Attachment 10 - Playbook Responses and Final IS-ND — Sunnyvale City Council, June 25, 2024 (part 1 of 2)

City of Sunnyvale
TO:

FROM:

RE:

City Council
Christina Raby, Environmental Engineering Coordinator
Game Plan 2028 – Public Comments
Staff received comments on the Initial Study / Negative Declaration (ISND). The response to comments, corrected IS/ND, letter from the Department of Fish and Wildlife and final GHG Thresholds and Guidance
Report have been attached for reference.

ATTACHMENTS

1. Playbook Response to Comments

2. Updated ISND

3. Letter f
rom the Department of Fish and Wildlife

4. GHG Thresholds and Guidance Report
Memo
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City of Sunnyvale
Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds Final Initial Study –Negative Declaration
Comments and Responses on the Draft Initial
Study- Negative Declaration
This section includes comments received during public circulation of the Draft Initial Study- Negative Declaration (IS-ND) prepared for the Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds (proposed plan or plan). The California Environmental Quality Act (CEQA) Guidelines Section 15074(b) states that prior to approving a project, the lead agency must consider the proposed IS-ND together with any comments received during the public review process.

The Draft IS-ND was circulated for a 30-day public review period that began on April 9, 2024 and ended on May 8, 2024. The City received one comment letter on the Draft IS-ND. Each separate issue raised by the commenter, if more than one, has been assigned a number. The responses to each comment identify first the number of the comment letter, and then the number assigned to each issue (Response 1.1, for example, indicates that the response is for the first issue raised in comment Letter, Individual 1).

Where a comment resulted in a change to the Draft IS-ND text, a notation is made in the response indicating that the text is revised. Changes in text are signified by strikeout font (strikeout font) where text was removed and by underlined font (underlined font) where text was added. These changes in text are noted in the Final IS-ND. The comment letter and responses follow.

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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director Bay Delta Region
2825 Cordelia Road, Suite 100
Fairfield, CA 94534
(707) 428-2002
www.wildlife.ca.gov
Conserving California’s Wildlife Since 1870
May 6, 2024
Madeline Khair, Environmental Programs Manager
City of Sunnyvale
456 W Olive Avenue
Sunnyvale, CA 94086
[email protected]
Subject: Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds, Initial Study/Negative Declaration, SCH No. 2024040387, City of Sunnyvale, Santa Clara County Dear Ms. Khair:

The California Department of Fish and Wildlife (CDFW) received a Notice of Intent to Adopt an Initial Study/Negative Declaration (IS/ND) from the City of Sunnyvale (City) for the Sunnyvale Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds (Project) pursuant the California Environmental Quality Act (CEQA) and CEQA Guidelines.1 CDFW is submitting comments on the draft IS/ND as a means to inform the City of Sunnyvale as the Lead Agency, of potentially significant impacts to biological resources associated with the Project.

Thank you for the opportunity to provide comments and recommendations regarding those activities involved in the Project that may affect California fish and wildlife.

Likewise, we appreciate the opportunity to provide comments regarding those aspects of the Project that CDFW, by law, may be required to carry out or approve through the exercise of its own regulatory authority under the Fish and Game Code.

CDFW ROLE
CDFW is California’s Trustee Agency for fish and wildlife resources and holds those resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)). CDFW, in its trustee capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations of those species. (Id., § 1802.) Similarly, for purposes of CEQA, CDFW is charged by law to provide, as available, biological expertise during public agency environmental review efforts, focusing specifically on projects and related activities that have the potential to adversely affect fish and wildlife resources. 1 CEQA is codified in the California Public Resources Code in section 21000 et seq. The “CEQA Guidelines” are found in Title 14 of the California Code of Regulations, commencing with section 15000.

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Madeline Khair
City of Sunnyvale
May 6, 2024

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CDFW is also submitting comments as a Responsible Agency under CEQA. (Pub.

Resources Code, § 21069; CEQA Guidelines, § 15381). CDFW expects that it may need to exercise regulatory authority over the Project pursuant to the Fish and Game Code. For example, the Project may be subject to CDFW’s Lake and Streambed Alteration (LSA) regulatory authority, if the Project impacts the bed, channel or bank of any river, stream or lake within the State (Fish & G. Code, § 1600 et seq.). Likewise, to the extent the Project may result in “take” as defined by state law of any species protected under the California Endangered Species Act (CESA) (Fish & G. Code, § 2050 et seq.), the Project proponent may seek related take authorization as provided by the Fish and Game Code.

REGULATORY REQUIREMENTS
California Endangered Species Act
A CESA Incidental Take Permit (ITP) must be obtained from CDFW if the Project has the potential to result in “take” of plants or animals listed under CESA, either during construction or over the life of the Project. Under CESA, “take” means “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill.” (Fish & G.

Code, § 86). CDFW’s issuance of an ITP is subject to CEQA and to facilitate permit issuance, any Project modifications and mitigation measures must be incorporated into the CEQA document analysis, discussion, and mitigation monitoring and reporting program. If the Project will impact CESA listed species, early consultation is encouraged, as significant modification to the Project and mitigation measures may be required in order to obtain a CESA Permit.

CEQA requires a mandatory finding of significance if a project is likely to substantially impact threatened or endangered species. Pub. Resources Code, §§ 21001, subd. € & 21083; CEQA Guidelines, §§ 15380, 15064 & 15065). In addition, pursuant to CEQA, the Lead Agency cannot approve a project unless all impacts to the environment are avoided or mitigated to less-than-significant levels, or the Lead Agency makes and supports Findings of Overriding Consideration (FOC) for impacts that remain significant despite the implementation of all feasible mitigation. FOC under CEQA, however, does not eliminate the Project proponent’s obligation to comply with the Fish and Game Code.

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

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Madeline Khair
City of Sunnyvale
May 6, 2024

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may pass into a river, lake, or stream. Work within ephemeral streams, drainage ditches, washes, watercourses with a subsurface flow, and floodplains is generally subject to notification requirements. In addition, infrastructure installed beneath such aquatic features, such as through hydraulic directional drilling, is also generally subject to notification requirements. Therefore, any impact to the mainstems, tributaries, or floodplains or associated riparian habitat caused by the proposed Project will likely require an LSA Notification.

Migratory Birds and Raptors
CDFW has authority over actions that may result in the disturbance or destruction of active bird nest sites or the unauthorized take of birds. Fish and Game Code sections protecting birds, their eggs, and nests include section 3503 (regarding unlawful take, possession, or needless destruction of the nests or eggs of any bird), section 3503.5 (regarding the take, possession, or destruction of any birds-of-prey or their nests or eggs), and section 3513 (regarding unlawful take of any migratory nongame bird).

Migratory birds are also protected under the federal Migratory Bird Treaty Act.

Fully Protected Species
Several Fully Protected Species (Fish & G. Code § 3511 and 4700) have the potential to occur within or adjacent to the Project area, including, but not limited to: salt-marsh harvest mouse (Reithrodontomys raviventris), white-tailed kite (Elanus leucurus), golden eagle (Aquila chrysaetos), California least tern (Sternula antillarum browni), and California Ridgway's rail (Rallus obsoletus obsoletus).

Project activities described in the IS/ND should be designed to completely avoid any fully protected species that have the potential to be present within or adjacent to the Project area. Fully protected species may not be taken or possessed at any time and no licenses or permits may be issued for their take except as follows:

Take is for necessary scientific research;
 Efforts to recover a fully protected, endangered, or threatened species, live capture, and relocation of a bird species for the protection of livestock; or  They are a covered species whose conservation and management are provided for in a Natural Community Conservation Plan (Fish & G. Code, §§ 3511, 4700, 5050, & 5515).

Specified types of infrastructure projects may be eligible for an ITP for unavoidable impacts to fully protected species if certain conditions are met (see Fish & G. Code §2081.15).

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Madeline Khair
City of Sunnyvale
May 6, 2024

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CDFW also recommends the IS/ND analyze potential adverse impacts to fully protected species due to habitat modification, loss of foraging habitat, and/or interruption of migratory and breeding behaviors. CDFW recommends that the City include in the analysis how appropriate avoidance, minimization and mitigation measures will reduce indirect impacts to fully protected species. Project proponents should consult with CDFW early in the Project planning process.

PROJECT DESCRIPTION SUMMARY
Proponent: City of Sunnyvale
Objective: The objective of the Project is to achieve the 2030 GHG emissions target for the City of Sunnyvale. Primary Project activities include; the City has developed 19 strategies related clean electricity, building decarbonization, transportation decarbonization and sustainable land use planning, solid waste and water use reductions, community engagement, and climate adaptation.

Location: Sunnyvale, Santa Clara County (County), Citywide Timeframe: The plan will be implemented over the next 21 years.

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

The IS/ND should define the threshold of significance for each impact and describe the criteria used to determine whether the impacts are significant (CEQA Guidelines, § 15064, subd. (f)). The IS/ND relies on General Plan policies and on requirements that subsequent Projects, if necessary, obtain appropriate permits but does not sufficiently describe how these policies will reduce impacts to less-than-significant.

ENVIRONMENTAL SETTING
Sufficient information regarding the environmental setting is necessary to understand any potentially significant impacts on the environment of the proposed Project (CEQA Guidelines, §§15063 & 15360). CDFW recommends that a full list or table is included in the updated Biological Resources Section of the IS/ND that notes species common name, scientific name, state and federal listing status (as applicable), habitat type preference and determination on presence, for all special-status species with the potential to occur within the Project area.

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Madeline Khair
City of Sunnyvale
May 6, 2024

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CDFW recommends the IS/ND provide baseline habitat assessments for special-status plant, fish and wildlife species located and potentially located within the Project area and surrounding lands, including all rare, threatened, and endangered species (CEQA Guidelines, §15380). The IS/ND should describe aquatic habitats, such as wetlands or waters of the U.S. or State, and any sensitive natural communities or riparian habitat occurring on or adjacent to the Project area (for sensitive natural communities see:
https://wildlife.ca.gov/Data/VegCAMP/NaturalCommunities#sensitive%20natural%20co mmunities), and any stream or wetland set back distances the City or County may require.

CDFW recommends that the California Natural Diversity Database (CNDDB), as well as previous studies performed in the area, be consulted to assess the potential presence of sensitive species and habitats. A nine U.S. Geologic Survey (USGS) 7.5-minute quadrangle search is recommended to determine what may occur in the region, larger if the Project area extends past one quad (See Data Use Guidelines on the Department webpage https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data.). Please review the webpage for information on how to access the database to obtain current information on any previously reported sensitive species and habitat, including Significant Natural Areas identified under Chapter 12 of the Fish and Game Code, in the vicinity of the Project. CDFW recommends that CNDDB Field Survey Forms be completed and submitted to CNDDB to document survey results. Online forms can be obtained and submitted at: https://www.wildlife.ca.gov/Data/CNDDB/Submitting-Data.

Please note that CDFW’s CNDDB is not exhaustive in terms of the data it houses, nor is it an absence database. CDFW recommends that it be used as a starting point in gathering information about the potential presence of species within the general area of the Project site. Other sources for identification of species and habitats near or adjacent to the Project area should include, but may not be limited to, State and federal resource agency lists, California Wildlife Habitat Relationship System, California Native Plant Society Inventory, agency contacts, environmental documents for other projects in the vicinity, academics, and professional or scientific organizations. Only with sufficient data and information can the City adequately assess which special-status species are likely to occur in the Project vicinity.

According to Biogeographic Information and Observation System (BIOS) records, the Project site contains positive detections of several special-status species and has the potential to support numerous special-status species and their associated habitat.

Species with potential to occur on-site include but are not limited to those listed in Attachment 1.

I. Project Description and Related Impact Shortcoming
COMMENT 1: Subsequent Project Review, (Biological Resources 4.a. p. 42)

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Madeline Khair
City of Sunnyvale
May 6, 2024

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The IS/ND identifies that “implementation of the following Sunnyvale Playbook Update/ Game Plan 2028 Plays may promote infrastructure development and redevelopment and may result in impacts to species through construction activities.” (4.a. p. 42). It is not clear what level of environmental review future Projects would receive. The IS/ND does not include a checklist for subsequent project review, nor adequate description of how the City’s policies would mitigate any potential impacts of the Project. While the Project has a necessarily broad scope, CDFW recommends providing as much information related to anticipated future activities as possible. CDFW recognizes that, pursuant to CEQA Guidelines section 15152, subdivision (c), if a Lead Agency is using the tiering process in connection with large-scale planning approval, the development of detailed, site-specific information may not be feasible and can be deferred, in many instances, until such time as the Lead Agency prepares a future environmental document. This future environmental document would cover a project of a more limited geographical scale and is appropriate if the deferred information does not prevent adequate identification of significant effects of the planning approval at hand.

The CEQA Guidelines section 15168, subdivision (c)(4) states, “Where the later activities involve site-specific operations, the agency should use a written checklist or similar device to document the evaluation of the site and the activity to determine whether the environmental effects of the operation were within the scope.” Recommended Mitigation Measure 1: Subsequent Project CEQA Evaluation. The IS/ND should include a procedure or checklist for evaluating subsequent Project impacts on biological resources to determine if the impacts are within the scope of the IS/ND or if an additional environmental document is warranted. Future analysis shall include all special-status species and sensitive habitats including, but not limited to, species considered rare, threatened, or endangered species pursuant to CEQA Guidelines, section 15380. The checklist shall be accompanied by enough relevant information and reasonable inferences to support a “within the scope” of the IS/ND conclusion. For subsequent Project activities that may affect sensitive biological resources, a site-specific analysis shall be prepared by a professional biologist experienced with the applicable species and habitat to provide the necessary supporting information.

II. Environmental Setting and Related Impact Shortcoming Would the Project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by CDFW or U.S. Fish and Wildlife Service (USFWS)?
COMMENT 2: Nesting Bird Surveys, (Biological Resources 4.a. p. 42)

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Madeline Khair
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The draft IS/ND states that the Project has the potential to disturb special-status species and nesting habitat for birds and raptors; however, the draft IS/ND does not state that baseline data will be collected if active nests are discovered.

Recommended Mitigation Measure 2: Nesting Bird Surveys. If Project-related work is scheduled during the nesting season (typically February 15 to August 30 for small bird species such as passerines; January 15 to September 15 for owls; and February 15 to September 15 for other raptors), a professional biologist experienced with the applicable species and habitat shall conduct two surveys for active nests of such birds within 14 days prior to the beginning of Project construction, with a final survey conducted within 48 hours prior to construction. Appropriate minimum survey radii surrounding the work area are typically the following: i) 250 feet for passerines; ii) 500 feet for small raptors such as accipiters; and iii) 1,000 feet for larger raptors such as buteos. Surveys shall be conducted at the appropriate times of day and during appropriate nesting times.

COMMENT 3: Marsh and Shoreline Birds, (Biological Resources 4.a. p. 42) The IS/ND does not state potential impacts to shoreline and marsh birds from the Project. A number of marsh bird species occur along Sunnyvale’s shoreline and throughout the Don Edwards San Francisco Bay National Wildlife Refuge. These include but are not limited to black skimmer (Rynchops niger), California least tern, California black rail, California Ridgway's rail, and western snowy plover (Charadrius nivosus nivosus). The IS/ND includes actions to advance shoreline protection projects and restore and expand salt marshes and natural waterways. Any in-water and shoreline work has the potential to cause the take of state listed marsh and shoreline bird species.

Recommended Mitigation Measure 3: Surveys. CDFW recommends the Project include a measure for marsh bird surveys following the 2017 Site-Specific Protocol for Monitoring Marsh Birds (https://ecos.fws.gov/ServCat/Reference/Profile/68062). CDFW recommends inclusion of avoidance and minimization measures in the Biological Resources Section of the IS/ND to reduce impacts below a level of significance.

COMMENT 4: State Listed Fish Species, (Table 2, item 6.2, page 17) The IS/ND does not include potential impacts to state listed fish species known to be present in the Project area, including steelhead (Oncorhynchus mykiss irideus) - Central California Coast Distinct Population Segment (DPS) and longfin smelt (Spirnichus thaleichthys) along Sunnyvale’s shoreline and throughout the Don Edwards San Francisco Bay National Wildlife Refuge. The IS/ND includes actions to advance shoreline protection projects and restore and expand salt marshes and natural

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Madeline Khair
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waterways. Any in-water work has the potential to cause the take of state listed fish species.

Recommended Mitigation Measure 4: Construction Activities and Work Windows.

The IS/ND should include mitigation measures to avoid potential impacts to aquatic species for construction methods such as pile driving and dredging. In-water construction shall only occur during the CDFW approved work window of June 1 through November 30. A vibratory pile driver shall be used to the maximum extent possible. If an impact hammer is to be considered for construction, the City shall consult with CDFW regarding a CESA ITP for potential impacts to state listed species such as longfin smelt and Chinook salmon (Oncorhynchus tshawytscha). See also Recommended Mitigation Measure 9.

COMMENT 5: Crotch’s bumble bee, (Biological Resources 4.a. p. 42) Crotch’s bumble bee (Bombus crotchii) are candidate species under CESA (CEQA Guidelines, §15380, subds. (c)(1)). The IS/ND does not address whether the proposed Project could result in impacts to Crotch’s bumble bee. Crotch’s bumble bee occurrences have been documented within the vicinity of the Project area and historic observations occur elsewhere in the County (CDFW 2023). The Project location is within the Crotch’s bumble bee range (https://wildlife.ca.gov/Conservation/CESA) and grassland within and adjacent to the Project area may contain potential habitat for Crotch’s bumble bees.

The Project includes strategies such as solar arrays and solar battery storage projects that may occur within ruderal grass and herbaceous vegetation and that may be potential Crotch’s bumble bee nesting and foraging habitat. Potential impacts include direct mortality through crushing or filling of active bee colonies and hibernating bee cavities, reduced reproductive success, loss of suitable breeding and foraging habitats, loss of native vegetation that may support essential foraging habitat.

Recommended Mitigation Measure 5: Habitat Assessment. A habitat assessment shall be conducted by a qualified entomologist knowledgeable with the life history and ecological requirements of Crotch’s bumble bee. The habitat assessment shall include all suitable nesting, overwintering, and foraging habitats within the Project area and surrounding areas. Potential nest habitat (February through October) could include that of other Bombus species such as bare ground, thatched grasses, abandoned rodent burrows or bird nests, brush piles, rock piles, and fallen logs. Overwintering habitat (November through January) could include that of other Bombus species such as soft and disturbed soil or under leaf litter or other debris. The habitat assessment shall be conducted during peak bloom period for floral resources on which Crotch’s bumble bee feed. Further guidance on habitat surveys can be found within Survey Considerations

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Madeline Khair
City of Sunnyvale
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for California Endangered Species Act (CESA) Candidate Bumble Bee Species (https://wildlife.ca.gov/Conservation/CESA).

COMMENT 6: Western Burrowing Owl (Biological Resources 4.a. p. 42) Burrowing owl (Athene cunicularia) is designated by CDFW as a California Species of Special Concern (SSC) due to population decline and breeding range retraction. The species has also experienced a severe population decline in the County. The IS/ND notes ruderal infill lots could support burrowing owl but does not discuss potential impacts. Known populations of burrowing owl occur within and adjacent to the Project area, including Moffett Federal Airfield, the Golf Club at Moffett Field, Sunnyvale Baylands County Park, the grasslands along the City of Sunnyvale Water Pollution Control Plant, and other suitable habitat.

The Project includes strategies such as solar arrays and solar battery storage projects that may occur within ruderal grass and herbaceous vegetation that may be potential burrowing owl habitat. The Project also includes shoreline protection strategies which could impact grassland habitat along the shoreline, currently utilized by burrowing owl.

Direct mortality could occur through crushing of adults or young within burrows, loss of nesting burrows, loss of nesting habitat, loss of foraging habitat resulting in reduced nesting success (loss or reduced health or vigor of eggs or young), nest abandonment, and reduced frequency or duration of care for young resulting in reduced health or vigor of young.

Recommended Mitigation Measure 6: Habitat Assessment and Surveys. The IS/ND should include a thorough habitat assessment of potential burrowing owl habitat within and adjacent to the Project area. A professional biologist experienced with burrowing owl and their habitat should conduct a field assessment that includes all areas that could be directly or indirectly impacted by the Project and include data such as vegetation type, vegetation structure and presence of burrows. Specific information on habitat assessment, burrowing owl survey methods, buffer distances and mitigation is provided in the CDFW Staff Report on Burrowing Owl Mitigation, dated March 7, 2012, and available at https://wildlife.ca.gov/Conservation/Survey-Protocols#377281284-birds.

Would the Project 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? Would the Project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by CDFW or USFWS?
COMMENT 7: Permits for Stream, Wetland, and Other Waters Impacts, Impacts to Sensitive Natural Communities, Riparian Habitat, Wetlands, Lake and Streambed

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City of Sunnyvale
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Alteration Notification and Clean Water Act compliance (Biological Resources 4.c, p. 43-44)
The IS/ND identifies that future development under the Project may be subject to the Clean Water Act and the Porter-Cologne Water Quality Control Act, but not Fish and Game Code section 1600 et seq. (p. 43). The IS/ND does not provide certainty that such impacts would comply with Fish and Game Code section 1600 et seq., the Porter- Cologne Water Quality Control Act, and the Clean Water Act, as the IS/ND does not include a mitigation measure requiring that development under the Project apply for CDFW, Regional Water Quality Control Board (RWQCB), or U.S. Army Corps of Engineers (USACE) Permits, nor does it contain a mitigation measure requiring compliance with the terms of these permits, if issued.

Development facilitated by the Project may result in impacts to streams and riparian habitats, such as Stevens Creek, Calabazas Creek, and Moffett Channel (p. 44). When riparian habitat is substantially altered, riparian functions become impaired, thereby likely substantially adversely impacting aquatic and terrestrial species. The IS/ND does not provide certainty that impacts to riparian habitats, sensitive natural communities, wetlands, and waters of the State would be reduced to less-than-significant. Without specific mitigation measures containing performance standards CDFW considers impacts to these resources as potentially significant (CEQA Guidelines, §§ 15065, 15380).

To reduce potential impacts to streams, wetlands, and other waters to less-than- significant and comply with Fish and Game Code section 1600 et seq., the Porter- Cologne Water Quality Control Act, and the Clean Water Act, CDFW recommends including the mitigation measure below in the IS/ND.

Recommended Mitigation Measure 7: Stream and Wetland Mitigation and Resource Agency Permits. The Project shall be designed to minimize fill of jurisdictional waters. If impacts to any streams cannot be avoided, then prior to the impacts the Project shall submit an LSA notification to CDFW and comply with the LSA Agreement, if issued. Additionally, if impacts to any streams, wetlands, or other waters cannot be avoided, the Project shall obtain authorization from the RWQCB and USACE pursuant to the Porter-Cologne Water Quality Control Act and Clean Water Act sections 401 and 404, as applicable. Impacts to waters, wetlands, and riparian habitat subject to the permitting authority of CDFW, the RWQCB, or the USACE shall be mitigated by providing restoration at a minimum 3:1 restoration to impact ratio in area for permanent impacts and 1:1 ratio for temporary impacts, unless otherwise approved in writing by CDFW or otherwise required by the RWQCB or USACE. A Habitat Mitigation and Monitoring Plan shall be prepared and implemented for the proposed mitigation. The Project shall obtain written approval of this plan from CDFW, the RWQCB, or the USACE as applicable prior to any disturbance of stream or riparian habitat, wetlands, or other waters.

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City of Sunnyvale
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Recommended Mitigation Measure 8: LSA Notification and other Resource Agency Permits. The Project shall notify CDFW pursuant to Fish and Game Code section 1600 et seq. using the Environmental Permit Information Management System (EPIMS, see: https://wildlife.ca.gov/Conservation/Environmental-Review/EPIMS) for Project activities affecting lakes or streams, associated riparian or otherwise hydrologically connected habitat, and any connected wetlands, and shall comply with the LSA Agreement, if issued. Projects shall also obtain and comply with applicable permits from the RWQCB and USACE pursuant to the Clean Water Act and Porter- Cologne Water Quality Control Act.

Recommended Mitigation Measure 9: Habitat Restoration and Compensation. The Project shall implement restoration on-site or off-site to mitigate temporary or permanent impacts to sensitive natural communities, riparian habitat, and wetlands at a minimum 1:1 (restore on-site temporary impacts) or 3:1 (permanent impacts) mitigation to impact ratio for acres and linear feet of impacts, or habitat compensation including permanent protection of habitat at the same ratio through a conservation easement and preparing and funding implementation of a long-term management plan, unless otherwise approved in writing by CDFW.

III. Editorial Comments and/or Suggestions
CDFW appreciates the inclusion of strategies to restore and enhance marshes along the shoreline of the City to improve climate resilience and habitat for fish and wildlife. CDFW additionally appreciates the inclusion and proposed implementation of an Urban Forest Management Plan that will result in increased canopy cover within the Project area.

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

ENVIRONMENTAL DOCUMENT FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and assessment of environmental document filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment of the environmental document filing fee is

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Madeline Khair
City of Sunnyvale
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required in order for the underlying project approval to be operative, vested, and final. (See: Cal. Code Regs, tit. 14, § 753.5; Fish & G. Code, § 711.4; Pub. Resources Code, § 21089.).

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

Questions regarding this letter or further coordination should be directed to Marcus Griswold, Senior Environmental Scientist (Specialist), at (707) 815-6451 or [email protected].

Sincerely,

Erin Chappell
Regional Manager
Bay Delta Region
Attachment 1: Special-Status Species and Commercially/Recreationally Important Species
ec: Office of Planning and Research, State Clearinghouse (SCH No. 2024040387) Craig Weightman, CDFW Bay Delta Region – [email protected] Jason Faridi, CDFW Bay Delta Region – [email protected]

REFERENCES
California Department of Fish and Wildlife (CDFW). 2024. Biogeographic Information and Observation System (BIOS). https://wildlife.ca.gov/Data/BIOS. Accessed April 25, 2024.

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ATTACHMENT 1: Special-Status Species
Species Status
steelhead - central California coast DPS (Oncorhynchus
mykiss irideus) Federally Threatened (FT), State SSC
longfin smelt (Spirinchus thaleichthys) Proposed FT, State Threatened (ST) San Francisco dusky-footed woodrat (Neotoma fuscipes
annectens) SSC
salt-marsh harvest mouse (Reithrodontomys raviventris) Federal Endangered (FE), State Fully Protected (FP)
Bryant's savannah sparrow (Passerculus sandwichensis
alaudinus) SSC
saltmarsh common yellowthroat (Geothlypis trichas sinuosa) SSC burrowing owl (Athene cunicularia) SSC
Alameda song sparrow (Melospiza melodia pusillula) SSC
grasshopper sparrow (Ammodramus savannarum) SSC
tricolored blackbird (Agelaius tricolor) ST, SSC
white-tailed kite (Elanus leucurus) FP
golden eagle (Aquila chrysaetos) FP
northern harrier (Circus hudsonius) SSC
black skimmer (Rynchops niger) SSC
California least tern (Sternula antillarum browni) FE, FP California Ridgway's rail (Rallus obsoletus obsoletus) FE, SE, FP California black rail (Laterallus jamaicensis coturniculus) ST, SSC western snowy plover (Charadrius nivosus nivosus) FT, SSC western mastiff bat (Eumops perotis californicus) SSC
Townsend's big-eared bat (Corynorhinus townsendii) SSC

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Madeline Khair
City of Sunnyvale
May 6, 2024

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western pond turtle (Emys marmorata) Proposed FT, SSC
Crotch's bumble bee (Bombus crotchii) State candidate (SC)

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Comments and Responses on the Draft IS-MND

Final Initial Study – Negative Declaration
Letter 1
COMMENTER: Erin Chappell, Regional Manager Bay Delta Region, California Department of Fish and Wildlife (CDFW)
DATE: May 6, 2024
Response 1.1
The commenter describes CDFW’s role as a Trustee and Responsible Agency. The commenter states that their comments have been prepared pursuant to the CDFW’s authority as a Trustee Agency under Fish and Game Code Section 711.7a and 1802, Public Resources Code (PRC) Section 21070, and CEQA Guidelines Sections 15386(a) and as a Responsible Agency under PRC Section 21069 and CEQA Guidelines Section 15381. The commenter also states that CDFW may need to exercise regulatory authority as the proposed plan may be subject to CDFW’s Lake and Streambed Alteration (LSA) regulatory authority or result in “take.” The commenter states that CDFW recommends the project obtain appropriate authorization under the Fish and Game Code.

This comment is noted, and specific concerns raised by the commenter are addressed below. No further response is required.

Response 1.2
The commenter provides an overview of regulatory requirements related to biological resources, including the California Endangered Species Act (CESA), LSA, Fish and Game Code Sections 3503, 3511, and 4700, and Migratory Bird Treaty Act.

This comment is noted, and specific concerns raised by the commenter are addressed below. No further response is required.

Response 1.3
The commenter describes the proposed plan, location, and objectives as outlined in the IS-ND.

This comment is noted, and specific concerns raised by the commenter are addressed below. No further response is required.

Response 1.4
The commenter provides an introduction to their more detailed comments. The commenter states the IS-ND should define the threshold of significance for each impact and describe the criteria used to determine whether the impacts are significant. The commenter also states the IS-ND relies on General Plan policies and on requirements that subsequent projects obtain appropriate permits but does not sufficiently describe how these policies will reduce impacts to less-than-significant.

The thresholds of significance for each resource topic are listed at the beginning of each section of the IS-ND. Section 4, Biological Resources, of the IS-ND includes six thresholds of significance, labeled a. through f. As a policy document that does not include any specific planned projects, the potential for significant impacts for each of these thresholds was assessed based on the potential for the plan to result in future physical changes to the environment at a programmatic level. The comment regarding references to compliance with the General Plan and permitting requirements is Attachment 10

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an introduction to the commenter’s later comments, and specific concerns raised by the commenter are addressed below.

Response 1.5
The commenter recommends that the IS-ND include a list of special status species and sensitive habitat with the potential to occur within the City.

Pages 42 and 43 of the Draft IS-ND note that there is the potential for protected species and sensitive habitat to occur within the City. These descriptions have been expanded upon in the Final IS-ND to detail the specific species and habitats that the commenter’s later recommendations focus on, as follows.

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Sunnyvale is a primarily urbanized community with limited habitat to support special-status species.

However, ruderal infill lots could support burrowing owl, Crotch’s bumble bee, and Congdon’s tarplant. Shoreline areas and wetlands in Sunnyvale may support protected shore birds and fish species, such as black skimmer, California least tern, California black rail, California Ridgway's rail, western snowy plover, steelhead, and longfin smelt. These special status species are afforded protection under the federal Endangered Species Act, California Endangered Species Act, and/or California Fish and Game Code (CFGC). Additionally, urban parks, open space, and riparian areas could support nesting birds. Active nests of all migratory birds, including raptors, are protected by State and federal law. Migratory and nesting birds are protected by Sections 3503, 3503.5, and 3513 of the CFGC and the Migratory Bird Treaty Act (MBTA), and may utilize trees, landscaping, and structures throughout Sunnyvale for nesting habitat.

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Sunnyvale contains wetlands, streams, shoreline, riparian areas, and other sensitive habitat in the areas adjacent to the San Francisco Bay and Stevens Creek, Calabazas Creek, and Moffett Channel.

Wetlands and other waters in Sunnyvale are protected by the federal Clean Water Act, the California Porter-Cologne Water Quality Control Act, and CFGC Section 1600 et seq., and are under the jurisdiction of the U.S. Army Corps of Engineers, the San Francisco Bay Regional Water Quality Control Board, and the California Department of Fish and Wildlife. Federal and State regulations require avoidance of impacts to the extent feasible, as well as compensation for unavoidable losses of jurisdictional wetlands and waters and sensitive natural communities and riparian habitat. SMC Chapter 12.60 requires compliance with the Clean Water Act and the Porter-Cologne Water Quality Control Act.

Response 1.6
The commenter states that the IS-ND does not include a checklist for subsequent project review nor adequate description of how the City’s policies would mitigate any potential impacts of the proposed plan. The commenter recommends that the IS-ND include a procedure or checklist for evaluating subsequent project impacts on biological resources.

As described throughout Section 2, Biological Resources, projects implemented in support of the proposed plan would be reviewed for consistency with and required to comply with federal and state regulations that protect biological resources, such as the federal Endangered Species Act, California Endangered Species Act, CFCG, Migratory Bird Treaty Act, and Clean Water Act. In addition, projects implemented in support of the proposed plan would also be reviewed for Attachment 10

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consistency with local policies such as those contained in the City’s General Plan. Specific policies and actions contained in the General Plan that provide for the protection of biological resources include the following:
▪ Policy LT-1.10: participate in federal, state, and regional programs and processes in order to protect the natural and human environment in Sunnyvale and the region.  Action LT-1.10a: Protect and preserve the diked wetland areas in the baylands to preserve or enhance flood protection.
 Action LT-1.10e: Continue to evaluate and ensure mitigation of potential biological impacts of future development and redevelopment projects in a manner consistent with applicable local, state, and federal laws and regulations.
▪ Policy LT-2.3: Accelerate the planting of large canopy trees to increase tree coverage in Sunnyvale in order to add to the scenic beauty and walkability of the community; provide environmental benefits such as air quality improvements, wildlife habitat, and reduction of heat islands; and enhance the health, safety, and welfare of residents.  Action LT-2.3c: Evaluate increasing the level of required tree planting and canopy coverage for new developments and site renovation projects while preserving solar access for photovoltaic systems.
 Action LT-2.3d: Require tree replacement for any project that results in tree removal, or in cases of constrained space, require payment of an in-lieu fee. Fee revenues shall support urban forestry programs.
▪ Policy LT-2.4: Maintain and regularly review and update regulations and practices for the planting, protection, removal, replacement, and long-term management of large trees on private property and city-owned golf courses and parks.  Action LT-2.4a: Strictly enforce Chapters 13.16 City Trees and 19.94 Tree Preservation to prevent the unauthorized removal, irreversible damage, and pruning of large protected trees.
▪ Policy LT-2.5: Recognize the value of protected trees and heritage landmark trees (as defined in city ordinances) to the legacy, character, and livability of the community by expanding the designation and protection of large signature and native trees on private property and in city parks.
 Action LT-2.5c: Emphasize tree relocation, site redesign, or special construction provisions over removing and irreparably damaging healthy heritage landmark trees and protected trees. Consider more than the economic value of a tree. ▪ Policy LT-9.5: Maintain existing park and open space tree inventory through the replacement of trees with an equal or greater number of trees when trees are removed due to disease, park development or other reasons.
▪ Policy LT-9.19: Protect creeks and wetlands as important parts of the community’s natural environment and open space and for their contribution to flood control.  Action LT-9.19a: Work with other agencies to maintain creeks and wetlands in their natural state.
 Action LT-9.19c: Minimize or divert pollutants from draining into creeks and wetlands by enforcing best management practices during construction, site development, and ongoing operations.

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▪ Policy LT-10.5: Engage in regional efforts to enhance and protect land uses near streams and to respond to sea level rise and climate change.
 Action LT-10.5a: Maintain and regularly review and update a streamside development review and permitting process.
 Action LT-10.5b: Apply development standards provided by the Santa Clara Valley Water District (SCVWD).
 Action LT-10.5c :Conduct streamside development review as part of a building permit plan check process, design review, the miscellaneous plan permit, and/or the discretionary review process.
 Action LT-10.5d: Minimize effects of development on natural streambeds.  Action LT-10.5e: When opportunities exist, remove existing structures adjacent to streams that impact the streambed.

The City also maintains Bird Safe Design Guidelines in reviewing the design of new structures in the city.1 These policies are listed in Section 2, Biological Resources, and it is noted that future projects under the proposed plan would be required to comply with these policies. Projects would also be subject to environmental review under CEQA, and individual biological resources assessments and impact analyses may identify required plan- or project-specific mitigation measures where applicable, such as nesting bird and special status species surveys and habitat restoration, as recommended in subsequent comments made by the commenter. Therefore, implementation of the proposed plan will comply with the commenter’s suggestions for surveys and mitigation measures when applicable and warranted.

Response 1.7
The commenter recommends a mitigation measure requiring nesting bird surveys prior to project construction activities if construction occurs within the nesting season.

Please refer to Response 1.6, which describes how the City will review and evaluate projects prior to approval which would include enforcing federal, state (including CDFW), and local regulations to minimize impacts to sensitive species including nesting birds when projects supporting the plan are proposed with the specific site location, size, and details of potential construction. Furthermore, completion of pre-construction nesting bird surveys is a standard practice for any project that disturbs vegetation in order to comply with the Migratory Bird Treaty Act and CDFW regulations.

These surveys would be implemented as a regulatory requirement and mitigation is not required.

Therefore, implementation of the proposed plan will comply with the commenter’s suggestions for nesting bird surveys when applicable and warranted.

Response 1.8
The commenter states the IS-ND does not state potential impacts to shoreline and marsh birds from the plan, such as from projects that would restore and expand salt marshes. The commenter recommends inclusion of a mitigation measure that requires surveys for marsh birds.

The following information has been added to Page 42 of the IS-ND for clarification:

1 https://www.sunnyvale.ca.gov/home/showpublisheddocument/1542/638273438333130000 Attachment 10

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Shoreline areas and wetlands in Sunnyvale may support protected shore birds and fish species, such as black skimmer, California least tern, California black rail, California Ridgway's rail, western snowy plover, steelhead, and longfin smelt…
…However, implementation of the following Sunnyvale Playbook Update/Game Plan 2028 Plays may promote infrastructure development and redevelopment and may that have the potential to result in impacts to special status species through construction activities that could directly cause mortality or result in indirect impacts through loss of breeding, foraging, and nesting habitat.

Nonetheless, as addressed below, with adherence to the requirements of federal Endangered Species Act, California Endangered Species Act, CFCG, SMC, and Sunnyvale General Plan policies and actions, construction impacts would be minimized.

Please refer to Response 1.6, which describes how the City will review and evaluate projects prior to approval which would include enforcing federal, state (including CDFW), and local regulations to minimize impacts to sensitive species including shore birds when projects supporting the plan are proposed with the specific site location, size, and details of potential construction. Therefore, implementation of the proposed plan will comply with the commenter’s suggestions for surveys and mitigation measures when applicable and warranted.

Response 1.9
The commenter states the IS-ND does not include potential impacts to state listed fish species from the plan, such as from projects that would restore and expand salt marshes. The commenter recommends inclusion of a mitigation measure that would limit in-water construction activities during the CDFW approved work window and use of vibratory pile drivers.

The following information has been added to Page 42 of the IS-ND:

Shoreline areas and wetlands in Sunnyvale may support protected shore birds and fish species, such as black skimmer, California least tern, California black rail, California Ridgway's rail, western snowy plover, steelhead, and longfin smelt…
…However, implementation of the following Sunnyvale Playbook Update/Game Plan 2028 Plays may promote infrastructure development and redevelopment and may that have the potential to result in impacts to special status species through construction activities that could directly cause mortality or result in indirect impacts through loss of breeding, foraging, and nesting habitat.

Therefore, implementation of the proposed plan will comply with the commenter’s suggestion for mitigation measures when applicable and warranted.

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Final Initial Study –Negative Declaration
Response 1.10
The commenter states the IS-ND does not address whether the proposed plan could result in impacts to Crotch’s bumble bee, which has been documented to occur in the area. The commenter recommends a mitigation measure requiring habitat assessment for Crotch’s bumble bee.

The following information has been added to Page 42 of the IS-ND for clarification:

Sunnyvale is a primarily urbanized community with limited habitat to support special-status species.

However, ruderal infill lots could support burrowing owl, Crotch’s bumble bee, and Congdon’s tarplant…
…However, implementation of the following Sunnyvale Playbook Update/Game Plan 2028 Plays may promote infrastructure development and redevelopment and may that have the potential to result in impacts to special status species through construction activities that could directly cause mortality or result in indirect impacts through loss of breeding, foraging, and nesting habitat.

Therefore, implementation of the proposed plan will comply with the commenter’s suggestions for surveys and mitigation measures when applicable and warranted.

Response 1.11
The commenter states the IS-ND does not address whether the proposed plan could result in impacts to burrowing owl. The commenter recommends a mitigation measure requiring habitat assessment and surveys for burrowing owl.

The following information has been added to Page 42 of the IS-ND for clarification:

Sunnyvale is a primarily urbanized community with limited habitat to support special-status species.

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Comments and Responses on the Draft IS-MND

Final Initial Study – Negative Declaration
Therefore, implementation of the proposed plan will comply with the commenter’s suggestions for surveys and mitigation measures when applicable and warranted.

Response 1.12
The commenter states the IS-ND does not identify that future development under the plan may be subject to Fish and Game Code section 1600 et seq. The commenter also states the plan could result in impacts to streams and riparian habitat and recommends incorporation of mitigation measures requiring projects to obtain the appropriate CDFW, Regional Water Quality Control Board, and U.S.

Army Corps of Engineers permits and provide habitat restoration and compensation as applicable.

The following information has been added to Page 44 of the IS-ND for clarification:

Any future Playbook Update/Game Plan 2028-related projects that could affect sensitive habitat, streams, or wetlands would be required to comply with the requirements of the California Porter- Cologne Water Quality Control Act, and CFGC Section 1600 et seq. Compliance with these regulations would include obtaining the appropriate CDFW, U.S. Army Corps of Engineers, and/or Regional Water Quality Control Board permits and complying with any avoidance, minimization, and habitat restoration measures required by the applicable agencies.

If future plan-related projects would involve activities within rivers, lakes, streams, or riparian habitat, the City would provide written notification to CDFW and any other applicable resource agencies and comply with all regulatory requirements.

Response 1.13
The commenter state they appreciate the inclusion of strategies to restore and enhance marshes along the shoreline of the City and to implement an Urban Forest Management Plan that will result in increased canopy cover.

The commenter’s editorial comments are noted and will be shared with City decision makers for their consideration.

Response 1.14
The commenter states that the City should report any special status species and natural communities detected during project surveys to the California Natural Diversity Database.

This information is noted, and the City will comply with this requirement if special status species or natural communities are encountered.

Response 1.15
The commenter states that payment of filing fees is required upon filing of the Notice of Determination for the IS-ND.

This information is noted, and the City will pay the applicable filing fees.

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Final Initial Study –Negative Declaration

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Sunnyvale Climate Action Playbook Update/
Game Plan 2028
and CEQA GHG Emissions Thresholds
Final Initial Study – Negative Declaration
prepared for
City of Sunnyvale
City Manager’s Office
456 W. Olive Avenue
Sunnyvale, CA 94086
prepared by
Rincon Consultants, Inc.
449 15th Street, Suite 303
Oakland, California 94612
May 2024

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Table of Contents

Final Initial Study– Negative Declaration i
Table of Contents
Initial Study ............................................................................................................................................. 1 Proposed Plan Title ......................................................................................................................... 1 Lead Agency/Plan Sponsor and Contact ......................................................................................... 1 Plan Location and Physical Setting ................................................................................................. 1 Existing Sustainability Setting ......................................................................................................... 6 General Plan Designation and Zoning ...........................................................................................15 Description of Plan ........................................................................................................................15 Cumulative Projects Scenario .......................................................................................................25 Required Approvals ......................................................................................................................26 Environmental Factors Potentially Affected .........................................................................................27 Determination ......................................................................................................................................27 1 Aesthetics .....................................................................................................................................29 2 Agriculture and Forestry Resources ..................................................................................33 3 Air Quality .........................................................................................................................36 4 Biological Resources ..........................................................................................................41 5 Cultural Resources ............................................................................................................47 6 Energy ...............................................................................................................................50 7 Geology and Soils ..............................................................................................................53 8 Greenhouse Gas Emissions ...............................................................................................59 9 Hazards and Hazardous Materials ....................................................................................63 10 Hydrology and Water Quality ...........................................................................................68 11 Land Use and Planning ......................................................................................................73 12 Mineral Resources ............................................................................................................75 13 Noise .................................................................................................................................76 14 Population and Housing ....................................................................................................81 15 Public Services ...................................................................................................................83 16 Recreation .........................................................................................................................85 17 Transportation ..................................................................................................................87 18 Tribal Cultural Resources ..................................................................................................90 19 Utilities and Service Systems ............................................................................................93 20 Wildfire..............................................................................................................................98 21 Mandatory Findings of Significance ................................................................................100 References ..........................................................................................................................................102 List of Citations ...........................................................................................................................102 List of Document Preparers ........................................................................................................107 Attachment 10

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City of Sunnyvale
Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

ii
Tables
Table 1 Sunnyvale 2019 Communitywide GHG Emissions Levels .................................................16 Table 2 Sunnyvale Playbook Update/Game Plan 2028 GHG Emissions Reduction Strategies, Plays, and Moves ..............................................................................................................17 Table 3 Sunnyvale 2030 GHG Emissions Forecasts (MT of CO2e) .................................................21 Table 4 Targets Versus GHG Reductions .......................................................................................22 Table 5 Cumulative Projects Scenario ...........................................................................................26 Table 6 Human Response to Different Levels of Groundborne Vibration .....................................79 Figures
Figure 1 Regional Location ................................................................................................................ 2 Figure 2 Plan Location ....................................................................................................................... 3 Figure 3 Sunnyvale Transit Routes .................................................................................................... 5 Figure 3 Sunnyvale GHG Emissions Projections and Targets ..........................................................22 Figure 5 Determining CEQA GHG Emissions Analysis Methodology ..............................................24 Appendices
Appendix A Sources, Health Effects, and Typical Controls Associated with Criteria Pollutants Appendix B Description of Greenhouse Gases of California Concern

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Final Initial Study–Negative Declaration 1
Initial Study
Proposed Plan Title
Sunnyvale Climate Action Playbook Update/Game Plan 2028 and California Environmental Quality Act (CEQA) Greenhouse Gas (GHG) Emissions Thresholds Lead Agency/Plan Sponsor and Contact
Lead Agency/Plan Sponsor
City of Sunnyvale
City Manager’s Office
456 W. Olive Avenue
Sunnyvale, CA 94086
Contact Person
Madeline Khair
Environmental Programs Manager
408-730-7798
[email protected]
Plan Location and Physical Setting
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would apply to all areas and plans and projects within the City of Sunnyvale limits. Figure 1 shows the regional location, and Figure 2 shows the plan location.

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2 Figure 1 Regional Location

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Final Initial Study–Negative Declaration 3
Figure 2 Plan Location

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4 Regional Location and Setting
The City of Sunnyvale is approximately 24 square miles and located in Santa Clara County within the larger San Francisco Bay Area. Sunnyvale is also located within an area informally referred to as Silicon Valley, which is located approximately 42 miles south of San Francisco and generally includes the Cities of Sunnyvale, Cupertino, San Jose, Menlo Park, Palo Alto, Mountain View, Santa Clara, and Redwood City. Sunnyvale is bordered by the San Francisco Bay to the north, City of Santa Clara to the east, City of Cupertino to the south, and Cities of Mountain View and Los Altos to the west.

Sunnyvale is at the crossroads of five major freeways and expressways: US 101 and State Route (SR) 237 to the north, State Route (SR) 85 to the west, Interstate 280 (I-280) to the south, and Lawrence Expressway to the east. These freeways provide regional access to Sunnyvale. Sunnyvale is also served by public transit facilities, including Santa Clara Valley Transportation Authority (SCVTA) rail and bus lines and the Caltrain commuter rail. There are two Caltrain stations located within Sunnyvale: Lawrence Station located beneath the Lawrence Expressway overcrossing between Reed Avenue and Kifer Road and Sunnyvale Station located near the intersection of Frances Street and Evelyn Avenue.1 Transit routes in Sunnyvale are shown in Figure 3. In addition, nearby airports include the San Jose International Airport and Moffett Federal Airfield.

Local Setting
Sunnyvale is the second most populous city in Santa Clara County, with a population of 156,317 in 2022 according to the California Department of Finance (DOF).2 Nearly all properties in Sunnyvale are developed; only 0.9 percent of land area is vacant. Residential areas account for the single largest land use, amounting to 54 percent of the developed area, while industrial and office uses constitute 25 percent of the developed area, excluding baylands and streets. The balance comprises open space and commercial and other urban land uses.3 Sunnyvale is almost entirely surrounded by cities and the San Francisco Bay, generally between Calabazas Creek on the east and Stevens Creek on the west. Elevations in Sunnyvale rise slightly from sea level at San Francisco Bay to 300 feet in the city’s southwest corner.

Sunnyvale is characterized by a temperate climate with dry summers and wet winters. The warm season lasts from June to October with an average daily high temperature above 73°F. The cool season lasts from November to February with a daily high temperature below 61°F.4 The warmest months of the year in Sunnyvale are July and August, while the coldest months of the year are December and January.

1 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed November 2023). 2 California Department of Finance (DOF). 2023. E-5 Population and Housing Estimates. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing-estimates-for-cities-counties-and-the-state-2020- 2023/ (accessed November 2023).
3 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed November 2023). 4 Weather Spark. 2023. Climate and Average Weather Year Round in Sunnyvale. https://weatherspark.com/y/571/Average-Weather-in- Sunnyvale-California-United-States-Year-Round#:~:text=Over%20the%20course%20of%20the,or%20above%2087%C2%B0F (accessed November 2023).

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Final Initial Study–Negative Declaration 5
Figure 3 Sunnyvale Transit Routes

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6 Existing Sustainability Setting
Sunnyvale Sustainability and Greenhouse Gas Emissions Reduction Efforts The City has actively implemented a variety of environmental programs contributing to GHG emissions reductions. The following is a listing of Sunnyvale’s primary sustainability and climate protection programs and policies:
▪ Zero Waste Strategic Plan adopted (2013)
▪ CAP 1.0 adopted (2014)
▪ General Plan Environmental Management Element adopted (2016) ▪ Joined Silicon Valley Clean Energy (SVCE), a Community Choice Energy opt-in program (2017) ▪ Climate Action Playbook and Game Plan 2022 adopted (2019) ▪ Green Building Program update adopted (2019)
▪ Climate Action Scoreboard launched (2020)
▪ Sunnyvale Active Transportation Plan adopted (2020)
▪ Vehicle Miles Traveled (VMT) Transportation Policy (City Council Policy 1.2.8) adopted (2020) ▪ Sunnyvale Reach Codes requiring all-electric new construction and increased solar and electric vehicle (EV) requirements adopted (2021-2023)
The City has also taken several additional sustainability actions, such as converting streetlights to light-emitting diode (LED), increasing number of EV charging stations, increasing rooftop solar on homes and offices, and increasing number of trees planted.

Regional Sustainability and GHG Reduction Efforts
In coordination with Santa Clara County, the State of California, and the federal government, the City of Sunnyvale has committed to implementing regional and State policies related to GHG emissions reductions. As follows is a summary of the existing regional GHG emissions reduction efforts, which the Draft Sunnyvale Playbook Update/Game Plan 2028 is intended to be consistent with or exceed.

Plan Bay Area: Strategy for a Sustainable Region
In October 2021, the Association of Bay Area Governments (ABAG) and Metropolitan Transportation Commission (MTC) jointly adopted Plan Bay Area 2050, which serves as the Bay Area regional long- range plan and identifies how the Bay Area would meet its GHG emission reduction targets. Plan Bay Area is also considered the ABAG/MTC Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). In accordance with SB 743, Plan Bay Area includes elements designed to encourage the type of land-use development to preserve affordable housing, improve economic mobility, enhance the transit network to reduce vehicle miles traveled (VMT) per capita, and reduce hazard risks including through adaptation to sea level rise and reducing GHG emissions.5 Bay Area Air Quality Management District CEQA Guidelines In 2022, the Bay Area Air Quality Management District (BAAQMD) adopted the CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans and is in the

5 ABAG-MTC. 2021. Plan Bay Area 2050. https://www.planbayarea.org/finalplan2050 (accessed November 2023).

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Final Initial Study–Negative Declaration 7
process of updating their 2017 CEQA Guidelines.6 The CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans include requirements for projects and plans in jurisdictions that do not have an adopted local GHG reduction strategy that meets the criteria of CEQA Guidelines Section 15183(b). In addition, according to the BAAQMD, if a project is consistent with a local GHG reduction strategy, then it can be presumed that the project will not have significant GHG impacts.7 This approach is consistent with CEQA Guidelines, Section 15183.5:

Lead agencies may analyze and mitigate the significant impacts of GHG emissions at a programmatic level, such as…a plan to reduce GHG emissions. Later project-specific environmental documents may tier from and/or incorporate by reference that existing programmatic review. Project-specific environmental documents may rely on an [Environmental Impact Report] containing a programmatic analysis of GHG emissions.

Santa Clara Countywide Transportation Plan
In 2014, the Santa Clara County Transportation Valley Transportation Authority (VTA) adopted the Valley Transportation Plan (VTP) 2040 to provide the County with a long-range plan for establishing the vision and priorities for transportation over a 25-year planning horizon. The VTP seeks to facilitate and support an integrated, multi-modal transportation system in order to improve mobility and access for all segments of the population and promote environmental sustainability. The plan identifies 371 projects across the county including transit capacity improvements, express lane and highway improvement projects, bicycle and pedestrian facilities, and operations and maintenance.

Projects identified for Sunnyvale include Lawrence Expressway and Wildwood Avenue realignment and signalization; Mary Avenue extension; Sunnyvale local streets improvements; and adding bike lanes to Belleville Way, Bernardo Avenue, California Avenue, El Camino Real, Fair Oaks Avenue, Hendy Avenue, Hollenbeck Avenue, Java Drive, Lakewood and Sandia Drive, Mathilda Avenue, Maude Avenue, Moffett Park area, Stevens Creek Trail, Tasman Drive, Fair Oaks/Tasman Drive, Fair Oaks Junction Trail, and Olive Avenue.8 VTA is currently in the process of updating the VTP, with the 2050 VTP anticipated to be adopted in winter 2024.9
Santa Clara County Climate Roadmap 2030
Santa Clara County is currently developing the Climate Roadmap 2030 which will outline actions the County and partners will take to reduce greenhouse gas emissions. The Roadmap will serve to align existing efforts to reduce GHG emissions among Cities that have already adopted CAPs, prioritize actions in unincorporated areas of the County, and help leverage and facilitate regional partnerships to further encourage sustainable and resilient communities. The County aims to use the Roadmap as a tool to increase coordination and collaboration in efforts to reach shared sustainability goals.

The Roadmap will include the following:
▪ A countywide greenhouse gas emissions inventory and forecast

6 BAAQMD. 2022. CEQA Thresholds for Evaluating the Significance of Climate Impacts from Land Use Projects and Plans. https://www.baaqmd.gov/~/media/files/planning-and-research/ceqa/ceqa-guidelines-2022/appendix-b-thresholds-for-evaluating- significance-of-climate-impacts_final-pdf.pdf?la=en (accessed November 2023). 7 Ibid
8 Valley Transportation Authority (VTA). 2014. Valley Transportation Plan 2040. http://vtaorgcontent.s3-us-west-

1.amazonaws.com/Site_Content/VTP2040_final_hi%20res_030315.pdf (accessed November 2023). 9 VTA. 2023. Valley Transportation Plan (VTP) 2050 webpage. https://www.vta.org/projects/valley-transportation-plan-vtp-2050 (accessed November 2023).

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8 ▪ An online interactive map tool that will provide a comprehensive overview of the cities, organizations, institutions, and companies working on climate action in Santa Clara County ▪ Community and partner input
▪ An implementation roadmap10
Silicon Valley Clean Energy Community Choice Energy
SVCE formed in 2017 as the community-owned electricity provider for several south bay cities, including Sunnyvale. SVCE developed its Decarbonization Strategy and Programs Roadmap with extensive community input to help guide community electrification, which entails switching from relying on fossil fuel use in homes, buildings and transportation to electricity from renewable sources. By 2030, SVCE programs aim to cut energy-related pollution in half from the 2015 baseline.

That equates to preventing two million metric tons of carbon dioxide equivalents (MT of CO2e) from being released into the environment each year.

State Sustainability and GHG Reduction Efforts
As follows is a summary of existing State GHG emissions reduction efforts, which the Playbook Update/Game Plan 2028 are intended to be consistent with or exceed.

GHG Reduction Policies
CALIFORNIA EXECUTIVE ORDER S-3-05
In 2005, the California governor issued Executive Order (EO) S-3-05, which identifies Statewide GHG emissions reduction targets to achieve long-term climate stabilization as follows:
▪ Reduce GHG emissions to 1990 levels by 2020
▪ Reduce GHG emissions to 80 percent below 1990 levels by 2050 In response to EO S-3-05, California Environmental Protection Agency (CalEPA) created the Climate Action Team (CAT), which in March 2006 published the Climate Action Team Report (the “2006 CAT Report”). The 2006 CAT Report identified a recommended list of strategies that the State could pursue to reduce GHG emissions. These are strategies that could be implemented by various State agencies to ensure that the emission reduction targets in EO S-3-05 are met and can be met with existing authority of the State agencies. The strategies include the reduction of passenger and light duty truck emissions, the reduction of idling times for diesel trucks, an overhaul of shipping technology/infrastructure, increased use of alternative fuels, increased recycling, and landfill methane capture, among others.

CALIFORNIA ASSEMBLY BILL 32, CALIFORNIA GLOBAL WARMING POLLUTION SOLUTIONS ACT In 2006, the California legislature signed Assembly Bill (AB) 32 – the Global Warming Solutions Act – into law, requiring a reduction in Statewide GHG emissions to 1990 levels by 2020 and California Air Resources Board (CARB) preparation of a Scoping Plan that outlines the main State strategies for reducing GHGs to meet the 2020 deadline. In addition, AB 32 required CARB to adopt regulations to require reporting and verification of Statewide GHG emissions. Based on this guidance, CARB approved a 1990 Statewide GHG level and 2020 limit of 427 MT of CO2e.

10 Santa Clara County. 2023. Climate Roadmap 2030. https://sustainability.sccgov.org/climate-roadmap-2030 (accessed November 2023).

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CALIFORNIA SENATE BILL 375, SUSTAINABLE COMMUNITIES AND CLIMATE PROTECTION ACT In 2008, Senate Bill (SB) 375 enhanced the State’s ability to reach AB 32 targets by CARB to develop regional GHG emissions reduction targets to be achieved from passenger vehicles for 2020 and 2035. In addition, SB 375 directs each of the State’s 18 major Metropolitan Planning Organizations (MPO) to prepare a sustainable community’s strategy (SCS) that contains a growth strategy to meet such regional GHG emissions reduction targets for inclusion in the respective regional transportation plan (RTP).

On March 22, 2018, CARB adopted updated regional targets for reducing GHG emissions from 2005 levels by 2020 and 2035. The Association of Bay Area Governments was assigned targets of a ten percent reduction in per capita GHG emissions from passenger vehicles by 2020 and a nineteen percent reduction in per capita GHG emissions from passenger vehicles by 2035.11

CALIFORNIA CLIMATE CHANGE SCOPING PLAN
In 2008, CARB approved the original California Climate Change Scoping Plan, which included measures to address GHG emission reduction strategies related to energy efficiency, water use, and recycling and solid waste, among other measures. Many of the GHG reduction measures included in the Scoping Plan (e.g., Low Carbon Fuel Standard, Advanced Clean Car standards, and Cap-and- Trade) have been adopted and implemented since approval of the Scoping Plan.

CALIFORNIA CLIMATE CHANGE SCOPING PLAN UPDATE (2013)
In 2013, CARB approved the first update to the California Climate Change Scoping Plan. The 2013 Scoping Plan Update defined CARB climate change priorities for the next five years and set the groundwork to reach post-2020 Statewide GHG emissions reduction goals. The 2013 Scoping Plan Update highlighted California’s progress toward meeting the “near-term” 2020 GHG emission reduction goals defined in the original Scoping Plan. It also evaluated how to align the State’s longer-term GHG reduction strategies with other State policy priorities, including those for water, waste, natural resources, clean energy, transportation, and land use.

CALIFORNIA EXECUTIVE ORDER B-30-15
In 2015, the California governor issued Executive Order B-30-15, which established a Statewide mid- term GHG reduction target of 40 percent below 1990 levels by 2030.

CALIFORNIA SENATE BILL 32, CALIFORNIA GLOBAL WARMING POLLUTION SOLUTIONS ACT UPDATE In 2016, SB 32 was passed, extending AB 32 by requiring further reduction in Statewide GHG emissions to 40 percent below 1990 levels by 2030 (the other provisions of AB 32 remain unchanged). On December 14, 2017, CARB adopted the 2017 Scoping Plan, which provides a framework for achieving the 2030 target. The 2017 Scoping Plan relies on the continuation and expansion of existing policies and regulations, such as the Cap-and-Trade Program, as well as implementation of recently adopted policies and policies, such as SB 350 and SB 1383 (see below).

CALIFORNIA CLIMATE CHANGE SCOPING PLAN UPDATE (2017)
In 2017, CARB approved the second update to the California Climate Change Scoping Plan. The 2017 Scoping Plan put an increased emphasis on innovation, adoption of existing technology, and

11 CARB. 2023. SB 375 Regional Plan Climate Targets. https://ww2.arb.ca.gov/our-work/programs/sustainable-communities- program/regional-plan-targets (accessed November 2023).

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10 strategic investment to support its strategies. As with the 2013 Scoping Plan Update, the 2017 Scoping Plan Update does not provide project-level thresholds for land use development. Instead, it recommends that local governments adopt policies and locally-appropriate quantitative thresholds consistent with Statewide per-capita goals of six MT of CO2e by 2030 and two MT of CO2e by 2050.

As stated in the 2017 Scoping Plan Update, these goals may be appropriate for plan-level analyses (city, county, subregional, or regional level), but not for specific individual projects, because they include all GHG emissions sectors in the State.12
CALIFORNIA EXECUTIVE ORDER B-55-18
In 2018, the California governor issued Executive Order B-55-18, which established a new Statewide goal of achieving carbon neutrality by 2045 and maintaining net negative emissions thereafter. This goal is in addition to the existing Statewide GHG reduction targets established by SB 32.

For more information on the Senate and Assembly Bills, Executive Orders, and Scoping Plans discussed above, and to view reports and research referenced above, please refer to the following websites: www.climatechange.ca.gov and www.arb.ca.gov/cc/cc.htm.

ASSEMBLY BILL 1279
In September 2022, AB 1279 was approved, which established a legally binding requirement for California to achieve and maintain carbon neutrality no later than 2045. Assembly Bill 1279 also established the requirement to achieve a Statewide reduction in GHG emissions of 85 percent below 1990 levels by 2045. This indicates that the remaining 15 percent to achieve carbon neutrality can be achieved via carbon sequestration and other non-direct-GHG-emissions-reductions techniques.

CALIFORNIA CLIMATE CHANGE SCOPING PLAN UPDATE (2022)
In response to the passage of AB 1279 and the identification of the 2045 GHG reduction target, CARB adopted the Final 2022 Climate Change Scoping Plan in November 2022. The 2022 Update builds upon the framework established by the 2008 Climate Change Scoping Plan and previous updates while identifying new, technologically feasible, cost-effective, and equity-focused path to achieve California’s climate target. The 2022 Update includes policies to achieve a significant reduction in fossil fuel combustion, further reductions in short-lived climate pollutants, support for sustainable development, increased action in natural working lands to reduce emissions and sequester carbon, and the capture and storage of carbon. The 2022 Update assesses the progress California is making toward reducing its GHG emissions by at least 40 percent below 1990 levels by 2030, as called for in SB 32 and laid out in the 2017 Scoping Plan, addresses recent legislation and direction from Governor Newsom, extends and expands upon these earlier plans, and implements a target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045, as well as taking an additional step of adding carbon neutrality as a science-based guide for California’s climate work.13

12 CARB. 2017. California 2017 Climate Change Scoping Plan. https://ww2.arb.ca.gov/sites/default/files/classic//cc/scopingplan/scoping_plan_2017.pdf (accessed November 2023). 13 CARB. 2022. 2022 Scoping Plan for Achieving Carbon Neutrality. https://ww2.arb.ca.gov/sites/default/files/2022-12/2022-sp.pdf (accessed November 2023)
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Energy- and Vehicle-Related Policies
ASSEMBLY BILL 1493, PAVLEY BILL VEHICLE EFFICIENCY STANDARDS In 2002, the California State Legislature enacted Assembly Bill 1493 (aka “the Pavley Bill”), which directs the CARB to adopt standards that will achieve "the maximum feasible and cost-effective reduction of GHG emissions from motor vehicles," taking into account environmental, social, technological, and economic factors. In September 2009, CARB adopted amendments to the “Pavley” regulations to reduce GHG emissions in new passenger vehicles from 2009 through 2016.

The Pavley Bill is considered to be the national model for vehicle emissions standards. In January of 2012, CARB approved a new emissions control program for vehicle model years 2017 through 2025.

The program combines the control of smog, soot, and GHGs and the requirement for greater numbers of zero emission vehicles into a single package of standards called Advanced Clean Cars.

CALIFORNIA ENERGY EFFICIENCY STRATEGIC PLAN OF 2008
In 2008, the California Public Utilities Commission (CPUC) adopted California’s first Long Term Energy Efficiency Strategic Plan, presenting a single roadmap to achieve maximum energy savings across all major groups and sectors in California. The Strategic Plan was subsequently updated in January 2011 to include a lighting chapter. The Strategic Plan sets goals of all new residential construction and all new commercial construction in California to be zero net energy (ZNE) by 2020 and 2030, respectively. In 2018, the California Energy Commission voted to adopt a policy requiring all new homes in California to incorporate rooftop solar. This change went into effect in January 2020 with the adoption of the 2019 California Code of Regulations (CCR) Title 24 Code and is a step towards the State achieving its goal of all residential new construction being ZNE by 2020.

Additionally, the Strategic Plan sets goals of 50 percent of existing commercial buildings to be retrofitted to ZNE by 2030, and all new State buildings and major renovations to be constructed to ZNE by 2025.

CALIFORNIA CODE OF REGULATIONS TITLE 24 (CALIFORNIA BUILDING CODE) Updated every three years through a rigorous stakeholder process, Title 24 of the CCR requires California homes and businesses to meet strong energy efficiency measures, thereby lowering their energy use. Title 24 contains numerous subparts, including Part 1 (Administrative Code), Part 2 (Building Code), Part 3 (Electrical Code), Part 4 (Mechanical Code), Part 5 (Plumbing Code), Part 6 (Energy Code), Part 8 (Historical Building Code), Part 9 (Fire Code), Part 10 (Existing Building Code), Part 11 (Green Building Standards Code), Part 12 (Referenced Standards Code). The California Building Code is applicable to all development in California. (Health and Safety Code §§ 17950 and 18938(b).)
The regulations receive input from members of industry, as well as the public, with the goal of "[r]educing of wasteful, uneconomic, inefficient, or unnecessary consumption of energy." (Pub. Res.

Code § 25402.) These regulations are carefully scrutinized and analyzed for technological and economic feasibility (Pub. Res. Code § 25402(d)) and cost effectiveness (Pub. Res. Code § 25402(b)(2) and (b)(3)). The 2022 Title 24 standards went into effect on January 1, 2023.

Part 6 – Building Energy Efficiency Standards
CCR Title 24 Part 6 is the Building Energy Efficiency Standards. This code, originally enacted in 1978, establishes energy-efficiency standards for residential and non-residential buildings in order to reduce California’s energy demand. The Building Energy Efficiency Standards is updated periodically Attachment 10

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12 to incorporate and consider new energy-efficiency technologies and methodologies as they become available. New construction and major renovations must demonstrate their compliance with the current Building Energy Efficiency Standards through submission and approval of a Title 24 Compliance Report to the local building permit review authority and the California Energy Commission.

Part 11 – California Green Building Standards
The California Green Building Standards Code, referred to as CALGreen, was added to Title 24 as Part 11, first in 2009 as a voluntary code, which then became mandatory effective on January 1, 2011 (as part of the 2010 California Building Standards Code). The 2022 CALGreen includes mandatory minimum environmental performance standards for all ground-up new construction of residential and non-residential structures. It also includes voluntary tiers with stricter environmental performance standards for these same categories of residential and non-residential buildings. Local jurisdictions must enforce the minimum mandatory CALGreen standards and may adopt additional amendments for stricter requirements.

The mandatory standards applicable to air quality require:
▪ Minimum 20 percent reduction in indoor water use relative to specified baseline levels;14 ▪ Waste Reduction:
 Minimum 65 percent non-hazardous construction/demolition waste diverted from landfills;  Non-residential and multi-family dwellings with five or more units: Provide readily accessible areas identified for the depositing, storage and collection of nonhazardous materials for recycling, including (at a minimum) paper, corrugated cardboard, glass, plastic, organic waste, and metals; and/or
 Non-residential: Reuse and/or recycling of 100 percent of trees, stumps, rocks, and associated vegetation soils resulting from primary land clearing; ▪ Inspections of energy systems to ensure optimal working efficiency; ▪ Low-pollutant emitting exterior and interior finish materials such as paints, carpets, vinyl flooring, and particleboards; and
▪ EV Charging for New Construction:15
 One- and two-family dwellings and town houses with attached private garages: Dedicated circuitry to facilitate installation of electric vehicle (EV) charging;  Multi-family dwellings and hotels/motels with less than 20 units/rooms: Designation of at least 10 percent of the total number of parking spaces shall be EV capable and at least 25 percent of the total number of parking spaces shall be EV-ready;  Multi-family dwellings and hotels/motels with greater than 20 units/rooms: Designation of at least 10 percent of the total number of parking spaces shall be EV capable, at least 25

14 Similar to the compliance reporting procedure for demonstrating Energy Code compliance in new buildings and major renovations, compliance with the CALGreen water reduction requirements must be demonstrated through completion of water use reporting forms.

Buildings must demonstrate a 20 percent reduction in indoor water use by either showing a 20 percent reduction in the overall baseline water use as identified in CALGreen or a reduced per-plumbing-fixture water use rate. 15 EV Capable = a vehicle space with electrical panel space and load capacity to support a branch circuit and necessary raceways to support EV charging; EV-ready = a vehicle space which is provided with a branch circuit and any necessary raceways to accommodate EV charging stations, including a receptacle for future installation of a charger (see 2022 California Green Building Standard Code, Title 24 Part 11 for full explanation of mandatory measures, including exceptions).

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percent of the total number of parking spaces shall be EV-ready, and at least 5 percent of the total number of parking spaces shall be equipped with a Level 2 charging station;  Non-residential land uses shall comply with the following EV charging requirements based on the number of passenger vehicle parking spaces:
0-9: no EV capable spaces or charging stations required; 10-25: 4 EV capable spaces but no charging stations required; 26-50: 8 EV capable spaces of which 2 must be equipped with charging stations; 51-75: 13 EV capable spaces of which 3 must be equipped with charging stations; 76-100: 17 EV capable spaces of which 4 must be equipped with charging stations; 101-150: 25 EV capable spaces of which 6 must be equipped with charging stations; 151-200: 35 EV capable spaces of which 9 must be equipped with charging stations; and More than 200: 20 percent of the total available parking spaces of which 25 percent must be equipped with charging stations;
□ Non-residential land uses shall comply with the following EV charging requirements for medium- and heavy-duty vehicles: warehouses, grocery stores, and retail stores with planned off-street loading spaces shall install EV supply and distribution equipment, spare raceway(s) or busway(s) and adequate capacity for transformer(s), service panel(s), or subpanel(s) at the time of construction based on the number of off-street loading spaces as indicated in Table 5.106.5.4.1 of the California Green Building Standards; ▪ Bicycle Parking:
 Non-residential short-term bicycle parking for projects anticipated to generate visitor traffic:
permanently anchored bicycle racks within 200 feet of visitor entrance for 5 percent of new visitor motorized vehicle parking spaces with a minimum of one 2-bike capacity rack; and/or  Non-residential buildings with tenant spaces of 10 or more employees/tenant-occupants:
secure bicycle parking for 5 percent of the employee/tenant-occupant vehicle parking spaces with a minimum of one bicycle parking facility.
▪ Shade Trees (Non-Residential):
 Surface parking: minimum No. 10 container size or equal shall be installed to provide shade over 50 percent of the parking within 15 years (unless parking area covered by appropriate shade structures and/or solar);
 Landscape areas: minimum No. 10 container size or equal shall be installed to provide shade of 20 percent of the landscape area within 15 years; and/or  Hardscape areas: minimum No. 10 container size or equal shall be installed to provide shade of 20 percent of the landscape area within 15 years (unless covered by applicable shade structures and/or solar or the marked area is for organized sports activities).

The City of Sunnyvale Reach Codes modify CALGreen and require that all new buildings and certain alterations be constructed as all-electric (no natural gas lines permitted). The Reach Codes also Attachment 10

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14 require all new buildings to include EV charging infrastructure installed above and beyond that required by CALGreen.16,17
ASSEMBLY BILL 117, COMMUNITY CHOICE AGGREGATION
AB 117 allows the creation of Community Choice Aggregation (CCA) that fosters clean and renewable energy markets. CCA allows cities and counties to aggregate the buying power of individual jurisdictions. The California CCA markets were created as an answer to the brownouts and energy shortages of the early 2000’s. AB 117 was passed in 2002 as an answer to California’s increased energy independency by incorporating more alternative and renewable energy sources into its energy portfolio. With AB 117, municipalities can provide alternative energy choices to their local carrier (e.g., Pacific Gas and Electric). Marin Clean Energy was the first CCA in the State of California to go online with a 50 percent to 100 percent clean energy portfolio in 2010. In 2017, SVCE began supplying south bay area communities, including Sunnyvale, with options for 100 percent renewable energy-sourced electricity or electricity from a mix of renewable and non- renewable sources. CCAs are governed by the CPUC. SB 790 further ensures fair and transparent competition by creating a code of conduct and guiding principles for entrants into the CCA field.

SENATE BILL 1275, CHARGE AHEAD INITIATIVE
In 2014, SB 1275 established a State goal of one million zero-emissions and near-zero-emissions vehicles in service by 2020 and directed CARB to develop a long-term funding plan to meet this goal.

SB 1275 also established the Charge Ahead California Initiative requiring planning and reporting on vehicle incentive programs and increasing access to and benefits from zero-emissions vehicles for disadvantaged, low- and moderate-income communities and consumers.

SENATE BILL 350, CLEAN ENERGY AND POLLUTION REDUCTION ACT OF 2015 In 2015, SB 350 established new clean energy, clean air, and GHG reduction goals for 2030 and beyond. SB 350 codified Governor Brown’s aggressive clean energy goals and established the State 2030 GHG reduction target of 40 percent below 1990 levels. To achieve this goal, SB 350 increases California’s renewable electricity procurement goal from 33 percent by 2020 (legislation originally enacted in 2002) to 50 percent by 2030. Renewable resources include wind, solar, geothermal, wave, and small hydroelectric power. In addition, SB 350 requires the State to double State-wide energy efficiency savings in electricity and natural gas end uses by 2030 from a base year of 2015.

SENATE BILL 1020, CLEAN ENERGY, JOBS, AND AFFORDABILITY ACT OF 2022 Established in 2002 under SB 1078, and accelerated by SB 107 (2006), SB X 1-2 (2011), SB 100 (2018), and SB 1020, California’s Renewable Portfolio Standard (RPS) obligates investor-owned utilities, energy service providers, and community choice aggregators to transition the electricity supply to renewable resources. The RPS requires energy service providers to supply renewable energy as follows: 90 percent of retail sale electricity and 100 percent of electricity procured to serve state agencies by 2035, 95 percent by 2040, and 100 percent by 2045. The CPUC and the CEC are jointly responsible for implementing the program.

16 Sunnyvale, City of. 2023. Single-Family, Duplex, and Townhome Reach Codes. https://www.sunnyvale.ca.gov/home/showpublisheddocument/1780/638114476018662936 (accessed November 2023). 17 Sunnyvale, City of. 2021. Nonresidential and Multifamily Residential Reach Codes. https://www.sunnyvale.ca.gov/home/showpublisheddocument/1496/637820847520270000 (accessed November 2023).

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Other GHG Emissions-Related Policies
ASSEMBLY BILL 197, STATE AIR RESOURCES BOARD GHGS REGULATIONS In 2016, the California legislature approved AB 197, a bill linked to SB 32, which increases legislature oversight over CARB and directs CARB to prioritize disadvantaged communities in its climate change regulations, and to evaluate the cost-effectiveness of measures it considers. AB 197 requires CARB to protect the State’s most impacted and disadvantaged communities [and] consider the social costs of the emissions of GHGs when developing climate change programs. The bill also adds two new legislatively appointed non-voting members to CARB, increasing the Legislature’s role in CARB’s decisions.

SENATE BILL 97, CEQA GUIDELINES FOR ADDRESSING GHG EMISSIONS CEQA requires public agencies to review the environmental impacts of proposed projects, including General Plans, Specific Plans, and specific kinds of development projects. In February 2010, the California Office of Administrative Law approved the recommended amendments to the State CEQA Guidelines for addressing GHG emissions. The amendments were developed to provide guidance to public agencies regarding the analysis, mitigation, and effects of GHG emissions in draft CEQA documents.

General Plan Designation and Zoning
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would be implemented throughout the City and would apply to all General Plan designations and in all zoning designations.

Description of Plan
Sunnyvale Playbook Update/Game Plan 2028
The Sunnyvale Playbook Update/Game Plan 2028 incorporates the many climate protection programs noted above that would continue to reduce GHG emissions. The City has developed the Sunnyvale Playbook Update/Game Plan 2028 in order to achieve a resilient and sustainable community and support regional, State, and global climate goals through achieving the City’s 2030 and 2045 climate action targets.

The Playbook Update/Game Plan 2028 seeks to achieve several future targets, including reducing GHG emissions 56 percent below 1990 levels by 2030 and putting Sunnyvale on a trajectory to meet the State goal of achieving carbon neutrality by 2045. The Playbook Update/Game Plan 2028 is also intended to provide a framework through its actions for a safer future and enhanced quality of life for the community, new economic opportunities through green jobs, and enhanced social equity and citizen engagement on the issue of climate change. The Playbook Update/Game Plan 2028 provides a foundation for future sustainable development efforts in Sunnyvale. It is anticipated that environmental review documents for future development projects would identify and incorporate applicable GHG reduction measures and actions from the Playbook Update/Game Plan 2028.

The Playbook Update/Game Plan 2028 addresses communitywide GHG emissions and includes a discrete target for Sunnyvale to reach maximum annual emissions of 441,846 MT of CO2e emissions by 2030. The Playbook Update/Game Plan 2028 includes a 2019 communitywide GHG emissions Attachment 10

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16 inventory, contains a list of Strategies, Plays, and Moves to achieve Sunnyvale’s sustainability goals, and focuses on actions through 2030 for purposes of meeting the City’s 2030 GHG emissions target.

The 2019 GHG emissions inventory provides the basis for emissions forecasts for the years 2025, 2030, 2035, 2040, and 2045. The GHG emissions inventory was completed in compliance with all relevant protocols and guidance documents, including U.S. Community Protocol, Local Government Operations Protocol, the Global Protocol for Community Scale GHG Emissions, and the Intergovernmental Panel on Climate Change (IPCC) Guidelines for National GHG Inventories. In 2019, Sunnyvale’s total GHG emissions were estimated to be 716,382 MT of CO2e. GHG emissions in the inventory are categorized based on sectors. These sectors include off-road vehicles and equipment, solid waste, water and wastewater, on-road transportation, Caltrain, residential energy use, and nonresidential energy use. Table 1 provides the summary of Sunnyvale’s 2019 GHG emissions by sector, as well as each sector’s percentage of communitywide emissions.18 As shown therein, the largest GHG emissions are related to transportation and building energy use.

Table 1 Sunnyvale 2019 Communitywide GHG Emissions Levels GHG Emissions Sector/Source CO2e (MT) Percent of Total Emissions Residential Energy 103,299 14
Nonresidential Energy 147,710 21
Transportation 373,498 52
Caltrain 1,119 <1
Off-Road Equipment 41,425 6
Water and Wastewater 825 <1
Solid Waste 48,506 7
Total 716,382 100
CO2e = carbon dioxide equivalent; MT = Metric Tons
Source: Rincon Consultants, Inc. Sunnyvale 2019 Community Inventory Memorandum. February 6, 2023.

The Sunnyvale Playbook Update/Game Plan 2028 establishes a target to reduce communitywide GHG emissions to 56 percent below 1990 levels by 2030 (441,846 MT of CO2e). This would exceed the SB 32 State GHG emissions target of 40% below 1990 levels by 2030, consistent with CEQA for a qualified GHG emissions reduction strategy and to be achievable by City-supported Plays and Moves identified in the Playbook Update/Game Plan 2028. The Playbook Update/Game Plan 2028 includes a business-as-usual (BAU) forecast and an adjusted BAU (ABAU) forecast of GHG emissions, based on the 2019 inventory, that enables Sunnyvale to estimate the emissions reductions required to meet its communitywide reduction targets.

The Sunnyvale Playbook Update/Game Plan 2028 is organized into Strategies, each of which includes “Plays” and “Moves.” These Strategies focus on clean electricity, building decarbonization, transportation decarbonization and sustainable land use planning, solid waste and water use reductions, community engagement, and climate adaptation. Table 2 includes a complete list of the Strategies, Plays, and Moves established by the Playbook Update/Game Plan 2028, as well as anticipated annual GHG reductions in 2030.

18 Rincon Consultants, Inc. Sunnyvale 2019 Community Inventory Memorandum. February 6, 2023.

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Table 2 Sunnyvale Playbook Update/Game Plan 2028 GHG Emissions Reduction Strategies, Plays, and Moves
Move
ID # Strategies and Respective Supporting Plays and Moves Anticipated GHG
Emissions Reduction
(MT of CO2e)1
Strategy 1: Promoting Clean Energy
Play 1.1 : Promoting 100% clean energy with 100% clean energy participation by 2030

1.A Continue to support and steer SVCE in providing clean power and decarbonization programs.
2030: 3,299
2045: 0

1.B Collaborate with SVCE to target Direct Access (DA) customers to shift to 100% clean electricity.

1.C Implement an Organic Waste-to-Energy program at the Donald M. Somers Water Pollution Control Plant.

1.D Work with SVCE to maintain a SVCE GreenPrime opt-out rate of no more than 3% and provide educational materials to community members on available incentives and benefits of the program.

Play 1.2: Increase local solar photovoltaics with 3% of load from local solar by 2030 and 5% by 2045

1.E Continue to enforce the solar panel requirements of the new building Reach Codes and Moffett Park Specific Plan policies to increase solar energy generation and storage in Moffett Park and throughout the community. 2030: 3
2045: 0

Play 1.3: Increase distributed electricity storage with 2% of electricity demand stored in batteries locally by 2030 and 5% by 2045

1.F Collaborate with SVCE to evaluate opportunities for community-scale energy storage to maximize utilization of local solar supply and to enhance resiliency.

Supportive

1.G Support a shared thermal energy system with energy storage at Moffett Park to serve as a potential model for other areas.

Strategy 2: Decarbonizing Buildings
Play 2.1: Reduce energy in existing buildings with 5% of homes and businesses receiving a deep energy retrofit by 2030 and 30% by 2045

2.A Research and develop energy disclosure and energy benchmarking requirements for existing commercial and multi-family residential buildings to encourage property owners and managers to invest in energy efficiency upgrades and building information systems.

Supportive

2.B Update the local Green Building Program by fiscal year 2024/25 to incentivize energy efficiency measures and the achievement of net zero energy in existing buildings.

2.C Conduct a municipal GHG emissions inventory every five years and continue tracking measure implementation.

Play 2.2: Support electrification of existing buildings with 44% of homes and businesses electrified by 2030 and 92% by 2045

2.D Develop an engagement and incentive program to accelerate the adoption of all- electric appliances.
2030: 108,935
2045: 162,360

2.E Eliminate non-electric sources of power in municipal buildings upon rebuild or significant remodel.

2.F Develop and implement an existing residential building electrification strategy (RBES).

2.G Adopt an electrification ordinance for existing residential buildings by 2026.

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18 Move
ID # Strategies and Respective Supporting Plays and Moves Anticipated GHG
Emissions Reduction
(MT of CO2e)1

2.H Conduct a study to evaluate the feasibility of adopting an end-of-flow ordinance for natural gas by 2045.

2.I Develop and implement an existing commercial building electrification strategy (CBES).

2. J Adopt an electrification ordinance for existing commercial buildings by 2026.

2.K Enforce the residential and commercial electrification ordinance compliance by developing and implementing a comprehensive permitting compliance program.

2.L Develop a Building Performance Standard (BPS) for existing buildings that requires electrification by 2030.

2.M Partner with Santa Clara County, Bay Area Renewable Energy Network (BayREN) and SVCE to create community-support programs to provide residents the resources and utility rate structures needed to convert to all-electric, energy efficient equipment and appliances.

Play 2.3: Achieve all-electric new construction with 100% all-electric new buildings by 2030

2.N Continue implementing and augmenting Reach Codes through a phased approach.
2030: 75,786
2045 213,785

Strategy 3: Decarbonizing Transportation and Sustainable Land Use Play 3.1: Increase opportunities for and encourage development of mixed-use sites to reduce vehicle miles per person by 20% by 2030 and 30% by 2045

3.A Identify areas that are most appropriate for parking strategies that discourage vehicle use, such as pricing, time limits and supply reductions. 2030: 66,162
2045: 75,239
(emissions
reductions of Play

3.1 and Play 3.2
combined)
Play 3.2: Increase transportation options and support shared mobility to reduce vehicle miles per person by 20% by 2030 and 25% by 2045

3.B Enhance City Transportation Demand Management (TDM) program implementation and monitoring to facilitate further reductions in single-occupant automobile trips, citywide.

See above

3.C Advocate that regional service providers implement high quality transit service and a robust set of first- and last-mile (FLM) strategies in over two-thirds of the cross-city corridors.

3.D Update and implement the Active Transportation Plan (ATP) to achieve a connected, safe and active network.

3.E Continue to evaluate the potential for the shared bicycle and scooter pilot program as a permanent program.

3.F Pilot shuttle service in Peery Park and consider options for expansion of a similar service in other areas undergoing redevelopment.

3.G Develop design standards for streets and parking lots to accommodate increased pickup and drop-off for rideshare passengers and apply as appropriate.

3.H Create a TDM program for City staff to promote alternative transportation modes and carpooling to the greatest extent possible.

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Move
ID # Strategies and Respective Supporting Plays and Moves Anticipated GHG
Emissions Reduction
(MT of CO2e)1

3.I Establish and implement a plan to convert vehicle roadways to bicycle and pedestrian space to increase opportunities for active transportation in the community.

3.J Require employers with 1,000 employees and more to develop TDM Plans.

3.K Establish tracking metrics to evaluate effectiveness of Moves impact on VMT and a monitoring schedule to report progress. Revise Moves accordingly based on VMT progress report.

Play 3.3: Increase zero-emission vehicles (ZEVs) with 42% of all vehicles on road being ZEVs by 2030 and 90% by 2045

3.K Continue implementing the Drive Electric Program and providing resources to assist and encourage community adoption of EVs.
2030: 98,079
2045: 99,836

3.L Electrify the Municipal Fleet as existing vehicles need replacement and install EV infrastructure (EVI) at municipal properties to support the electric fleet.

3.M Support the development of the Community EV Readiness and Infrastructure Plan and facilitate the installation of EVI.

3.N Partner with SVCE to strengthen and expand their incentive program for EVI.

Play 3.4: Decarbonize off-road equipment and vehicles with 30% of off-road equipment and vehicles being zero- emissions by 2030 and 75% by 2045

3.O Create a phased ordinance by 2026 to ban local operation of gasoline and diesel- powered off-road equipment by type, including banning local operation of gasoline and diesel-powered small off-road equipment (SORE) by 2028. 2030: 15,753
2045: 18,603
Strategy 4: Managing Resources Sustainably
Play 4.1: Achieve zero waste goals of by reducing landfilled garbage to 1 pound (lb) per person per day and achieve 75% diversion of landfilled organics by 2030 and <1 lb per day and achieve 75% diversion of landfilled organics by 2045

4.A Implement a campaign for waste reduction. 2030: 45,258 2045: 65,093 4.B Conduct a pilot program with reusable foodware for dine-in and takeout orders.

4.C Comply with SB 1383 requirements to help the state reduce organic waste disposal 75% by 2025.

4.D Expand the City’s edible food recovery program to edible food generators beyond those required by SB 1383.

4.E Continue to implement the mandatory waste diversion ordinance requiring all residents, visitors, and businesses to place their discards in the appropriate container (i.e., recycle, food scraps or garbage).

Play 4.2: Ensure resilience of water supply

4.F Promote and seek incentives for making water conservation a way of life and set a water reduction target consistent with statewide requirements.

Supportive

4.G Partner with Valley Water to evaluate opportunities to expand water reuse.

4.H Conduct a feasibility study to assess the costs and benefits of implementing Advanced Metering Infrastructure (AMI) citywide and implement if determined feasible.

4.I Implement a policy that prohibits installation of non-functional turf in new commercial construction.

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20 Move
ID # Strategies and Respective Supporting Plays and Moves Anticipated GHG
Emissions Reduction
(MT of CO2e)1

4.J Streamline the permitting process for rainwater catchment, dual water piping and graywater systems.

4.K Adopt an ordinance requiring new construction to be built with dual plumbing, where allowable, in preparation for the availability of recycled water infrastructure.

Play 4.3: Enhance natural carbon sequestration capacity

4.L Implement the City’s Urban Forest Management Plan and continue to protect and greatly expand tree canopy.

Supportive

4.M Implement the City’s Green Stormwater Infrastructure Plan.

Play 4.4: Promote awareness of sustainable goods and services

4.N Update the City purchasing policy to be aligned with Playbook goals and develop an implementation strategy.

Supportive
Strategy 5: Empowering our Community
Play 5.1: Enhance community awareness and engagement

5.A Pilot a targeted grassroots community engagement strategy to create stronger connections between neighbors to advance climate action and emergency preparedness.

Supportive

5.B Create a stronger social media and web presence for Sunnyvale climate action.

5.C Implement the Sustainability Speaker Series.

5.D Cultivate relationship between City and youth groups to engage students on climate, building on current engagement with school classrooms and green teams.

5.E Build relationships with largest employers to collaborate on climate action, such as: (a) engaging employees to participate in sustainability initiatives; (b) encouraging and facilitating investment in climate action programs or projects.

5.F Create demonstration projects within City operations to educate the community on ways to reduce emissions.

5.G Continue to develop and implement educational programs at the Sunnyvale Public Library that focus on environmental and sustainability topics.

Play 5.2: Track and Share Data and Tools

5.H Implement improvements for climate action data performance tracking and reporting progress to the public (e.g., community dashboard).

Supportive

5.I Publish annual GHG inventory.

Strategy 6: Adapting to a Changing Climate
Play 6.1: Assess climate vulnerabilities for Sunnyvale

6.A Participate in regional forums on climate vulnerability and adaptation. Supportive Play 6.2: Protect shoreline area from sea level rise and coastal flooding

6.B Collaborate with Valley Water to advance a shoreline protection project with the US Army Corps of Engineers or other partners.

Supportive
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Final Initial Study–Negative Declaration 21
Move
ID # Strategies and Respective Supporting Plays and Moves Anticipated GHG
Emissions Reduction
(MT of CO2e)1

6.C Develop strategies and projects to restore, protect and expand our tidal/salt marshes and natural water ways to the Bay using as much of the dredged materials from the Bay as possible.

Play 6.3: Strengthen community resiliency

6.D Update existing emergency preparedness and response plans to address climate- related impacts such as heat events, air quality issues and flooding.

Supportive

6.E Develop a community resiliency plan.

6.F Implement a Resilience Hub Initiative.

Notes:

MT of CO2e = metric tons of carbon dioxide equivalent
Strategy 5 entails administrative and community engagement actions that would not result in environmental impacts.

Strategy 6 entails future climate adaptation planning efforts that cannot be assessed in terms of environmental impacts until specific policies, actions, and/or physical projects are identified; CEQA review would be required at that point.

Source: Compiled by Rincon based on information contained in the Draft Sunnyvale Playbook Update/Game Plan 2028.

The Plays and Moves shown in Table 2, combined with existing State legislation and City initiatives, would enable Sunnyvale to meet its GHG emissions reduction target pathway to reduce GHG emissions 56 percent below 1990 levels by 2030. Table 3 summarizes the communitywide GHG emissions forecasts under the BAU and ABAU scenarios, as well as with implementation of the Sunnyvale Playbook Update/Game Plan 2028, beginning from the 2019 through 2045.

Table 3 Sunnyvale 2030 GHG Emissions Forecasts (MT of CO2e) GHG Emissions Pathways 2019 2025 2030 2035 2040 2045
BAU Forecast 716,382 841,327 931,298 1,029,366 1,138,832 1,259,700 Adjusted Forecast 716,382 790,257 833,092 886,784 960,795 1,052,263 Forecast with Playbook
Update/Game Plan 2028
716,382 590,277 419,818 403,734 403,267 417,347 Source: Compiled from the Sunnyvale Draft Playbook Update/Game Plan 2028 and the Sunnyvale Playbook Update GHG Forecast Report
Figure 4 depicts the 2030 and 2045 GHG emissions targets for Sunnyvale, including anticipated emissions once the Plays and Moves Moves listed in Table 2 are implemented. Figure 4 also illustrates the forecasted BAU and ABAU emissions, and the target pathway to achieve carbon neutrality by 2045.

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

22 Figure 4 Sunnyvale GHG Emissions Projections and Targets

Table 4 shows the Sunnyvale climate action target emissions and the emissions reductions expected from implementing the Plays and Moves shown in Table 2. Table 4 also shows that Sunnyvale would meet its 2030 GHG reduction target and make substantial progress towards the 2045 goal of carbon neutrality.

Table 4 Targets Versus GHG Reductions
Target/Forecast
2030 GHG Emissions
(MT of CO2e)
2045 GHG Emissions
(MT of CO2e)
Adjusted Forecast 833,092 1,052,263
Sunnyvale Targets 441,846 150,629
GHG Reductions from Full Implementation of Plays
and Moves
413,274 634,916
GHG Emissions after Measure Reductions
(Adjusted Forecast – GHG Emissions Reductions)
419,818 417,347
Target Anticipated to be Met? Yes Substantial progress demonstrated MT of CO2e = metric tons of carbon dioxide equivalent
Source: Compiled from the Sunnyvale Draft Playbook Update/Game Plan 2028 and the Sunnyvale Playbook Update GHG Forecast Report
The Playbook Update/Game Plan 2028 would provide substantial progress toward meeting the City’s carbon neutrality goal by 2045 (85 percent emissions reduction from 1990 levels or 150,629 MT of CO2e). However, full implementation of the Sunnyvale Playbook Update/Game Plan 2028 would leave a gap of approximately 270,000 MT of CO2e that would still need to be addressed to achieve carbon neutrality. As such, the Sunnyvale Playbook Update/Game Plan 2028 acknowledges 2045 Gap
(266,717) MT CO2e
2030 Target Met
(58% below 1990 levels)
441,846 MT CO2e
2045 Target
(85% below 1990 levels)
150,629 MT CO2e
-
200,000
400,000
600,000
800,000
1,000,000
1,200,000
1,400,000
2008 2019 2025 2030 2035 2040 2045
GHG Emissions (MT CO2e)
Reductions Needed to Meet Target 1990 Baseline
Business-as-Usual Forecast Adjusted Forecast
Sunnyvale Target Pathway Emissions after Game Plan 2028 Reductions Attachment 10

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Final Initial Study–Negative Declaration 23
that additional actions beyond those identified in the plan will be necessary to achieve carbon neutrality and, therefore, provides a mechanism for adopting new Game Plan updates every five years. This allows for certainty in the updated schedule, ensures that the carbon neutrality work is directly tied to the City’s financial decision making and prioritization process and allows for constant integration of learning, best practices, and new measures and technologies to further the City toward meeting its goal of carbon neutrality.

Implementation of the Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves identified in Table 2 could result in physical changes to the environment that could potentially have an impact on the environment. While individual projects resulting from these Plays and Moves have not been identified for the purposes of this document, the types of actions that could result from realization of the Plays and Moves are taken into account in considering potential environmental impacts that could occur through implementation of the Playbook Update/Game Plan 2028. For example, the use of carbon-free electricity may require the installation of new infrastructure to accommodate use and transmission of alternative and renewable fuels. Similarly, increasing the use of EVs would require the installation of EV charging stations and supporting infrastructure. Additionally, Sunnyvale Playbook Update/Game Plan 2028 implementation may require the installation of new bicycle or pedestrian facilities. These types of activities would introduce physical changes, such as the temporary presence and operation of construction vehicles and equipment during installation of required facilities, and the long-term presence of new facilities such as bike and pedestrian facilities, solar arrays, and EV charging stations, which could alter pedestrian and vehicular traffic patterns.

Future plans or projects requiring discretionary approval would be subject to environmental review under CEQA, and individual impact analyses may identify required plan- or project-specific mitigation measures where applicable.

Sunnyvale CEQA GHG Emissions Thresholds
In 2007, SB 97 acknowledged that climate change is an environmental issue that requires analysis in CEQA documents, and in 2010 the California Natural Resources Agency adopted amendments to the CEQA Guidelines for the feasible mitigation of GHG emissions or the effects of GHG emissions. The adopted guidelines gave lead agencies the discretion to set quantitative or qualitative thresholds for the assessment and mitigation of GHGs and climate change impacts. Specifically, Section 15183.5(b)(1)A-G of Title 14 of the California Code of Regulations was amended to state that a qualified GHG Reduction Plan, or a Climate Action Plan (CAP), may be used for tiering and streamlining the analysis of GHG emissions in subsequent CEQA project evaluation, provided that the GHG Reduction Plan or CAP does the following:
▪ Quantifies GHG emissions both existing and projected over a specific period of time, resulting from activities within a defined geographical area.
▪ Establishes a level, based on substantial evidence, below which the contribution to greenhouse gas emissions from activities covered by the plan would not be cumulatively considerable. ▪ Identifies and analyzes the GHG emissions resulting from specific actions or categories of actions anticipated within the geographic area.
▪ Specifies measures or a group of measures, including performance standards, that substantial evidence demonstrates, if implemented on a project-by-project basis, would collectively achieve the specified emissions level.
▪ Establishes a mechanism to monitor the plan's progress toward achieving the level and to require amendment if the plan is not achieving specified levels.

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

24 ▪ Be adopted in a public process following environmental review.

Therefore, the City of Sunnyvale proposes to also adopt quantitative efficiency thresholds for use in evaluating whether a plan or project’s GHG emissions would result in a potentially significant environmental impact under CEQA for plans or projects with pre-2030 buildout or initial operation years. The CEQA GHG Emissions Thresholds would be applied to plans or projects that cannot tier from the environmental analysis for the Sunnyvale Playbook Update/Game Plan 2028 (as contained in this Initial Study- Negative Declaration [IS-ND]) due to one of the following circumstances, which are illustrated in Figure 5:
▪ The plan or project would not be consistent with the Sunnyvale General Plan land use and zoning designations for the project site and would result in greater GHG emissions than existing on-site development; or
▪ The plan or project would not be consistent with the CEQA GHG Emissions Analysis Compliance Checklist.

Figure 5 Determining CEQA GHG Emissions Analysis Methodology

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Final Initial Study–Negative Declaration 25
These thresholds are set at the level of GHG emissions that new development would need to achieve to be consistent with the Sunnyvale Playbook Update/Game Plan 2028’s communitywide emissions reduction target of 441,846 MT of CO2e by 2030. The efficiency thresholds, listed below, are expressed in terms of MT of CO2e per service person19 and are applicable to plans or projects with pre-2030 buildout or initial operational years:
▪ 0.32 per resident
▪ 0.57 per employee
▪ 0.38 per service person20
Efficiency thresholds for beyond 2030 would be established later in conjunction with subsequent Play Book and Game Plan amendments.

Plans or projects that do not tier from the Sunnyvale Playbook Update/Game Plan 2028 IS-ND that would generate GHG emissions in excess of these thresholds would result in a potentially significant impact on the environment related to GHG emissions and climate change. Mitigation measures would be required to reduce potentially significant impacts resulting from such plans or projects.

Plans or projects that are unable to reduce GHG emissions below these thresholds through implementation of identified mitigation measures would result in a significant and unavoidable environmental impact. The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to General Plan land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not have direct construction or operational impacts.

Cumulative Projects Scenario
For purposes of CEQA cumulative impacts analysis of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds, the cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 and 2050. The cumulative projects scenario is shown in Table 7.

19 The service population is equal to the residential population plus half the number of jobs. 20 Sunnyvale, City of. 2024. Draft CEQA GHG Thresholds.

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

26 Table 5 Cumulative Projects Scenario
Demographics/
Sector
2025 2030 2035 2040 2045 2050
Population1 201,140 231,502 266,446 306,666 352,957 406,235 Employment2 101,341 109,322 117,931 127,218 137,237 148,045 Households2 78,974 92,353 107,999 126,295 147,690 172,710 Service
Population3 302,481 340,823 384,377 433,884 490,194 554,280 1 Population estimates were calculated by applying Bay Area region growth factors from Play Bay Area 2050 to Sunnyvale’s 2015 estimates from Play Bay Area 2040 (i.e., 2.63 people/household in 2015). Growth factors were calculated to represent the comp ound annual growth rate (i.e., -0.32% annual growth in people/household) from the modeled change in people per household in the Bay Area region between the years 2015 and 2050.
2 Employment and household estimates were calculated by applying North Santa Clara County growth factors from Play Bay Area 2050 to Sunnyvale’s 2015 estimates from Play Bay Area 2040 (i.e., 87,085 jobs in 2015 and 57,750 households in 2015). Growth factors were calculated to represent the compound annual growth rate (i.e., 1.53% annual growth in employment and 3.18% annual growth in households) from the modeled change in employment and households in North Santa Clara County between the years 2015 and 2050. 3 Service population is calculated as the combined total number of employees and residents in the City.

Source: Rincon Consultants, Inc. Sunnyvale Playbook Update GHG Forecast Report. February 2023.

Required Approvals
City of Sunnyvale
Required approvals include:
▪ Adoption of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds IS-ND;
▪ Adoption of the Sunnyvale Playbook Update/Game Plan 2028; and ▪ Adoption of the Sunnyvale CEQA GHG Emissions Thresholds.

Although individual plans or projects may be implemented later under the umbrella of the Sunnyvale Playbook Update/Game Plan 2028, each individual plan or project would be subject to separate environmental review under CEQA.

Other Public Agencies
The City of Sunnyvale has sole approval authority over the Sunnyvale Playbook Update/Game Plan 2028 as well as the Sunnyvale CEQA GHG Emissions Thresholds. There are no other public agencies whose approval is required.

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Environmental Factors Potentially Affected

Final Initial Study–Negative Declaration 27
Environmental Factors Potentially Affected
This project would potentially affect the environmental factors checked below, involving at least one impact that is “Potentially Significant” or “Less than Significant with Mitigation Incorporated” as indicated by the checklist on the following pages.
□ Aesthetics □ Agriculture and
Forestry 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
Determination
Based on 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.
□ I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions to the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be prepared.
□ I find that the proposed project MAY have a significant effect on the environment, and an ENVIRONMENTAL IMPACT REPORT is required.
□ I find that the proposed project MAY have a “potentially significant impact” or “less than significant with mitigation incorporated” impact on the environment, but at least one effect (1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and (2) has been addressed by mitigation measures based on the earlier analysis as described on attached sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed.

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28 □ I find that although the proposed project could have a significant effect on the environment, because all potential significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are imposed upon the proposed project, nothing further is required.

Lead Agency Representative Signature Date

Lead Agency Representative Printed Name Title

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Environmental Checklist
Aesthetics

Final Initial Study–Negative Declaration 29
Environmental Checklist
1 Aesthetics

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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 a publicly accessible vantage point). If
the project is in an urbanized area, would the
project conflict with applicable zoning and
other regulations governing scenic quality? □ □ ■ □
d. Create a new source of substantial light or
glare that would adversely affect daytime or
nighttime views in the area? □ □ ■ □
a. Would the project have a substantial adverse effect on a scenic vista? According to the Sunnyvale General Plan Land Use and Transportation Element Draft Environmental Impact Report (EIR), Sunnyvale does not contain any designated scenic vistas or viewsheds.21 As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to effects on a scenic vista. b. Would the project substantially damage scenic resources, including but not limited to, trees, rock outcroppings, and historic buildings within a State scenic highway? According to the California Scenic Highway Mapping System, Interstate I-280, traversing the south border of Sunnyvale, is an eligible State scenic highway, but it is not officially designated.22 There are no officially designated State scenic highways in Sunnyvale, and no portions of the City

21 Sunnyvale, City of. 2016. Sunnyvale General Plan Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023). 22 Caltrans. 2018. California State Scenic Highway System Map. https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa (accessed December 2023).

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30 encompass the viewshed from a State scenic highway.23 The nearest designated State scenic highway is a portion of I-280 running from Alpine Road to Valleywood Drive, located approximately

7.5 miles west of Sunnyvale City limits at its closest point. Due to the distance between Sunnyvale and the nearest designated State scenic highway, as well as the developed nature of Sunnyvale and the surrounding communities, views of Sunnyvale from I-280 are not available. Additionally, the Sunnyvale General Plan Land Use and Transportation Element does not identify any local scenic roadways.24 As such, implementation of the Playbook Update/Game Plan and CEQA GHG Emissions Thresholds could not result in impacts related to scenic resources within the viewshed from a State scenic highway. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to effects on scenic resources within a State scenic highway.
c. In non-urbanized areas, would the project 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 a publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? According to the Sunnyvale General Plan Land Use and Transportation Element Draft Environmental Impact Report (EIR), Sunnyvale is 98 percent urbanized, surrounded by other cities, and has limited aesthetic resources. Within Sunnyvale, there are several visual landmarks, including Libby Water Tower, the Murphy Avenue Commercial District, and the cherry orchards on Mathilda Avenue, that comprise important local scenic attributes.25 The Sunnyvale General Plan Community Character Element includes policies that require preservation of existing visual landmarks, as well as goals and policies that govern scenic quality within the City. These include the following:
▪ Goal CC-1: Distinguished City Image: Promote Sunnyvale’s image by maintaining, enhancing and creating physical features, including functional and decorative art, which distinguish Sunnyvale from surrounding communities and by preserving historic buildings, special districts and residential neighborhoods which make the City unique.
▪ Goal CC-3: Well-Designed Sites and Buildings: Ensure that buildings and related site improvements for private development are well designed and compatible with surrounding properties and districts.
▪ Policy CC-3.2: Ensure site design is compatible with the natural and surrounding built environment.
▪ Goal CC-3: Protection of Sunnyvale’s Heritage: To enhance, preserve, and protect Sunnyvale’s heritage including natural features, the built environment, and significant artifacts. ▪ Policy CC-5.1: Preserve existing landmarks and cultural resources and their environmental settings.
▪ Policy CC-5.2: Enhance the visual character of the City by preserving diverse as well as harmonious architectural styles, reflecting various phases of the City’s historical development and the cultural traditions of past and present residents.

23 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023). 24 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023). 25 Sunnyvale, City of. 2016. Sunnyvale General Plan Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023).

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Aesthetics

Final Initial Study–Negative Declaration 31
In addition, Sunnyvale has adopted a variety of design guidelines, including guidelines specifically for identified landmark and heritage areas such as the Murphy Station Heritage Landmark District Design Guidelines and the Taaffe Frances Heritage Neighborhood Design Guidelines.26 The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in impacts related to visual character. As a policy and guidance document, the Sunnyvale Playbook Update/Game Plan 2028 does not propose specific development or changes to land use and zoning designations that would result in impacts to scenic vistas and visual character or conflict with City policies regulating scenic resources. However, implementation of some Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves may promote infrastructure development and other physical changes through policies and programs. Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 promote installation of small-scale solar photovoltaic (PV) systems, thermal energy systems, and battery energy storage systems to increase renewable energy generation and storage in Sunnyvale. Play 3.1 would encourage mixed-use development (as permitted by land use and zoning designations) within the City that could alter visual character via changes in building heights and designs. Additionally, Play 4.3 facilitates the expansion of the urban forest that could have a positive effect on the visual quality of the City by adding new tree cover.

While implementation of the Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves may result in future Playbook Update/Game Plan projects that slightly alter the visual character of Sunnyvale, Sunnyvale Playbook Update/Game Plan 2028-related projects would generally be limited to the existing developed areas of Sunnyvale and would be small-scale in nature. In addition, Sunnyvale Playbook Update/Game Plan 2028-related projects and actions, including those identified above, would be required to adhere to City zoning and regulations that protect aesthetic resources, including the City design guidelines, Sunnyvale Municipal Code (SMC) Chapter 19.80, Design Review, and SMC Chapter 19.96, Heritage Sites, that establish the City’s Design Review process and protections for heritage areas.27,28,29 Compliance with the SMC and design guidelines would require that potential future infrastructure development and redevelopment related to the Sunnyvale Playbook Update/Game Plan 2028 would be carefully integrated with the existing character of the community, minimizing potential impacts related to visual character. In addition, Sunnyvale Playbook Update/Game Plan 2028 projects and actions would be reviewed for consistency with the Sunnyvale General Plan Community Character Element goals and policies related to scenic resources prior to approval to avoid lack of consistency with regulations established to protect scenic quality.

Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to visual character or scenic quality.
d. Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area?
Sunnyvale is an urbanized community and contains many existing sources of nighttime light and daytime glare including street and vehicle lighting, security lighting, interior and exterior building

26 Sunnyvale, City of. 2023. Design Guidelines, Standards, and Specific Plans. https://www.sunnyvale.ca.gov/business-and- development/planning-and-building/permit-center/design-guidelines-standards-and-specific-plans (accessed December 2023). 27 Ibid
28 Sunnyvale, City of. 2023. Sunnyvale Municipal Code Chapter 19.80. https://ecode360.com/42732806#42732806 (accessed December 2023).
29 Sunnyvale, City of. 2023. Sunnyvale Municipal Code Chapter 19.96. https://ecode360.com/42733144#42733144 (accessed December 2023).

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

32 lighting, and reflective building materials. The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use or zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in impacts related to light and glare. The Sunnyvale Playbook Update/Game Plan 2028 would promote sustainable infrastructure development and redevelopment that is complimentary to existing land uses in the City. As a policy document, the Sunnyvale Playbook Update/Game Plan 2028 would not directly result in impacts related to light and glare. However, implementation of Sunnyvale Playbook Update/Game Plan 2028 Play 1.2 promotes installation of small-scale solar PV systems to increase renewable energy generation in Sunnyvale. Solar panels have the potential to result in new sources of glare within Sunnyvale if not thoughtfully designed and located. The design and location of future solar infrastructure would be complimentary to existing development in Sunnyvale, such as the addition of small-scale rooftop solar panels that would reduce potential glare impacts. Furthermore, Sunnyvale Playbook Update/Game Plan 2028 projects would be reviewed for consistency with the CCR Title 24 lighting standards (CCR Title 24 Part 6), Sunnyvale design guidelines, which provide guidance on reducing light impacts and associated glare and design considerations to address glare, and SMC Section 19.42.050 regarding restrictions on lighting would require that lights, spotlights, floodlights, reflectors, and other means of illumination are shielded or equipped with special lenses in such a manner as to prevent any glare or direct illumination on a public street or other property.30, 31 In addition, Sunnyvale Playbook Update/Game Plan 2028 projects or Moves would be reviewed for consistency with the Sunnyvale General Plan and other applicable aesthetic regulations prior to approval. Compliance with these regulations would minimize environmental impacts related to light and glare by requiring the shielding of exterior lighting and limiting the use of highly reflective materials, respectively. Thus, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to light and glare.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). Cumulative impacts related to scenic vistas and resources, visual character and scenic quality, and light and glare would generally be site-specific, and cumulative projects are not anticipated to contribute to cumulative aesthetic impacts with adherence to Sunnyvale General Plan policies, the SMC, and applicable Specific Plans and design guidelines. As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts. Because of the developed nature of Sunnyvale, future infrastructure projects under the Sunnyvale Playbook Update/Game Plan 2028, in combination with other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth, would not adversely impact the visual character of the community. In addition, cumulative projects would be required to comply with the City design review process, as applicable, and be reviewed against applicable Sunnyvale General Plan policies and design standards for design quality and compatibility with adjacent land uses. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant cumulative impact related to aesthetics.

30 Ibid
31 Sunnyvale, City of. 2023. Sunnyvale Municipal Code Section 19.42.050. https://ecode360.com/42730956 (accessed December 2023).

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Agriculture and Forestry Resources

Final Initial Study–Negative Declaration 33
2 Agriculture and Forestry Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Convert Prime Farmland, Unique Farmland,
or Farmland of Statewide Importance
(Farmland), as shown on 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? □ □ □ ■
a. Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b. Would the project conflict with existing zoning for agricultural use or a Williamson Act contract? e.1. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use? Sunnyvale is characterized primarily by urban and suburban development. Maps prepared pursuant to the Farmland Mapping and Monitoring Program primarily identify Sunnyvale as Urban and Built- up Land, and no Prime Farmland or Farmland of Statewide Importance is mapped within Sunnyvale; however, there are a few pockets of Unique Farmland located in the southern portions of Attachment 10

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34 Sunnyvale.32 Likewise, there are no Williamson Act contracts within Sunnyvale.33 While Sunnyvale has some small pockets of remaining orchards zoned for nonagricultural uses, it does not contain any agricultural operations.

The Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves focus on electrification of buildings, improving active transportation, ZEV and public transit infrastructure, water conservation, reducing solid waste sent to landfills, increasing carbon sequestration through additional trees, and community engagement around climate change. Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would not involve projects or policies that would result in increased development or impacts related to conversion or loss of farmland. Additionally, the CEQA GHG Emissions Thresholds would provide guidance during CEQA review and do not propose development or changes to land use and zoning that could result in the loss of farmland or conflict with existing agricultural zoning.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to degradation of agricultural resources or conversion of agricultural land to non-agriculture uses, nor would there be a conflict with existing zoning, Sunnyvale General Plan land use designations, and Williamson Act Contracts. c. Would the project 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. Would the project result in the loss of forest land or conversion of forest land to non-forest use? e.2. Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of forest land to non-forest use? Sunnyvale is entirely built-out and does not contain forest or timberland resources, and no parcels are zoned for Timberland Production. SMC Chapter 19.94 outlines policies, regulations, and standards to provide for tree preservation within the city. Additionally, Policy 14 and Actions 1 through 4 of the Sunnyvale Land Use and Transportation Element encourages the planting of large canopy trees and implementation of an Urban Forestry Plan, which illustrate the City’s commitment to managing and preserving Sunnyvale’s urban forest.34
The Sunnyvale Playbook Update/Game Plan 2028 aligns with the Sunnyvale General Plan by including Play 4.3 and Move 4.L, which seeks to facilitate the implementation of an urban forest master plan to increase the number of trees throughout Sunnyvale. The Sunnyvale Playbook Update/Game Plan 2028 does not include actions that would result in the loss of forest land or the conversion of forest land to non-forest use, nor would it conflict with or cause the rezoning of forest, timber land, or Timberland Production areas. Likewise, the CEQA GHG Emissions Thresholds would provide guidance during CEQA review and do not propose development or changes to land use and zoning that could result in the loss of forestland or conflict with existing zoning for forest uses. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions

32 California Department of Conservation. 2023. California Important Farmland Finder Map. https://maps.conservation.ca.gov/dlrp/ciff/ (accessed December 2023).
33 Santa Clara County. 2022. Williamson Act Properties. https://sccplanning.maps.arcgis.com/apps/webappviewer/index.html?id=1f39e32b4c0644b0915354c3e59778ce (accessed December 2023).
34 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).

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Agriculture and Forestry Resources

Final Initial Study–Negative Declaration 35
Thresholds would result in no impact related to degradation of forestry resources or conversion of forest land to non-forest uses, nor would there be a conflict with existing zoning.

4.L to maintain an urban forest and plant additional trees throughout the City. Furthermore, as discussed above, the Sunnyvale Playbook Update/Game Plan 2028 would not include Plays or Moves that could impact agricultural or forestry resources. In addition, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning changes that could result in cumulative impacts related to conversion or loss of farmland or forest land. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no cumulative impact related to agricultural and forestry resources.

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36 3 Air Quality

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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? □ □ ■ □
a. Would the project conflict with or obstruct implementation of the applicable air quality plan? The federal Clean Air Act (CAA) governs air quality in the United States and is administered by the United States Environmental Protection Agency (U.S. EPA) at the federal level. Air quality in California is also governed by regulations under the California CAA, which is administered by CARB at the State level. At the regional and local levels, local air districts typically administer the federal and California CAA. As part of implementing the federal and California CAA, the U.S. EPA and CARB have established ambient air quality standards for major pollutants at thresholds intended to protect public health. Sunnyvale is located within the San Francisco Bay Area Air Basin (the Air Basin), which includes the nine Bay Area counties of Alameda, Contra Costa, Marin, Napa, San Francisco, San Mateo, Santa Clara, southwestern Solano, and southern Sonoma. The Air Basin is under the jurisdiction of BAAQMD. As the local air quality management agency, BAAQMD is required to monitor air pollutant levels to ensure that State and federal air quality standards are met and, if they are not met, to develop strategies to meet the standards. Depending on whether or not the standards are met or exceeded, the Air Basin is classified as being in “attainment” or “nonattainment.” Under State law, air districts are required to prepare a plan for air quality improvement for pollutants for which the district is in non-attainment. BAAQMD is in non- attainment for the State and federal ozone standards, the State and federal PM2.5 (particulate matter up to 2.5 microns in size) standards, and the State PM10 (particulate matter up to 10 microns in size) standards and is required to prepare a plan for improvement.35 The sources, health effects, and typical controls associated with criteria pollutants are described in Appendix A.

35 BAAQMD. 2017. Air Quality Standards and Attainment Status. http://www.baaqmd.gov/research-and-data/air-quality-standards-and- attainment-status (accessed December 2023).

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Air Quality

Final Initial Study–Negative Declaration 37
The Bay Area 2017 Clean Air Plan provides a plan to improve Bay Area air quality and protect public health as well as the climate. The legal impetus for the Clean Air Plan is to update the most recent ozone plan, the 2010 Clean Air Plan, to comply with State air quality planning requirements as codified in the California Health and Safety Code. Although steady progress has been made toward reducing ozone levels in the Bay Area, the region continues to be designated as non‐attainment for both the one‐hour and eight‐hour State ozone standards as noted previously. In addition, emissions of ozone precursors in the Bay Area contribute to air quality problems in neighboring air basins.

Under these circumstances, State law requires the Clean Air Plan to include all feasible measures to reduce emissions of ozone precursors and reduce transport of ozone precursors to neighboring air basins.36
The Federal Clean Air Act Amendments (CAAA) mandate that states submit and implement a State Implementation Plan (SIP) for areas not meeting air quality standards. The SIP includes pollution control measures to demonstrate how the standards will be met through those measures. The SIP is established by incorporating measures established during the preparation of Air Quality Management Plans (AQMP) and adopted rules and regulations by each local Air Pollution Control District (APCD) and AQMD, which are submitted for approval to CARB and the U.S. EPA.37 The goal of an AQMP is to reduce pollutant concentrations below the NAAQS through the implementation of air pollutant emissions controls.

The Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes or specific development. Rather the Sunnyvale Playbook Update/Game Plan 2028 would promote sustainable infrastructure development and redevelopment. Likewise, the CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves focus on increasing the use of renewable energy, building electrification, improving active transportation, ZEV and public transit infrastructure, increasing urban trees, and reducing waste production and water use. Implementation of Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves, such as those aimed at reducing VMT, electrifying vehicles, and reducing natural gas use through building electrification, would have co-benefits to air quality within the Air Basin.

These Plays and Moves would help BAAQMD meet applicable air quality plan goals, and would generally reduce air pollutant concentrations. Although the purpose and intended effect of the Sunnyvale Playbook Update/Game Plan 2028 is to reduce GHG emissions generated in Sunnyvale to help reduce the effects of climate change, many of its Plays and Moves would also reduce criteria pollutant emissions. Specifically, Plays 2.1 through 2.3 involve reducing the use of natural gas through building electrification of new and existing buildings, thereby reducing criteria pollutants associated with building energy use. Plays 3.1 and 3.2 seek to improve active transportation and public transit facilities and programs in order to reduce VMT and increase the use of sustainable transportation options in Sunnyvale. In addition, Plays 3.3 and 3.4 would encourage the adoption of ZEVs and low-emissions off-road vehicles and equipment by enhancing EV infrastructure and phasing out gasoline- and diesel-powered off-road equipment. These energy- and transportation- related strategies would reduce air pollutant emissions as well as GHG emissions. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds are consistent

36 BAAQMD. 2017. Final Clean Air Plan: Spare the Air Cool the Climate: A Blueprint for Clean Air and Climate Protection in the Bay Area.

Final 2017 Clean Air Plan. https://www.baaqmd.gov/plans-and-climate/air-quality-plans/current-plans (accessed December 2023). 37 CARB. 2022. 2022 State Strategy for the State Implementation Plan. https://ww2.arb.ca.gov/sites/default/files/2022- 08/2022_State_SIP_Strategy.pdf (accessed November 2023).

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38 with the 2017 Clean Air Plan and would result in no impact related to a conflict with or obstruction of the applicable air quality plan.
b. Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard?
The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to an increase of criteria pollutants. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes but would instead promote sustainable infrastructure development and redevelopment. As a policy document, the Sunnyvale Playbook Update/Game Plan 2028 would not result in impacts related to criteria pollutants. However, implementation of the following Sunnyvale Playbook Update/Game Plan 2028 actions may promote construction activities that would temporarily generate criteria pollutants during the construction phase.

Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within Sunnyvale. Play 2.2 promotes electrification of existing residential, commercial, and municipal buildings that may require minor construction to modify the electrical and natural gas connections to existing buildings. Play 3.2 would encourage development of new bicycle and pedestrian infrastructure that may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale.

Play 3.3 would incentivize or require the installation of new EV charging stations. In addition, Play

4.3 seeks to increase the number of trees throughout Sunnyvale that may require the use of construction equipment for the moving and placement of trees.

Construction-related air quality impacts are generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles and soil hauling trucks, in addition to reactive organic gases that would be released during the drying phase upon application of architectural coatings. However, implementation of Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would not include large-scale construction and would involve temporary and short- term criteria pollutant emissions. As such, the Sunnyvale Playbook Update/Game Plan 2028 would result in low-level criteria pollutant emissions and negligible impacts related to air quality. Through the standard review process for new development or capital improvement projects, Sunnyvale Playbook Update/Game Plan 2028 projects would also be reviewed for consistency with BAAQMD air quality regulations and other applicable local, State, and federal regulations. Thus, the construction associated with implementation of the Sunnyvale Playbook Update/Game Plan 2028 would result in a less-than-significant impact related to net increase of criteria pollutants.

With respect to operational emissions, many of the Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would have the secondary benefit of reducing criteria pollutant emissions, such as strategies aiming to increase reduce natural gas use, promote EVs, reduce on- and off-road gasoline fuel use, and reduce VMT. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would be beneficial by helping the City meet applicable air quality plan goals. Therefore, overall, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to criteria pollutant emissions. c. Would the project expose sensitive receptors to substantial pollutant concentrations? Attachment 10

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Air Quality

Final Initial Study–Negative Declaration 39
The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to exposure of sensitive receptors to substantial pollutant concentrations. Implementation of some of the Sunnyvale Playbook Update/Game Plan 2028 Plays, as described under Response 3b., promotes infrastructure development and redevelopment that may result in temporary construction activities. Construction- related air quality impacts are generally associated with fugitive dust (PM10 and PM2.5) and exhaust emissions from heavy construction vehicles and soil hauling trucks, in addition to reactive organic gases that would be released during the drying phase upon application of architectural coatings.

However, implementation of Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would not include large-scale construction, and construction-related emissions would be temporary. As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 could result in low-level toxic air contaminant emissions associated with construction.

While the Sunnyvale Playbook Update/Game Plan 2028 could result in construction-related impacts related to toxic air contaminants and exposure to sensitive receptors, Sunnyvale Playbook Update/Game Plan 2028 projects or actions would be reviewed for consistency with BAAQMD air quality regulations and other applicable local, State, and federal regulations through the standard development review process once project details and locations are known to minimize air pollutant exposure impacts. Thus, construction associated with implementation of the Sunnyvale Playbook Update/Game Plan 2028 is not expected to result in substantial emissions of toxic air contaminants and exposure to sensitive receptors. No operational toxic air contaminant emissions are anticipated with implementation of the Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves.

Therefore, overall, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to exposure of sensitive receptors to toxic air contaminants.
d. Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The CARB 2005 Air Quality Land Use Handbook: A Community Health Perspective identifies land uses associated with odor complaints which include: sewage treatment plants, landfills, recycling facilities, waste transfer stations, petroleum refineries, biomass operations, auto body shops, coating operations, fiberglass manufacturing, foundries, rendering plants, and livestock operations.38 The CEQA GHG Emissions Thresholds would provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to odors. The Sunnyvale Playbook Update/Game Plan 2028 includes Play 4.1, which seeks to reduce community landfilled organics by 75 percent by 2030. Moves associated with this play include implementing the organic waste diversion requirements of Senate Bill (SB) 1383, encouraging food waste diversion, and implementing edible food recovery programs. As such, the Sunnyvale Playbook Update/Game Plan 2028 could result in minor odors related to organic waste collection. However, green waste collection bins and compost application are not identified on the list of “Sources of Odor Complaints” (Table 1-4) as provided in the CARB Air Quality Land Use Handbook and would not be anticipated to result in other odors that would adversely affect a

38 CARB. 2005. Air Quality and Land Use Handbook: A Community Health Perspective. https://www.aqmd.gov/docs/default- source/ceqa/handbook/california-air-resources-board-air-quality-and-land-use-handbook-a-community-health-perspective.pdf (accessed December 2023).

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40 substantial number of people.39 Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Thresholds would not facilitate development that could create odors, and there would be a less-than-significant impact related to odors exposure.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts. Sunnyvale Playbook Update/Game Plan 2028-related projects, in combination with other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth, could result in air pollutant emissions that exceed applicable BAAQMD thresholds or be inconsistent with the 2017 Clean Air Plan. However, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would have a less-than-significant contribution related to potential cumulative air quality impacts within the Air Basin and on sensitive receptors within Sunnyvale, given that the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in communitywide reduction of GHG emissions, energy use, single-occupancy vehicle travel, and associated air pollutant emissions and just temporary air pollutant emissions during infrastructure construction activities. As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not result in adverse impacts related to contribution of criteria pollutants to the air basin or exposure of sensitive receptors to toxic air contaminants but rather result in co-benefits to air quality within the Air Basin. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to air quality.

39 Ibid
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Biological Resources

Final Initial Study–Negative Declaration 41
4 Biological Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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 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 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? □ □ □ ■
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42 a. Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as candidate, sensitive, or special status 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?
Sunnyvale is a primarily urbanized community with limited habitat to support special-status species.

However, ruderal infill lots could support burrowing owl, Crotch’s bumble bee, and Congdon’s tarplant. Shoreline areas and wetlands in Sunnyvale may support protected shore birds and fish species, such as black skimmer, California least tern, California black rail, California Ridgway's rail, western snowy plover, steelhead, and longfin smelt. These special status species are afforded protection under the federal Endangered Species Act, California Endangered Species Act, and/or California Fish and Game Code (CFGC). Additionally, urban parks, open space, and riparian areas could support nesting birds.40 Active nests of all migratory birds, including raptors, are protected by State and federal law. Migratory and nesting birds are protected by Sections 3503, 3503.5, and 3513 of the California Fish and Game Code (CFGC) and the Migratory Bird Treaty Act (MBTA), and may utilize trees, landscaping, and structures throughout Sunnyvale for nesting habitat. SMC Chapter

19.94 provides for the protection of trees within the City, and Policy LT-1.10 of the Land Use and Transportation Element illustrates the City’s commitment to protecting biological resources.41,42 The City also maintains Bird Safe Design Guidelines in reviewing the design of new structures in the city.43
The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not have construction or operational impacts related to special status species and their habitats. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes. Rather the Sunnyvale Playbook Update/Game Plan 2028 would address infrastructure development and programming to reduce GHG emissions and increase sustainable practices within Sunnyvale. As a policy document, the Sunnyvale Playbook Update/Game Plan 2028 would not directly result in impacts related to wildlife species identified as candidate, sensitive, or special status. However, implementation of the following Sunnyvale Playbook Update/Game Plan 2028 Plays may promote infrastructure development and redevelopment thathave the potential to result in impacts to special status species through construction activities that could directly cause mortality or result in indirect impacts through loss of breeding, foraging, and nesting habitat. Nonetheless, as addressed below, with adherence to the requirements of federal Endangered Species Act, California Endangered Species Act, CFCG, SMC, and Sunnyvale General Plan policies and actions, construction impacts would be minimized.

Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within the City. Play 2.2 promotes electrification of existing residential, commercial, and municipal buildings, which may require minor construction to modify the electrical and natural gas connections to existing buildings. Play 3.2

40 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023). 41 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 19.94, Tree Preservation. https://ecode360.com/42733058#:~:text=It%20is%20unlawful%20to%20damage,a%20protected%20tree%20removal%20permit.&text=% C2%A7%2019.94.,-050%20Permits%20required (accessed January 2024). 42 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023). 43 Sunnyvale, City of. N.d. Bird-Safe Building Design Guidelines. https://www.sunnyvale.ca.gov/home/showpublisheddocument/1542/638273438333130000 (accessed May 2024).

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Biological Resources

Final Initial Study–Negative Declaration 43
would encourage development of new bicycle and pedestrian infrastructure, which may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale. In addition, Play 4.3 seeks to increase the number of trees throughout Sunnyvale, which may require the use of construction equipment for the moving and placement of trees. These Plays have the potential to disturb special-status species and nesting habitat for birds and raptors protected under the CFGC and the MBTA. However, construction activities for future Sunnyvale Playbook Update/Game Plan 2028 projects would be required to comply with the provisions of the CFGC and the MBTA that include requirements for nesting bird and roosting bat avoidance. Compliance with State and federal requirements for the protection of special-status species would be required for all future Sunnyvale Playbook Update/Game Plan 2028-related projects and would minimize the potential for impacts to biological resources.

Furthermore, the Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would not conflict with the SMC or objectives and policies of the Sunnyvale General Plan related to wildlife but would rather be consistent with and promote those policies. Sunnyvale Playbook Update/Game Plan 2028 Plays involving infrastructure development or redevelopment would generally apply to the urbanized areas of the City, with little application to parks, open spaces area, or undeveloped portions of Sunnyvale where sensitive habitat and related species may be present. In addition, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 facilitates an increase in the tree canopy throughout Sunnyvale, and Move 6.C would restore, protect and expand tidal/salt marshes and natural water ways. This play and this move would help increase and improve habitat for special status species and migratory and nesting birds. As such, the Sunnyvale Playbook Update/Game Plan 2028 would not have a substantial adverse effect on candidate, threatened, or endangered wildlife species either directly through individual take or indirectly through species habitat modification.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to special-status wildlife species. b. Would the project 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 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?
Sunnyvale contains wetlands, streams, shoreline, riparian areas, and other sensitive habitat in the areas adjacent to the San Francisco Bay and Stevens Creek, Calabazas Creek, and Moffett Channel.44 Wetlands and other waters in Sunnyvale are protected by the federal Clean Water Act, the California Porter-Cologne Water Quality Control Act, and CFGC Section 1600 et seq., and are under the jurisdiction of the U.S. Army Corps of Engineers, the San Francisco Bay Regional Water Quality Control Board, and the California Department of Fish and Wildlife. Federal and State regulations require avoidance of impacts to the extent feasible, as well as compensation for unavoidable losses of jurisdictional wetlands and waters and sensitive natural communities and riparian habitat. SMC Chapter 12.60 requires compliance with the Clean Water Act and the Porter-Cologne Water Quality Control Act.45 In addition, Policies LT-1.10, LT-9.19, and LT-10.5 of the Land Use and Transportation

44 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed May 2024). 45 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 12.60, Stormwater Management. https://ecode360.com/42718251#42718251 (accessed January 2024).

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44 Element describe the City’s commitment to protection of wetlands, riparian areas, and other natural habitats within Sunnyvale.46
The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not have construction or operational impacts related to riparian, wetland, or other sensitive habitats. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning changes but would instead promote sustainable infrastructure development and redevelopment within urbanized areas of the City, with little application to parks, open spaces area, or other locations where riparian, wetland, and sensitive habitat is located.

Furthermore, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 facilitates an increase in the tree canopy throughout Sunnyvale, and Move 6.C would restore, protect and expand tidal/salt marshes and natural water ways. This play and this move align with the Sunnyvale General Plan goals and policies related to the preservation of sensitive habitats.

In addition, future Sunnyvale Playbook Update/Game Plan 2028-related projects would be required to adhere to City development regulations and General Plan policies, including SMC Chapter 12.60 and General Plan Policies LT-1.10, LT-9.19, and LT-10.5, to limit the potential for project impacts related to biological resources. In addition, the location and details of future Sunnyvale Playbook Update/Game Plan 2028-related projects would be reviewed for consistency with applicable local, regional, and State regulations related to sensitive habitat prior to approval. Any future Playbook Update/Game Plan 2028-related projects that could affect sensitive habitat, streams, or wetlands would be required to comply with the requirements of the California Porter-Cologne Water Quality Control Act, and CFGC Section 1600 et seq. Compliance with these regulations would include obtaining the appropriate CDFW, U.S. Army Corps of Engineers, and/or Regional Water Quality Control Board permits and complying with any avoidance, minimization, and habitat restoration measures required by the applicable agencies. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to riparian habitat or sensitive natural communities, such as wetlands. d. Would the project 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?
Sunnyvale is largely developed and offers limited habitat to provide migratory wildlife corridors or wildlife nursery sites. Areas that may support wildlife movement are generally limited to the wetlands and open space areas along San Francisco Bay and the Baylands Park where development is not permitted. In addition, creek and waterway corridors within the City such as Stevens Creek, Calabazas Creek, and Moffett Channel may serve as wildlife corridors.47 Policies LT-1.10, LT-9.19, and LT-10.5 of the Land Use and Transportation Element describe the City’s commitment to protection of wetlands, rivers, and other natural habitats within Sunnyvale that may be utilized by wildlife for movement and nurseries.48

46 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023). 47 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023). 48 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).

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Biological Resources

Final Initial Study–Negative Declaration 45
The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not have construction or operational impacts related to interference with species movement or wildlife nurseries. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes but would instead promote sustainable infrastructure development and redevelopment within urbanized areas of the City, with little application to the wetlands and baylands, open spaces area, creeks, or other locations where habitat supporting wildlife migration and nurseries may be present. Furthermore, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 facilitates an increase in the tree canopy throughout Sunnyvale, and Move 6.C would restore, protect and expand tidal/salt marshes and natural water ways. This play and this move align with the Sunnyvale General Plan policies related to the preservation of natural habitats, such as Policies LT-1.10, LT-9.19, and LT-10.5 that seek to preserve and enhance natural areas and habitat in Sunnyvale.

Future Sunnyvale Playbook Update/Game Plan 2028-related projects would be required to adhere to City development regulations and General Plan policies to limit the potential for project impacts related to biological resources, including wildlife movement corridors and nursery sites. In addition, the location and details of future Sunnyvale Playbook Update/Game Plan 2028-related projects would be reviewed for consistency with applicable local, regional, and State regulations related to sensitive habitat prior to approval. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Thresholds would result in a less-than-significant impact related to interference with wildlife migratory corridors or nursery sites.
e. Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
Sunnyvale maintains a Heritage Resources Inventory, which identifies several heritage tree locations. Chapter 19.94 of the SMC, also known as the Tree Preservation Ordinance, was established to regulate the protection, installation, removal and long term management of significantly sized trees on private and City-owned property, encourage the proper protection and maintenance of significantly sized trees, establish a review and permit procedure to assure the correct planting, maintenance, protection and removal of significant trees, and establish penalties for violation of its provisions.49 Additionally, Policies LT-2.3 through LT-2.5 and LT-9.5 and LT-9.6 of the Land Use and Transportation Element would further protect and encourage the planting of trees within the City.50
The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not have construction or operational impacts related to biological resources.

Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning changes but would instead promote sustainable infrastructure development and redevelopment within urbanized areas of the City. The purpose and intended effect of the Sunnyvale Playbook Update/Game Plan 2028 is to reduce GHG emissions generated in Sunnyvale to help reduce the effects of climate change. Implementation of proposed Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves would be beneficial by helping Sunnyvale meet applicable local policies and

49 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 19.94, Tree Preservation. https://ecode360.com/42733058#:~:text=It%20is%20unlawful%20to%20damage,a%20protected%20tree%20removal%20permit.&text=% C2%A7%2019.94.,-050%20Permits%20required (accessed January 2024). 50 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).

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46 ordinances for protecting biological resources, including the SMC Chapter 19.94 and the General Plan policies related to tree protection and preservation. Specifically, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 facilitates the implementation of an urban forest master plan that would increase tree canopy throughout the City and Move 6.C would restore, protect and expand tidal/salt marshes and natural water ways to support a biodiverse ecology and protect the shoreline from sea level rise and coastal flooding. Future Sunnyvale Playbook Update/Game Plan 2028-related projects would also be required to comply with SMC Chapter 19.94 during any construction activities. As such, the Sunnyvale Playbook Update/Game Plan 2028 would not conflict with or obstruct implementation of the applicable policies for preserving biological resources, including protected trees, and would not affect the City’s ability to attain goals and policies that protect biological resources. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with local biological resources protection policies.
f. Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plan?
No portion of Sunnyvale is currently subject to a habitat conservation plan or natural community conservation plan. The Santa Clara Valley Habitat Plan is a Natural Community Conservation Plan that applies to portions of Santa Clara County, but Sunnyvale is not included in the boundaries of that plan area.51,52 Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with an adopted habitat or natural community conservation plan.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in any development or land use changes that could lead to cumulative impacts. Implementation of Sunnyvale Playbook Update/Game Plan 2028 projects, in combination with other cumulative projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth, could result in impacts to biological resources during infrastructure and building construction. However, infrastructure development or redevelopment resulting from implementation of the Sunnyvale Playbook Update/Game Plan 2028 would be required to comply with applicable Sunnyvale General Plan policies, the SMC, and State and federal regulatory requirements regarding avoidance of special wildlife species and habitat. In addition, the Sunnyvale Playbook Update/Game Plan 2028 would not result in new building construction and contains actions that prioritize the preservation of trees and natural habitats. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant cumulative impact related to biological resources.

51 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed December 2023). 52 California Department of Fish and Wildlife. 2024. NCCP Plan Summary- Santa Clara Valley Habitat Plan. https://wildlife.ca.gov/Conservation/Planning/NCCP/Plans/Santa-Clara (accessed January 2024) Attachment 10

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Cultural Resources

Final Initial Study–Negative Declaration 47
5 Cultural Resources

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Cause a substantial adverse change in the
significance of a historical resource pursuant
to §15064.5? □ □ ■ □
b. Cause a substantial adverse change in the
significance of an archaeological resource
pursuant to §15064.5? □ □ ■ □
c. Disturb any human remains, including those
interred outside of formal cemeteries? □ □ ■ □
a. Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
The City maintains a Heritage Resources Inventory, which includes landmarks, trees, residential and commercial districts, and individual structures of local importance. Approximately 65 individual structures are listed as heritage resources, along with several heritage tree locations, and 11 properties are identified as local landmarks. In addition, Sunnyvale also contains two historical districts—the Taaffe-Frances Heritage Neighborhood (a residential district) and the Murphy Station Heritage Landmark District (a commercial district).53,54 Sunnyvale General Plan Goal CC-5 and Policies CC-5.1 through CC-5.5, LT-1.10, and LT-2.5 illustrate the City’s goals and policies related to the preservation of historical and cultural resources within Sunnyvale.55,56 In addition, SMC Chapter

19.96 provides regulations for the protection of heritage resources within the City.57 The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to historical resources. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes but would promote infrastructure development and redevelopment that would be complimentary to existing development. Sunnyvale Playbook Update/Game Plan 2028 projects would be required to comply with the applicable General Plan policies, including Policy CC-5.1, which aims to preserve existing landmarks and cultural resources

53 Sunnyvale, City of. 2018. Heritage Resources Inventory. https://www.sunnyvale.ca.gov/home/showpublisheddocument/1556/637820850915270000 (accessed January 2024). 54 Sunnyvale, City of. 2011. Community Character Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/598/637819113519200000 (accessed January 2024). 55 Ibid
56 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023). 57 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 19.96, Heritage Preservation. https://ecode360.com/42733144#42733144 (accessed January 2024).

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48 and their environmental settings, and Policy CC-5.3, which seeks to identify and work to resolve conflicts between the preservation of historic resources and alternative land uses.58 Future projects would also be required to comply with Chapter 19.96 of the SMC, which regulates development affecting historical and cultural resources within the City. Sunnyvale Playbook Update/Game Plan 2028-related projects would be reviewed for compliance with applicable local, regional, and State regulations regarding cultural resources and the Sunnyvale General Plan Land Use and Community Design Element to avoid adverse impacts related to historical resources. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than- significant impact related to historical resources.
b. Would the project cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
A number of recorded archaeological resources and sites exist within Sunnyvale, and there is the potential for undiscovered archaeological resources during construction activities within the City.59 Policy CC-5.5 of the General Plan Community Character Element directs that archaeological resources should be protected whenever possible, and Action LT-1.10f of the Land Use and Transportation Element includes a requirement that projects halt all ground-disturbing activities when unusual amounts of shell or bone, isolated artifacts, or other similar features are discovered and retain an archaeologist to assess the finding and implement mitigation measures.60 Additionally, Chapter 19.96 of the SMC aims to protect the City’s historical and cultural resources. 61 The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not have construction or operational impacts related to archaeological resources. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes but would promote infrastructure development and redevelopment that would generally be limited to previously developed and disturbed areas of the City where the presence of archaeological resources is unlikely. Nonetheless, there is a possibility for archaeological sites not previously recorded to be present in areas where Sunnyvale Playbook Update/Game Plan 2028 projects could occur. In particular, Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2, 1.3, 2.2, 3.2, and 4.3 may result in small-scale construction that could expose previously undiscovered archaeological resources during ground disturbing activities.

Future Sunnyvale Playbook Update/Game Plan 2028 projects would be located and designed strategically to reduce ground disturbance to the maximum extent possible. In addition, Sunnyvale Playbook Update/Game Plan 2028 projects would be reviewed for consistency with applicable local, regional, and State archeological regulations prior to final siting and construction and would be required to comply with Policy CC-5.5 and Action LT-1.10f of the General Plan and Chapter 19.96 of the SMC. As such, archeological resources would be protected, and impacts would be reduced to a minimal level. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG

58 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed January 2024). 59 Ibid
60 Sunnyvale, City of. 2011. Sunnyvale General Plan Community Character Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/598/637819113519200000 (accessed January 2024). 61 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 19.96, Heritage Preservation. https://ecode360.com/42733144#42733144 (accessed January 2024).

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Final Initial Study–Negative Declaration 49
Emissions Thresholds would result in a less-than-significant impact related to archaeological resources.
c. Would the project disturb any human remains, including those interred outside of formal cemeteries?
There is a possibility of encountering unknown buried human remains throughout Sunnyvale. The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not have construction or operational impacts related to human remains. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes but would promote infrastructure development and redevelopment that would generally be limited to previously developed and disturbed areas of the City where the presence of human remains is unlikely. However, there is the potential for future Sunnyvale Playbook Update/Game Plan 2028-related projects to encounter unknown human remains during project construction activities. Future projects that occur in accordance with the Sunnyvale Playbook Update/Game Plan 2028 would be required to comply with California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98 regulations related to burial findings, including notification, assessment, and treatment of burial sites. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to potential disturbance of human remains.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). Projects that occur to accommodate Sunnyvale’s anticipated population, employment, and housing growth would cumulatively increase the potential for adverse effects on historic and archaeological resources in Sunnyvale. As a guidance document, the CEQA GHG Emissions Thresholds would not result in cumulative impacts; however, the Sunnyvale Playbook Update/Game Plan 2028 could incrementally contribute to this cumulative effect through small-scale construction activities that could affect previously undiscovered cultural resources. Impacts related to historic and archaeological resources are generally site-specific. Accordingly, as required under applicable laws and regulations, potential impacts associated with future development in Sunnyvale, including Sunnyvale Playbook Update/Game Plan 2028-related projects, would be addressed on a project-by-project basis as project details and locations are determined. Future projects in Sunnyvale, including those associated with implementation of the Sunnyvale Playbook Update/Game Plan 2028, would be required to comply with the applicable General Plan policies and SMC Chapter 19.96, that require the identification and protection of sites and structures of historical, archaeological, and cultural significance in order to avoid impacts related to cultural resources. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to cultural resources.

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50 6 Energy

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact No Impact
Would the project:
a. Result in a 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? □ □ □ ■
a. Would the project result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
California is one of the lowest per-capita energy users in the United States, ranked 46th in the nation, due to its energy efficiency programs and mild climate.62 California consumed 287,826 gigawatt-hours (GWh) of electricity and 23,421 million therms of natural gas in 2022.63,64 The single largest end-use sector for energy consumption in California is transportation (37.8 percent), followed by industry (23.2 percent), residential (20.0 percent), and commercial (19.0 percent).65 The City of Sunnyvale has demonstrated its commitment to energy efficiency and renewable energy through many efforts, as described in the Existing Sustainability Setting section above. The City has adopted CALGreen, pursuant to SMC Chapter 16.43, which requires efficiency measures to reduce energy use and provide energy reduction benefits. The City has also completed communitywide GHG emissions inventories starting in 2008 and has been updating the inventory regularly since 2014. In 2019, transportation was responsible for approximately 52 percent of total GHG emissions within the Sunnyvale community, followed by commercial/industrial gas, residential gas, off-road equipment, solid waste, commercial/industrial electricity, residential electricity, water and wastewater, and finally Caltrain. In 2017, Sunnyvale’s electricity emissions declined due to receiving carbon-free electricity from Silicon Valley Clean Energy (SVCE).

The CEQA GHG Emissions Thresholds provide guidance during CEQA review and do not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to wasteful consumption of energy resources. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing climate action strategies to reduce communitywide GHG emissions. The

62 U.S. Energy Information Administration (USEIA). 2023. “California - Profile Overview.” https://www.eia.gov/state/?sid=CA.(accessed October 2023).
63 CEC. 2023. Electricity Consumption by County. http://www.ecdms.energy.ca.gov/elecbycounty.aspx (accessed October 2023). 64 CEC. 2023. Gas Consumption by County. http://www.ecdms.energy.ca.gov/gasbycounty.aspx (accessed October 2023). 65 USEIA. 2023. “California - Profile Overview.” https://www.eia.gov/state/?sid=CA (accessed October 2023).

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Final Initial Study–Negative Declaration 51
Sunnyvale Playbook Update/Game Plan 2028 would encourage energy efficiency and a transition away from natural gas use in existing and new residential and nonresidential building stock through Plays 2.1 through 2.3. The Sunnyvale Playbook Update/Game Plan 2028 would also incentivize increased use of renewable energy sources and renewable energy production and storage within Sunnyvale through Plays 1.1 through 1.3. Additionally, the Sunnyvale Playbook Update/Game Plan 2028 would reduce transportation-related energy consumption by increasing active transportation and public transit use, reducing VMT, and reducing the use of gasoline vehicles through Plays 3.1 through 3.4.

Implementation of some Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves, such as the installation of new active transportation infrastructure, would require small-scale construction.

However, energy use for the construction of such projects would be temporary in nature, and construction equipment used would be typical of similar-sized construction projects in the region. In addition, construction contractors would be required to comply with the provisions of CCR Title 13 Sections 2449 and 2485, which would minimize unnecessary fuel consumption. Construction equipment would be subject to the United States Environmental Protection Agency (U.S. EPA) Construction Equipment Fuel Efficiency Standard, which would also minimize inefficient, wasteful, or unnecessary fuel consumption. Furthermore, pursuant to the applicable regulatory requirements such as the 2022 CALGreen (CCR Title 24, Part 11), future infrastructure projects would comply with construction waste management practices to divert a minimum of 65 percent of construction and demolition debris pursuant to Chapter 16.74 of the SMC. These practices would result in efficient use of energy necessary to construct Sunnyvale Playbook Update/Game Plan 2028-related projects.

Upon completion of construction for any Sunnyvale Playbook Update/Game Plan 2028-related infrastructure development and redevelopment, non-renewable energy use would be reduced by increasing renewable energy production and storage and reducing VMT within the City.

The purpose and intended effect of the Sunnyvale Playbook Update/Game Plan 2028 is to reduce GHG emissions generated within the Sunnyvale community to minimize the effects of climate change, including those emissions generated by energy demand and supply. The Sunnyvale Playbook Update/Game Plan 2028 would not result in the use of non-renewable resources in a wasteful or inefficient manner; rather, it would assist in reducing use of non-renewable energy resources and increasing the production of local renewable energy. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to the wasteful, inefficient, or unnecessary consumption of energy. b. Would the project conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Relevant plans and policies that aim to increase energy efficiency and the production of renewable energy include SB 1020, 2022 CALGreen (Title 24 Part 11), and 2022 California Building Energy Efficiency Standards (Title 24 Part 6). SB 1020 supports the reduction of GHG emissions from the electricity sector by accelerating the State RPS Program and requires electricity providers to increase procurement from eligible renewable energy resources to 90 percent of total retail sales by 2035, 95 percent by 2040, and 100 percent by 2045. CALGreen (Title 24 Part 11) institutes mandatory minimum environmental performance standards for all ground-up new construction of non- residential and residential structures. In addition, the California Building Energy Efficiency Standards (Title 24 Part 6) establishes energy-efficiency standards for residential and non-residential buildings in order to reduce California’s energy demand. CCR Title 24 (Parts 6 and 11) is updated periodically to incorporate and consider new energy-efficiency technologies and methodologies as they become available. New construction and major renovations must demonstrate their compliance with the Attachment 10

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52 current Building Energy Efficiency Standards through submission and approval of a Title 24 Compliance Report to the local building permit review authority and the CEC.

Sunnyvale is part of the SVCE, a Joint Powers Agreement that provides electricity primarily from clean, renewable sources. Sunnyvale would continue to reduce its use of nonrenewable energy resources as the electricity and power resources generated by renewable sources provided by SVCE continues to increase to comply with State requirements through SB 1020. The Sunnyvale Playbook Update/Game Plan 2028 includes Plays and Moves to reduce non-renewable electricity use and increase production and storage of renewable energy, as discussed further below, and would, thus, align with the overall intent of SB 1020.

In addition, the City of Sunnyvale has adopted CALGreen (Title 24 Part 11) and the California Building Energy Efficiency Standards (Title 24 Part 6) pursuant to SMC Chapter 16.43, Green Building Code. Future Sunnyvale Playbook Update/Game Plan 2028-related projects would be required to demonstrate compliance with the CALGreen and California Building Energy Efficiency standards by implementing sustainability and energy efficiency measures such as high-efficiency lighting and HVAC systems, low-flow water fixtures, dual-paned windows, and water efficient landscaping and irrigation systems. Compliance with these regulations would minimize potential conflicts with adopted energy conservation plans.

As discussed under Response 6a., Sunnyvale Playbook Update/Game Plan 2028 Plays 2.1 through

2.3 seek to decrease non-renewable energy consumption in new and existing buildings by requiring electrification, efficiency upgrades, and phasing out natural gas use. Additionally, Plays 1.1 through

1.3 would encourage the production, use, and storage of local renewable energy. These Plays are consistent with the goals and policies established by SB 1020, CALGreen, and the California Building Energy Efficiency Standards. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with State and local renewable energy and energy efficiency plans.

Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in any development or land use changes that could result in cumulative impacts. Implementation of the Sunnyvale Playbook Update/Game Plan 2028 would result in reduced use of non-renewable energy resources across the community by phasing out natural gas use, increasing the use of the SVCE, and reducing gasoline vehicle use. Implementation of the Sunnyvale Playbook Update/Game Plan 2028 would also increase the production and storage of renewable energy within the City by incentivizing the inclusion of small-scale solar and battery storage projects. As Sunnyvale’s population grows and development intensifies in the future, actions contained within the Sunnyvale Playbook Update/Game Plan 2028 would require that planned new development not related to the Sunnyvale Playbook Update/Game Plan 2028 is constructed to strict energy efficiency standards and that VMT is reduced. As the Sunnyvale Playbook Update/Game Plan 2028 would result in decreased non- renewable energy use and would align with existing plans and policies related to renewable energy and energy efficiency, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result a no cumulative impact related to energy.

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Final Initial Study–Negative Declaration 53
7 Geology and Soils

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Expose people or structures to potentially
substantial adverse effects, including the
risk of loss, injury, or death involving:

1. 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? □ □ □ ■

2. Strong seismic ground shaking? □ □ □ ■

3. Seismic-related ground failure,
including liquefaction? □ □ □ ■

4. 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 1-B of the Uniform Building Code
(1994), creating substantial direct or indirect
risks to life or property? □ □ ■ □
e. Have soils incapable of adequately supporting
the use of septic tanks or alternative
wastewater disposal systems where sewers
are not available for the disposal of
wastewater? □ □ □ ■
f. Directly or indirectly destroy a unique
paleontological resource or site or unique
geologic feature? □ □ ■ □
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54 a. Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:
▪ 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?
▪ Strong seismic ground shaking?
▪ Seismic-related ground failure, including liquefaction? ▪ Landslides?
Sunnyvale is located in a seismically active region, and there are several active faults within the vicinity of Sunnyvale that could cause seismic-related impacts. 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 that traverse the City—the San Jose fault, the Stanford fault, and the Cascade fault that cross the City in a northwesterly-southeasterly direction.66 There are no Alquist-Priolo Fault Zones within Sunnyvale.67 However, the City could experience strong seismic ground shaking and seismic-related ground failure (e.g., liquefaction and settlement) from earthquakes on active faults located in and outside of the City. The northern half of Sunnyvale starting at roughly Washington Avenue and Central Expressway northward is considered susceptible to liquefaction. Additionally, Sunnyvale is underlain by young alluvial sediments that can be susceptible to settlement, and sediments located immediately adjacent to San Francisco Bay consisting of Bay muds are generally very susceptible to settlement.68
Although Sunnyvale is at risk of earthquake-induced ground shaking and associated hazards, the Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing Plays and Moves to reduce GHG emissions. The Sunnyvale Playbook Update/Game Plan 2028 does not propose habitable development or policies that could result in exposure of people to potential substantial adverse effects, including the risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure including liquefaction, or landslides. Likewise, the CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to risk of loss, injury, or death involving rupture of a known earthquake fault, strong seismic ground shaking, seismic-related ground failure including liquefaction, or landslides. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to seismic- and landslide-related hazards.
b. Would the project result in substantial soil erosion or the loss of topsoil? The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to substantial loss of topsoil.

66 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed January 2024). 67 California Geological Survey. 2023. Earthquake Zones of Required Investigation. https://maps.conservation.ca.gov/cgs/EQZApp/app/ (accessed October 2023).
68 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed January 2024).

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Final Initial Study–Negative Declaration 55
Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning designation changes but would promote sustainable infrastructure development. As a policy document, the Sunnyvale Playbook Update/Game Plan 2028 would not directly require ground- disturbing activities. However, implementation of several Sunnyvale Playbook Update/Game Plan 2028 Plays may result in small-scale construction activities that could cause soil erosion or the loss of topsoil during construction. Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within the City. Play 2.2 promotes electrification and energy efficiency upgrades for existing residential and commercial buildings, which may require minor construction to modify the electrical and natural gas connections to existing buildings. Play 3.2 would encourage development of new bicycle and pedestrian infrastructure, which may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale. Play 3.3 would incentivize or require the installation of new EV charging stations. In addition, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3 seeks to plant additional trees throughout Sunnyvale. As such, the Sunnyvale Playbook Update/Game Plan 2028 could result in construction-related soil erosion and topsoil loss impacts associated with such installations and plantings.

Sunnyvale Playbook Update/Game Plan 2028 projects would be reviewed for consistency with local and State erosion and grading regulations prior to final siting and construction. The potential for Sunnyvale Playbook Update/Game Plan 2028 project construction activities involving soil disturbance to result in increased erosion and sediment transport by stormwater to surface waters would be minimized through compliance with CBC Chapter 70 standards, which would ensure implementation of appropriate measures during grading activities to reduce soil erosion.

Additionally, any development involving clearing, grading, or excavation that causes soil disturbance of 1 or more acres would be required to prepare and comply with a stormwater pollution prevention plan (SWPPP) that provides a schedule for the implementation and maintenance of erosion control measures and a description of applicable erosion control practices, including appropriate design details and a time schedule. Future projects would also be required to comply with SMC Chapter 12.60, which establishes local requirements for stormwater management and Section 18.12.110, which specifies that when grading would create a nuisance or hazard to other properties, public ways, or public facilities due to erosion from storm runoff or rainfall, no grading may commence or continue without specific consent in writing from the Director of Public Works or the Director of Community Development.69,70 The City’s grading regulations would require public and private development projects to include control measures for erosion and sediment control as well as permanent features to minimize stormwater pollution. The City’s current development review process also requires construction projects to obtain required permits and that on-site regional control measures are considered for new development projects.71 Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to soil erosion and loss of topsoil.

69 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 12.60, Stormwater Management. https://ecode360.com/42718154#42718154 (accessed February 2024). 70 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 18.12.100, Grading. https://ecode360.com/42728788?highlight=&searchId=16481596759239067#42728788 (accessed February 2024). 71 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed January 2024).

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56 c. Would the project be located on a geologic unit or soil that is unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
d. Would the project be located on expansive soil, as defined in Table 1-B of the Uniform Building Code, creating substantial risks to life or property?
The northern half of Sunnyvale starting at roughly Washington Avenue and Central Expressway northward is considered susceptible to liquefaction. The liquefaction probability for Sunnyvale is between 0 and 10 percent. Additionally, surficial soils in Sunnyvale are largely composed of expansive clays. Bay mud and clayey alluvium located generally in the northern half of Sunnyvale have the potential for expansive movement. However, locally expansive soils may occur wherever clayey soils exist.72 The City requires new development to prepare geotechnical soils reports pursuant to SMC Section 18.20.100 in order to improve the structural safety of buildings in areas of Sunnyvale with unstable soils. The resulting report recommended mitigation techniques for site- specific expansive soil conditions, compressive (settlement) soil conditions, and seismic hazards such as strong ground motion and liquefaction are required to be implemented by projects. 73 Future projects would also be required to comply with SMC Chapter 16.16, which adopts the CBC and includes common engineering practices requiring special design and construction methods that minimize potential expansive soil-related impacts.74
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to project location on an unstable geologic unit or soil. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 is a policy document that does not propose specific development or land use designation changes. Some of the proposed Plays and Moves in the Sunnyvale Playbook Update/Game Plan 2028 would support small-scale construction projects as discussed under Response 7b., such as new solar panels and EV charging stations. However, Sunnyvale Playbook Update/Game Plan 2028 projects and actions would be reviewed for consistency with local and State geotechnical regulations prior to final siting and construction. In addition, new structures would be required to comply with SMC Section

18.20.100 and Chapter 16.16to address applicable unstable soil conditions. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to risks associated with unstable geologic units or soils. e. Would the project have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater?
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not involve the development of habitable structures and, thus, no use of septic tanks or alternative wastewater disposal systems would be required. Therefore, no impact would occur related to soil capability support of alternative wastewater disposal systems.

72 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (Accessed January 2024). 73 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 18.20.100, Final or parcel map—Action before filing. https://ecode360.com/42728788?highlight=&searchId=16481596759239067#42728788 (accessed February 2024). 74 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 16.16, Building Code. https://ecode360.com/42720766?highlight=&searchId=16482460774455457#42720766 (accessed February 2024).

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Final Initial Study–Negative Declaration 57
f. Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Sunnyvale’s underlying geology consists of basin and alluvial deposits that have the potential to contain fossils, based on previously reported finds in similar materials in other locations in the Bay Area. Because Sunnyvale is largely developed, it is likely there has been a substantial amount of ground disturbance and placement of fill that has altered the subsurface soils and underlying geologic materials at varying depths. However, if a large area were excavated to depths greater than 10 feet, it is possible the excavation could be within Holocene-age deposits or older Pleistocene alluvial materials that could contain fossils.75 Policy LT-1.10 of the General Plan Land Use and Transportation Element establishes the City’s commitment to the protection of the natural and human environment in Sunnyvale, and Action LT-1.10f requires work stoppage during construction of projects if archaeological or paleontological resources are discovered, investigation by a qualified professional, and implementation of measures to protect the resource.76 The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to paleontological resources.

Likewise, the Sunnyvale Playbook Update/Game Plan 2028 would not involve land use or zoning changes but would instead promote infrastructure development and redevelopment primarily within previously developed areas of the City. As a policy document, the Sunnyvale Playbook Update/Game Plan 2028 would not directly result in impacts related to paleontological resources or unique geologic features. Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves that would involve construction activities, such as those related to building electrification retrofits (Play 2.2) and EV charging infrastructure (Play 3.3), would involve work within existing, previously graded and disturbed areas where the likelihood of encountering intact and previously undiscovered paleontological resources would be minimal. In general, Sunnyvale Playbook Update/Game Plan 2028 projects would be located and designed to reduce ground disturbance to the maximum extent possible. Nonetheless, there is a possibility that small-scale construction projects may expose paleontological resources during ground-disturbing activities. To reduce such risks, future Sunnyvale Playbook Update/Game Plan 2028-related projects would be reviewed for consistency with geotechnical and paleontological policies and regulations prior to final siting and construction, including General Plan Action LT-1.10f. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to paleontological resources or unique geologic features.

75 Sunnyvale, City of. 2016. Land Use and Transportation Element Draft Environmental Impact Report. https://www.sunnyvale.ca.gov/home/showpublisheddocument/608/637819113538930000 (accessed January 2024). 76 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).

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58 and property to the seismic and geologic hazards that are present in the region. The magnitude of geologic hazards for individual projects, including those associated with implementation of the Sunnyvale Playbook Update/Game Plan 2028, would depend upon the location, type, and size of development and the specific hazards associated with individual sites. Specific geologic hazards associated with individual project sites would be limited to those sites without affecting other areas.

Similarly, potential impacts related to paleontological resources associated with each individual site would be limited to that site without affecting other areas, and impacts related to these resources would be minimized on a project-by-project basis. Furthermore, compliance with existing regulations, including CBC requirements, City-issued permit requirements, the Sunnyvale General Plan, the CMC, and/or Construction General Permit requirements, would minimize potential cumulative seismic and geologic hazard impacts. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to geology and soils.

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Greenhouse Gas Emissions

Final Initial Study–Negative Declaration 59
8 Greenhouse Gas Emissions

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Generate greenhouse gas emissions, either
directly or indirectly, that may have a
significant impact on the environment? □ □ ■ □
b. Conflict with any applicable plan, policy, or
regulation adopted to reduce the emissions
of greenhouse gases? □ □ □ ■
a. Would the project generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment?
The greenhouse effect is a natural occurrence that helps regulate the temperature of the Earth. The majority of radiation from the sun hits Earth’s surface and warms it. The surface in turn radiates heat back towards the atmosphere, known as infrared radiation. Gases and clouds in the atmosphere trap and prevent some of this heat from escaping into space and re-radiate it in all directions. This process is essential to support life on Earth, because it warms the planet by approximately 60°F. Emissions from human activities since the beginning of the industrial revolution (approximately 270 years ago) have been adding to the natural greenhouse effect by resulting in increased gases in the atmosphere that trap heat and contribute to an average increase in Earth’s temperature. Global warming is the observed increase in the average temperature of the Earth’s surface, and climate change is the resultant change in wind patterns, precipitation, and storms over an extended period.

GHGs produced by human activities include CO2, methane (CH4), nitrous oxide (N2O), sulfur hexafluoride, hydrofluorocarbons, and perfluorinated compounds. Combustion of fossil fuels (gasoline, natural gas, and coal), deforestation, and decomposition of waste release carbon into the atmosphere that had been locked underground and stored in oil, gas, and other hydrocarbon deposits or in the biomass of surface vegetation. Since 1750, estimated concentrations of CO2, CH4, and N2O in the atmosphere have increased by over 36 percent, 148 percent, and 18 percent respectively, primarily due to human activity. Emissions of GHGs affect the atmosphere directly by changing its chemical composition.

Changes to the land surface also indirectly affect the atmosphere by changing the way in which Earth absorbs gases from the atmosphere. Potential impacts in California due to climate change include sea level rise, more extreme-heat days and high-ozone days, larger and more frequent forest fires, and more frequent and severe drought years.77 Although GHG emissions do not

77 CARB and California Environmental Protection Agency (CalEPA). 2009. Environmental Health and Equity Impacts from Climate Change and Mitigation Policies in California: A Review of the Literature. https://www.researchgate.net/profile/Seth- Shonkoff/publication/237420289_ENVIRONMENTAL_HEALTH_AND_EQUITY_IMPACTS_FROM_CLIMATE_CHANGE_AND_MITIGATION_PO LICIES_IN_CALIFORNIA_A_REVIEW_OF_THE_LITERATURE/links/0deec533acf69321ea000000/ENVIRONMENTAL-HEALTH-AND-EQUITY-

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60 typically cause direct health impacts at a local level, GHG emissions can result in indirect health impacts by contributing to climate change, which can have public health implications. The primary public health impacts of climate change include the following:
▪ Increased incidences of hospitalization and deaths due to increased incidences of extreme heat events;
▪ Increased incidences of health impacts related to ground-level ozone pollution due to increased average temperatures that facilitate ozone formation;
▪ Increased incidences of respiratory illnesses from wildfire smoke due to increased incidences of wildfires;
▪ Increased vector-borne diseases due to the growing extent of warm climates; and ▪ Increased stress and mental trauma due to extreme events and disasters, economic disruptions, and residential displacement.78
Sunnyvale has completed a communitywide GHG emissions inventory for 2019, which is summarized in Table 1. In 2019, communitywide GHG emissions totaled 716,382 MT of CO2e, with the transportation sector contributing approximately 52 percent of overall GHG emissions, followed by nonresidential and residential energy use. Under the business-as-usual scenario, communitywide GHG emissions are forecasted to increase to approximately 931,298 MT of CO2e by the year 2030 and 1,259,700 MT of CO2e by the year 2045. Implementation of the Sunnyvale Playbook Update/Game Plan 2028 alongside State laws and programs would reduce annual communitywide GHG emissions to approximately 419,818 MT of CO2e by the year 2030 and 417,347 MT of CO2e by the year 2045.

The Plays and Moves included in the Sunnyvale Playbook Update/Game Plan 2028 combined with Statewide legislation and initiatives would enable the City of Sunnyvale to meet its target of reducing communitywide GHG emissions output to 56 percent below 1990 levels by 2030, which exceeds the State target of 40 percent below 1990 levels by 2030 pursuant to SB 32. Because SB 32 is considered an interim target toward meeting the 2045 State goal of carbon neutrality, implementation of the Sunnyvale Playbook Update/Game Plan 2028 would be considered substantial progress toward meeting the State long-term 2045 goal. Avoiding interference with, and making substantial progress toward, these long-term State targets is important, because these targets have been set at levels that achieve California’s fair share of international emissions reduction targets that will stabilize global climate change effects and help avoid the associated adverse environmental consequences.

The Sunnyvale Playbook Update/Game Plan 2028 includes Strategies, Plays, and associated Moves intended to reduce communitywide GHG emissions in terms of the building energy, transportation, waste/water, and carbon sequestration sectors. The Playbook/Game Plan also includes strategies related to community engagement and climate adaptation. Implementation of the Sunnyvale Playbook Update/Game Plan 2028 would result in the reduction of communitywide operational GHG emissions, while only generating temporary GHG emissions during construction of infrastructure such as EV charging stations and building energy efficiency upgrades. Additionally, the Sunnyvale Playbook Update/Game Plan 2028 would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and sustainability effects. These benefits include

IMPACTS-FROM-CLIMATE-CHANGE-AND-MITIGATION-POLICIES-IN-CALIFORNIA-A-REVIEW-OF-THE-LITERATURE.pdf (accessed February 2024).
78 State of California. 2019. California’s Fourth Climate Change Assessment Statewide Summary Report. http://www.climateassessment.ca.gov/state/ (accessed February 2024).

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Greenhouse Gas Emissions

Final Initial Study–Negative Declaration 61
reduction in building energy consumption, vehicle miles traveled (and thus air pollution), solid waste generation, and water consumption. The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning and, thus, would not result in construction or operational impacts related to GHG emissions. The CEQA GHG Emissions Thresholds would establish GHG emissions targets and analysis methodologies consistent with the goals established by the Sunnyvale Playbook Update/Game Plan 2028 that are enforced during CEQA review with the intention of reducing GHG emissions associated with construction and operation of future projects and plans in Sunnyvale. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to generation of GHG emissions.
b. Would the project conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
The CARB 2022 Climate Change Scoping Plan outlines a pathway for achieving the 2045 carbon neutrality goal established by AB 1279. The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds are policy-level documents that establish policies to reduce GHG emissions within Sunnyvale in an effort to comply with State regulations. As discussed under Response 8a, the Sunnyvale Playbook Update/Game Plan 2028 includes Plays and Moves that would reduce Sunnyvale GHG emissions from forecasted BAU annual levels to approximately 419,818 MT of CO2e by 2030. The purpose of the Sunnyvale Playbook Update/Game Plan 2028 is to meet Sunnyvale’s proportionate fair share of the Statewide GHG emissions reduction target set by SB 32 and work toward the State’s longer-term target of carbon neutrality identified by the 2022 Scoping Plan and AB 1279.

The Sunnyvale Playbook Update/Game Plan 2028 would not conflict with any applicable GHG reduction plans, including the CARB 2022 Climate Change Scoping Plan. The Sunnyvale Playbook Update/Game Plan 2028 identifies how the City would achieve consistency with the Statewide GHG emissions reduction goals. The Sunnyvale Playbook Update/Game Plan 2028 would serve as a pathway to reduce GHG emissions and introduce other beneficial environmental and sustainability effects. These benefits include reduction in building energy consumption, VMT (and thus air pollution), solid waste generation, and water consumption. Likewise, the CEQA GHG Emissions Thresholds would establish GHG emissions targets and analysis methodologies consistent with the Sunnyvale Playbook Update/Game Plan 2028 and would be enforced during CEQA review with the intention of reducing GHG emissions associated with construction and operation of future projects and plans in the City. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with applicable GHG emissions reduction plans, policies, and regulations.

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62 Sunnyvale. The Sunnyvale Playbook Update/Game Plan 2028 also includes a series of Plays and Moves that are intended to reduce communitywide GHG emissions by approximately 56 percent below 1990 levels by 2030 and that provides substantial progress toward Sunnyvale meeting State carbon neutrality goals by 2045. As such, the Sunnyvale Playbook Update/Game Plan 2028 would result in the reduction of GHG emissions rather than generating GHG emissions. Some GHG emissions would occur during future construction of Sunnyvale Playbook Update/Game Plan 2028- related infrastructure projects; however, these emissions would be temporary and minor in nature.

Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Thresholds would result in a less-than-significant cumulative impact related to GHG emissions.

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Hazards and Hazardous Materials

Final Initial Study–Negative Declaration 63
9 Hazards and Hazardous Materials

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a. Create a significant hazard to the public or
the environment through the routine
transport, use, or disposal of hazardous
materials? □ □ ■ □
b. Create a significant hazard to the public or
the environment through reasonably
foreseeable upset and accident conditions
involving the release of hazardous
materials into the environment? □ □ ■ □
c. Emit hazardous emissions or handle
hazardous or acutely hazardous materials,
substances, or waste within 0.25 mile of an
existing or proposed school? □ □ ■ □
d. Be located on a site that is included on a list
of hazardous material 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 in 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? □ □ □ ■
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64 a. Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? b. Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to hazardous materials.

The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing Plays and Moves to reduce GHG emissions. The Sunnyvale Playbook Update/Game Plan 2028 does not involve identified site-specific development and, for the most part, would not facilitate new development that would involve the routine use of hazardous materials. Implementation of some of the Sunnyvale Playbook Update/Game Plan 2028 actions, such as building electrification and energy efficiency retrofits and installation of EV charging stations, would require construction activities.

Construction would involve the temporary use of hazardous materials such as vehicle fuels and fluids that could be released should an accidental leak or spill occur. However, these types of materials are not considered acutely hazardous, and storage, handling, and disposal of these materials are regulated by the California Department of Toxic Substances Control, U.S. EPA, and Occupational Safety & Health Administration. In addition, standard construction BMPs for the use and handling of such materials would avoid or reduce the potential for such conditions to occur. Any use of potentially hazardous materials during construction of projects would comply with all local, State, and federal regulations regarding the handling of potentially hazardous materials, including Title 49 of the Code of Federal Regulations and Title 22, Division 4.5 of the CCR. Risk of spills would cease after construction is completed. Thus, construction activities related to Sunnyvale Playbook Update/Game Plan 2028 actions would not be anticipated to create upset and accident conditions involving the release of hazardous materials, and operation of the majority of Sunnyvale Playbook Update/Game Plan 2028-related projects would not involve the routine transport, use, or disposal of hazardous materials during operation.

Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 emphasize increasing local renewable energy production and battery energy storage facilities within the City. Lithium-ion batteries, the typical battery technology used in battery storage systems, may pose a risk of upset and accidental release of hazardous chemicals contained within the batteries (e.g., in the event of a fire). Lithium-ion technology is a common battery storage medium and is considered one of the safest and most efficient methods of energy storage on the market. During normal operation, lithium-ion batteries do not represent a risk to off-site receptors, and safety standards applicable to energy storage facilities and safety certification tests established by independent bodies, such as Underwriters Laboratories, National Fire Protection Association, and International Electrotechnical Commission would prevent any reasonable possibility of a substantial adverse effect on the environment related to the lithium-ion batteries. However, in the unlikely event of a fire, there is a risk of the accidental release of hazardous materials associated with renewable energy systems.

Future proposed battery energy storage facilities would, thus, be carefully reviewed for appropriate locations, safety measures, and consistency with the Sunnyvale General Plan, SMC, and applicable local, State, and federal regulations. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to creation of a significant hazard through the routine transport, use, or disposal of hazardous Attachment 10

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Hazards and Hazardous Materials

Final Initial Study–Negative Declaration 65
materials and reasonably foreseeable upset and accident conditions involving the release of hazardous materials.
c. Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within 0.25 mile of an existing or proposed school? The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to handling hazardous materials in the vicinity of schools. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing Plays and Moves to reduce GHG emissions. The Sunnyvale Playbook Update/Game Plan 2028 does not include site-specific proposals and development. Implementing some Sunnyvale Playbook Update/Game Plan 2028 Plays and Moves may require future development or improvements, such as EV charging stations and building improvements related to energy efficiency. However, Sunnyvale Playbook Update/Game Plan 2028 projects would be reviewed to confirm the appropriate location of projects in relation to existing development in the City and would be reviewed for consistency with the Sunnyvale General Plan, SMC, and applicable local, State, and federal regulations. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to handling of hazardous materials within 0.25 mile of schools. d. Would the project be located on a site included on a list of hazardous material 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?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to project site location on a site listed on a hazardous material site. The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing Plays and Moves to reduce GHG emissions. The Sunnyvale Playbook Update/Game Plan 2028 does not include site-specific proposals or non-infrastructure development, but certain Plays and Moves could result in projects that could be located on listed hazardous materials sites. However, Sunnyvale Playbook Update/Game Plan 2028-related projects would be reviewed for consistency with the Sunnyvale General Plan and SMC and would be required to comply with applicable local, State, and federal regulations related to hazardous materials sites.

In addition, future Sunnyvale Playbook Update/Game Plan 2028 projects would be required to comply with applicable local, State, and federal regulations pertaining to hazardous materials, such as those discussed under Response 9a. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Thresholds would result in a less-than-significant impact related to location on a listed hazardous materials site.
e. For a project located in 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? Sunnyvale does not contain any airports. The nearest airport to Sunnyvale is the Moffett Federal Airfield, located immediately west of the City’s northern limits. Although Moffett Federal Airfield is located adjacent to the City, the CEQA GHG Emissions Thresholds and Sunnyvale Playbook Update/Game Plan 2028 are policy documents that would not increase airport activity or result in additional habitable development or commercial development that could increase potential Attachment 10

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66 exposure of residents and employees to aircraft-related hazards. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to risks associated with location proximate to a public airport. f. Would the project impair implementation of or physically interfere with an adopted emergency response plan or emergency evacuation plan?
The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds are policy documents intended to reduce GHG emissions. The proposed Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds do not involve site-specific development, nor would they facilitate new development that would interfere with adopted emergency plans.

Implementation of some Sunnyvale Playbook Update/Game Plan 2028 Plays, such as Play 3.2, which would provide for the addition of new bicycle and pedestrian infrastructure, may involve construction within a local right-of-way. Construction activities have the potential to require lane closures and may impact traffic and vehicle speeds on the affected roadways; however, these impacts would be temporary and access to roadways would be maintained throughout project construction. Furthermore, future projects involving work in a public right-of-way would be required to coordinate with the City to ensure appropriate construction staging and adequate vehicular and pedestrian access on adjacent roadways, pursuant to SMC Chapter 13.08.79 Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to impairment or interference with implementation of an emergency response or evacuation plan.
g. Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires?
According to the Santa Clara Operational Area Hazard Mitigation Plan- Sunnyvale Annex, Sunnyvale is urbanized and is categorized as having no risk of wildland fire.80 The Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds do not propose specific development or new residential or commercial land uses that could be subject to wildland fire, nor would they result other physical changes to the environment that could increase the risk of a wildland fire.

Therefore, the Update and CEQA GHG Emissions Thresholds would result in no impact related to risks associated with exposure to wildland fires.

79 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 13.08, Right-of-Way Encroachments. https://ecode360.com/42719687?highlight=encroachments&searchId=16491543957131113#42719687 (accessed February 2024). 80 County of Santa Clara. 2017. Santa Clara Operational Area Hazard Mitigation Plan; Volume 2—Partner Annexes. https://sunnyvaleca.legistar.com/LegislationDetail.aspx?ID=3216998&GUID=7E0A85F2-3134-4300-B6FC-DF5ACC14A82C&FullText=1 (accessed February 2024).

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Hazards and Hazardous Materials

Final Initial Study–Negative Declaration 67
applicable Sunnyvale General Plan policies, SMC requirements, and State and federal regulatory requirements. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to hazards and hazardous materials.

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68 10 Hydrology and Water Quality

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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 erosion or siltation
on- or off-site; □ □ ■ □
(ii) Substantially increase the rate or
amount of surface runoff in a manner
which would result in flooding on- or
off-site; □ □ ■ □
(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? □ □ □ ■
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Hydrology and Water Quality

Final Initial Study–Negative Declaration 69
a. Would the project violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or groundwater quality? The CEQA GHG Emissions Thresholds is a guidance document as does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to water quality standards. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing actions intended to reduce GHG emissions within the City and does not propose specific development or land use designation changes. Sunnyvale Playbook Update/Game Plan 2028 Plays

1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within the City. Play 2.2 promotes electrification and energy efficiency upgrades for existing residential and commercial buildings, which may require minor construction to modify the electrical and natural gas connections to existing buildings. Play 3.2 would encourage development of new bicycle and pedestrian infrastructure, which may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale. Play 3.3 would incentivize or require the installation of new EV charging stations. In addition, Play 4.3 seeks to plant additional trees throughout Sunnyvale. These Plays may result in small scale construction activities in the future that could result in temporary water quality impacts due to soil erosion and ground disturbance, as further discussed under Response 10c and in Section 7, Geology and Soils.

However, Sunnyvale Playbook Update/Game Plan 2028 projects would be reviewed for consistency with local and State regulations, including the NPDES permitting program that requires implementation of SWPPPs and SMC Chapter 12.60 and Section 18.12.100 that regulate stormwater management and grading and include erosion, pollution, and sediment control standards.81,82 These regulations require BMPs to reduce water quality impacts from construction activities. Compliance with the SMC and/or NPDES permitting program would require that BMPs are implemented during construction to minimize potential impacts to surface and groundwater quality. As such, the Sunnyvale Playbook Update/Game Plan 2028’s related infrastructure and retrofit projects would not result in new or different waste discharge that would violate water quality standards, waste discharge requirements, or otherwise degrade surface or groundwater quality. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to surface or groundwater water quality in Sunnyvale. b. Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to groundwater supplies.

Likewise, the Sunnyvale Playbook Update/Game Plan 2028 does not propose development or land use designation changes but rather is a policy document containing strategies intended to reduce GHG emissions and increase sustainability. Sunnyvale Playbook Update/Game Plan 2028 Play 4.2 seeks to decrease community water use through water efficiency retrofits and sustainable landscaping and irrigation. Reduced water use within Cupertino would aid in maintaining

81 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Chapter 12.60, Stormwater Management. https://ecode360.com/42718154#42718154 (accessed February 2024). 82 Sunnyvale, City of. 2024. Sunnyvale Municipal Code Section 18.12.100, Grading. https://ecode360.com/42728788?highlight=&searchId=16481596759239067#42728788 (accessed February 2024).

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70 groundwater supplies. Additionally, Play 4.3 directs the City to implement the Green Stormwater Infrastructure Plan, which would increase groundwater recharge. As such, implementing the Sunnyvale Playbook Update/Game Plan 2028 would have a beneficial effect related to local groundwater recharge as well as support groundwater management in Sunnyvale. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to impedance of sustainable groundwater management. c. Would the project 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:
▪ Result in substantial erosion or siltation on- or off-site? ▪ Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
▪ 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? ▪ Impede or redirect flood flows?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to alterations in drainage patterns and impervious surfaces. Likewise, the Sunnyvale Playbook Update/Game Plan 2028 does not propose specific development or land use designation changes but rather emphasizes strategies intended to reduce GHG emissions and increase sustainability in the City. Implementation of several Sunnyvale Playbook Update/Game Plan 2028 Plays may promote infrastructure development and small-scale construction activities within the City. Sunnyvale Playbook Update/Game Plan 2028 Plays 1.2 and 1.3 would result in the addition of solar PV and thermal energy systems, along with battery storage, within the City. Play 2.2 promotes electrification and energy efficiency upgrades for existing residential and commercial buildings, which may require minor construction to modify the electrical and natural gas connections to existing buildings. Play 3.2 would encourage development of new bicycle and pedestrian infrastructure, which may involve construction activities to create new bike lanes and bike/pedestrian paths throughout Sunnyvale. Play 3.3 would incentivize or require the installation of new EV charging stations. In addition, Play 4.3 seeks to plant additional trees throughout the City that may require the use of construction equipment for the moving and placement of trees.

Implementation of these Sunnyvale Playbook Update/Game Plan 2028 Plays would primarily occur within previously developed areas and would not result in substantial alterations to Sunnyvale’s existing drainage pattern and amount of impervious surface. Construction of Sunnyvale Playbook Update/Game Plan 2028 projects could result in erosion as discussed in Section 7, Geology and Soils.

However, impacts related to drainage and water quality during construction would be minimized through the implementation of BMPs as required by the SMC and NPDES Construction General Permit program. In addition, Sunnyvale Playbook Update/Game Plan 2028 projects would be in accordance with the Sunnyvale General Plan Land Use and Transportation Element, which includes Policies LT-1.10, LT-9.19, and LT-10.5 for the protection and preservation of wetlands, creeks, and streams within Sunnyvale.83 Furthermore, Sunnyvale Playbook Update/Game Plan 2028 Play 4.3

83 Sunnyvale, City of. 2022. General Plan Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed October 2023).

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Hydrology and Water Quality

Final Initial Study–Negative Declaration 71
directs the City to implement the Green Stormwater Infrastructure Plan, which would improve drainage and water quality. As such, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not substantially alter drainage patterns or impervious surfaces within the City. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in a less-than-significant impact related to erosion, flooding, and polluted runoff.
d. Would the project result in flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Portions of Sunnyvale are located within the 100-year floodplain designated by Federal Emergency Management Agency (FEMA). Therefore, areas of Sunnyvale are at risk of flooding.84 The Sunnyvale Playbook Update/Game Plan 2028 does not propose specific development or land use designation changes but rather emphasizes strategies intended to reduce GHG emissions and increase sustainability in Sunnyvale. Implementation of several Sunnyvale Playbook Update/Game Plan 2028 Plays may promote infrastructure development and small-scale construction activities within Sunnyvale. As described under Response 10c., Sunnyvale Playbook Update/Game Plan 2028 projects would not impede or redirect flood flows, and as discussed under Response 9a. and 9b. in Section 9, Hazards and Hazardous Materials, Sunnyvale Playbook Update/Game Plan 2028 projects would generally not involve the regular use or storage of hazardous materials with the exception of battery energy storage that include the storage of lithium-ion batteries. Future Sunnyvale Playbook Update/Game Plan 2028 projects, such as battery energy storage facilities, would be reviewed for compliance with the applicable local and State regulations related to flooding and hazardous materials use and storage, including the SMC and CBC standards for construction within flood-prone areas. SMC Chapter 16.62 regulates development in flood-prone areas and requires new structures built within a FEMA-designated Special Flood Hazard Area to meet requirements for flood resistance. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 would result in a less-than- significant impact related to flooding and inundation resulting in release of pollutants. e. Would the project conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
The CEQA GHG Emissions Thresholds is a guidance document and does not propose development or changes to land use and zoning designations. Thus, implementation of the CEQA GHG Emissions Thresholds would not result in construction or operational impacts related to obstruction of a water quality control plan. The Sunnyvale Playbook Update/Game Plan 2028 would not include projects that would result in the direct extraction of groundwater. Rather, the Sunnyvale Playbook Update/Game Plan 2028 encourages water savings through Play 4.2 and sustainable stormwater management and groundwater recharge through Play 4.3. The Sunnyvale Playbook Update/Game Plan 2028 would not interfere with or obstruct implementation of water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with a water quality control plan or sustainable groundwater management plan.

84 Sunnyvale, City of. 2011. General Plan Safety and Noise Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/602/638370338402370000 (accessed February 2024).

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72 Cumulative Impacts
The cumulative projects scenario is the population, employment, and households forecasts identified in the supporting documentation for the Sunnyvale Playbook Update/Game Plan 2028, based on demographic data contained in Plan Bay Area 2040 (refer to Table 5). As a guidance document, the CEQA GHG Emissions Thresholds would not result in any development or land use changes that could result in cumulative impacts related to hydrology. Future Sunnyvale Playbook Update/Game Plan 2028-related projects, in combination with other cumulative projects that occur to accommodate the City’s anticipated population, employment, and housing growth, are not anticipated to contribute to cumulative hydrology and water quality impacts with adherence to applicable Sunnyvale General Plan policies and local, State, and federal regulatory requirements.

Implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would not contribute to an increase in development but could result in infrastructure development projects and minor construction activities. As such, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and other cumulative projects could have incremental impacts related to hydrology and water quality, such as erosion and sedimentation due to construction activities. However, the Sunnyvale Playbook Update/Game Plan 2028’s contribution to such impacts would be minor and temporary, and the Sunnyvale Playbook Update/Game Plan 2028 would have the long-term effect of reducing water use and improving stormwater capture and groundwater recharge. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in an overall less-than-significant cumulative impact related to hydrology and water quality.

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Land Use and Planning

Final Initial Study–Negative Declaration 73
11 Land Use and Planning

Potentially
Significant
Impact
Less than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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? □ □ □ ■
a. Would the project physically divide an established community? The Sunnyvale Playbook Update/Game Plan 2028 is a policy document containing strategies that are consistent with the Sunnyvale General Plan and does not include actions or specific development projects that would divide an established community. Sunnyvale Playbook Update/Game Plan 2028 Play 3.2 facilitates the provisioning of new bike and pedestrian infrastructure and amenities, improved public transit connectivity, and enhanced safety and active transportation throughout the community. Such actions would help to increase connectivity within the Sunnyvale community.

Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to division of an established community. b. Would the project 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?
The Sunnyvale Playbook Update/Game Plan 2028 is a policy document and does not propose development or changes to land use and zoning designations and contains strategies that are consistent with the Sunnyvale General Plan, including General Plan Land Use and Transportation Element Policy LT-2.2 and Action LT-2.2a that direct the City to maintain and implement a CAP for GHG reduction and green development.85 Nonetheless, implementing the Sunnyvale Playbook Update/Game Plan 2028 would require some modification of existing policies, including developing and implementing new programs, and projects, or modifying existing ones. For example, Sunnyvale Playbook Update/Game Plan 2028 Play 2.2 includes adoption of new building ordinance to require building electrification for existing developments. Play 3 would include adoption of an ordinance to phase out the use of gasoline- and diesel-powered off-road equipment. In addition, Play 4.2 would involve the adoption of new plans and policies related to water efficiency, recycled water, and water efficient landscaping. In order to implement these Plays, the SMC and other applicable City documents may need to be amended to reflect new or modified requirements. However, where modifications of existing policies are needed, such as updates to policies related to energy and

85 Sunnyvale, City of. 2022. Land Use and Transportation Element. https://www.sunnyvale.ca.gov/home/showpublisheddocument/596/638130909277830000 (accessed December 2023).

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Climate Action Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds

74 water, the Sunnyvale Playbook Update/Game Plan 2028 Plays would result in greater avoidance or reduction of environmental effects. Furthermore, future updates to existing policies or via new proposed policies would require a separate public review process and environmental review in accordance with applicable local and State regulations. Therefore, the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no impact related to consistency with current land use plans or policies.

Future Sunnyvale Playbook Update/Game Plan 2028-related projects and actions would be reviewed for consistency with the Sunnyvale General Plan, SMC, and other applicable regulatory land use actions prior to approval and would have the overall effect of greater avoidance or reduction of environmental effects. Therefore, implementation of the Sunnyvale Playbook Update/Game Plan 2028 and CEQA GHG Emissions Thresholds would result in no cumulative impact related to land use.

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Sunnyvale City CouncilJune 25, 2024

Sunnyvale City Council
June 25, 2024