook), which builds upon the City’s previous Climate Action Plan (CAP 1.0) in 2014. Through implementation of measures in CAP 1.0, the City experienced a 12 percent decrease below 1990 emissions levels in 2016. In 2016, the City emitted 880,000 metric tons of carbon dioxide equivalent (MTCO
2e). To demonstrate compliance with the state’s long-term climate change reduction goals, the City must achieve an interim target of a 56 percent reduction below 1990 levels by 2030 (SB 32) with the goal of meeting the state’s target of 80 percent below 1990 emissions by 2050 (Executive Order [EO] S-3-05). The Playbook includes a Game Plan 2020, which contains the “next moves” for the City and contains 46 actions that were implemented over the last 3 years (2019–2022). Several Playbook next moves are directly applicable to land use development projects. The City requires land use development projects to adhere to the CAP as a condition of approval.

Below is a summary of greenhouse gas (GHG) executive orders, plans, policies, or regulations  EO B-55-18: This executive order, signed September 10, 2018, sets a goal “to achieve carbon neutrality as soon as possible, and no later than 2045, and achieve and maintain net negative emissions thereafter.”  Scoping Plan Update: EO B-30-15 and SB 32 require CARB to prepare another update to the Scoping Plan to address the 2030 target for the state. On December 15, 2022, CARB approved the 2022 Climate Change Scoping Plan Update which outlines potential programs and policies designed to meet the state’s long term 2045 GHG emissions goal. Also, the 2022 Scoping Plan Update adopts a new, more ambitious GHG goal for 2030 by aiming to reduce GHG emissions by 48 percent below 1990 levels. The plan includes strategies consistent with Assembly Bill (AB) 197 requirements.
 2017 Update to the SB 375 Targets: Under SB 375, CARB is required to update the emission reduction targets for the metropolitan planning organizations every 8 years. CARB adopted the updated targets and methodology in March 2018. Subsequent sustainable community strategies adopted after this date are subject to these new targets.  SB 100: SB 100 raises California’s Renewables Portfolio Standard requirements to 60 percent by 2030, with interim targets, and 100 percent by 2045. The bill also establishes a state policy that eligible renewable energy resources and zero-carbon resources supply 100 percent of all retail sales of electricity to California end-use customers and 100 percent of electricity procured to serve all state agencies by December 31, 2045. Under the bill, the state cannot increase carbon emissions elsewhere in the western grid or allow resource shuffling to achieve the 100 percent carbon free electricity target.
 Building Energy Efficiency Standards: Energy conservation standards for new residential and nonresidential buildings were adopted by the California Energy Resources Conservation and Development Commission (now the California Energy Commission) in June 1977 and most recently revised in 2016 (Title 24, Part 6, of the Attachment 3

California Code of Regulations). Title 24 requires the design of building shells and building compon ents to conserve energy. The standards are updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods. The 2019 Building Energy Efficiency Standards, which were adopted on May 9, 2018, went into effect starting January 1, 2020. The 2022 Building Energy Efficiency Standards went into effect on January 1, 2023, and will result in more energy efficiency buildings than the 2019 standards.  CALGreen Updates: CALGreen established planning and design standards for sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and internal air contaminants. The recently adopted 2019 standards went into effect on January 1, 2020. Each iteration of the CALGreen standards improves the energy efficiency and sustainability of new development from the prior iteration. The current iteration went into effect on January 1, 2023.  Senate Bill 743: Requires transportation CEQA impacts to no longer consider congestion but instead focus on the impacts of VMT. The Governor’s Office of Planning and Research (OPR) technical advisory explains that this criterion is consistent with Public Resources Code Section 21099, which states that the criteria for determining significance must “promote the reduction in greenhouse gas emission” (Governor’s Office of Planning and Research 2018). This metric is intended to replace the use of delay and level of service to measure transportation - related impacts.
 2022 BAAQMD Justification Report: BAAQMD released its 2022 Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans, which contains recommended thresholds of significance for use in determining whether a project will have a significant impact on climate change. BAAQMD recommends that the thresholds of significance identified in the 2022 BAAQMD Justification Report be used by public agencies for CEQA compliance. In its analysis, BAAQMD found that a new land use development project being built today needs to incorporate design elements to do its “fair share” of implementing the goal of carbon neutrality by 2045. If a project is designed and built to incorporate the design elements identified in the 2022 Justification Report, then the project will contribute its portion of what is necessary to achieve California’s long-term climate goals—its “fair share”—and an agency reviewing the project under CEQA can conclude that the project will not make a cumulatively considerable contribution to global climate change. The thresholds for land use projects include two options, either option “A” or option “B.” Option “A” requires that projects incorporate building design elements (such as excluding natural gas appliances or natural gas plumbing, in both residential and nonresidential development; and avoiding any wasteful, inefficient, or unnecessary energy usage as determined by the analysis required under CEQA Section 21100(b)(3) and Section 15126.2(b) of the State CEQA Guidelines) and transportation design elements (such as achieving a reduction in project-generated VMT for residential projects at 15 percent below the existing VMT per capita; and achieving compliance with off-street electric vehicle requirements in the most recently adopted version of CALGreen Tier 2). Option “B” requires projects be consistent with a local GHG reduction strategy that meets the criteria under State CEQA Guidelines Section 15183.5(b).
 Nonresidential and Multifamily Reach Codes: The City of Sunnyvale Reach Codes are building codes that exceed the State’s standard energy construction codes. The California Energy Commission sets standards (California Energy Code) for energy efficiency to reduce GHG emissions. The Reach Codes exceed the California Energy Code requirements to accelerate the reduction of GHG emissions. Reach Codes apply to new buildings.

3.8.2 Discussion
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and Attachment 3

the Moffett Specific Plan. The generation of greenhouse gas emissions having an impact on the environment from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.13.1 (less than significant with mitigation)  2020 DSP Draft EIR Impact GHG-1 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.7-1 (less than significant)  ECRSP Draft EIR Impact 3.7.1 (less than significant)
 MPSP Draft EIR Impact GHG-1 (significant and unavoidable) The original DSP EIR did not address impacts related to greenhouse gas emissions. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would generate greenhouse gas emissions impacting the environment that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address GHG emission impacts. b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transporta tion Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict with an applicable plan, policy or regulation adopted to reduce greenhouse gas emissions from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.13.1 (less than significant with mitigation)  2020 DSP Draft EIR Impact GHG-2 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.7-1 (less than significant)  ECRSP Draft EIR Impact 3.7.2 (less than significant)
 MPSP Draft EIR Impact GHG-2 (significant and unavoidable) The original DSP EIR did not address impacts related to greenhouse gas emissions. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would conflict with an applicable plan, policy or regulation adopted to reduce greenhouse gas emissions that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address GHG emission impacts.

Attachment 3

3.9 HAZARDS AND HAZARDOUS MATERIALS

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
IX. Hazards and Hazardous Materials.

Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
☐ ☐ ☒ ☐
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and/or accident conditions involving the release of
hazardous materials into the environment?
☐ ☐ ☒ ☐
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
☐ ☐ ☒ ☐
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or
the environment?
☐ ☐ ☒ ☐
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within
two miles of a public airport or public use airport,
would the project result in a safety hazard or
excessive noise for people residing or working in the
project area?
☐ ☐ ☒ ☐
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
☐ ☐ ☒ ☐
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury, or death involving wildland fires?
☐ ☐ ☒ ☐

3.9.1 Environmental Setting
Sunnyvale has been home to many innovative high tech companies. New and emerging technology companies (e.g., solar cell companies and LED manufacturers), whose presence contributes to a thriving and diverse business community, require the use of a large variety of hazardous materials, including highly toxic compressed gases. The highest hazard facilities, those with larger quantities of hazardous materials or materials having greater toxicity, are generally located in the industrial area in the northern part of the city.

Sunnyvale is in the landing pattern of Moffett Federal Airfield and when south winds blow, planes take off over heavily developed areas. Risk of future accidents exists even though the Navy’s usage of Moffett Field as a Naval Air Station ended in 1994. The Moffett Federal Airfield Comprehensive Land Use Plan (CLUP) was adopted in 2012. This plan sets standards on reviewing land use around Moffett Federal Airfield.

Attachment 3

A wildfire is an uncontrolled fire spreading through vegetative fuels, posing danger, and causing destruction to life and property. Wildfires can occur in undeveloped areas and spread to urban areas where structures and other human development are more concentrated. Because Sunnyvale is urban and because the City has a strong facilities inspection and fire education program, wildfire hazards are minimized.

3.9.2 Discussion
a) Create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Hazards to the public or environment from the transport, use, or disposal of hazardous materials from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.3.1 (less than significant)
 DSP Draft EIR pages 13-10 through 13-13 (less than significant)  2020 DSP Draft EIR HAZ-1 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.8-1 and 3.8-2 (less than significant)  ECRSP Draft EIR Impact 3.8.1 (less than significant)
 MPSP Draft EIR Impact HAZ-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would create hazards to the public or environment from the transport, use, or disposal of hazardous materials that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address hazard impacts. b) Create a significant hazard to the public or the environment through reasonably foreseeable upset and/or accident conditions involving the release of hazardous materials into the environment?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Accidental release and exposure to hazardous materials from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.3.2 (less than significant)
 DSP Draft EIR pages 13-10 through 13-13 (less than significant)  2020 DSP Draft EIR HAZ-1 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.8-1 and 3.8-2 (less than significant)  ECRSP Draft EIR Impact 3.8.2 (less than significant)
 MPSP Draft EIR Impact HAZ-2 (less than significant with mitigation) Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause an accidental release and exposure to hazardous materials Attachment 3

that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address hazard impacts. c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Exposure of hazardous emissions or materials within one-quarter mile of an existing or proposed school from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.3.3 (less than significant)
 DSP Draft EIR pages 13-10 through 13-13 (less than significant)  2020 DSP Draft EIR Impact HAZ-2 (no impact)
 LSAP Update Draft SEIR Impact 3.8-3 (less than significant)  ECRSP Draft EIR Impact 3.8.3 (less than significant)
 MPSP Draft EIR Impact HAZ-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause exposure of hazardous emissions or materials within one- quarter mile of an existing or proposed school that would alter the conclusions of the above certified EIRs. d) Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts from hazardous materials sites (including sites that may be on the list of hazardous materials sites compiled pursuant to Government Code Section 65962.5) creating a significant hazard from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.3.2 (less than significant)
 DSP Draft EIR pages 13-10 through 13-13 (less than significant)  2020 DSP Draft EIR HAZ-3 (no impact)
 LSAP Update Draft SEIR Impact 3.8-4 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.8.4 (less than significant with mitigation)  MPSP Draft EIR Impact HAZ-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause significant hazards from being on a hazardous materials site that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address hazard impacts.

Attachment 3

e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts associated with safety hazards towards people working or residing in the vicinity of a public and private airports from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.3.4 (less than significant)
 2020 DSP Draft EIR HAZ-4 (less than significant with mitigation)  LSAP Update Draft SEIR page 3.8-15 (no impact)
 ECRSP Draft EIR Impact 3.8.5 (less than significant with mitigation)  MPSP Draft EIR Impact HAZ-5 (less than significant)
The original DSP EIR does not discuss aviation hazards. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause safety hazards towards people working or residing in the vicinity of a public and private airports that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address airport impacts. f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to an adopted emergency response plan or evacuation plan from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.3.5 (less than significant)
 DSP Draft EIR pages 13-10 through 13-13 (less than significant)  2020 DSP Draft EIR Impact HAZ-5 (less than significant)  LSAP Update Draft SEIR Impact 3.8.5 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.8.6 (less than significant)
 MPSP Draft EIR Impact HAZ-6 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would interfere with an adopted emergency response plan or evacuation plan that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address emergency access and emergency response impacts.

Attachment 3

g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Pla n, El Camino Real Specific Plan, and the Moffett Specific Plan. Hazardous impacts related to wildland fires from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.3-15 (no impact)
 2020 DSP Draft EIR Impact HAZ-6 (no impact)
 LSAP Update Draft SEIR page 3.8-15 (no impact)
 ECRSP Draft EIR Impact 3.8.7 (less than significant)
 MPSP Draft EIR Impact HAZ-7 (no impact)
The original DSP Draft EIR does not discuss hazardous impacts related to wildland fires. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would cause hazardous impacts related to wildland fires that would alter the conclusions of the above certified EIRs.

Attachment 3

3.10 HYDROLOGY AND WATER QUALITY

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
X. Hydrology and Water Quality.

Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade
surface or groundwater quality?
☐ ☐ ☒ ☐
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge such
that the project may impede sustainable groundwater
management of the basin?
☐ ☐ ☒ ☐
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the
course of a stream or river or through the addition of
impervious surfaces, in a manner which would:
☐ ☐ ☒ ☐
i) Result in substantial on- or offsite erosion or siltation; ☐ ☐ ☒ ☐ ii) Substantially increase the rate or amount of
surface runoff in a manner which would result in
flooding on- or offsite;
☐ ☐ ☒ ☐
iii) Create or contribute runoff water which would
exceed the capacity of existing or planned
stormwater drainage systems or provide
substantial additional sources of polluted runoff; or
☐ ☐ ☒ ☐
iv) Impede or redirect flood flows? ☐ ☐ ☒ ☐
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
☐ ☐ ☒ ☐
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
☐ ☐ ☒ ☐

3.10.1 Environmental Setting
Natural regional drainage courses convey rainfall runoff from the southwest portion of Sunnyvale to Stevens Creek and in the east to Calabazas Creek. The regional flood control agency is the Santa Clara Valley Water District (SCVWD). The SCVWD provides flood control protection throughout Santa Clara County, including Sunnyvale. To provide flood protection of urbanized areas, the SCVWD constructed three open channels (Sunnyvale West, Sunnyvale East, and El Camino) to increase drainage capacity to San Francisco Bay. A system of levees protects Sunnyvale at its northern border from encroachment of San Francisco Bay waters. Some of these levees were constructed and remain in the ownership and operation of the Cargill Salt Company. Stormwater runoff in low-lying portions of the city is pumped out over the levees for discharge into San Francisco Bay by Sunnyvale-owned and operated pump stations. The City of Sunnyvale is not located within an area subject to a sustainable groundwater plan.

Attachment 3

3.10.2 Discussion
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to water quality from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.8.1 (less than significant)
 DSP Draft EIR Impact 11-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact HYD-1 (less than significant)  LSAP Update Draft SEIR Impact 3.9-1 (less than significant)  ECRSP Draft EIR Impact 3.9.1 (less than significant)
 MPSP Draft EIR Impact HYD-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts to water quality that would alter the conclusions of the above certified EIRs. Subsequent housing development would be subject to Sunnyvale Municipal Code Chapter

12.60 water quality requirements for construction and drainage improvements. b) Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to groundwater supplies or groundwater recharge from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.11.1.2 (less than significant)  DSP Draft EIR Impact 11-1 (less than significant with mitigation)  2020 DSP Draft EIR Impact HYD-2 (less than significant)  LSAP Update Draft SEIR Impact 3.9-2 (less than significant)  ECRSP Draft EIR Impact 3.9.2 (less than significant)
 MPSP Draft EIR Impact HYD-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts to groundwater supplies or groundwater recharge that would alter the conclusions of the above certified EIRs.

Attachment 3

c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i) R esult in substantial on- or offsite erosion or siltation; ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite;
iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
iv) Impede or redirect flood flows?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to existing drainage patters from development (in cluding housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.8.1 and 3.8.2 (less than significant)  DSP Draft EIR pages 11-13 through 11-15 (less than significant)  2020 DSP Draft EIR Impact HYD-3 (less than significant with mitigation)  LSAP Update Draft SEIR page 3.9-5 (no impact)
 ECRSP Draft EIR Impact 3.9.3 (less than significant)
 MPSP Draft EIR Impact HYD-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts to drainage patterns that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with Sunnyvale Municipal Code Chapter 12.60 and adopted mitigation measures identified in these EIRs that address hydrologic and water quality impacts.
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to the release of pollutants from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.8.3 (less than significant)
 DSP Draft EIR pages 11-13 through 11-15 (less than significant)  2020 DSP Draft EIR Impact HYD-4 (less than significant)  LSAP Update Draft SEIR page 3.9-5 (less than significant)  ECRSP Draft EIR Impact 3.9.4 (less than significant)
 MPSP Draft EIR Impact HYD-4 (less than significant)
Attachment 3

Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts related to the release of pollutants that would alter the conclusions of the above certified EIRs.
e) C onflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict or obstruction with a water quality control plan or sustainable groundwater management plan from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.8.1 (less than significant)
 DSP Draft EIR pages 11-13 through 11-15 (less than significant)  2020 DSP Draft EIR Impact HYD-1 (less than significant)  LSAP Update Draft SEIR page 3.9-5 (less than significant)  ECRSP Draft EIR Impact 3.9.5 (less than significant)
 MPSP Draft EIR Impact HYD-5 (less than significant)
As noted above, the City of Sunnyvale is not located within an area subject to a sustainable groundwater plan .

Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in conflict or obstruction with a water quality control plan that would alter the conclusions of the above certified EIRs.

Attachment 3

3.11 LAND USE AND PLANNING

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XI. Land Use and Planning.

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

3.11.1 Environmental Setting
The City of Sunnyvale is largely built out and consists of a mix of residential, commercial, and office uses. Land uses are regulated by the Land Use and Transportation Element (LUTE) and City Municipal Code.

3.11.2 Discussion
a) Physically divide an established community?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts related to the division of an established community from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.1.1 (less than significant)
 DSP Draft EIR page 4-20 (less than significant)
 2020 DSP Draft EIR Impact LU-1 (less than significant)  LSAP Update Draft SEIR Impact 3.10-1 (less than significant)  ECRSP Draft EIR pages 4-5 through 4-6 (no impact)
 MPSP Draft EIR Impact LU-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would divide an established community that would alter the conclusions of the above certified EIRs.
b) Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict with land use plan, policy, or regulations from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:

Attachment 3

 LUTE Draft EIR Impact 3.1.2 (less than significant)
 DSP Draft EIR Impact 4-1 (significant and unavoidable)  2020 DSP Draft EIR Impact LU-2 (less than significant)  LSAP Update Draft SEIR Impact 3.10-2 (less than significant)  ECRSP Draft EIR Impact 3.10.1 (less than significant)  MPSP Draft EIR Impact LU-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose any new policy provisions that would conflict with land use plans, policies, or regulations that protect the environment or would alter the conclusions of the above certified EIRs.

Attachment 3

3.12 MINERAL RESOURCES

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XII. Mineral Resources.

Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and
the residents of the state?
☐ ☐ ☐ ☒
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local
general plan, specific plan, or other land use plan?
☐ ☐ ☐ ☒

3.12.1 Environmental Setting
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to mineral resources from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.1-14 (no impact)
 DSP Draft EIR page 17-3 (no impact)
 2020 DSP Draft EIR Impact MIN-1 (no impact)
 LSAP Update Draft SEIR page 1-3 (no impact)
 ECRSP Draft EIR pages 4-5 through 4-6 (no impact)
 MPSP Draft EIR Impact MIN-1 and MIN-2 (no impact)
As documented in these EIRs, there are no known significant mineral resources located within the City.

Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would impact mineral resources that would alter the conclusions of the above certified EIRs.

Attachment 3

3.13 NOISE

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIII. Noise.

Would the project result in:
a) Generation of a substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable
standards of other agencies, or a substantial
temporary or permanent increase in noise levels
above existing ambient levels that could result in an
adverse effect on humans?
☐ ☐ ☒ ☐
b) Generation of excessive groundborne vibration or
groundborne noise levels?
☐ ☐ ☒ ☐
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a
plan has not been adopted, within two miles of a
public airport or public use airport, would the project expose people residing or working in the project area
to excessive noise levels?
☐ ☐ ☒ ☐

3.13.1 Environmental Setting
Major noise sources in the city consist of transportation sources and community sources. Major roadways cause most of the ambient noise in Sunnyvale. Highways include US Highway 101 (US 101), Interstate 280, State Route (SR) 85, and SR 237. Major local roadways include Mathilda Avenue, Wolfe Road, Lawrence Expressway, El Camino Real (SR 82), and Homestead Road. Mary Avenue, Hollenbeck Road, Fremont Avenue, and Remington Drive generate less noise than area highways, but they are adjoined by a large number of residences and therefore contribute to residential noise exposure in Sunnyvale.

Aircraft operations at Moffett Federal Airfield contribute to the noise environment in northwest Sunnyvale. Northeast Sunnyvale is also affected by San Jose International Airport flight patterns. Commuter and freight train operations affect noise levels in central Sunnyvale. Light rail and Caltrain operations also create transportation noise in the city.

Stationary noise sources in the city include light industrial and manufacturing facilities.

Attachment 3

3.13.2 Discussion
a) Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies, or a substantial temporary or permanent increase in noise levels above existing ambient levels that could result in an adverse effect on humans?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Generation of noise levels in excess of standards from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.6.1 (significant and unavoidable) and 3.6.2 (less than significant)  DSP Draft EIR Impact 9-1 and 9-2 (less than significant with mitigation)  2020 DSP Draft EIR Impact NOI-1 (less than significant with mitigation), NOI-3 (less than significant, and NOI-4 (significant and unavoidable)
 LSAP Update Draft SEIR Impact 3.11-1, 3.11-3, and 3.11-4 (less than significant)  ECRSP Draft EIR Impact 3.11.1 (less than significant with mitigation)  MPSP Draft EIR Impact NOI-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would generate noise levels in excess of standar d that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address noise impacts. b) G eneration of excessive groundborne vibration or groundborne noise levels? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, and amendments Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Generation of excessive groundborne vibration or noise levels from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.6.3 (less than significant with mitigation)  DSP Draft EIR pages 9-11 through 9-18 (less than significant with mitigation)  2020 DSP Draft EIR Impact NOI-2 (less than significant)  LSAP Update Draft SEIR Impact 3.11-2 (less than significant)  ECRSP Draft EIR Impact 3.11.2 (less than significant with mitigation)  MPSP Draft EIR Impact NOI-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would generate groundborne vibration or noise levels that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address vibration impacts.

Attachment 3

c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Exposing people residing or working within two miles of a public or private use airport to excess noise levels from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.6.5 (less than significant)
 DSP Draft EIR page 9-11 (no impact)
 2020 DSP Draft EIR Impact NOI-5 (no impact)
 LSAP Update Draft SEIR page 3.11-10 (no impact)
 ECRSP Draft EIR page 3.11-10 (no impact)
 MPSP Draft EIR Impact NOI-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that expose people residing or working within two miles of a public or private use airport to excessive ambient noise levels from airport operations that would alter the conclusions of the above certified EIRs.

Attachment 3

3.14 POPULATION AND HOUSING

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIV. Population and Housing.

Would the project:
a) Induce substantial unplanned population growth in
an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
☐ ☐ ☒ ☐
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
☐ ☐ ☒ ☐

3.14.1 Environmental Setting
The proposed Housing Element Table 3-2 identifies that the City of Sunnyvale’s population is anticipated to increase from 149,935 persons in 2020 to 222,210 persons in 2040. Table 3-4 of the proposed Housing Element identifies that jobs are anticipated to grow from 92,305 in 2020 to 108,640 jobs in 2040.

3.14.2 Discussion
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Substantial unplanned population growth from development (including housing identified in the proposed Housing Element Update) is addressed in the following EI Rs:
 LUTE Draft EIR Impact 3.2.1 (less than significant)
 DSP Draft EIR pages 6-5 through 6-7 (less than significant)  2020 DSP Draft EIR Impact POP-1 (less than significant)  LSAP Update Draft SEIR Impact 3.12-1 (less than significant)  ECRSP Draft EIR Impact 3.12.1 (less than significant)  MPSP Draft EIR Impact POP-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that induce substantial unplanned population growth that would alter the conclusions of the above certified EIRs.

Attachment 3

b) Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Displacement of a substantial number of people or housing from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.2.2 (less than significant)
 DSP Draft EIR pages 6-5 through 6-7 (less than significant)  2020 DSP Draft EIR Impact POP-2 (less than significant)  LSAP Update Draft SEIR page 3.12-5 (no impact)
 ECRSP Draft EIR Impact 3.12.2 (less than significant)  MPSP Draft EIR Impact POP-2 (no impact)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that displace a substantial number of people or housing that would alter the conclusions of the above certified EIRs.

Attachment 3

3.15 PUBLIC SERVICES

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XV. Public Services.

Would the project:
a) Result in substantial adverse physical impacts
associated with the provision of new or physically
altered governmental facilities, or the need for new
or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times, or other
performance objectives for any of the public services:

Fire protection? ☐ ☐ ☒ ☐
Police protection? ☐ ☐ ☒ ☐
Schools? ☐ ☐ ☒ ☐
Parks? ☐ ☐ ☒ ☐
Other public facilities? ☐ ☐ ☒ ☐

3.15.1 Environmental Setting
The City of Sunnyvale provides the following public services through the following departments:
 Fire protection: Department of Public Safety Bureau of Fire Services (Fire Bureau)  Law enforcement: Department of Public Safety Bureau of Police Services (Police Bureau)  Parks and recreation services: Department of Library and Recreation Services Sunnyvale residents are served by four public school districts: Sunnyvale School District, Cupertino Union School District, Santa Clara Unified School District, and Fremont Union High School District .

3.15.2 Discussion
a) Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives for any of the public services:

Fire protection?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Increased demand in fire protection services from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:

Attachment 3

 LUTE Draft EIR Impact 4.1.1 (less than significant)
 DSP Draft EIR pages 8-14 through 8-16 (less than significant)  2020 DSP Draft EIR Impact PS-1 (less than significant)  LSAP Update Draft SEIR Impact 3.13-1 (less than significant)  ECRSP Draft EIR Impact 3.13.1 (less than significant)  MPSP Draft EIR Impact PS-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that increase demand in fire protection services that would alter the conclusions of the above certified EIRs.

Police protection?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Increased demand in police protection services from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 4.2.1 (less than significant)
 DSP Draft EIR pages 8-11 through 8-12 (less than significant)  2020 DSP Draft EIR Impact PS-2 (less than significant)  LSAP Update Draft SEIR Impact 3.13-1 (less than significant)  ECRSP Draft EIR Impact 3.13.2 (less than significant)  MPSP Draft EIR Impact PS-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that increase demand in police protection services that would alter the conclusions of the above certified EIRs.

Schools?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Increased demand in public schools from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 4.3.1 (less than significant)
 DSP Draft EIR pages 8-17 through 8-18 (less than significant)  2020 DSP Draft EIR Impact PS-3 (less than significant)  LSAP Update Draft SEIR Impact 3.13-2 (less than significant)  ECRSP Draft EIR Impact 3.13.3 (less than significant)  MPSP Draft EIR Impact PS-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that increase demand in public schools that would alter the conclusions of the above certified EIRs.

Attachment 3

Parks?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Increased demand in parks and recreational facilities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 4.4.1 (less than significant)
 DSP Draft EIR pages 8-25 through 8-26 (less than significant)  2020 DSP Draft EIR Impact PS-5 (less than significant)  LSAP Update Draft SEIR Impact 3.13-3 (less than significant)  ECRSP Draft EIR Impact 3.14.1 and 3.14.2 (less than significant)  MPSP Draft EIR Impact PS-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that increase demand in parks and recreational facilities that would alter the conclusions of the above certified EIRs.

Other public facilities?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Increased demand in other public facilities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 DSP Draft EIR pages 8-1 through 8-29 (less than significant)  2020 DSP Draft EIR PS-4 (less than significant)
 ECRSP Draft EIR Impact 3.13.4 (less than significant)  MPSP Draft EIR Impact PS-5 (less than significant)
The LUTE EIR and LSAP Update SEIR did not address impacts related to other public facilities. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that increase demand in other public facilities that would alter the conclusions of the above certified EIRs.

Attachment 3

3.16 RECREATION

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVI. Recreation.

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

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

3.16.1 Environmental Setting
Approximately 773 acres, over 7 percent of the area within Sunnyvale’s incorporated city limits, is devoted to park and recreation facilities owned or maintained by the City for public use, including 185 acres of parks, 264 acres of special use facilities, 87 acres of school open space, three acres of public grounds, and 48 acres of greenbelts and trails. The City’s parkland total includes other recreational facilities such as the John W. Christian Greenbelt, a senior center, tennis courts, and a skate park. The nearest public parks and recreational facilities to Moffett Park are Baylands Park, located directly east of Moffett Park; Bay trail located north of Moffett Park; and the Sunnyvale Municipal Golf Course, located directly southwest of Moffett Park. The Golf Club at Moffett Field, located directly northwest of Moffett Park, is privately owned, not operated or maintained by the City.

3.16.2 Discussion
a) Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Increased use in parks and recreational facilities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 4.4.1 (less than significant)
 DSP Draft EIR pages 8-25 through 8-26 (less than significant)  2020 DSP Draft EIR Impact REC-1 (less than significant)  LSAP Update Draft SEIR Impact 3.13-3 (less than significant)  ECRSP Draft EIR Impact 3.14.1 (less than significant)  MPSP Draft EIR Impact REC-1 (less than significant)
Attachment 3

Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in the physical deterioration of parks and recreational facilities that would alter the conclusions of the above certified EIRs. b) Include recreational facilities or require the construction or expansion of recreational facilities that might have an adverse physical effect on the environment? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts from the construction or expansion of recreational facilities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 4.4.1 (less than significant)
 DSP Draft EIR pages 8-25 through 8-26 (less than significant)  2020 DSP Draft EIR Impact REC-1 (less than significant)  LSAP Update Draft SEIR Impact 3.13-3 (less than significant)  ECRSP Draft EIR Impact 3.14.2 (less than significant)  MPSP Draft EIR Impact REC-2 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts from the construction or expansion of recreational facilities that would alter the conclusions of the above certified EIRs. Per Chapter 18.10 (ownership) and Chapter 19.74 (rental) of the City’s Municipal Code, the housing projects would be required to pay an in-lieu fee for park or recreation purposes associated with the increase in population.

Attachment 3

3.17 TRANSPORTATION

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVII. Transportation.

Would the project:
a) Conflict with a program, plan, ordinance or policy
addressing the circulation system, including transit,
roadway, bicycle, and pedestrian facilities?
☐ ☐ ☒ ☐
b) Conflict or be inconsistent with CEQA Guidelines
section 15064.3, subdivision (b)?
☐ ☐ ☒ ☐
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (e.g., farm
equipment)?
☐ ☐ ☒ ☐
d) Result in inadequate emergency access? ☐ ☐ ☒ ☐

3.17.1 Environmental Setting
The following is a summary of regulatory changes related to transportation.

SENATE BILL 743
SB 743, passed in 2013, required OPR to develop new State CEQA guidelines that address traffic metrics under CEQA.

As stated in the legislation, upon adoption of the new guidelines, “automobile delay, as described solely by level of service (LOS) or similar measures of vehicular capacity or traffic congestion shall not be considered a significant impact on the environment pursuant to this division, except in locations specifically identified in the guidelines, if any.” The change in the focus of transportation analysis is intended to shift the emphasis from congestion to reducing GHG emissions, promoting a diversity of land uses, and developing multimodal transportation networks.

In December of 2018, OPR published the most recent version of the Technical Advisory on Evaluating Transportation Impacts in CEQA (December 2018) which provides guidance for vehicle miles traveled (VMT) analysis. The Office of Administrative Law approved the updated State CEQA Guidelines and lead agencies had an opt -in period until July 1, 2020 to implement the updated guidelines regarding VMT. As of July 1, 2020, implementation of Section 15064.3 of the updated CEQA Guidelines apply statewide.

CITY OF SUNNYVALE COUNCIL POLICY MANUAL
Sunnyvale City Council adopted Council Policy 1.2.8, “Transportation Analysis Policy,” on June 30, 2020; thus, establishing VMT as the primary threshold of significance for analysis of transportation impacts under CEQA. This policy is designed to provide guidance in the preparation of transportation analysis for land use and transportation projects as part of the environmental review process to comply with CEQA.

Council Policy 1.2.8 requires that all projects evaluate and disclose transportation-related environmental impacts using VMT as the primary metric, as required by CEQA. Additionally, the policy establishes LOS as an operational measurement of intersection efficiency that is also required to be addressed for all projects. However, because a project’s effect on automobile delay no longer constitutes a significant impact under CEQA, LOS is not analyzed here-in.

Attachment 3

The following policy requirements are to be applied to projects for VMT:

1. Land Use Projects. For residential and employment projects, projects will use the Countywide Average VMT as the baseline with a VMT reduction threshold set at 15 percent below the baseline to identify potential transportation impacts and propose mitigations.

2. Exemptions. The requirement to prepare a detailed VMT analysis applies to all projects except the following types as these projects will further the City’s goals and policies and will not result in significant transportation impacts.

A. Small Infill Projects (110 daily trips or less).

B. Neighborhood-Serving Retail/Service Development uses (maximum 100,000 square feet total for entire commercial development), similar to uses permitted by right or with a Miscellaneous Planning Permit (MPP) in the C-1 (Neighborhood Business Zoning District) subject to evaluation by the Director of Community Development.

Such uses not considered neighborhood-serving include auto dealerships, car wash/repair facilities, drive-thru restaurants/services, restaurants with banquet halls, hotels, and similar uses that have a regional draw.

C. City Facilities such as fire stations, parks, community centers, branch libraries.

D. Restricted Affordable Housing Projects that meet the following:
(I) For rental developments: At least 25 percent of the proposed residential units dedicated as affordable to households up to 80 percent area median income (AMI). The developer shall meet the requirements for the City’s Rental Inclusionary (SMC Ch. 19.77), and then may provide the remainder of the required units at low income.
(II) For ownership developments: At least 25 percent of the proposed residential units dedicated as affordable to households up to 120 percent AMI. The developer shall meet the requirements for the City’s Below Market Rate Ownership Inclusionary (SMC Ch. 19.67). (III) For either type of development: The development may utilize the State Density Bonus, however 25 percent of the total constructed units on site must be deed restricted. Prior to the issuance of any building permit for the project, an Affordable Housing Regulatory Agreement shall be recorded against the parcel(s) which sets rent and occupancy restrictions for fifty-five years and shall run with the land through any change of ownership.

E. Transportation Projects that reduce or do not increase VMT including, but not limited to:
(I) Roadway maintenance, rehabilitation, and safety improvements; (II) Installation or reconfigured traffic lanes to provide left-turns, right-turns, etc.; (III) Conversion of existing lanes to managed or transit lanes; (IV) Multimodal improvements that promote walking, bicycling and transit; (V) Technology projects that optimize intersection operations, and traffic metering systems, detection, cameras, and other electronics designed to optimize traffic flow; (VII) Installation of traffic control devices and roundabouts; (VIII) Relocation or removal of parking; and
(IX) Installation of publicly available alternative fuel/charging infrastructure.

F. Transit Supportive Projects (office/R&D projects with a floor area ratio of more than 75 percent or a residential project of at least 35 dwelling units/acre) within ½ mile of an existing major bus stop or existing stop along a high quality transit corridor that meet all of the following requirements:
(I) Support the multimodal transportation network by facilitating access to multimodal transportation with improved pedestrian facilities, bike lanes, transit stops; does not harm or hinder access to multimodal transportation;
Attachment 3

(II) Does not exceed maximum parking requirements or propose higher than what is allowed per the development standards;
(III) Is transit oriented in design:
a. Has a walkable design that prioritizes pedestrians; b. Is sustainable, and compact;
c. Facilitates ease of bicycle use;
d. Is focused or centered around transit; and
(IV) Redevelopment of a site which provides at least as many affordable units as previously existed.

3. Transportation Projects. Project types that would likely lead to a measurable and substantial increase in vehicle travel generally include addition of through lanes on existing or new highways, including general purpose lanes, high occupancy vehicle (HOV) lanes, peak period lanes, auxiliary lanes, or lanes through grade - separated interchanges Transportation projects that add vehicle capacity to the roadway network will be required to analyze:

A. Direct, indirect, and cumulative effects of the transportation project B. Near term and long term induced vehicle travel in total VMT C. Consistency with state and local greenhouse gas reduction goals D. Impacts on the development of multimodal transportation networks E. Impacts on the development of diversity of land uses

4. Regional Projects. For projects such as regional retail, hospitals, stadium, sports complexes, or schools that are not regulated by a Public School District or that require permits from a local jurisdiction, a net increase in total VMT may indicate a significant transportation impact.

In October of 2021, the City of Sunnyvale adopted the City of Sunnyvale Transportation Analysis Guideline for Vehicle Miles Traveled and Local Transportation Analysis. This document provides the significance criteria, exemption screening criteria, thresholds of significance, and methodologies of the analysis for VMT; along with the operation analyses required and methodologies in a Local Transportation Analysis for development projects. This document incorporates Council Policy 1.2.8 by reference; and thus, the policy requirements associated with Council Policy 1.2.8 detailed above are consistent the guidance and direction provided in the City of Sunnyvale Transportation Analysis Guideline for Vehicle Miles Traveled and Local Transportation Analysis.

Additionally, as detailed in City of Sunnyvale Transportation Analysis Guideline for Vehicle Miles Traveled and Local Transportation Analysis, generally, VMT analysis is required for all projects that are not screened out per Council Policy

1.2.8, Section 2, Exemptions. However, the OPR Technical Advisory on Evaluating Transportation Impacts in CEQA provides that where a project replaces existing VMT-generating land uses, if the replacement leads to a net overall decrease in VMT, the project would lead to a less-than-significant transportation impact (City of Sunnyvale 2021). If the project leads to a net overall increase in VMT, then the City VMT thresholds would apply (City of Sunnyvale 2021).

CITY OF SUNNYVALE ACTIVE TRANSPORTATION PLAN
The purpose of the 2020 Sunnyvale Active Transportation Plan is to create a safe, connected, and efficient citywide active transportation network. This plan updates Sunnyvale’s 2006 Bicycle Plan, 2007 Pedestrian Safety and Opportunities Study, and 2012 Comprehensive School Traffic Study. The Plan lays out policies, infrastructure projects, and supporting programs, as well as identifies funding sources and implementation priorities; and includes various proposed bicycle and pedestrian improvements that may be used to reduce VMT.

Attachment 3

PEDESTRIAN ACCESS TO TRANSIT PLAN
VTA adopted the Pedestrian Access to Transit Plan in fall 2017, which “is the first-ever look at pedestrian conditions for VTA’s customers in Santa Clara County and is one component of a larger effort to strengthen and expand VTA's pedestrian program.” The Pedestrian Access to Transit Plan identifies Focus Areas with high bus ridership and the opportunity for pedestrian facility improvements. It also identifies 165 potential capital projects that would improve safety and the quality of the walk to transit, which could potentially increase ridership. VTA staff updated the geographic analysis done for the Pedestrian Access to Transit Pan using 2018 data, which can be used by member agencies, developers, and others to determine the need for pedestrian improvements across Santa Clara County.

3.17.2 Discussion
a) Conflict with a program, plan, ordinance or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict with a program, plan, ordinance, or policy addressing the circulation system from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.4.1 and 3.4.3 (less than significant)  DSP Draft EIR pages 7-69 through 7-71 (less than significant)  2020 DSP Draft EIR Impact TRN-6 (less than significant)  LSAP Update Draft SEIR Impact 3.14-2, 3.14-3, 3.14-4 (less than significant)  ECRSP Draft EIR Impact 3.15.2, 3.15.3, and 3.15.4 (less than significant)  MPSP Draft EIR Impact TRN-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in conflict with a program, plan, ordinance, or policy addressing the circulation system that would alter the conclusions of the above certified EIRs. b) Conflict or be inconsistent with CEQA Guidelines section 15064.3(b), which pertains to vehicle miles travelled?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. VMT impacts from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LSAP Update Draft SEIR Impact 3.14-1 (less than significant)  ECRSP Draft EIR Impact 3.15.1 (less than significant)  MPSP Draft EIR Impact TRN-2 (less than significant)
The LUTE EIR, DSP EIR, and 2020 DSP EIR did not address development impacts associated with the City’s VMT standards. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in VMT impacts that would alter the conclusions of the above certified EIRs. The proposed Housing Element Update would also not alter land use conditions that would create new VMT impacts beyond what is anticipated under current land use designations.

Attachment 3

c) Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. The increase in hazards due to a geometric design feature or incompatible uses from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.4.5 (less than significant)
 DSP Draft EIR pages 7-41 through 7-71 (less than significant)  2020 DSP Draft EIR Impact TRN-4 (less than significant)  LSAP Update Draft SEIR Impact 3.14-5 (less than significant)  ECRSP Draft EIR Impact 3.15.5 (less than significant)  MPSP Draft EIR Impact TRN-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would increase hazards due to a geometric design feature or incompatible uses that would alter the conclusions of the above certified EIRs. d) Result in inadequate emergency access?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to emergency access from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.4.6 (less than significant)
 DSP Draft EIR pages 7-41 through 7-71 (less than significant)  2020 DSP Draft EIR Impact TRN-5 (less than significant)  LSAP Update Draft SEIR Impact 3.14-6 (less than significant)  ECRSP Draft EIR Impact 3.15.6 (less than significant)  MPSP Draft EIR Impact TRN-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would impact emergency access that would alter the conclusion s of the above certified EIRs.

Attachment 3

3.18 TRIBAL CULTURAL RESOURCES

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XVIII. Tribal Cultural Resources.

Has a California Native American Tribe requested
consultation in accordance with Public Resources Code
section 21080.3.1(b)?
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site,
feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:

a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of
historical resources as defined in Public Resources
Code section 5020.1(k)?
☐ ☐ ☒ ☐
b) A resource determined by the lead agency, in its
discretion and supported by substantial evidence, to
be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe?
☐ ☐ ☒ ☐

3.18.1 Environmental Setting
On March 18, 2022, in compliance with AB 52 requirements, the City sent notification letters to the following tribal representatives:
 Amah Mutsun Tribal Band; Valentin Lopez, Chairperson
 Amah Mutsun Tribal Band of Mission San Juan Bautista; Irene Zwierlein, Chairperson  Indian Canyon Mutsun Band of Costanoan; Ann Marie Sayers, Chairperson  Indian Canyon Mutsun Band of Costanoan; Kanyon Sayers-Roods  Muwekma Ohlone Indian Tribe of the SF Bay Area; Monica Arellano, Vice Chairperson  North Valley Yokuts Tribe; Timothy Perez
 North Valley Yokuts Tribe; Katherine Perez, Chairperson  The Ohlone Indian Tribe; Andrew Galvan, Chairperson
 The Ohlone Indian Tribe; Desiree Vigil, THPO
 Wuksache Indian Tribe/Eshom Valley Band; Kenneth Woodrow, Chairperson Attachment 3

 Tamien Nation; Johnathan Wasaka Costillas, THPO
 Tamien Nation; Quirina Luna Geary, Chairperson
 Tamien Nation; Lillian Camarena, Secretary
No responses were received during the 30-day response period for AB 52 as defined in PRC Section 21080.3.2.

3.18.2 Discussion
Would the project cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
a) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code section 5020.1(k)?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to a tribal cultural historic resource from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LSAP Update Draft SEIR page 3.3-4 (no impact)
 2020 DSP Draft EIR Impact CR-2 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.4.4 (less than significant)
 MPSP Draft EIR Impact TRC-1 (less than significant)
The LUTE EIR and original DSP EIR did address impacts to tribal cultural resources. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would impact a tribal cultural historic resource that would alter the conclusions of the above certified EIRs. As noted above, no tribes responded to the City’s request for consultation or provided information on tribal cultural resources in the city.
b) A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to a tribal cultural historic resource from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LSAP Update Draft SEIR page 3.3-4 (no impact)
 2020 DSP Draft EIR Impact CR-2 (less than significant with mitigation)  ECRSP Draft EIR Impact 3.4.4 (less than significant)
Attachment 3

 MPSP Draft EIR Impact TRC-1 (less than significant)
The LUTE EIR and original DSP EIR did address impacts to tribal cultural resources. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would impact a tribal cultural historic resource that would alter the conclusions of the above certified EIRs. As noted above, no tribes responded to the City’s request for consultation or provided information on tribal cultural resources in the city.

Attachment 3

3.19 UTILITIES AND SERVICE SYSTEMS

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XIX. Utilities and Service Systems.

Would the project:
a) Require or result in the relocation or construction of construction of new or expanded water, wastewater
treatment or stormwater drainage, electric power,
natural gas, or telecommunication facilities, the
construction or relocation of which could cause
significant environmental effects?
☐ ☐ ☒ ☐
b) Have insufficient water supplies available to serve the project and reasonably foreseeable future development
during normal, dry and multiple dry years?
☐ ☐ ☒ ☐
c) Result in a determination by the wastewater
treatment provider that serves or may serve the
project that it has inadequate capacity to serve the
project’s projected demand, in addition to the
provider’s existing commitments?
☐ ☐ ☒ ☐
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment of
solid waste reduction goals?
☐ ☐ ☒ ☐
e) Fail to comply with federal, state, and local
management and reduction statutes and regulations
related to solid waste?
☐ ☐ ☒ ☐

3.19.1 Environmental Setting
Sunnyvale has three sources of potable water supply: purchased surface water from the San Francisco Public Utilities Commission (SFPUC), purchased treated surface water from the Santa Clara Valley Water District (SCVWD), and groundwater. Recycled water produced at the City’s Water Pollution Control Plant (WPCP) makes up the remaining part of the water portfolio. The City of Sunnyvale 2020 Urban Water Management Plan identifies adequate supply through 2040 under normal and dry year conditions.

The City collects and treats wastewater at its Water Pollution Control Plant. In 2016, the City adopted the Water Pollution Control Plant Master Plan (Master Plan) for the Sunnyvale Clean Water Program to serve as a long-term guide for replacing the WPCP’s facilities and operations. The purpose of the Master Plan is to ensure that the WPCP can meet changing regulations, treat existing and projected wastewater flows reliably and cost-effectively, and increase recycled water production. As a result of the rebuild, the influent flow design capacity is projected to decrease to 19.5 million gallons per day (mgd) for average dry weather flow, while retaining a design capacity of 40 mgd for peak wet weather flows.

The City also maintains its storm drainage system and requires individual development projects under Municipal Code Section 12.60.160 to demonstrate that each individual development project would not increase runoff over pre - project rates and durations. In addition, General Plan Policy EM-9.1 requires that the City maintain and operate the storm drain system so that stormwater is drained from 95 percent of the streets within one hour after a storm stops.

For flood-prone locations, Policy EM-10.2 requires incorporation of appropriate controls to detain excess stormwater.

Attachment 3

Sunnyvale provides garbage collection and recycling services to all residences and businesses in the City. The City also operates a recycling center at the SMaRT Station.

3.19.2 Discussion
a) Require or result in the relocation or construction of construction of new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts associated with the relocation or construction of a new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.11.2.2 (less than significant)  DSP Draft EIR pages 8-4 through 8-5, 8-8 through 8-9, and 8-28 through 8-29 (less than significant)  2020 DSP Draft EIR Impacts UTL-2, UTL-4, UTL-5 (less than significant with mitigation)  LSAP Update Draft SEIR Impact 3.15-2 (less than significant)  ECRSP Draft EIR Impact 3.16.1 (less than significant)  MPSP Draft EIR Impact UTL-1 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts associated with the relocation or construction of a new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities that would alter the conclusions of the above certified EIRs. Subsequent housing development would be required to comply with adopted mitigation measures identified in these EIRs that address infrastructure construction impacts.
b) Have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts associated with the relocation or construction of a new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.11.1.1 (less than significant)  DSP Draft EIR page 8-4 (less than significant)
 2020 DSP Draft EIR UTL-5 (less than significant)
 LSAP Update Draft SEIR Impact 3.15-1 (less than significant)  ECRSP Draft EIR Impact 3.16.2 (less than significant)  MPSP Draft EIR Impact UTL-2 (less than significant)
Attachment 3

Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts associated with the relocation or construction of a new or expanded water, wastewater treatment or stormwater drainage, electric power, natural gas, or telecommunication facilities that would alter the conclusions of the above certified EIRs. c) Result in a determination by the wastewater treatment provider that serves or may serve the project that it has inadequate capacity to serve the project’s projected demand, in addition to the provider’s existing commitments? Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts to wastewater treatment capacity from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.11.2.2 (less than significant)  DSP Draft EIR page 8-8 through 8-9 (less than significant)  2020 DSP Draft EIR Impact UTL-3 (less than significant)  LSAP Update Draft SEIR Impact 3.15-4 (less than significant)  ECRSP Draft EIR Impact 3.16.3 (less than significant)  MPSP Draft EIR Impact UTIL-3 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts to wa stewater treatment capacity that would alter the conclusions of the above certified EIRs.
d) Generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Impacts from the generation of solid waste from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.11.3.1 (less than significant)  DSP Draft EIR page 8-28 through 8-29 (less than significant)  2020 DSP Draft EIR Impact UTL-6 (less than significant)  LSAP Update Draft SEIR Impact 3.15-6 (less than significant)  ECRSP Draft EIR Impact 3.16.4 (less than significant)  MPSP Draft EIR Impact UTL-4 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in impacts from the generation of solid waste that would alter the conclusions of the above certified EIRs.

Attachment 3

e) Fail to comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict with federal, state, and local management and reduction statutes and regulations related to solid waste from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR Impact 3.11.3.2 (less than significant)  DSP Draft EIR page 8-28 through 8-29 (less than significant)  2020 DSP Draft EIR Impact UTL-4 (less than significant)  LSAP Update Draft SEIR Impact 3.15-6 (less than significant)  ECRSP Draft EIR Impact 3.16.5 (less than significant)  MPSP Draft EIR Impact UTIL-5 (less than significant)
Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in conflict with federal, state, and local management and reduction statutes and regulations related to solid waste that would alter the conclusions of the above certified EIRs.

Attachment 3

3.20 WILDFIRE

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XX. Wildfire.

Is the project located in or near state responsibility areas or lands classified as high fire hazard severity zones? If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:

a) Substantially impair an adopted emergency response
plan or emergency evacuation plan?
☐ ☐ ☐ ☒
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire
or the uncontrolled spread of a wildfire?
☐ ☐ ☐ ☒
c) Require the installation of associated infrastructure (such as roads, fuel breaks, emergency water
sources, power lines or other utilities) that may
exacerbate fire risk or that may result in temporary
or ongoing impacts to the environment?
☐ ☐ ☐ ☒
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
☐ ☐ ☐ ☒

3.20.1 Environmental Setting
No Fire Hazard Severity Zones, state responsibility areas, Very High Fire Hazard Severity Zones, or local responsibility areas are located in or adjacent to Sunnyvale. Given that the city is urbanized and not adjacent to large areas of open space or agricultural lands that are subject to wildland fire hazards, no impacts associated with exposure to wildland fire would occur.

Attachment 3

3.20.2 Discussion
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
b) Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c) Require the installation of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment? d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Conflict with federal, state, and local management and reduction statutes and regulations related to solid waste from development (including housing identified in the proposed Housing Element Update) is addressed in the following EIRs:
 LUTE Draft EIR page 3.3-15 (no impact)
 LSAP Update Draft SEIR page 1-3 (no impact)
 ECRSP Draft EIR page 4-6 through 4-7 (no impact)
 MPSP Draft EIR page 342 (no impact)
The original DSP EIR and 2020 DSP EIR do not address impacts related to wildland fires. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in new wildfire impacts that would alter the conclusions of the above certified EIRs.

Attachment 3

3.21 MANDATORY FINDINGS OF SIGNIFICANCE

ENVIRONMENTAL ISSUES
Potentially
Significant
Impact
Less Than
Significant with
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
XX. Mandatory Findings of Significance.
a) Does the project have the potential to substantially degrade the quality of the environment, substantially
reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-
sustaining levels, threaten to eliminate a plant or
animal community, substantially reduce the number
or restrict the range of an endangered, rare, or
threatened species, or eliminate important examples
of the major periods of California history or
prehistory?
☐ ☐ ☒ ☐
b) Does the project have impacts that are individually
limited, but cumulatively considerable?
(“Cumulatively considerable” means that the
incremental effects of a project are considerable
when viewed in connection with the effects of past
projects, the effects of other current projects, and
the effects of probable future projects.)
☐ ☐ ☒ ☐
c) Does the project have environmental effects that will cause substantial adverse effects on human beings,
either directly or indirectly?
☐ ☐ ☒ ☐

3.21.1 Environmental Setting

3.21.2 Discussion
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially reduce the number or restrict the range of an endangered, rare, or threatened species, or eliminate important examples of the major periods of California history or prehistory?
Less Than Significant. As described in the previous sections, the proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in a more or new significant physical changes or environmental effects as those addressed in the previously identified EIRs.

Attachment 3

b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively considerable” means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.) Less Than Significant. The proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Cumulative environmental impacts (including housing identified in the proposed Housing Element Update) are addressed in the following EIRs:
 LUTE Draft EIR impacts 3.1.5, 3.2.3, 3.2.4, 3.3.6, 3.4.4, 3.5.8, 3.6.6, 3.7.5, 3.7.6, 3.8.4, 3.8.5, 3.9.5, 3.10.3, 3.11.1.3,

3.11.2.3, 3.11.3.3, 3.11.4.1, 3.12.5, 3.13.1, 4.1.2, 4.2.2, 4.3.2, 4.4.2 (cumulatively considerable and significant and unavoidable for air quality, noise, and cultural resources)  2020 DSP Draft EIR impacts AES-C, AG-C, AQ-C, BIO-C, CR-C, EN-C, GEO-C, GHG-C, HAZ-C, HYD-C, LU-C, MIN- C, NOI-C, PS-C, REC-C, TRN-C, and UTL-C (cumulatively considerable and significant and unavoidable for noise and wastewater treatment capacity)
 LSAP Update Draft SEIR impacts 4-1, 4-2, 4-3, 4-4. 4-5, 4-6, 4-7, 4-8, 4-9, 4-10, 4-11, 4-12, 4-13, 4-14, 4-15, 4-16, 4-17, 4-18, 4-19, 4-20, 4-21, 4-22, 4-23 (cumulatively considerable and significant and unavoidable for air quality and wastewater treatment capacity)
 ECRSP Draft EIR impacts 3.1.3, 3.2.2, 3.2.8, 3.3.3, 3.4.4, 3.5.3, 3.6.5, 3.7.3, 3.8.8, 3.9.6, 3.10.2, 3.11.3, 3.12.3, 3.13.5,

3.14.3, 3.15.8, and 3.16.6 (cumulatively considerable and significant and unavoidable for air quality and wastewater treatment capacity)
 MPSP Draft EIR impacts AES-C, AG-C, AQ-C, BIO-C, CR-C, EN-C, GEO-C, GHG-C, HAZ-C, HYD-C, LU-C, MIN-C, NOI-C, PS-C, REC-C, TRN-C, and UTL-C (cumulatively considerable and significant and unavoidable for air quality, GHG emissions, and wastewater treatment capacity) Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in increased or new cumulative impacts that would alter the conclusions of the above certified EIRs.
c) Does the project have environmental effects that will cause substantial adverse effects on human beings, either directly or indirectly? Less Than Significant. As described in the previous sections, the proposed Housing Element Update would promote the development of housing that is consistent with current City land use designations and zoning as set forth in the Land Use and Transportation Element of the General Plan, Downtown Specific Plan and amendments, Lawrence Station Area Plan, El Camino Real Specific Plan, and the Moffett Specific Plan. Implementation of the proposed Housing Element Update consists of revisions to housing policy and programs but does not propose new development that would result in a more or new significant physical changes or environmental effects as those addressed in the previously identified EIRs.

Attachment 3

4 REFERENCES
California Air Resources Board. 2022a. California ambient air quality standards. Available:
https://ww2.arb.ca.gov/resources/california-ambient-air-quality-standards. ———. 2022b. Maps of State and Federal Area Designations. Last updated October 2020. Available:
https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area-designations.

City of Sunnyvale. 2018 (July). Climate Action Plan 2018 Biennial Progress Report. Available:
https://www.sunnyvale.ca.gov/home/showpublisheddocument/1316/637820055380570000. Accessed September 2018.
———. 2021 (October). Trans portation Analysis Guidelines for Vehicle Miles Traveled and Local Transportation Analysis.

Governor’s Office of Planning and Research. 2018 (December). Technical Advisory on Evaluating Transportation Impacts in CEQA. Available: https://opr.ca.gov/ceqa/docs/20190122-743_Technical_Advisory.pdf.

US Environmental Protection Agency. 2022a. Criteria Air Pollutants. Available: https://www.epa.gov/criteria-air- pollutants/naaqs-table.
———. 2022b . Nonattainment Areas for Criteria Pollutants (Green Book). Available: https://www.epa.gov/green-book.

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5 REPORT PREPARERS
Ascent Environmental
Pat Angell ............................................................................................................................................................................. Principal-in-Charge Jacklyn Bottomley ........................................................................................................................................................ Environmental Planner Michele Mattei ................................................................................................................................................................... Publishing Specialist Brian Perry .............................................................................................................................................................................. Graphics Specialist Riley Smith ........................................................................................................................................................................... Publishing Specialist

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