Sunnyvale City Council
August 27, 2024

ENVIRONMENTAL CHECKLIST/ADDENDUM
Intuitive North Site Modification Project
Prepared for:

City of Sunnyvale
June 2024
Attachment 13

ENVIRONMENTAL CHECKLIST/ADDENDUM
Intuitive North Site Modification Project
Prepared for:

City of Sunnyvale
Community Development
Department, Planning Division
465 W. Olive Avenue
Sunnyvale, California 94086
Contact:

Julia Klein
Principal Planner
408.730.7463
Prepared by:

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

Kari Zajac
Project Manager
916.732.3329
June 2024
20220117.01
Attachment 13

City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 1 Addendum to the
Lawrence Area Station Plan Update/Intuitive
Surgical Corporate Campus Project
Final Subsequent Environmental Impact Report
June 2024
State Clearinghouse No. 2019012022

BACKGROUND AND ACTION TRIGGERING THE ADDENDUM
This document serves as an addendum to the Final Subsequent Environmental Impact Report (LSAP Update SEIR) for the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project. This addendum evaluates an amendment to the Intuitive Surgical Corporate Campus Project (ISI Project). This analysis evaluates the major modification to the Special Development Permit and Development Agreement for the North Site (945-955 Kifer Road) that would remove the approved underground parking and relocate this parking to a new above- grade parking structure on the adjacent site to the east at 2900 Semiconductor Drive (Extension Site) that is owned by Intuitive Surgical (ISI), but in the City of Santa Clara (referred to as the Intuitive North Site Modification Project or project). Also included in the project are minor architectural changes to the approved north building and a different geometry for the approved intersection and private driveway leading to the loading area and new garage. The City of Sunnyvale permit process is a modification to the Special Development Permit and Development Agreement for the ISI North Site. A separate approval process through the City of Santa Clara, that includes an Architectural Review Permit and Use Permit, is required for the construction of the parking structure in their jurisdiction. In both jurisdictions, ministerial building permits would be required to undertake construction.

As the lead agency under the California Environmental Quality Act (CEQA), the City of Sunnyvale has determined that, in accordance with Section 15164 of the CEQA Guidelines, the proposed changes to the North Site and relocation of the parking garage to the Extension Site require minor technical changes or additions to the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project Final LSAP Update SEIR but not of the conditions described in Section 15162 calling for the preparation of a subsequent EIR or negative declaration have occurred, and therefore preparation of an addendum is appropriate.

PREVIOUS ENVIRONMENTAL ANALYSES
The environmental process for the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project involved the preparation of the following documents that are relevant to the consideration of the proposed Intuitive North Site Modification Project.
 Draft EIR for the Lawrence Station Area Plan, May 2016  Final EIR for the Lawrence Station Area Plan, November 2016  Draft SEIR for the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project and Appendices, May 2021;
 Final LSAP Update SEIR for the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project, May 2021;
 CEQA Findings of Fact and Statement of Overriding Considerations for the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project, August 2021; Attachment 13

Administrative Draft – For Internal Review Only Ascent
City of Sunnyvale
2 Intuitive North Site Modification Project Environmental Checklist  Mitigation Monitoring and Reporting Program for the Lawrence Area Station Plan Update/Intuitive Surgical Corporate Campus Project, August 2021.

CALIFORNIA ENVIRONMENTAL QUALITY ACT GUIDELINES REGARDING

AN ADDENDUM TO AN ENVIRONMENTAL IMPACT REPORT
Altered conditions, changes, or additions to a project that require discretionary approval and occur after certification of an EIR may require additional analysis under CEQA. The legal principles that guide decisions regarding whether additional environmental documentation is required are provided in the CEQA Guidelines, which establish three mechanisms to address these changes: a subsequent environmental impact report (SEIR), a s upplement to an EIR, and an Addendum to an EIR.

Section 15162 of the CEQA Guidelines describes the conditions under which a SEIR would be prepared. In summary, when an EIR has been certified for a project, no Subsequent EIR shall be prepared for that project unless the lead agency determines, on the basis of substantial evidence in light of the whole record, one or more of the following:
(1) Substantial changes are proposed in the project which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified effects;
(2) Substantial changes occur with respect to the circumstances under which the project is undertaken which will require major revisions of the previous EIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or (3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete, shows any of the following:
(A) The project will have one or more significant effects not discussed in the previous EIR; (B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; (C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measures or alternatives; or
(D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

Section 15163 of the CEQA Guidelines states that a lead agency may choose to prepare a supplement to an EIR rather than a Subsequent EIR if:
(1) any of the conditions described above for Section 15162 would require the preparation of a SEIR; and (2) only minor additions or changes would be necessary to make the previous EIR adequately apply to the project in the changed situation.

According to section 15164 of the CEQA Guidelines, a lead agency or a responsible agency must prepare an addendum to a previously certified EIR if some changes or additions to the EIR are necessary but none of the conditions described in section 15162 of the CEQA Guidelines calling for preparation of a subsequent EIR have occurred.

Attachment 13

Ascent Administrative Draft – For Internal Review Only
City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 3 This addendum evaluates the proposed Intuitive North Site Modification Project, which would be a change relative to what is described and evaluated in the Lawrence Area Station Plan Update/Intuitive Surgical Campus SEIR, and provides substantial evidence that none of the conditions in described in section 15162 of the CEQA Guidelines have occurred. This addendum is organized as an environmental checklist, and is intended to evaluate all environmental topic areas for any changes in the project, the circumstances under which it would be taken, or the presence of new information of substantial importance that could not have been known at the time of the Final LSAP Update SEIR, as compared to the certified Final LSAP Update SEIR (which includes the Draft SEIR), and if so determine whether such changes, new information, or changed circumstances could cause new or substantially more severe significant impacts than covered in the certified EIR or show new feasible mitigation measures or alternatives that would substantially reduce significant project impacts but that the project proponent declines to adopt. As explained below, the purpose of this checklist is to evaluate the checklist categories in terms of any “changed condition” (i.e., changed circumstances, project changes, or new information of substantial importance) that may result in a different environmental impact significance conclusion from the SEIR or new feasible mitigation measures or alternatives that would reduce impacts but that the project proponent declines to adopt. The column titles of the checklist have been modified from the CEQA Guidelines Appendix G presentation to help answer the questions to be addressed pursuant to CEQA Section 21166 and CEQA Guidelines Section 15162, 15163, and 15164.

Attachment 13

Administrative Draft – For Internal Review Only Ascent
City of Sunnyvale
4 Intuitive North Site Modification Project Environmental Checklist This page intentionally left blank.

Attachment 13

Administrative Draft – For Internal Review Only
City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist i

TABLE OF CONTENTS
Section Page
1 INTRODUCTION AND PROJECT HISTORY ................................ ................................ ................................ .......................... 1-1 2 PROJECT DESCRIPTION ................................ ................................ ................................ ................................ ........................... 2-1

2.1 Project Overview ................................................................................................................................................................ 2-1

2.2 Project Location ................................................................................................................................................................. 2-1

2.3 Existing Setting ................................................................................................................................................................... 2-1

2.4 Project Objectives ............................................................................................................................................................. 2-4

2.5 Construction Activities .................................................................................................................................................. 2-15

2.6 Required Actions ............................................................................................................................................................ 2-15 3 ENVIRONMENTAL CHECKLIST FOR SUBSEQUENT ENVIRONMENTAL REVIEW ................................ ...................... 3-1

3.1 Explanation of Checklist Evaluation Categories ...................................................................................................... 3-1

3.2 Discussion and Mitigation Sections ........................................................................................................................... 3-3

3.3 Addendum Approach ..................................................................................................................................................... 3-3 4 ENVIRONMENTAL CHECKLIST................................ ................................ ................................ ................................ .............. 4-1

4.1 Aesthetics ............................................................................................................................................................................. 4-1

4.2 Agriculture and Forest Resources ............................................................................................................................... 4-6

4.3 Air Quality ........................................................................................................................................................................... 4-8

4.4 Biological Resources ...................................................................................................................................................... 4-20

4.5 Cultural Resources ......................................................................................................................................................... 4-28

4.6 Energy................................................................................................................................................................................. 4-32

4.7 Geology and Soils .......................................................................................................................................................... 4-37

4.8 Greenhouse Gas Emissions ........................................................................................................................................ 4-44

4.9 Hazards and Hazardous Materials ........................................................................................................................... 4-53

4.10 Hydrology and Water Quality .................................................................................................................................... 4-65

4.11 Land Use and Planning ................................................................................................................................................. 4-73

4.12 Mineral Resources .......................................................................................................................................................... 4-76

4.13 Noise ................................................................................................................................................................................... 4-77

4.14 Population and Housing .............................................................................................................................................. 4-85

4.15 Public Services ................................................................................................................................................................. 4-87

4.16 Recreation ......................................................................................................................................................................... 4-90

4.17 Transportation ................................................................................................................................................................. 4-92

4.18 Tribal Cultural Resources ........................................................................................................................................... 4-100

4.19 Utilities and Service Systems .................................................................................................................................... 4-103

4.20 Wildfire ............................................................................................................................................................................. 4-109

4.21 Mandatory Findings of Significance ........................................................................................................................ 4-111 5 LIST OF PREPARERS ................................ ................................ ................................ ................................ ................................ ..5-1

5.1 List of Preparers ................................................................................................................................................................. 5-1 6 REFERENCES ................................ ................................ ................................ ................................ ................................ ............... 6-1 Appendices
A Biological Resources Records Search
B Project Site Plans
C Noise Calculations
Attachment 13

Table of Contents Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
ii Intuitive North Site Modification Project Environmental Checklist Figures
Figure 2-1 Project Vicinity ................................................................................................................................................................... 2-2 Figure 2-2 Project Site .......................................................................................................................................................................... 2-3 Figure 2-3 Central Expressway and Project Driveway ............................................................................................................... 2-7 Figure 2-4 Proposed Parking Plan ................................................................................................................................................... 2-9 Figure 2-5 Illustrative Parking Garage North and South Renderings ................................................................................. 2-11 Figure 2-6 Illustrative Parking Garage East and West Rendering ....................................................................................... 2-13 Figure 4-1 Overall Site Plan .............................................................................................................................................................. 4-61

Tables
Table 2-1 Comparison of Proposed Parking Structure Modifications to Currently Approved Project .................. 2-6 Table 4.3-1 National and California Ambient Air Quality Standards ..................................................................................... 4-9 Table 4.3-2 Attainment Status Designations for Santa Clara County .................................................................................. 4-10 Table 4.3-3 Project Consistency with Applicable Control Strategies of 2017 Clean Air Plan ....................................... 4-12 Table 4.8-1 City of Sunnyvale 2020 Greenhouse Gas Emissions Inventory ...................................................................... 4-46 Table 4.8-2 City of Santa Clara 2016 Greenhouse Gas Emissions Inventory .................................................................... 4-46 Table 4.8-3 Project Consistency with the 2019 Sunnyvale Climate Action Playbook .................................................... 4-49 Table 4.8-4 Proposed Extension Site Project Consistency with the City of Santa Clara Climate Action Plan ........ 4-51 Table 4.13-1 City of Santa Clara General Plan Noise Standards (Ldn, CNEL) ....................................................................... 4-78 Table 4.13-2 City of Santa Clara City Code Exterior Noise Limits (dBA) ............................................................................... 4-78

Attachment 13

Ascent Administrative Draft – For Internal Review Only List of Abbreviations City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist iii

LIST OF ABBREVIATIONS
2017 Clean Air Plan 2017 Clean Air Plan: Spare the Air, Cool the Climate 2022 Scoping Plan Final 2022 Scoping Plan for Achieving Carbon Neutrality

AB Assembly Bill
ABAG Association of Bay Area of Governments
AFY acre feet per year
APN Assessor’s Parcel Numbers

BMP best management practices

CAA California Clean Air Act
CAAQS California Ambient Air Quality Standards
Cal/OSHA California Occupational Safety and Health Agency CalMod Caltrain Modernization Program
CAP climate action plan
CCA community choice aggregation
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
City City of Sunnyvale
CNDDB California Natural Diversity Database
CNPS California Native Plant Society
CO carbon monoxide

dB decibels
dBA A-weighted decibels

EIR Environmental Impact Report
EO Executive Order
ESA Environmental Site Assessment

FAR Floor Area Ratio

GHG greenhouse gas
Attachment 13

List of Abbreviations Administrative Draft – For Internal Review Only Ascent Environmental City of Sunnyvale
iv Intuitive North Site Modification Project Environmental Checklist GWP global warming potential

HPRD high-performance renewable diesel

in/sec inches per second
IPaC Inventory of Rare Plants
ISI Site Intuitive Surgical campus
ISI Intuitive Surgical

Justification Report Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts

lbs pounds
L
eq energy-equivalent noise level
LID Low Impact Development
Lmax maximum noise level (the maximum instantaneous noise level during a specific period) LOS level of service
LSAP Lawrence Station Area Plan
LUTE Land Use and Transportation Element

MRP Municipal Regional Stormwater Permit
MTC Metropolitan Transportation Commission’s
MTCO
2e metric tons of carbon dioxide equivalent
MTCO2e/yr/SP metric tons of carbon dioxide equivalent per year per service population

NAAQS National Ambient Air Quality Standards
NO
X nitrogen oxides
NPDES National Pollutant Discharge Elimination System

PG&E Pacific Gas and Electric Company
Playbook Climate Action Playbook
PM
10 respirable particulate matter with an aerodynamic resistance diameter of 10 micrometers or less
PM2.5 fine particulate matter with an aerodynamic resistance diameter of 2.5 micrometers or less PPV peak particle velocity
PRC Public Resources Code Section

Attachment 13

Ascent Administrative Draft – For Internal Review Only List of Abbreviations City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist v REC Recognized Environmental Conditions
ROG reactive organic gases
RTP/SCS Regional Transportation Plan/Sustainable Communities Strategy RWQCB regional water quality control board

SB Senate Bill
SDP Special Development Permit
SEIR Subsequent Environmental Impact Report
SFBAAB San Francisco Bay Area Air Basin
SVCE Silicon Valley Clean Energy
SVP Silicon Valley Power
SWPPP s tormwater pollution prevention plan

TAC toxic air contaminants
TDM T ransportation Demand Management
TPA Transit Priority Area
TPP Transit Priority Project

USFWS United States Fish and Wildlife Service

VCP vitrified clay pipe
VMT vehicle miles traveled
VOC volatile organic compound

Attachment 13

List of Abbreviations Administrative Draft – For Internal Review Only Ascent Environmental City of Sunnyvale
vi Intuitive North Site Modification Project Environmental Checklist This page intentionally left blank.

Attachment 13

Administrative Draft – For Internal Review Only
City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 1-1 1 INTRODUCTION AND PROJECT HISTORY
On December 6, 2016, the Sunnyvale City Council adopted the 319-acre Lawrence Station Area Plan (LSAP) for development of up to 2,323 new residential units and 1.2 million square feet of new office/research and development (R&D) uses. The City of Sunnyvale (City) prepared an Environmental Impact Report (LSAP EIR) (State Clearinghouse No. 2013082030) for the LSAP that evaluated the environmental impacts associated with development of the entire plan area based on the land use and zoning designations established in the LSAP (City of Sunnyvale 2016). Following LSAP adoption, the City Council directed staff to update the LSAP. The LSAP Update included an increase in housing potential within the LSAP, expansion of the western LSAP boundary, and a Sense of Place Plan that would function as a policy document for LSAP area circulation, open space, and streetscape improvements. A Subsequent Environmental Impact Report (LSAP Update SEIR) was prepared for the LSAP Update and the Intuitive Surgical Corporate Campus (described below) (City of Sunnyvale 2021), and the City Council certified the LSAP Update SEIR and approved the LSAP Update and the Intuitive Surgical Corporate Campus Project on September 14, 2021.

The LSAP Update expanded the LSAP boundary west on Kifer Road to include the Intuitive Surgical (ISI) corporate campus (ISI Site). The ISI Site encompasses three sites (containing four parcels) located at the western portion of the original LSAP boundary. ISI acquired these sites with the intent to expand and unify its operations adjacent to ISI’s existing headquarters in Sunnyvale at 1020 Kifer Road. The ISI Site contains four parcels (932, 945, 950, and 955 Kifer Road) on 32.4 acres located on the north and south sides of Kifer Road. To distinguish between the two areas bisected by Kifer Road, the proposed ISI Project Site was referred to as North Site and South Site in the LSAP Update SEIR. The approved development for the ISI Site consists of approximately 1,211,000 gross square feet of office/R&D development, including amenity space. ISI would demolish approximately 172,7 06 square feet of existing industrial development (of which approximately 105,000 square feet is currently being used) on the ISI Site, resulting in approximately 1,038,294 square feet of net new Office/R&D area. The net new square feet was assumed to be 1,106,000, in the LSAP Update SEIR. The LSAP Update SEIR evaluated the ISI Project at the project level, while evaluating other potential future development in the LSAP area at a program level.

As analyzed in the LSAP Update SEIR, the 15.6-acre North Site (945/955 Kifer Road) would contain an approximately 364,000 square foot office headquarters and visitor experience center, new multi-purpose amenity building, outdoor sports fields and courts, an outdoor dining area, and two levels of underground parking. The 16.8 -acre South Site (932 and 950 Kifer Road) would include an 847,000 square feet, three-story manufacturing and research and development facility. The basement level of the facility would include a covered loading dock, manufacturing storage, and service space. The South Site would also include a six-level, above-grade parking garage in a separate structure.

In September of 2021, the City approved a Special Development Permit (permit no. 2019 -7557), Vesting Tentative Parcel Map, and Development Agreement for the ISI Project. As of February 2024, the South Site development is currently under construction. Construction activities have not yet been initiated on the North Site.

The proposed Intuitive North Site Modification Project (project) proposes to modify the proposed development on the North Site of the approved ISI Project. The proposed modification would remove the approved underground parking and relocate this parking to a new six-level above-grade parking structure on the adjacent site to the east that is owned by ISI (2900 Semiconductor Drive), but is located outside of the City of Sunnyvale LSAP in the City of Santa Clara, which requires separate discretionary review and approval.

Also included in the project are minor changes on the North Site, including:
 Addition of an internal courtyard in the middle of the North Site building footprint, which reduces the gross building area from 364,000 to 358,000 square feet;
 Relocation of the loading area approximately 100 feet to the south;  Different geometry for the approved Kifer Road intersection across from the 1020 Kifer Road site and private driveway leading to the North Site loading area and proposed new parking structure at 2900 Semiconductor Drive;
Attachment 13

Introduction and Project History Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
1-2 Intuitive North Site Modification Project Environmental Checklist  Design refinements to the approved pedestrian bridge across Kifer Road, linking together the North and South Sites at the second floor;
 Relocation of the employee restaurant from the west to east side of the North Site;  Extension of roof trellis element along the edges of the building;  Installation of rooftop screening units with associated screening structures;  Change spandrel glazing at the second and third floors to vision (transparent) glazing; and Increase 12” spandrel glazing to 24” consistently throughout the façade.

The City of Sunnyvale permit process is a modification to the Special Development Permit (SDP) and a Development Agreement amendment for the ISI Project. The City of Santa Clara’s discretionary approvals include an Architectural Review Permit and Use Permit for the construction of the parking structure on the adjacent 2900 Semiconductor Drive property in Santa Clara.

The 2016 LSAP EIR and 2021 LSAP Update SEIR were prepared at the program “first-tier” level of environmental review of the LSAP and LSAP Update, consistent with the requirements of the California Environmental Quality Act (CEQA) Sections 15152 and 15168, and the 2021 LSAP Update SEIR also was prepared as a project-specific EIR for the ISI Project. The project-level analysis prepared for the ISI Project considered the potential environmental impacts associated with development of the ISI Project on the ISI Site. The North Site Modification Project is a modification to an approved project being implemented under the LSAP.

The LSAP EIR and LSAP Update SEIR acknowledged that subsequent development of the LSAP area would occur in multiple years and phases. This North Site Modification Project is evaluated to determine whether it would require changes or additions to the LSAP Update SEIR but none of the conditions described in Section 15162 of the CEQA Guidelines calling for preparation of a subsequent EIR have occurred. Should the evaluation show that any of the conditions described in Section 15162 of the CEQA Guidelines have occurred, additional environmental review through the subsequent review provisions of CEQA for changes to previously reviewed and approved projects may be warranted (see CEQA Guidelines Section 15164, subdivision (a) [referring to CEQA Guidelines Section 15162]).

Consistent with the process described, the City is evaluating the project – including both the Intuitive North Site Modification application and the proposed garage in the City of Santa Clara - to determine whether subsequent environmental review is required. This environmental checklist has been prepared to determine whether the environmental impacts of the project are within the scope of the LSAP Update SEIR or if the changes in the project, changed circumstances, or new information would result in new or substantially more severe significant environmental impacts, or newly feasible or considerably different mitigation measures or alternatives that would reduce significant impacts but ISI declines to adopt them, as compared to those considered in the LSAP EIR and LSAP Update SEIR. As further described in the analysis in the environmental checklist, none of the circumstances identified above would occur and the City has elected to prepare an addendum consistent with CEQA Guidelines Section 15164.

Attachment 13

Administrative Draft – For Internal Review Only
City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-1 2 PROJECT DESCRIPTION

2.1 PROJECT OVERVIEW
The proposed Intuitive North Site Modification Project (project) includes a m ajor modification to the Special Development Permit and Development Agreement amendment for the North Site (945-955 Kifer Road) of the approved Intuitive Surgical (ISI) Corporate Campus that would remove the approved underground parking and relocate this parking to a new above-grade parking structure on the adjacent site to the east at 2900 Semiconductor Drive, in the City of Santa Clara, that is owned by ISI. Also included in the project are minor architectural changes to the approved north building and a different geometry for the approved intersection and private driveway leading to the loading area and new garage. The City of Sunnyvale permit process is a modification to the Special Development Permit and Development Agreement for the ISI North Site. A separate permit process through the City of Santa Clara, that includes Architectural Review Permit and Use Permit approval, is required for the construction of the parking structure in its jurisdiction. Both jurisdictions will require ministerial building permits for construction.

2.2 PROJECT LOCATION
The project site is within the City of Sunnyvale and City of Santa Clara and consists of two separate sites (Figure 2-1).

The western site is located at 945/955 Kifer Road on an approximately 15.6-acres in the City of Sunnyvale (Assessor’s Parcel Numbers [APN] 205-40-002 and 205-40-001) (North Site). The extension of the ISI Project to the east is located at 2900 Semiconductor Drive on approximately 2.5 acres in the City of Santa Clara (APN 205 -39-028) (Extension Site).

See Figure 2-2 for the project site and location.

2.3 EXISTING SETTING
The North Site (945/944 Kifer Road) in the City of Sunnyvale is bound by Kifer Road to the south, the City’s boundary with City of Santa Clara and an industrial shipping and receiving facility to the east, various small commercial and light industrial buildings to the west, and Central Expressway to the north. The North Site contains a private sports and recreation complex, a gymnasium, a baseball field, a soccer field, an amphitheater, a volleyball court, a children’s play area, a tented barbeque area, a recently filled-in former concrete manmade lake, portable bathroom and shower trailers, a parking area, a groundwater monitoring well, and landscaped areas with mature trees. The recreational facilities and parking lot are currently utilized by ISI employees.

The adjacent parcel (Extension Site) to the east (2900 Semiconductor Drive) in the City of Santa Clara is bound by Central Expressway to the north, a private access drive, an industrial/office building and Kifer Road to the south, 945/955 Kifer Road (North Site) to the west, and industrial/office buildings to the east. The Extension Site contains a paved surface parking lot with varied species of mature trees that provide shade to the parking lot.

The project site is within a Transit Priority Area (TPA) and partially within a Priority Development Area (PDA) a s designated by the Association of Bay Area of Governments (ABAG) and Metropolitan Transportation Commission’s (MTC) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) ( ABAG and MTC 2021). A TPA is an
area within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program or applicable RTP (Public Resources Code Section [PRC] 21099[a][7]). Aesthetic and parking impacts of a residential, mixed-use residential, or employment center project on an infill site within a TPA are not considered significant impacts on the environment under CEQA. (PRC Section 21099(d)(1)). An “employment center project” means a project located on property zoned for commercial uses with a floor area ratio of no less than 0.75. An “infill site” is a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses.

Attachment 13

Project Description Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
2-2 Intuitive North Site Modification Project Environmental Checklist

Source: prepared by Ascent Environmental in 2023.

Figure 2-1 Project Vicinity
Attachment 13

Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-3

Source: prepared by Ascent in 2023.

Figure 2-2 Project Site
Attachment 13

Project Description Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
2-4 Intuitive North Site Modification Project Environmental Checklist Under the RTP/SCS, a PDA is an area within an existing community that local city or county governments have identified and approved for future growth (MTC 2018). The Extension Site in the City of Santa Clara is in a PDA.

The City’s General Plan land use designation for the North Site is Transit Mixed-Use, and the site is zoned M-S/LSAP 60% – LSAP Industrial and Service 60% Floor Area Ratio (FAR). Allowed uses under this zoning district include industrial, office, research and development uses up to 60 percent FAR and smaller -scale retail and service uses.

Residential uses are prohibited. The maximum building height is 85 feet.

The Extension Site located in the City of Santa Clara has a General Plan designation of Medium Density Residential and is zoned Light Industrial (ML). The Medium Density Residential Land Use is intended for residential development at densities ranging from 20 to 36 units per gross acre. This density range accommodates a variety of housing types.

The Light Industrial zoning district permits general industrial development, and is intended to accommodate industries operating substantially within an enclosed building. The maximum FAR is 0.45 and maximum building height is 70 feet for new development.

2.4 PROJECT OBJECTIVES
The ISI Project objectives from the LSAP Update SEIR were:
 Create an innovative campus that unifies ISI’s workforce in connected buildings to promote creativity and collaboration, and to reduce daily trips between existing ISI buildings and the new campus.  Construct a project that accommodates ISI’s existing needs in proximity to its existing employment base and allows for its long-term continued presence in the City.  Fulfill the LSAP goals of increasing transit ridership and promoting economic, social, and environmental sustainability through integrated design and development of a sustainable campus in proximity to the Lawrence Caltrain Station.
 Promote transit and active commute modes through thoughtful site planning coupled with a robust Transportation Demand Management (TDM) program to reduce daily vehicle trips. The TDM program will provide amenities such as employee shuttle services between ISI buildings and public transit, extensive bicycle parking, showers and lockers, free Caltrain Go Passes, rideshare matching services, flexible work schedule programs and dedicated carpool spaces.
 Provide on-site amenities to promote ISI employees’ health and well-being, reduce daily vehicle trips, and create a strong sense of place.
 Create a campus design that reflects ISI’s innovative technology.  Develop the campus over time in response to ISI’s needs.  Achieve the appropriate security and privacy required for the invention and manufacture of new surgical products and technologies by limiting public access to certain areas within the new campus.

The objectives for the proposed revision to the ISI Project are the following:
 Maintain open space on the North Site while providing adequate parking to meet the needs of an office/R&D facility;
 Reduce soil disturbance and associated construction emissions by reducing excavation work; and  Increase operational efficiencies through appropriately locating employee amenities.

2.4.1 Project Background
As analyzed in the LSAP Update SEIR, the ISI Project would include a North and South Site. The 15.6-acre North Site (945/955 Kifer Road) would contain a 364,000 square-foot office headquarters and visitor experience center, new Attachment 13

Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-5 multi-purpose amenity building, outdoor sports fields and courts, an outdoor dining area, and two levels of underground parking including 785 parking spaces. The 16.8-acre South Site (932 and 950 Kifer Road) would include an 847,000 square feet, three-story manufacturing, research, and development facility. The basement level of the facility would include a covered loading dock, manufacturing storage, and service space. The South Site would also include a six-level, above-grade parking garage in a separate structure. As of February 2024, the South Site development is currently under construction. Construction activities have not yet been initiated on the North Site.

The Special Development Permit approval in 2021 (permit no. 2019-7557) included 822 parking spaces (including 37 surface parking spaces) on the North Site, plus an allocation of 115 parking spaces for the North Site in the South Site’s parking structure because there was not sufficient space on the North Site. A total of 1,728 parking spaces were approved on the South Site. Since the original 2021 approval, a Miscellaneous Plan Permit (permit no. 2022-7336) was approved to adjust the parking supply on the South Site based on building refinements since the planning entitlement, notably a reduced South Site building area due to an interior courtyard addition, which was approved under another Miscellaneous Plan Permit (permit no. 2022-7014). The currently approved parking supply on the South Site is 1,675 parking spaces, with 100 parking spaces allotted to the North Site.

Since certification of the LSAP Update SEIR, ISI has purchased the parcel east of the North Site at 2900 Semiconductor Drive (Extension Site). The City boundary between Sunnyvale and Santa Clara is the eastern property line of the North Site.

2.4.2 Proposed Project
The project proposes a major modification to the Special Development Permit and Development Agreement for the North Site of the ISI Project that would remove the approved two levels of underground parking and relocate this parking to a new six-level, above-grade parking structure on the adjacent surface parking lot to the east at 2900 Semiconductor Drive, in the City of Santa Clara, which is owned by ISI. There are no changes to the proposed jurisdictional boundaries of the Cities of Sunnyvale or Santa Clara as part of this project. Also included in the proposal are minor architectural changes to the north building, a different geometry for the private driveway leading from the new signalized intersection at Kifer Road to the loading area in the City of Sunnyvale and new garage in the City of Santa Clara, and improvements to Central Expressway north of both sites. Project components are described in more detail below.

EXTENSION SITE
With the addition of the Extension Site to the east in the City of Santa Clara (2900 Semiconductor Drive), the project includes modifying the plan for the North Site. The project proposes to remove the approved 785 -space underground parking serving the north building and instead build the required parking in a new six -level above- ground parking structure on the Extension Site. There would be a total of 1,183 parking spaces in the parking structure, including 454 electric vehicle charging stations and 714 electric vehicle -capable parking spaces. Of the 1,183 parking spaces, 904 parking spaces would be allocated to support the North Site in the City of Sunnyvale (Figure 2 - 4). The remaining 279 parking spaces would be allocated for the 2900 Semiconductor Drive and 3875 Kifer Road buildings in the City of Santa Clara, which are also owned by ISI. The parking spaces allocated for the buildings in the City of Santa Clara include the replacement of the 300 surface parking spaces on the Extension Site that would be removed to construct the parking structure. The North Site would provide 33 surface parking spaces near Kifer Road, a loss of one space from the 2021 approval due to additional space needed for the required electric vehicle parking spaces. Therefore, a total of 937 parking spaces would serve the North Site. Therefore, the total number of parking spaces serving the ISI Project would remain the same as analyzed in the LSAP Update SEIR.

The proposed parking garage would be six levels and approximately 52 feet in height from the parapet of the garage and 62 feet in height from the solar panels on the roof (Figures 2-4 and 2-5). The garage would be accessible via a private gated access. The parking garage façade would be visually screened architecturally.

Attachment 13

Project Description Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
2-6 Intuitive North Site Modification Project Environmental Checklist When the garage on the Extension Site is complete, 65 of the 100 parking spaces in the South Site garage, intended to support the North Site, would be caged or removed because they would be in excess of the 1,610 parking spaces required for the South Site. With removal of these 65 spaces, there would be no net increase in the overall parking allocation for the project as compared to what was analyzed in the LSAP Update SEIR. In addition to parking updates, the project would include moving the loading dock proposed on the North Site approximately 100 feet south.

As part of development on the Extension Site, ISI would record reciprocal easement and access agreements between parcels or a covenant of easements to the benefit of the City of Sunnyvale to ensure that the reciprocal parking and access rights would be retained or alternative parking arrangements sufficient to meet the City of Sunnyvale’s required parking standards for the North Site building would be implemented. While the Extension Site is associated with the ISI Project, the project does not include any changes to the LSAP boundary or Cities of Sunnyvale or Santa Clara boundaries.

Table 2-1 Comparison of Proposed Parking Structure Modifications to Currently Approved Project Site Characteristics Parking Structure Modifications Parking Structure as Currently Approved Type of Structure Above Grade Parking Structure Underground Parking Structure Location of Structure Extension Site South Site
Levels of Structure Six Levels Two Levels
Number of Parking Spaces 1,183 785
Source: Hellmuth, Obata and Kassabaum, Inc. 2024.

ROADWAY GEOMETRY
The geometry of the previously-approved signalized intersection at 945 Kifer Road would be changed to accommodate the proposed driveway leading to the private parking garage in the City of Santa Clara. The intersection of Kifer Road and the project site would be designed to provide gated access to the site and prevent public through traffic from Central Expressway to Kifer Road.

CENTRAL EXPRESSWAY IMPROVEMENTS
Vehicle access to the new parking structure would be from a private driveway on the north leg of a new signalized intersection on Kifer Road. There would also be a new access point from an existing right -in-right-out ramp intersection on Central Expressway, which has an existing gate that will be removed as part of the project. Vehicles could also access an existing right-out-only on-ramp onto Central Expressway at Semiconductor Drive, which is located on the neighboring parcel with same ownership in the City of Santa Clara. Vehicles would access this on- ramp at Semiconductor Drive from the project site via an access agreement.

The County of Santa Clara Roads and Airports Department requested a feasibility study for lengthening the deceleration and acceleration lanes at the Central Expressway driveway ramps due to the new project trip demands on Central Expressway. The applicant provided a study from Hexagon Transportation Consultants, Inc. (“Hexagon”) dated April 24, 2023. Hexagon concluded that the existing right-turn deceleration lane on Central Expressway (along the frontage in the City of Sunnyvale) is 225 feet long, which is 90 feet short of Caltrans guidelines. They recommend extending the deceleration lane to 315 feet, including a 90-foot bay taper, to meet Caltrans guidelines. The opportunity to extend the acceleration lane (along the City of Santa Clara frontage) is limited, and Hexagon recommends modifying the project frontage, to the extent feasible with the City of Santa Clara’s approval, to accommodate an acceleration lane length of up to 590 feet with a 300-foot transition at the on-ramp on Central Expressway at the project site. The applicant is incorporating these improvements in the proposed project , with an extended deceleration lane of 330 feet, including a 90-foot bay taper.

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Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-7

Source: Hellmuth, Obata & Kassabaum, Inc. 2024.

Figure 2-3 Central Expressway and Project Driveway
Attachment 13

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Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-9

Source: Hellmuth, Obata & Kassabaum, Inc. 2024.

Figure 2-4 Proposed Parking Plan
Attachment 13

Attachment 13

Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-11

Source: Hellmuth, Obata & Kassabaum, Inc. 2024.

Figure 2-5 Illustrative Parking Garage North and South Renderings Attachment 13

Attachment 13

Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-13

Source: Hellmuth, Obata & Kassabaum, Inc. 2024.

Figure 2-6 Illustrative Parking Garage East and West Rendering Attachment 13

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Ascent Administrative Draft – For Internal Review Only Project Description City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 2-15

NORTH SITE DESIGN REFINEMENTS
Refinements to the design of the North Site building are proposed as part of the project to ensure consistency with the building on the South Site. The following design refinements are proposed as part of the project:
 Replace atria and skylights with an internal, open to the sky courtyard in the middle of the North Site building footprint, which reduces the gross building area from approximately 364,000 to approximately 358,000 square feet;  Design refinements to the approved pedestrian bridge across Kifer Road, linking together the North and South Sites at the second floor;
 Relocate the loading dock proposed on the North Site approximately 100 feet south;  Relocate the employee restaurant from the west to east side;  Extension of roof trellis element along the edges of the building;  Install rooftop screening units with associated screening structures;  Change spandrel glazing at the second and third floors to vision (transparent) glazing; and  Increase 12” spandrel glazing to 24” consistently throughout the façade.

2.5 CONSTRUCTION ACTIVITIES
The project is anticipated to be built in sequences over approximately three years, consistent with the schedule evaluated in the LSAP Update EIR. The project would include demolition of the existing surface parking lot on the Extension Site, excavation, site preparation, building construction, and architectural coating. Pile driving would not be required.

2.6 REQUIRED ACTIONS
The project would require the following discretionary actions by the City:
 Approval of a major modification to the Special Development Permit  Development Agreement amendment for the North Site
The Extension Site is located in the City of Santa Clara. Therefore, the City of Santa Clara is a Responsible Agency for the project. The City of Santa Clara would require the following discretionary actions for the project:
 Approval of Architectural Review of the parking structure.  Use Permit approval

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Administrative Draft – For Internal Review Only
City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 3-1 3 ENVIRONMENTAL CHECKLIST FOR

SUBSEQUENT ENVIRONMENTAL REVIEW

3.1 EXPLANATION OF CHECKLIST EVALUATION CATEGORIES
The purpose of this checklist is to evaluate the categories in CEQA Guidelines Appendix G in terms of any “changed condition” (i.e., changed circumstances, substantial project changes, or new information of substantial importance) that may result in environmental impact significance conclusions different from those found in the 2021 LSAP Update SEIR (referred to as “LSAP Update SEIR”). As defined in Section 15162(a)(3) of the CEQA Guidelines new information of substantial importance is when any of the following can be shown:

A) A project will have one or more significant effects not discussed in the previous EIR or negative declaration; B) Significant effects previously examined will be substantially more severe than shown in the previous EIR; C) Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
D) Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

The row titles of the checklist include the full range of environmental topics, as presented in Appendix G of the CEQA Guidelines. The column titles of the checklist have been modified from the Appendix G presentation to help answer the questions to be addressed pursuant to CEQA Section 21166 and CEQA Guidelines Section 15162. A “no” answer does not necessarily mean that there are no potential impacts relative to the environmental category, but that there is no change in the condition or status of the impact because it was analyzed and addressed with mitigation measures in the LSAP EIR or LSAP Update SEIR. For instance, the environmental categories might be answered with a “no” in the checklist because the impacts associated with the project were adequately addressed in the LSAP Update SEIR, and the environmental impact significance conclusions of the LSAP Update SEIR remain applicable. The purpose of each column of the checklist is described below.

3.1.1 Where Impact was Analyzed
This column provides a cross-reference to the pages of the LSAP Update SEIR (including the Draft SEIR and Final SEIR) where information and analysis may be found relative to the environmental issue listed under each topic.

3.1.2 Do Proposed Project Changes Involve New or Substantially More Severe Significant Impacts?
Pursuant to Section 15162(a)(1) of the CEQA Guidelines, this column indicates whether there have been s ubstantial changes proposed in the project that would require major revisions of the LSAP Update SEIR due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.

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Environmental Checklist for Supplemental Environmental Review Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
3-2 Intuitive North Site Modification Project Environmental Checklist

3.1.3 Any Changes in Circumstances Involving New or Substantially More Severe Significant Impacts?
Pursuant to Section 15162(a)(2) of the CEQA Guidelines, this column indicates whether there have been changes to the circumstances under which the project is undertaken that have occurred subsequent to the prior environmental documents, which would result in the current project having new significant environmental impacts that were not considered in the prior environmental documents or having substantial increases in the severity of previously identified significant impacts.

3.1.4 Any New Information Of Substantial Importance?
Pursuant to Section 15162(a)(3)(A-D) of the CEQA Guidelines, this column indicates whether new information of substantial importance which was not known and could not have been known with the exercise of reasonable diligence at the time the previous environmental documents were certified as complete is available, requiring an update to the analysis of the previous environmental documents to verify that the environmental conclusions and mitigation measures remain valid. New information of substantial importance is new information showing that: (A) the project will have one or more significant effects not discussed in the prior environmental documents; or (B) that significant effects previously examined will be substantially more severe than shown in the prior environmental documents; or (C) that mitigation measures or alternatives previously found not to be feasible would in fact be feasible and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or (D) that mitigation measures or alternatives which are considerably different from those analyzed in the prior environmental documents would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative. If there is new information of substantial importance, the question would be answered “yes” requiring the preparation of a subsequent EIR or supplement to the EIR. However, if the additional analysis completed as part of this Environmental Checklist Review finds that there is no new information of substantial importance and the conclusions of the prior environmental documents remain the same and no new significant impacts are identified, or identified significant environmental impacts are not found to be substantially more severe, the question would be answered “no.” This column also is answered “no” if there are no mitigation measures or alternatives previously found not to be feasible that would in fact be feasible and would substantially reduce one or more significant effects of the project or there are such mitigation measures or alternatives but the project proponents agree to adopt them. Similarly, this column is answered “no” if there are no mitigation measures or alternatives that are considerably different from those analyzed in the previous EIR that would substantially reduce one or more significant effects on the environment or there are such measures or alternatives and the project proponents agree to adopt them. An answer of “no” means no additional EIR documentation (supplement to the EIR or subsequent EIR) would be required.

3.1.5 Do Prior Environmental Documents Mitigations
Address/Resolve Impacts?
This column indicates whether the prior environmental documents and adopted CEQA Findings require mitigation measures to address effects in the related impact category. In some cases, the mitigation measures have already been implemented. A “yes” response will be provided regardless whether the mitigation measures have already been implemented to indicate that a mitigation measure from the prior environmental documents will be carried forward for the project modification and no new mitigation is required. If “NA” is indicated, this Environmental Checklist Review concludes that there was no impact, or the impact was less than significant and, therefore, no mitigation measures are needed.

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Ascent Administrative Draft – For Internal Review Only Environmental Checklist for Supplemental Environmental Review City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 3-3

3.2 DISCUSSION AND MITIGATION SECTIONS

3.2.1 Discussion
A discussion of the elements of the checklist is provided under each environmental category to clarify the answers.

The discussion provides information about the particular environmental issue, how the project relates to the issue, and the status of any mitigation that may be required or that has already been implemented.

3.2.2 Mitigation Measures
Applicable mitigation measures from the prior environmental review that would apply to the project are listed under each environmental category. No new mitigation measures are proposed in this addendum.

3.2.3 Conclusions
A discussion of the conclusion relating to the need for additional environmental documentation is contained in each section.

3.3 ADDENDUM APPROACH
This document serves as an addendum to the LSAP Update EIR. This addendum is prepared in accordance with State CEQA Guidelines Section 15164 to evaluate whether the proposed project’s effects were adequately examined in the previous environmental analysis in the LSAP Update EIR or whether any changes trigger supplemental or subsequent review under State CEQA Guidelines Section 15162 or 15163. This document considers whether the environmental conditions that exist today have changed such that new or substantially more severe environmental impacts would occur compared to that evaluated in the LSAP Update EIR. As described throughout this document, no changes associated with the proposed project, and no changes in circumstances, trigger subsequent or supplemental review .

This addendum analyzes impact of the entire project as a whole and also breaks out the impacts of work on the Extension Site so that the document can be used the City of Santa Clara for CEQA clearance.

Under Section 15164, an addendum is appropriate where a previously certified EIR has been prepared and some changes or revisions to the project are proposed, or the circumstances surrounding the project have changed, but none of the changes or revisions would result in significant new or substantially more severe environmental impacts, consistent with CEQA Section 21166 and State CEQA Guidelines Sections 15162, 15163, 15164, and 15168.

Based on the criteria above and the results of the following EIR conformity evaluation, the City has determined that an addendum to the LSAP Update EIR is the appropriate CEQA document. The EIR conformity evaluation is intended to review relevant environmental topic areas for any changes in circumstances or the substantial new information as defined under State CEQA Guidelines Section 15162, as compared to the environmental impacts identified in the certified EIR prepared for the LSAP Update EIR.

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Environmental Checklist for Supplemental Environmental Review Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
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Administrative Draft – For Internal Review Only
City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-1 4 ENVIRONMENTAL CHECKLIST

4.1 AESTHETICS
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and
Final SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New Information
of Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

1. Aesthetics. Would the project:
a) Have a substantial adverse effect on
a scenic vista?
Draft SEIR page

3.1-6
No No No NA, no impact
would occur.
b) Substantially damage scenic
resources, including, but not limited
to, trees, rock outcroppings, and
historic buildings within a state
scenic highway?
Draft SEIR page

3.1-6

No No No NA, no impact
would occur.
c) In non-urbanized areas, substantially
degrade the existing visual character
or quality of public views of the site
and its surroundings? (Public views
are those that are experienced from
publicly accessible vantage points.) If
the project is in an urbanized area,
would the project conflict with
applicable zoning and other
regulations governing scenic quality?
Draft SEIR Impact

3.1-1;
Final SEIR
identified no
change in impact
conclusion

No No No NA, impact would
be less than
significant.
d) Create a new source of substantial
light or glare which would adversely
affect day or nighttime views in the
area?
Draft SEIR Impact

3.1-2;
Final SEIR
identified no
change in impact
conclusions
No No No NA, impact would
be less than
significant.

4.1.1 Discussion
No substantial change in the environmental and regulatory settings related to aesthetics, summarized above and described in the LSAP Update SEIR Section 3.1, Aesthetics, has occurred since certification of the LSAP Update SEIR in September 2021.

Applicable urban design and lighting standards for the City of Santa Clara include Chapter 18.48 of City of Santa Clara City Code that provides building and landscape design standards. Section 18.48.140 requires building lighting to reflect away from residential areas and public streets to prevent glare and light spillover. a) Have a substantial adverse effect on a scenic vista? As described in the LSAP Update SEIR there are no scenic vistas within the LSAP area, and the ISI Project site is not located near any officially designated state or county scenic highways. As such, the LSAP Update SEIR determined that no impact would occur. Similarly, there are also no scenic vistas within the City of Santa Clara from the Extension Site. Therefore, the proposed 62-foot parking garage on the Extension Site would not block scenic views. The proposed 63-foot-tall building on the North Site and parking garage on the eastern site extension would not have an Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-2 Intuitive North Site Modification Project Environmental Checklist adverse effect on a scenic vista. The project would not result in new significant impacts or substantially more severe impacts related to a scenic vista than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a scenic vista than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to scenic vistas the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? As described in the LSAP Update SEIR, the ISI Project site is not located near any officially designated state scenic highways in the City of Sunnyvale. Also, the ISI project site is not located near any officially designated state scenic highways in the City of Santa Clara. Therefore, no impacts to scenic resources within any state scenic highways would occur from the project. The project would not result in new significant impacts or substantially more severe impacts related to a scenic vista than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a scenic vista than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to scenic vistas the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt.

The findings of the LSAP Update SEIR for the ISI Project remain valid. c) In non-urbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are experienced from publicly accessible vantage points.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? (The project is in an urbanized area.) The LSAP Update SEIR determined that implementation of the ISI Project would improve the visual experience for pedestrians and cyclists and the overall visual and aesthetic character of the project site consistent with the LSAP. The ISI Project would include open space with passive and active recreation on the North Site and a publicly accessible pedestrian-bicycle path on the South Site. The ISI Project would be implemented to improve the overall character of the area consistent with the LSAP policies and other regulations governing scenic quality. Therefore, the LSAP Update SEIR concluded that the ISI Project would not result in a new or substantially more severe significant effect on visual character or quality of public views than analyzed in the LSAP EIR.

North Site
and South Site
The LSAP Update SEIR determined that implementation of the ISI Project would improve the visual experience for pedestrians and cyclists and the overall visual and aesthetic character of the project site consistent with the LSAP . The ISI Project would include open space with passive and active recreation on the North Site and a publicly accessible pedestrian-bicycle path on the South Site. The ISI Project would be implemented to improve the overall character of the area consistent with the LSAP policies and other regulations governing scenic quality. Therefore, the LSAP Update SEIR concluded that the ISI Project would not result in a new or substantially more severe significant effect on visual character or quality of public views than analyzed in the LSAP EIR.

Updates to the North Site would include refinements to the design of the North Site building to ensure consistency with the building on the South Site. The proposed modifications include the a ddition of an internal courtyard which would reduce the gross North Site building area from approximately 364,000 to approximately 358,000 square feet; Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-3 the relocation of the loading area approximately 100 feet to the south; different geometry for the approved Kifer Road intersection; design refinements to the approved pedestrian bridge; the relocation of the employee restaurant from the west to the east side of the building; the extension of the roof trellis element along the edges of the building; the installation of rooftop screening units with associated screening structures; and a change in spandrel and vision glazing on the second and third floors. The project would not include any substantial increases in the floor area ratio or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. Also, the parking spaces on the South Site would be removed or caged. This would prevent anyone from parking in those spaces and would therefore result in no increases to the total number of parking spaces on the ISI project site.

The project would not increase the height of the proposed building on the North Site, which would remain approximately 63 feet. The proposed building would remain within the zoning height restriction of 85 feet. The appearance of the height and mass of the North Site would not change as a result of the proposed refinements.

Aesthetic impacts would continue to be minimized through application of areawide design guidelines in the LSAP such as BH-UDG4, BMA-UDG1, BMA-UDG2, BO-UDG10, and PK-UDG14, which encourage the greatest concentration of taller buildings where the elevated portion of the station creates an existing vertical element. Variations in height at different portions of the North Site would be similar to what was assumed in the LSAP Update SEIR and would provide visual interest and variety would still avoid a blocky uniform appearance.

The project would not change the front yard setback of the North Site, which would be s et at 48 feet to provide enough space for existing tree canopies. The North Site would still be consistent with the minimum setback established in the LSAP. As explained in the LSAP Update SEIR, the ISI Project would include outdoor landscaping, street designs and trees consistent with applicable City and LSAP guidelines. The refined North Site designs would be consistent with and retain Sunnyvale’s established urban visual characters. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to visual character or quality than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to visual character than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to visual character the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
The Extension Site, located in the City of Santa Clara, would replace an existing parking lot with an above-ground 62- foot-tall parking garage. Zoning for the site establishes a maximum height restriction of 70 feet. Therefore, the height for the proposed parking garage is within the zoning height restriction for Santa Clara.

Associated zoning for the Extension Site requires a 15-foot setback for development. A 200-foot front yard setback is proposed for the parking garage. Therefore, the project would be consistent with the City of Santa Clara setback requirements. The proposed Extension Site would include outdoor landscaping and trees consistent with Santa Clara Municipal Code Chapter 18.48. The Extension Site is surrounded by development including Central Expressway to the north; a private access drive, industrial building and Kifer Road to the south; 945/955 Kifer Road (North Site) to the west; and industrial/office buildings to the east. Since the area immediately surrounding the project site is already developed, the project would be consistent with the urban visual character of the surrounding development. Because the Extension Site is on a parcel zoned for industrial uses, the proposed parking garage would be subject to the City of Santa Clara Community Design Guidelines for Industrial Development (Section F). The design of the proposed parking garage is consistent with these guidelines as it would include adequate landscaping, circulation, and parking.

As such, the project would be consistent with and retain Santa Clara’s established urban visual characteristics and would not conflict with policies established to govern scenic resources. Impacts would remain less than significant.

The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to visual character than were identified for the ISI Project in the LSAP Update SEIR, no changes Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-4 Intuitive North Site Modification Project Environmental Checklist in circumstances would result in new or substantial more severe impacts related to visual character than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to visual character the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid .. d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
The LSAP Update SEIR further pointed out that there are existing sources of nighttime lighting and glare in the plan area because it is largely built out with residential and nonresidential uses. The LSAP Update SEIR also identified that the lighting for expanded urban uses at the ISI Project site would be minimal, downward shielded, and include safety and security lighting as well as outdoor lighting that would not substantially increase light or glare. The LSAP Update SEIR further stated that implementation of the ISI Project would be installed in conformance with City codes and ordinances, applicable safety and illumination requirements produced by the Illuminating Engineering Society of North America and the Recommended Practice Design Guides, City’s Bird-Safe Design Guidelines, and California Title 24 requirements. As such, the LSAP Update SEIR determined that impacts related to conflicts with applicable zoning or other regulations governing scenic quality and the creation of new sources of substantial light and glare that would adversely affect day or nighttime views in the area would be less than significant.

North Site
As identified in the LSAP Update SEIR there are existing sources of nighttime lighting and glare in the plan area because it is largely built out with residential and nonresidential uses. The LSAP Update SEIR identified that the lighting for expanded urban uses at the ISI Project site would be minimal, downward shielded, and include safety and security lighting as well as outdoor lighting that would not substantially increase light or glare. The LSAP Update SEIR stated that implementation of the ISI Project would be installed in conformance with City codes and ordinances, applicable safety and illumination requirements produced by the Illuminating Engineering Society of North America and the Recommended Practice Design Guides, City’s Bird-Safe Design Guidelines, and California Title 24 requirements. For example, Section 19.42.050 of the Sunnyvale Municipal Code requires that all 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 any public street or other property .

Lighting associated with development on the North Site would similarly be required to conform to City codes and ordinances, applicable safety and illumination requirements produced by the Illuminating Engineering Society of North America and the Recommended Practice Design Guides, City’s Bird-Safe Design Guidelines, and California Title 24 requirements. Updates to the North Site would include refinements to the design of the North Site building but the North Site building would remain architecturally consistent with the building on the South Site. The project would not include any substantial increases to the floor area ratio or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. Therefore, additional lighting beyond what was analyzed in the LSAP Update SEIR would not be needed for the North Site. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to light or glare than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to light or glare than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to light or glare the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-5 Extension Site
The Extension Site, located in the City of Santa Clara, would replace an existing parking lot with an above-ground parking garage that would include lighting. There are existing sources of nighttime lighting and glare in the project area because it is largely built out with residential and nonresidential uses. Lighting associated with development of the parking garage would be similar to that of other parking garages in the area with exterior and interior lighting.

Lighting for such structures is normally minimal, downward shielded, and includes safety and security lighting.

Lighting for the proposed parking garage would be required to conform with City of Santa Clara codes and ordinances. Section 18.48.140 of the Santa Clara Municipal Code requires building lighting to reflect away from residential areas and public streets to prevent glare and light spillover. Illumination from the parking garage is also required to be either shielded or equipped with special lenses in such a manner as to prevent any glare or direct illumination on any public street or other property. As shown in the project plans, all lighting on the project site would be shielded and directed downward to prevent any glare or light from spilling over and illuminating any surrounding streets or neighboring properties. Compliance with the Santa Clara Municipal Code would ensure that potential light and glare impacts are reduced to a level that would be less than significant for the Extension Site. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to light or glare than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to light or glare than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to light or glare the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduc e impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Mitigation Measures from LSAP Update SEIR
No significant aesthetic impacts were identified in the LSAP Update SEIR, and no mitigation measures were required.

Conclusion
No new circumstances or project changes related to aesthetics have occurred that would result in new or substantially more severe aesthetics impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-6 Intuitive North Site Modification Project Environmental Checklist

4.2 AGRICULTURE AND FOREST RESOURCES
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and
Final SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New Information
of Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

2. Agriculture and Forestry Resources. Would the project:
a) Convert Prime Farmland, Unique
Farmland, or Farmland of Statewide
Importance (Farmland), as shown on
the maps prepared pursuant to the
Farmland Mapping and Monitoring
Program of the California Resources
Agency, to non-agricultural use?
Draft SEIR Section

1.3.1 No No No NA, there would be
no impact.
b) Conflict with existing zoning for
agricultural use or a Williamson Act
contract?
Draft SEIR Section

1.3.1 No No No NA, there would be
no impact.
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))?
Draft SEIR Section

1.3.1 No No No NA, there would be
no impact.
d) Result in the loss of forest land or
conversion of forest land to non-
forest use?
Draft SEIR Section

1.3.1 No No No NA, there would be
no impact.
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?
Draft SEIR Section

1.3.1 No No No NA, there would be
no impact.

4.2.1 Discussion and Conclusion
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? b) Conflict with existing zoning for agricultural use or a Williamson Act contract? c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-7 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?
Agricultural and forestry impacts were scoped out of the LSAP EIR and LSAP Update SEIR at the notice of preparation stage as these resources do not exist in the LSAP area. These resources also do not exist on the project site in the City of Santa Clara. The project site does not contain any of these resources; therefore, the project would also have no impact.

Conclusion
No new circumstances or project changes related to agricultural and forest resources have occurred that would result in new or substantially more severe impacts related to agricultural and forestry resources than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt . Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-8 Intuitive North Site Modification Project Environmental Checklist

4.3 AIR QUALITY
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and Final
SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

3. Air Quality. Would the project:
a) Conflict with or obstruct
implementation of the applicable
air quality plan?
Draft SEIR Impact

3.2-2;
Final SEIR identified
no change in impact
conclusion
No No No NA, impact would
be less than
significant.
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?
Draft SEIR
Impact 3.2-1 and

3.2-2;
Final SEIR identified
no change in impact
conclusion
No No No Yes, but LSAP
Update SEIR impact
would remain
significant and
unavoidable for
construction and
less than significant
for operation. The
project would not
make a cumulatively
considerable
contribution to
construction and
operation air quality
impacts.
c) Expose sensitive receptors to
substantial pollutant
concentrations?
Draft SEIR
Impact 3.2-3 and

3.2-4;
Final SEIR identified
no change in impact
conclusion
No No No Yes, impact would
be less than
significant with
application of
adopted mitigation
measures.
d) Result in other emissions (such as
those leading to odors) adversely
affecting a substantial number of
people?
Draft SEIR
Impact 3.2-5;
Final SEIR identified
no change in impact
conclusion
No No No Yes, impacts would
be less than
significant.

4.3.1 Discussion
As identified in Impact 3.2-2 of the LSAP Update SEIR, the LSAP Update, which includes the ISI Project, would be consistent with the BAAQMD’s Clean Air Plan’s control measures developed to reduce criteria air pollutants. This impact was determined to be less than significant.

Implementation of the project would involve the construction and operation the North Site (945/955 Kifer Road) , which would contain an approximately 358,000 square-foot office headquarters and visitor experience center, as well as the proposed Extension Site, an above ground parking structure that is owned by ISI but is in the City of Santa Clara. All other components of the Project (i.e., the office headquarters and visitor experience center, multi-purpose amenity building, outdoor sports fields and courts, and outdoor dining area) would remain located in the city of Sunnyvale. The following analysis addresses potential impacts to air quality that would result from the construction and operation of the project changes on both the North Site and Extension Site .

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-9 BAAQMD updated its 2022 CEQA Air Quality Guidelines in April 2023. The guidance provides updates to BAAQMD’s methodology and recommendations for assessing impacts from toxic air contaminant (TAC ); however, the updated 2022 CEQA Air Quality Guidelines do not amend BAAQMD’s previous mass emissions thresholds for construction- generated and operational criteria air pollutants, or recommendations for plan consistency and do not constitute substantial new information.

Table 4.3-1 National and California Ambient Air Quality Standards Pollutant Averaging Time CAAQSa,b NAAQSc Primaryb,d NAAQSc Secondaryb,e Ozone (O3) 1-hour 0.09 ppm (180 μg/m3) –e Same as primary standard 8-hour 0.070 ppm (137 μg/m3) 0.070 ppm (147 μg/m3) Same as primary standard Carbon monoxide (CO) 1-hour 20 ppm (23 mg/m3) 35 ppm (40 mg/m3) Same as primary standard 8-hour 9 ppmf (10 mg/m3) 9 ppm (10 mg/m3) Same as primary standard Nitrogen dioxide (NO2) Annual arithmetic mean 0.030 ppm (57 μg/m3) 53 ppb (100 μg/m3) Same as primary standard 1-hour 0.18 ppm (339 μg/m3) 100 ppb (188 μg/m3) —
24-hour 0.04 ppm (105 μg/m3) — —
Sulfur dioxide (SO2) 3-hour — — 0.5 ppm (1300 μg/m3)
1-hour 0.25 ppm (655 μg/m3) 75 ppb (196 μg/m3) —
Respirable particulate matter (PM10) Annual arithmetic mean 20 μg/m3 — Same as primary standard 24-hour 50 μg/m3 150 μg/m3 Same as primary standard
Fine particulate matter (PM2.5) Annual arithmetic mean 12 μg/m3 9.0 μg/m3 15.0 μg/m3 24-hour — 35 μg/m3 Same as primary standard
Lead f Calendar quarter — 1.5 μg/m3 Same as primary standard 30-Day average 1.5 μg/m3 — —
Rolling 3-Month Average – 0.15 μg/m3 Same as primary standard Hydrogen sulfide 1-hour 0.03 ppm (42 μg/m3) No national Standards No national Standards Sulfates 24-hour 25 μg/m3 No national Standards No national Standards Vinyl chloride f 24-hour 0.01 ppm (26 μg/m3) No national Standards No national Standards Visibility-reducing particulate matter 8-hour Extinction of 0.23 per km No national Standards No national Standards Notes: CAAQS = California Ambient Air Quality Standards; NAAQS = National Ambient Air Quality Standards; µg/m3 = micrograms per cubic meter; km = kilometers; ppb = parts per billion; ppm = parts per million. a. California standards for ozone, carbon monoxide, SO2 (1- and 24-hour), NO2, particulate matter, and visibility-reducing particles are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations. b. Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based on a reference temperature of 25 degrees Celsius (°C) and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas. c. National standards (other than ozone, particulate matter, and those based on annual averages or annual arithmetic means) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration in a year, averaged over three years, is equal to or less than the standard. The PM
10 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 μg/m3 is equal to or less than one. The PM2.5 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. Contact the U.S. Environmental Protection Agency for further clarification and current federal policies.
d. National primary standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. e. National secondary standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant.
f. The California Air Resources Board has identified lead and vinyl chloride as toxic air contaminants with no threshold of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants.

Source: EPA 2024, CARB 2022a.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-10 Intuitive North Site Modification Project Environmental Checklist Table 4.3-2 below summarizes the most recent attainment status of Santa Clara County.

Table 4.3-2 Attainment Status Designations for Santa Clara County Pollutant NAAQS CAAQS
Ozone Attainment (1-hour)1 Nonattainment (1-hour) Classification2 Nonattainment (8-hour)3 Classification – Marginal Nonattainment (8-hour) Nonattainment (8-hour)3 Classification – Marginal Nonattainment (24-hour) Respirable particulate matter (PM10) Attainment (24-hour) Nonattainment (24-hour) Attainment (24-hour) Nonattainment (Annual)
Fine particulate matter (PM2.5) Attainment (24-hour) (No State Standard for 24-Hour) Attainment (Annual) Nonattainment (Annual)
Carbon monoxide (CO) Attainment (Maintenance) (1-hour) Attainment (1-hour) Attainment (Maintenance) (8-hour) Attainment (8-hour)
Nitrogen dioxide (NO2) Attainment (Maintenance) (1-hour) Attainment (1-hour) Attainment (Maintenance) (Annual) Attainment (Annual)
Sulfur dioxide (SO2)4 Attainment (1-Hour) Attainment (1-hour) Attainment (3-month rolling avg.) Attainment (24-hour)
Lead (Particulate) Attainment (3-month rolling avg.) Attainment (30-day average) Hydrogen Sulfide Unclassified (1-hour)
Sulfates No Federal Standard Attainment (24-hour)
Visibly Reducing Particles Unclassified (8-hour)
Vinyl Chloride Unclassified (24-hour)
Notes: NAAQS = National Ambient Air Quality Standards; CAAQS = California Ambient Air Quality Standards 1 Air Quality meets federal 1-hour Ozone standard (77 FR 64036). EPA revoked this standard, but some associated requirements still apply. 2 Per Health and Safety Code Section 40921.5(c), the classification is based on 1989–1991 data, and therefore does not change. 3 2015 Standard.
4 2010 Standard.

Source: EPA 2022; CARB 2022b.

The LSAP Update SEIR quantitatively analyzed emissions of criteria air pollutants that would result from the ISI Project. This analysis uses a qualitative approach because emissions from the proposed Extension Site parking garage were captured in the LSAP Update SEIR analysis as a proposed underground parking garage. Relocation of the parking garage, as proposed under the east site expansion, would generate similar emissions to those previously addressed in the LSAP Update SEIR, as analyzed below.

The LSAP Update SEIR provided updated air pollutant emission estimates for the expanded development potential under the LSAP Update. The following discussion summarizes new air quality information as it relates to the proposed project and compares this information to the analysis presented in the LSAP Update S EIR. a) Conflict with or obstruct implementation of the applicable air quality plan? The LSAP has been developed to promote greater use of the existing Lawrence Station transit asset and guide the development of a diverse neighborhood for employment, residential, retail, and other support services. The LSAP includes policies that prioritize new residential development near transit stations, improve connections between the transit station and adjacent destinations, and densify and intensify the land uses at key locations within the plan area.

The project site is within a TPA and PDA. As designated by the Association of Bay Area Governments’ and Metropolitan Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-11 Transportation Commission’s (ABAG/MTC) Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) (Plan Bay Area 2050), a TPA is a geographic area that is within one-half mile of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon included in a Transportation Improvement Program or applicable regional transportation plan (Pub. Resources Code § 21099(a)(7)). The LSAP Update SEIR addresses potential impacts associated with the generation of criteria air pollutants and toxic air contaminants (TACs) from construction and operational activities associated with implementation of the ISI Project and the LSAP Update, as well as issues related to odor.

The California Clean Air Act (C AA) requires air districts to create clean air plans that provide the framework for how an air basin will meet the National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS). These plans must be updated periodically. The most recently adopted air quality plan for the San Francisco Bay Area Air Basin (SFBAAB) is the 2017 Clean Air Plan: Spare the Air, Cool the Climate (2017 Clean Air Plan).

To fulfill State ozone planning requirements, the 2017 Clean Air Plan control strategies include all feasible measures to reduce emissions of ozone precursors (reactive organic gases [ROG] and nitrogen oxides [NO X]) and reduce the transport of ozone and its precursors to neighboring air basins. In addition, the 2017 Clean Air Plan builds upon and enhances BAAQMD’s efforts to reduce emissions of fine particulate matter with an aerodynamic resistance diameter of 2.5 micrometers or less (PM2.5) and TACs. The 2017 Clean Air Plan does not include regulate individual development projects. Instead, the control strategy includes state measures related to stationary sources, transportation, energy, buildings, agriculture, natural and working lands, waste management, water, and greenhouse gas (GHG) pollutants with a high global warming potential (GWP) (BAAQMD 2017). Some of these measures, such as the sustainability requirements in the California Building Code, apply directly to the project and some, such as the Renewable Portfolio Standards, apply indirectly to the project because it would affect the emissions of the electricity provided to the project.

The 2017 Clean Air Plan focuses on two paramount goals (BAAQMD 2017):
 protect air quality and health at the regional and local scale by attaining all state and national air quality standards and eliminating disparities among San Francisco Bay Area communities in cancer health risk from TACs, and
 protect the climate by reducing Bay Area GHG emissions to 40 percent below 1990 levels by 2030, and 80 percent below 1990 levels by 2050.

Under BAAQMD’s methodology, a determination of consistency with the 2017 Clean Air Plan should demonstrate that a project:
 supports the primary goals of the 2017 Clean Air Plan,  includes applicable control measures from the 2017 Clean Air Plan, and  would not disrupt or hinder implementation of any control measures in the 2017 Clean Air Plan.

A project that would not support the 2017 Clean Air Plan’s goals would not be considered consistent with the 2017 Clean Air Plan. On an individual project basis, consistency with BAAQMD’s quantitative thresholds is interpreted as demonstrating support for the 2017 Clean Air Plan’s goals. Impact 3.2-1 of the LSAP Update SEIR concluded that implementation of the LSAP Update, which includes the ISI Project, would not result in emissions that would exceed BAAQMD-recommended thresholds and that the impact would be less than significant. The Extension Site would be developed with structured parking, which would have emissions similar to the approved North Site underground garage that the project would eliminate. Emissions would be similar in that the Extension Site would be a similar land use (i.e., parking) to the approved underground garage and the proposed Extension Site parking garage would serve the same function and same number of net new employees as the previously proposed underground parking garage on the North Site, resulting in similar quantities of emissions. These emissions are captured in the emissions modeling for the LSAP Update SEIR. Therefore, it can be concluded that the project would not result in exceedances of BAAQMD’s thresholds for criteria air pollutants and thus would not conflict with the 2017 Clean Air Plan’s goal to attain air quality standards. Furthermore, as shown in Table 4.3-3, the proposed project would include applicable control measures from the 2017 Clean Air Plan and would not disrupt or hinder implementation of such control Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-12 Intuitive North Site Modification Project Environmental Checklist measures. Therefore, the proposed project would not conflict with implementation of the policies of the 2017 Clean Air Plan and would not result in new significant impacts or substantially more severe impacts than what were identified in the LSAP Update SEIR.

Table 4.3-3 Project Consistency with Applicable Control Strategies of 2017 Clean Air Plan 2017 Control Strategy Evaluation
Direct new development to areas that are well
served by transit, and conducive to bicycling and
walking.

Consistent. The project site is located within walking and bicycling distance of various amenities, including commercial, retail, restaurant, and entertainment opportunities.

Additionally, the North Site is located within the Lawrence Station Are a Plan boundary and provides pedestrian and bike access to the Lawrence Caltrain Station. The Extension Site is located just outside of the Sunnyvale Lawrence Station Area Plan boundary but is within the transit-oriented development (TOD) boundary in the Santa Clara Lawrence Station Area Plan and provides similar pedestrian and bicycle access to the Lawrence Area Caltrain Station. Therefore, the project would be located in an area that is well served by transit and conducive to bicycling and walking.

Accelerate the widespread adoption of electric
vehicles.

Consistent. The project design would provide a parking garage that would provide Level 2 electric vehicle (EV) charging stations for a minimum of 35 percent of the total garage parking spaces. This would be consistent with both the City’s Municipal Code and Santa Clara County’s Green Building Standards Code, and would promote the adoption of electric vehicles by providing infrastructure to facilitate their use.

Expand the production of low-carbon, renewable
energy by promoting on-site technologies such as
rooftop solar, wind and ground-source heat pumps.

Consistent. The ISI Project included CalGreen-compliant building features and achieved LEED Gold status. The project would not alter these aspects of the ISI project. The North Site would continue to include the use of a solar photovoltaic system on the building rooftop. The parking structure on the Extension Site would also include a rooftop photovoltaic system.

Promote energy and water efficiency in both new
and existing buildings.

Consistent. The project would have building features, such as low-flow toilets and energy-efficient lighting, that would promote energy and water efficiency in accordance with California Energy Code and CalGreen requirements.

Source: BAAQMD 2017.

The project, including the parking structure on the Extension Site, would include project design features which align with the strategies of the 2017 Clean Air Plan. . No new circumstances or project changes related to conflict with an applicable air quality plan have occurred that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, there is no new information of substantial importance that shows the project would have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.
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 (including releasing emissions which exceed quantitative thresholds for ozone precursors)?
Construction
The SFBAAB is currently in nonattainment for the CAAQS and NAAQS for Ozone (1 -Hour and 8-Hour Standards) and PM2.5 and NAAQS for respirable particulate matter with an aerodynamic resistance diameter of 10 micrometers or less (PM10) (EPA 2022, CARB 2022a). The LSAP Update SEIR provided updated air pollutant emission estimates for the expanded development potential under the LSAP Update and concluded that there would be no increase in severity of this cumulative air quality impact, as daily ROG, PM2.5, and PM10 emissions for both construction and operations activities associated with the ISI Project would be below BAAQMD average daily thresholds. However, the LSAP Update SEIR analysis found that construction related emissions of NOX would likely exceed BAAQMD thresholds. The Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-13 analysis concluded that despite the application of Mitigation Measures MM 3.5.3a (apply BAAQMD basic construction mitigation measures), 3.5.3b (reduce construction equipment emissions through use of CARB Tier 3 or better certified construction equipment), and 3.2-1 (require the use of high-performance renewable diesel (HPRD) fuel for diesel- powered construction equipment), emissions of NOX would still exceed BAAQMD thresholds. ISI committed to the use of construction equipment that is CARB Tier 4 (City of Sunnyvale 2021:2-39) that would implement Mitigation Measure MM 3.5.3b. This impact was considered significant and unavoidable for the ISI project even with the use of Tier 4 final construction equipment.

Construction of the project would not result in emissions of criteria air pollutants greater than what was analyzed in the LSAP Update SEIR because emissions associated with construction of the ISI Projectproject would likely be less than what was estimated in the LSAP Update SEIR because of the exclusion of the underground parking lot previously proposed as part of the North Site, as that component of the previously approved North Site would generate the greatest construction emissions from trenching, excavation, and use of other heavy -duty construction equipment.

The removal of this component of the North Site would reduce the level of construction emissions generated by project implementation as fewer pieces of construction equipment would be required and fugitive dust emissions associated with excavation would be avoided. Specifically, the project would have structured parking instead of an underground parking garage. Although the proposed Extension Site parking garage would serve the same function and same number of net new employees as the previously proposed underground parking garage on the North Site, it would not require as much equipment to excavate and trench. Excavation and trenching are two of the greatest sources of construction-generated criteria air pollutants because such activities require heavy-duty construction equipment of high horsepower (hp) and result in more fugitive dust emissions from earth-moving activity than grading a site for structured parking. Moreover, excavation would entail extensive haul truck trips that could contribute emissions regionally. would not be required for an above ground parking garage.

Nevertheless, consistent with the findings of the LSAP Update SEIR for the ISI Project, the project would contribute NOx, an ozone precursor, in excess of the BAAQMD threshold and thus would make a cumulatively considerable contribution to the nonattainment of ozone in the SFBAAB and could therefore increase the potential for adverse health impacts to receptors from exposure to ozone. Construction impacts would continue to be significant and unavoidable consistent with the conclusions of the LSAP Update SEIR even with implementation of Mitigation Measures 3.5.3a, 3.5.3b, and 3.2-1. No new circumstances or project changes on the North Site related to a cumulatively considerable net increase in a nonattainment pollutant have occurred that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, there is no new information of substantial importance that shows the project would have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt . Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Operation
Emissions associated with project operations would not substantially differ from those addressed in the LSAP Update SEIR because the project would not include any increases in the number of employees, intensity of use, floor area ratio, or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. In addition, there would not be an increase in the net available parking for the ISI project or uses at the Extension Site. Because emissions of criteria air pollutants associated with project operations are estimated based on building size, land use type and density, and trips made by employees, the project would not increase operational air emissions from the emissions disclosed for the ISI project in the LSAP Update SEIR . As stated under Item “c” below, implementation of the project would not affect vehicle miles traveled (VMT), energy use/demand, maintenance activity frequency, water demand/usage or waste generation that would result in additional emissions compared to those estimated in the LSAP Update SEIR. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a air quality than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to air quality than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-14 Intuitive North Site Modification Project Environmental Checklist to air quality the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
Construction
Construction emissions related to the proposed Extension Site parking garage were accounted for as part of the ISI Project analysis in the LSAP Update SEIR as the below-ground parking structure previously proposed to be constructed under the North Site. It was concluded that construction of the ISI Project would result in emissions of criteria air pollutants which would exceed BAAQMD average daily thresholds for construction-related NOx emissions.

Because the parking structure accounted for a small fraction of the total emissions of the ISI Project , it can be assumed that construction of the parking structure itself would not result in exceedances of BAAQMD thresholds . The proposed Extension Site parking garage would serve a similar function as the previously proposed underground parking garage on the North Site. Construction of the proposed above-ground parking structure would result in reduced construction-related air quality emissions compared to the construction emissions from the underground parking garage analyzed in the LSAP Update SEIR because the types of construction equipment needed to excavate and trench a below ground parking lot would be avoided. Excavation and trenching are the greatest source of construction-generated criteria air pollutants and precursors because they require heavy-duty construction equipment of high horsepower (hp) and result in fugitive dust emissions from earth-moving activity. Moreover, excavation for an underground parking garage would entail extensive haul truck trips that could contribute emissions regionally and these haul trips would not be required for the above-ground parking garage. Construction impacts would continue to be significant consistent with the conclusions for the ISI Project in the LSAP Update SEIR. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a cumulatively considerable net increase in a nonattainment pollutant than were identified for in the LSAP Update SEIR. There would be no changes in circumstances that would result in new or substantially more severe impacts related to operational criteria air pollutants than were identified in the LSAP Update SEIR and there is no new information that shows that the project would result in one or more significant effects not discussed in the LSAP Update SEIR, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR remain valid.

Operation
The proposed garage would have similar operational air emissions as the underground garage because the net new parking spaces would be the same and other sources of emissions, such as electricity for lighting, would be similar.

The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a cumulatively considerable net increase in a nonattainment pollutant than were identified for in the LSAP Update SEIR. There would beno changes in circumstances that would result in new or substantially more severe impacts related to operational criteria air pollutants than were identified in the LSAP Update SEIR and there is no new information that shows that the project would result in one or more significant effects not discussed in the LSAP Update SEIR, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR, or that there would be feasible mitigation measures or alternatives that were pr eviously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR remain valid.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-15 c) Expose sensitive receptors to substantial pollutant concentrations? Carbon Monoxide Concentrations
North Site
Impact 3.2-3 of the LSAP Update SEIR included an analysis of the ISI Project to determine whether the implementation of the ISI Project would result in a short- or long-term increase in localized carbon monoxide (CO) emissions that exceed BAAQMD-recommended thresholds. It was determined that the ISI Project as a whole would not cause an intersection to exceed the BAAQMD-recommended peak hour thresholds of intersections experiencing a traffic volume greater than 44,000 vehicles per hour or 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited. Therefore, operation of the ISI Project would not violate a standard or contribute substantially to an existing or projected air quality violation or expose sensitive receptors to substantial CO concentrations and this impact was determined to be less than significant. Because the project would not increase square footage, floor-to- area ratio, and number of employees, the project would not result in additional trips beyond those accounted for in the LSAP Update SEIR. No new circumstances or project changes to the North Site related to CO emissions have occurred that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR.

Additionally, there is no new information of substantial importance that shows the project would have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Extension Site
The proposed parking structure would not result in increases in project-related VMT. Of the 1,183 parking spaces 279 parking spaces would be allocated for 2900 Semiconductor Drive and 3875 Kifer Road buildings in the City of Santa Clara and there would not be an increase in the total number of parking spaces. Therefore CO emissions would not increase because relocating the parking structure above ground, as opposed to being located underground as was analyzed in the LSAP Update SEIR, would not result in changes to square footage, floor-to-area ratio, or an increase in the number of employee trips associated with the ISI Project. Rather, VMT associated with these trips would be displaced to the proposed Extension Site adjacent to the North Site. Additionally, the project would be required to implement a TDM Plan that achieves 35 percent peak hour and 20 percent daily trip reduction as required by the LSAP. The portion of the project on the Extension Site would not result in new circumstances or project changes to related to CO emissions that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, there is no new information of substantial importance that shows the project would have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt.

Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Toxic Air Contaminant Concentrations
North Site
Impact 3.2-4 of the LSAP Update SEIR included an analysis to determine whether the implementation of the ISI Project would result in the exposure of sensitive receptors to substantial increases in TAC emissions during construction or operations activities.

Construction TACs
The TAC analysis of the ISI Project included in the LSAP Update SEIR stated that health risks associated with emissions of TACs during construction with the application of CARB Tier 4 construction equipment that was committed to by ISI (City of Sunnyvale 2021:2-39) consistent with adopted LSAP Mitigation Measure MM 3.5.3b (require CARB Tier 3 Certified or better off-road diesel-fuel equipment) and MM 3.5.5 (require site-specific construction-related impact analysis and construction pollutant mitigation plan) would be less than significant. It was also determined that Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-16 Intuitive North Site Modification Project Environmental Checklist conservative estimates of both maximum diesel PM2.5 emission concentration and carcinogenic risk from project construction would be below applicable BAAQMD thresholds. Sensitive receptors near the ISI Project site were identified and include multi-family residences approximately 120 feet south of the South Site and multi-family residences approximately 400 feet south of a temporary concrete batch plant that would be located in the northern part of the South Site. The project, occurring at the North Site, would be an even greater distance from the sensitive receptors identified in the LSAP Update SEIR and is not near any additional sensitive receptors. As stated above, the LSAP Update SEIR determined that both maximum diesel PM

2.5 emission concentration and carcinogenic risk from
construction of the ISI Project would be below applicable BAAQMD thresholds. The project would not include any increases in the number of employees, intensity, floor area ratio, or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. No new circumstances or project changes to the North Site related to construction TAC emissions have occurred that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, there is no new information of substantial importance that shows the project will have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Operational TACs
The TAC analysis of the ISI Project included in the LSAP Update SEIR stated while operational activities associated with the ISI Project would result in long term emissions of diesel PM

2.5 associated with emergency generator use and delivery truck idling, the highest expected annual average diesel PM2.5 emission concentrations at the ISI Campus site would remain below the BAAQMD threshold of 10 per million. Acute and chronic hazards also would be below the BAAQMD significance threshold of 1.0. Therefore, it was concluded that the ISI Project would not result in the exposure of any nearby sensitive receptors to TAC concentrations that exceed applicable thresholds of significance during operations.

No new circumstances or project changes to the North Site related to operational TAC or PM

2.5 emissions have occurred
that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, there is no new information of substantial importance that shows the project will have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Extension Site
Construction TACs
Emissions of TACs related to the parking garage were accounted for as part of the ISI Project analysis in the LSAP Update SEIR as construction of the below-ground parking structure previously proposed would have the same or more TAC emissions compared to the construction of the project’s parking structure . It was concluded that construction of the ISI Project would not result in emissions of TACs which would exceed BAAQMD thresholds. Because the parking structure accounted for a portion of the total emissions of the ISI Project, it can be reasonably assumed that construction of the parking structure itself would not result in exceedances of BAAQMD thresholds for TACs. Relocating the parking structure above-ground would not result in changes to construction duration than what was addressed in the LSAP Update SEIR analysis; however, as compared to a below-ground parking structure, the anticipated intensity and/or or equipment quantity/type likely that would be less than what would be required to build a below-ground parking structure as the excavation construction phase would be significantly reduced. There would still be excavation for footings, utilities, and foundation of the above-ground parking structure, but it is minimal compared to a full excavation for a below-ground parking structure. The proposed parking garage would not be located near any new sensitive receptors beyond those identified in the LSAP Update SEIR. Additionally, the project would not be any closer to the identified sensitive receptors than what was accounted for in the LSAP Update EIR. The portion of the project on the Extension Site would not result in new circumstances or project changes to related to construction TAC emissions that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-17 there is no new information of substantial importance that shows the project would have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Operational TACs
The LSAP Update EIR identified that operation of the ISI Project would result in long term emissions of diesel PM2.5 from emergency generator use and delivery truck idling, but that these emissions would be below BAAQMD thresholds. TAC emissions resulting from operation of the parking garage on the Extension Site would come from cars that were accounted for in the LSAP Update SEIR analysis as part of the previously proposed underground parking structure to be located under the North Site. Although the parking garage would have more spaces than the previously proposed underground parking structure, the net new spaces on the Extension Site and the number of spaces to serve employees associated with the project would be substantially similar to the spaces previously proposed (937 spaces allocated for the north site in 2021 and the same number proposed in the modification) .

Because emissions of TACs from the North Site, which included the previously proposed underground parking garage, account for a fraction of the total operational TAC emissions from the ISI Project, it can be reasonably assumed that emissions from the project, including the parking garage, would also be below BAAQMD thresholds.

Operational activities associated with the parking garage on the Extension Site would not substantially differ in type or intensity from what was previously analyzed as the underground parking structure in the LSAP Update SEIR.

Additionally, the proposed parking garage would not be located near any new sensitive receptors beyond those identified in the LSAP Update SEIR and the project would not be any closer to the identified sensitive receptors than what was accounted for in the LSAP Update EIR. The portion of the project on the Extension Site would not result in new circumstances or project changes to related to operational TAC emissions that would result in new or substantially more severe impacts than were identified in the LSAP Update SEIR. Additionally, there is no new information of substantial importance that shows the project would have one or more significant effects not previously discussed in the LSAP Update SEIR, that the discussed effects would be substantially more severe, or that there would be newly feasible mitigation measures, alternatives, or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt . Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required. d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
The LSAP EIR and LSAP Update SEIR determined that construction within the plan area is not anticipated to expose nearby receptors to objectionable odors. The project would be required to comply with BAAQMD Regulation 8, Rule 3, Architectural Coatings, and Rule 15, Emulsified Asphalt, which establish volatile organic compound (VOC) content limits for these construction materials. VOCs are the main sources of odors from these sources. Therefore, compliance with these regulatory requirements would further reduce odor impacts associated with these sources. The project would not result in new significant impacts or substantially more severe impacts related to construction - generated odors than what were identified in the LSAP Update SEIR.

With respect to operation, the BAAQMD’s CEQA Air Quality Guidelines identifies land uses associated with odor complaints to include, but not limited to, wastewater treatment plants, landfills, confined animal facilities, composting stations, food manufacturing plants, refineries, and chemical plants (BAAQMD 2017). The projects, a commercial office land use with associated parking garage, are not identified on this list. The land use designations of the North Site would not change from that which was analyzed in the LSAP Update SEIR, and the parking garage on the Extension Site is not considered a land use typically associated with odor complaints. The project would not result in new significant impacts or substantially more severe impacts related to odors than were identified in the LSAP Update SEIR, nor would there be new feasible mitigation measures or alternatives that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR remain valid.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-18 Intuitive North Site Modification Project Environmental Checklist Mitigation Measures from LSAP Update EIR
Mitigation Measures MM 3.5.3a and 3.5.3b were adopted as part of the LSAP EIR to ensure compliance with BAAQMD’s basic construction measures. As noted above, ISI has committed to the use of CARB Tier 4 construction equipment, which implements Mitigation Measure MM 3.5.3b. Mitigation Measure 3.2-1 was included for the ISI Project in the LSAP Update SEIR to reduce NOX emissions during construction. The following adopted mitigation measures referenced in the LSAP EIR and LSAP Update SEIR analysis would continue to be applicable for the North Site if the project was approved. ISI has also agreed to implement these mitigation measures on the Extension Site in a letter dated December 20, 2023 and as included on the project site plans.

Mitigation Measure MM 3.5.3a
Prior to the issuance of grading or building permits, the City of Sunnyvale and City of Santa Clara, as appropriate, shall ensure that BAAQMD’s basic construction mitigation measures from Table 8-1 of the BAAQMD 2011 CEQA Air Quality Guidelines (or subsequent updates) are noted on the construction documents. These basic construction mitigation measures include the following:
1) All exposed surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and unpaved access roads) shall be watered two times per day.
2) All haul trucks transporting soil, sand, or other loose material off-site shall be covered. 3) All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. 4) All vehicle speeds on unpaved roads shall be limited to 15 miles per hour (mph). 5) All roadways, driveways, and sidewalks to be paved shall be completed as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil binders are used. 6) All construction equipment shall be maintained and properly tuned in accordance with manufacturers’ specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation.
7) A publicly visible sign shall be posted with the telephone number of the job superintendent overseeing construction of the Extension Site parking structure regarding dust complaints. This person shall respond and take corrective action within 48 hours. The BAAQMD’s phone number shall also be visible to ensure compliance with applicable regulations.

Mitigation Measure MM 3.5.3b
In the cases where construction projects are projected to exceed the BAAQMD air pollutant significance thresholds for NOX, PM10, and/or PM2.5, all off-road diesel-fueled equipment (e.g., rubber-tired dozers, graders, scrapers, excavators, asphalt paving equipment, cranes, and tractors) shall be at least CARB Tier 3 Certified or better.

Mitigation Measure 3.2-1: Reduce construction-related NOX emission for the ISI Project The applicant shall require its construction contractors to use HPRD fuel for diesel-powered construction equipment, to the extent available. Any HPRD product that is considered for use by the construction contractor shall comply with California’s Low Carbon Fuel Standards. HPRD fuel must meet the following criteria:
 be hydrogenation-derived (reaction with hydrogen at high temperatures) from 100 percent biomass material (i.e., nonpetroleum sources), such as animal fats and vegetables,  contain no fatty acids or functionalized fatty acid esters, and  have a chemical structure that is identical to petroleum-based diesel which ensures HPRD will be compatible with all existing diesel engines; it must comply with American Society for Testing and Materials D975 requirements for diesel fuels.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-19 Conclusion
No new circumstances or project changes related to air quality have occurred that would result in new or substantially more severe air quality impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-20 Intuitive North Site Modification Project Environmental Checklist

4.4 BIOLOGICAL RESOURCES
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and Final
SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

4. Biological Resources. Would the project:
a) Have a substantial adverse effect,
either directly or through habitat
modifications, on any species
identified as a candidate, sensitive,
or special-status species in local or
regional plans, policies, or
regulations, or by the California
Department of Fish and Wildlife or
the U.S. Fish and Wildlife Service?
Draft SEIR Impacts

3.4-1 and 3.4-2

No No No Yes, impacts to
special-status bats,
nesting raptors,
and migratory
birds would be less
than significant
with application of
adopted mitigation
measures. Impact
on other special-
status species
remains less than
significant.
b) Have a substantial adverse effect on
any riparian habitat or other
sensitive natural community
identified in local or regional plans,
policies, or regulations or by the
California Department of Fish and
Wildlife or the U.S. Fish and Wildlife
Service?
Draft SEIR page 3.4-
14 No No No NA, impact would
be less than
significant.
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?
Draft SEIR page 3.4-
15 No No No NA, impact would
be less than
significant.
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?
Draft SEIR page 3.4-
15 No No No NA, impact would
be less than
significant.
e) Conflict with any local policies or
ordinances protecting biological
resources, such as a tree
preservation policy or ordinance?
Draft SEIR Impact

3.4-3

No No No NA, impact would
be less than
significant.
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?
Draft SEIR page 3.4-
15 No No No NA, no impact
would occur.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-21 Discussion
Biological resources are discussed in Chapter 3.4, “Biological Resources,” of the LSAP Update SEIR. To determine if any changes to biological resources have occurred on the North Site since adoption of the LSAP Update SEIR and to analyze the biological resources on the Extension Site, a literature review was completed for the North Site and Extension Site. This analysis utilizes updated and site-specific results of the California Natural Diversity Database (CNDDB) and California Native Plant Society (CNPS) Inventory of Rare Plants (IPaC) species searches prepared for the project. CNDDB and CNPS record searches were completed of the Mountain View, Mindego Hill, Palo Alto, Newark, Niles, Redwood Point, Milpitas, and San Jose West U.S. Geological Survey 7.5-minute quadrangles. Additionally, a list of biotic resources of interest to the federal government and that could be affected by activities conducted in the project area was obtained from the United States Fish and Wildlife Service (USFWS) Information for Planning and Consultation website. The analysis for the North Site also incorporates the Tree Survey of 945 Kifer Road, Sunnyvale, CA prepared for the ISI Project (Urban Tree Management 2015). Special-status plant and wildlife species known to occur in the vicinity of the project area, and their potential to occur within the project area, are listed in Appendix A.

Species that were previously addressed in the LSAP Update SEIR are not included. None of the additional species identified in the vicinity have potential to occur on or adjacent to the project site, due to lack of suitable habitat.

Santa Clara Municipal Code Chapter 12.35 includes standards relating to removal of trees and shrubs. Santa Clara Municipal Code Chapter 12.35.090 requires a permit for the removal of any heritage tree and all specimen trees with a diameter of 12 inches or more when measured at 54 inches above natural grade; and dictates the replacement ratios for removed trees. Tree replacement ratios required by the City of Santa Clara are 1:1 for dead or unsuitable trees and for live trees 2:1 if 24-inch box trees are planted and 4:1 if 15-gallon container trees are planted. a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special-status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service?
North Site
As discussed in Impact 3.4-1 of the LSAP Update SEIR the ISI Project area has the potential to be occupied by roosts of special-status bat species. The LSAP Update SEIR determined that pallid bat may use buildings and hollows of large trees within the ISI Project area for roosting and buildings in the ISI Project area may provide roosting for Townsend’s big eared bat. Removal of roost sites and roost disturbance could cause direct injury or mortality of bats.

Bats may occur on or adjacent to the North Site and be impacted by construction noise and dust. This impact would be mitigated through implementation of adopted LSAP Mitigation Measure MM 3.9.2, which would require pre - construction surveys and protection of bats and active roosts. Project compliance with Mitigation Measure MM 3.9.2 would ensure that impacts to roosting bats would be minimized.

The ISI Project does not contain habitat suitable for burrowing owl or other special-status bird species. All native breeding birds, regardless of their listing status, are protected under the Migratory Bird Treaty Act as well as California Fish and Game Code sections 3503 and 3513. As noted in Impact 3.4-3, the LSAP contains several guidelines intended to protect trees, but recognizes that some trees may need to be removed to accommodate new projects. If construction occurs during the nesting season and trees are removed or substantially pruned, this could result in direct impacts on nesting birds and raptors if present. Additionally, noise and other human activity may result in nest abandonment if nesting birds are present within 100 feet (250 feet for raptors) of a work site. The project site contains large ornamental trees which could provide suitable habitat for nesting birds and raptors, and removal of these trees may result in mortality of eggs or young birds that are not capable of flying away. Adopted LSAP Mitigation Measure MM 3.9.3 would mitigate this impact by requiring preconstruction surveys and avoidance of active nest sites under project and cumulative conditions.

Architectural updates to the North Site building would include refinements to the design of the North Site building to ensure consistency with the building on the South Site. Proposed site improvements would not result in additional impacts to sensitive species or their habitat because the project would be required to implement the LSAP Update Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-22 Intuitive North Site Modification Project Environmental Checklist SEIR mitigation measures protecting bats and birds. Bird-safe measures have been incorporated through low- reflectivity glass, interior window blinds, small glass panes, and shielded lighting near buildings. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a special status species than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to special status species than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to special status species the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid and this impact would remain less than significant with implementation of adopted LSAP Update SEIR Mitigation Measures MM 3.9.2 and 3.9.3.

Extension
Site
Effects on special-status plant or wildlife species related to the project on the Extension Site would be similar to those assumed as part of the ISI Project analysis in the LSAP Update SEIR. The Extension Site consists almost entirely of pavement, with no grassland habitat or other natural vegetation or bare ground suitable for burrowing owl.

The Extension Site contains redwoods and ornamental trees which could provide suitable habitat for pallid bat or nesting birds and raptors. Removal of these trees during project construction has the potential to result in loss pallid bats or nesting birds and raptors. Adopted LSAP Mitigation Measure MM 3.9.2 and 3.9.3 would mitigate this impact by requiring preconstruction surveys and avoidance of active roosts or nest sites under project and cumulative conditions and ISI has agreed to comply with these measures.

Project compliance with Mitigation Measures MM 3.9.2 and MM 3.9.3, as included on the site plans for the Extension Site, would minimize the impacts to roosting bats and migratory birds to a level that is less than significant. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a special status species than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to special status species than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to special status species the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the I SI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid and this impact would remain less than significant with implementation of adopted LSAP Update SEIR Mitigation Measures MM 3.9.2 and 3.9.3.
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife or the U.S. Fish and Wildlife Service? North Site
As stated in the LSAP Update SEIR, the ISI Project site and surrounding area are developed or disturbed and no longer support natural communities. No riparian habitat or other sensitive natural communities occur on the North Site. Architectural updates to the North Site would include refinements to the design of the North Site building to ensure architectural consistency with the building on the South Site. The project would not include any increases in the number of employees, intensity, floor area ratio, or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. Development would not expand into areas of riparian habitat or sensitive natural communities. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a sensitive habitat than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-23 related to a sensitive habitat than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to sensitive habitats the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
The proposed Extension Site is completely developed with a paved parking lot and site landscaping and is surrounded by roads and other urban and suburban development. The E xtension Site does not contain riparian habitat or any other sensitive natural communities. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a sensitive habitat than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a sensitive habitat than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to sensitive habitats the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measur es or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.
c) Have a substantial adverse effect on federally protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? North Site
The LSAP Update SEIR states that Calabazas Creek is the only protected waters of the United States within the LSAP project area. As stated in the LSAP Update SEIR, there are no wetlands or aquatic habitat on the North Site. The North Site contains a concrete and gravel lined artificial water feature, which does not possess the field characteristics used by the federal and state resource/regulatory agencies in defining their jurisdiction (i.e., waters of the U.S., under the Clean Water Act, or waters of the State, under the Porter-Cologne Water Quality Control Act). Therefore, no jurisdictional or regulated waters or aquatic habitats occur on the North Site. Architectural updates to the North Site would include refinements to the design of the North Site building to ensure architectural consistency with the building on the South Site, such as adding an internal courtyard, changing vision and spandrel glazing in similar locations, extending the trellis element, and relocating mechanical equipment to the rooftop with screening structures. The project on the North Site would not include any increases in the number of employees, intensity, floor area ratio, or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a wetland than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a wetland than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that a s to wetlands the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension
Site
The proposed Extension Site is paved and does not contain any wetland or other aquatic habitat, or any field characteristics used by the federal and state resource/regulatory agencies in defining their jurisdiction (i.e., waters of the U.S., under the Clean Water Act, or waters of the State, under the Porter-Cologne Water Quality Control Act).

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-24 Intuitive North Site Modification Project Environmental Checklist Therefore, no jurisdictional or regulated wetlands or aquatic habitats occur on the project site. There would be no impacts to state or federally protected wetlands. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a wetland than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a wetland than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to wetlands the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. 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?
North Site
As stated in the LSAP Update SEIR, the LSAP area does not overlap with an Essential Connectivity Area as defined by California Department of Fish and Wildlife (CDFW) and does not contain native wildlife nursery sites. An Essential Connectivity Area is an area that is essential for the ecological connectivity of large natural habitat blocks that support biodiversity. In addition, the LSAP and ISI Project would not result in a significant change in land use intensity and therefore would not alter the movements of wildlife currently utilizing the LSAP area. The entire LSAP area and surrounding lands are either developed or disturbed, and include impediments to migration such as rail tracks and busy roads, and provide very limited wildlife movement opportunities and no wildlife movement corridors. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a wildlife movement corridor than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a wildlife movement corridor than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to wildlife movement corridors the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension
Site
The proposed Extension Site does not overlap with an Essential Connectivity Area and does not contain native wildlife nursery sites. The area and surrounding lands are either developed or disturbed and provide limited wildlife movement opportunities. Therefore, there would be no impacts to wildlife corridors , wildlife movement, or wildlife nursery sites. Therefore, the portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a wildlife movement corridor than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a wildlife movement corridor than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to wildlife movement corridors the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-25 e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
North Site
Implementation of LSAP Policy OSP-6 and Guideline STP-UDG6 would ensure the protection and enhancement of trees throughout the plan area wherever possible. Sunnyvale Municipal Code Chapters 13.16 (City Trees) and 19.94 (Tree Preservation on private property) dictate the limited circumstances under which protected trees may be removed and require implementation of protection measures for trees to remain during construction activities. If any protected trees are affected by future development, the project applicant will be required to comply with Chapters

13.16 and 19.94. The LSAP would implement this requirement through guideline STP-UDG7, which requires that replacement trees be provided where tree removal is unavoidable. In addition, the LSAP has identified a goal to enhance the urban forest in the plan area to provide shade and shelter, add scale to pedestrian and vehicular streets, beautify the area, and provide wildlife habitat (LSAP Goal STP-G1). This would be accomplished through guidelines that require planting street trees on all streets, using medium- to large-canopy trees on large streets, and ensuring new tree plantings are appropriate for an urban environment. Impacts would be less than significant.

The portion of the project on the North Site would be subject to LSAP policy provisions and Municipal Code Chapters

13.16 and 19.94. Updates to the North Site would include refinements to the design of the North Site building to ensure consistency with the building on the South Site, such as adding an internal courtyard, changing vision and spandrel glazing in similar locations, extending the trellis element, and relocating mechanical equipment to the rooftop with screening structures. There would not be an increase in the number of trees removed on this portion of the project site as compared to what was analyzed in the LSAP Update SEIR. Since the 2021 approval, an additional four trees have been identified for preservation (tree #s 6372P, 6380P, 6388P, and 6396P) , two additional trees (6261 and 6259P) proposed for removal due to fire lane requirements for the surface parking lot, and one additional tree (5555P) proposed for removal due to the Central Expressway Improvements resulting in a net of one additional preserved tree. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to an ordinance protecting biological resources than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to an ordinance protecting biological resources than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to ordinances protecting biological resources the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension
Site
Project plans for the Extension Site include removal of the 84 existing trees on the site. Located in the City of Santa Clara, the proposed Extension Site would be subject to Santa Clara Municipal Code Chapter 12.35, relating to removal of trees and shrubs. Santa Clara Municipal Code Chapter 12.35.090 would require a permit for the removal of any heritage tree and specimen trees of a certain species (e.g. oaks, redwoods, cedars) with a diameter of 12 inches or more when measured at 54 inches above natural grade; and dictates the replacement ratios for removed trees. Tree replacement ratios required by the City of Santa Clara are 1:1 for dead or unsuitable trees and for live trees 2:1 if 24-inch box trees are planted and 4:1 if 15-gallon container trees are planted. There are a total of 32 trees with diameters of 12 inches or more when measured at 54 inches above natural grade, but only two of these trees are species that meet the specimen criteria (Coast Redwoods) (Monarch Consulting Arborists 2022). The applicant would plant 90 trees consisting of 24-inch and 36-inch box trees on the site, which exceeds the required replacement ratio of 2:1; which would offset the removal of the two specimen trees. Trees would line the proposed private access drive and would be planted to the north and south of the proposed parking structure. Planted trees would be of varying sizes and species and comply with applicable replacement standards. Therefore, the portion of the project on the Extension Site would be consistent with the City of Santa Clara tree preservation ordinance. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to an ordinance protecting biological resources Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-26 Intuitive North Site Modification Project Environmental Checklist than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to an ordinance protecting biological resources than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to ordinances protecting biological resources the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. 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?
The LSAP area and Extension Site are not located in an area covered by an adopted habitat conservation plan. No new conservation plans have been adopted since approval of the LSAP. As a result, no conflict with an adopted habitat conservation plan would occur, and no impact would result. The project would not result in new significant impacts or substantially more severe impacts related to a habitat conservation plan than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a habitat conservation plan than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to habitat conservation plans the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitig ation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Mitigation Measures from LSAP Update EIR
Mitigation Measures MM 3.9.2 and 3.9.3 were adopted as part of the LSAP EIR to ensure impacts to special status species would be reduced. The following adopted mitigation measures referenced in the LSAP EIR and LSAP Update SEIR analysis would continue to be applicable for the North Site if the project i s approved. ISI has also agreed to implement these mitigation measures on the Extension Site in a letter dated December 20, 2023 and as included on the project site plans.

Mitigation Measure MM 3.9.2
 Prior to the removal of trees or the demolition of buildings, a bat survey shall be performed by a qualified biologist no more than 3 days before the start of construction activities. If bat roosts are identified, the City shall require that the bats be safely flushed from the sites where roosting habitat is planned to be removed. If maternity roosts are identified during the maternity roosting season (typically May to September), they must remain undisturbed until a qualified biologist has determined the young bats are no longer roosting. If roosting is found to occur on-site, replacement roost habitat (e.g., bat boxes) shall be provided to offset roosting sites removed. If no bat roosts are detected, no further action is required if the trees and buildings are removed before the next breeding season.
 If a female or maternity colony of bats is found on the project site, and the project can be constructed without the elimination or disturbance of the roosting colony (e.g., if the colony roosts in a large oak tree not planned for removal), a qualified biologist shall determine what buffer zones shall be employed to ensure the continued success of the colony. Such buffer zones may include a construction-free barrier of 200 feet from the roost and/or the timing of the construction activities outside of the maternity roost season (after July 31 and before March 1).  If an active nursery roost is documented on-site and the project cannot be conducted outside of the maternity roosting season, bats shall be excluded from the site after July 31 and before March 1 to prevent the formation of maternity colonies. Nonbreeding bats shall be safely evicted under the direction of a bat specialist.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-27 Mitigation Measure MM 3.9.3
 All construction and clearing activities shall be conducted outside of the avian nesting season (January 15–August 31), when feasible. If clearing and/or construction activities occur during the nesting season, preconstruction surveys for nesting raptors, special-status resident birds, and other migratory birds protected by the Migratory Bird Treaty Act shall be conducted by a qualified biologist, up to 3 days before initiation of construction activities. The qualified biologist shall survey the construction zone and a 250-foot radius surrounding the construction zone to determine whether the activities taking place have the potential to disturb or otherwise harm nesting birds.  If an active nest is located within 100 feet (250 feet for raptors) of construction activities, the project applicant shall establish an exclusion zone (no ingress of personnel or equipment at a minimum radius of 100 feet or 250 feet, as appropriate, around the nest). Alternative exclusion zones may be established through consultation with the CDFW and the U.S. Fish and Wildlife Service (USFWS), as necessary. The City shall be notified if altered exclusion zones widths are authorized by these agencies before the initiation of work. The exclusion zones shall remain in force until all young have fledged.

Conclusion
No new circumstances or project changes related to biological resources have occurred that would result in new or substantially more severe biological resources impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-28 Intuitive North Site Modification Project Environmental Checklist

4.5 CULTURAL RESOURCES
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and Final
SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

5. Cultural Resources. Would the project:
a) Cause a substantial adverse change
in the significance of a historical
resource pursuant to Section
15064.5?
Draft SEIR page

3.3-4
No No No NA, no impact would
occur.
b) Cause a substantial adverse change
in the significance of an
archaeological resource pursuant to
Section 15064.5?
Draft SEIR Impact

3.3-1
No No No Yes, impacts would
be less than
significant with the
application of the
adopted mitigation
measure.
c) Substantially disturb human
remains, including those interred
outside of formal cemeteries?
Draft SEIR Impact

3.3-1
No No No Yes, impacts would
be less than
significant with the
application of the
adopted mitigation
measure.

4.5.1 Discussion
The analysis below is based on the Archaeological Resources Assessment Report s prepared for the ISI Project. The 2019 records search performed for the ISI Project noted that no archaeological resources have been previously recorded within or within one-eighth of a mile near the North and South Sites (Far Western 2019). A 2023 records search was performed for the Extension Site and noted that no archaeological resources have been previously recorded on or within one-eighth of a mile near the Extension Site (Far Western 2023). However, one prehistoric archaeological resource (human remains), SCL-863, has been recorded approximately 150 feet outside of the one-eighth mile records search radius of the North and South Sites (Far Western 2019). The human remains found at that location were reinterred at another location (Far Western 2019). The records search noted that the discovery site was completely covered in pavement and recommended the site be deemed ineligible for listing in the National Register (Far Western 2019). A pedestrian survey was performed of the North Site and no new prehistoric or historic-era archaeological resources were observed during the surface survey (Far Western 2019). a) Cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5?
As stated in the LSAP Update SEIR, the City of Sunnyvale has numerous buildings that may have historical value.

However, none of the structures or sites identified in the City’s Heritage Resources Inventory are located within or immediately adjacent to the LSAP area. The buildings and structures at 945–955 Kifer Road and 950 Kifer Road were constructed within the last 35 years and are not old enough to require historic evaluation because insufficient time has passed to fully assess the historical importance of the properties (Far Western 2019:1). The Extension Site includes a surface parking lot with no existing structures. The nearest structures are located approximately 130 feet east and 190 feet south of the parking lot and would not be disrupted during project construction or operation. The project would not result in new significant impacts or substantially more severe impacts related to a historic resource than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a historic resource than were identified for the ISI Project in the LSAP Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-29 Update SEIR, and no new information shows that as to historic resources the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt.

The findings of the LSAP Update SEIR for the ISI Project remain valid. b) Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5?
North Site
As discussed in the LSAP Update SEIR, implementation of the ISI Project would allow new development, redevelopment, and infrastructure improvements that could involve subsurface disturbance for installation of foundations and/or utilities. Development of the ISI Project has the potential to impact undiscovered archaeological resources. If such resources were to represent “unique archaeological resources” as defined by CEQA in CEQA Guidelines Section 15064.5 and Public Resources Code Section 21083.2(g), any substantial change to or destruction of these resources would be a significant impact. Archaeological resources may be discovered during ground disturbing construction activities. Implementation of adopted LSAP Mitigation Measure MM 3.10.2 would require halting of construction activities and protection of any discovered archaeological resources.

Updates to the North Site would include refinements to the design of the North Site building to ensure consistency with the building on the South Site, such as adding an internal courtyard, changing vision and spandrel glazing in similar locations, extending the trellis element, and relocating mechanical equipment to the rooftop with screening structures.

The project would not include any increases in floor area ratio or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. Therefore, the portion of the project on the North Site would not result in additional impacts to archeological resources. The project would also no longer include an underground parking garage. As such, there would be much less excavation completed at the project site, which would lower the likelihood of encountering buried archeological resources. The North Site contains no recorded archaeological resources and would be subject to adopted LSAP Mitigation Measure MM 3.10.2 to halt construction if archaeological resources are uncovered and assess the significance of the find. The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to an archaeological resource than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to an archaeological resource than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to archaeological resources the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.. This impact would remain less than significant with implementation of adopted LSAP Update SEIR Mitigation Measure MM 3.10.2.

Extension Site
Development on the Extension Site would include parking lot removal, construction, and landscaping activities for the proposed above-ground parking garage. Project construction would involve subsurface disturbance for installation of foundations and/or utilities. There are no known cultural resources on or near the project site (Far Western 2023).

However, there is the potential to impact undiscovered archaeological resources during project construction. If such resources were to be represent “unique archaeological resources” as defined by CEQA in CEQA Guidelines Section 15064.5 and Public Resources Code Section 21083.2(g), any substantial change to or destruction of these resources would be considered a significant impact. The Extension Site has been previously developed with a surface parking lot and is unlikely to contain unrecorded archaeological resources and would be subject to state regulations overseeing the discovering of archeological resources. However, if unanticipated cultural resources are discovered during project construction ISI has agreed to implement Mitigation Measure MM 3.10.2 to halt construction and evaluate the resource Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-30 Intuitive North Site Modification Project Environmental Checklist and, if a unique archeological resource, avoid significant adverse impacts. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to an archaeological resource than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to an archaeological resource than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to archaeological resources the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. This impact would remain less than significant with implementation of adopted LSAP Update SEIR Mitigation Measure MM 3.10.2. c) Substantially disturb human remains, including those interred outside of formal cemeteries?
North Site
The LSAP Update SEIR determined that there is low likelihood of the project to disturb human remains and adherence to state regulations related to discovery of human remains would reduce impacts. Updates to the North Site would include refinements to the design of the North Site building to ensure consistency with the building on the South Site, such as adding an internal courtyard, changing vision and spandrel glazing in similar locations, extending the trellis element, and relocating mechanical equipment to the rooftop with screening structures . Although these activities could involve subsurface disturbance for installation of foundations and/or utilities, the portion of the project on the North Site would not include any increases in the floor area ratio or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. The project would no longer include an underground parking garage on the North Site. As such, excavation would be substantially reduced, which would lower the likelihood of encountering interred human remains. California Health and Safety Code Section 7050.5, CEQA Guidelines Section 15064.5, and California Public Resources Code Section 5097.98 specify the actions to be followed in the event of accidental discovery of human remains in a location other than a dedicated cemetery.

These sections also provide guidance if the remains are determined to be Native American. The project would be subject to state regulations overseeing the preservation of human remains. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to human remains than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to human remains than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to human remains the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt.

The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
The project would include construction, demolition, and landscaping activities for the proposed above-ground parking garage on the Extension Site. Construction of the parking garage would involve subsurface disturbance for installation of foundations and/or utilities. The Extension Site is developed with a surface parking lot and there is low probability of encountering human remains during project construction. However, if human remains are discovered during construction the project would be required to adhere to state regulations related to human remains. California Health and Safety Code Section 7050.5, CEQA Guidelines Section 15064.5, and California Public Resources Code Section 5097.98 specify the actions to be followed in the event of accidental discovery of human remains in a location other than a dedicated cemetery. These sections also provide guidance if the remains are determined to be Native American. The project would be subject to state regulations overseeing the preservation of human remains.

Therefore, the portion of the project on the East Site would not result in new significant impacts or substantially more Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-31 severe impacts related to human remains than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to human remains than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to human remains the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid .

Mitigation Measures from LSAP Update EIR
Mitigation Measures MM 3.10.2 was adopted as part of the LSAP EIR to ensure proper treatment of unknown archaeological resources. The following adopted mitigation measure referenced in the LSAP EIR and LSAP Update SEIR analysis and would continue to be applicable for the North Site if the project i s approved. ISI has agreed to implement this mitigation measure on the Extension Site in a letter dated December 20, 2023 and as included on the project site plans.

Mitigation Measure MM 3.10.2
All subsequent projects within the LSAP plan area shall be required to include information on the improvement plans that if, during the course of grading or construction cultural resources (i.e., prehistoric or historic sites) are discovered , work will stop in that area and within 100 feet of the find until a qualified archaeologist can access the significance of the find and, if necessary, develop appropriate treatment measures as part of a treatment plan in consultation with the City and all other appropriate agencies. The treatment plan shall include measures to document and protect the discovered resource. Consistent with CEQA Guidelines Section 15126.4 (b)(3), preservation in place will be the preferred method of mitigating impacts to the discovered resource. Pursuant to Government Code Section 6254.10, information on the discovered resource shall be confidential.

Conclusion
No new circumstances or project changes related to cultural resources have occurred that would result in new or substantially more severe cultural resources impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-32 Intuitive North Site Modification Project Environmental Checklist

4.6 ENERGY
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and Final
SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

6. Energy. Would the project:
a) Result in potentially significant
environmental impact due to
wasteful, inefficient, or unnecessary
consumption of energy resources,
during project construction or
operation?
Draft SEIR Impact

3.5-1;
Final SEIR identified
no change in impact
conclusion
No No No NA, impact would
be less than
significant
b) Conflict with or obstruct a state or
local plan for renewable energy or
energy efficiency?
Draft SEIR
Impact 3.5-2;
Final SEIR identified
no change in impact
conclusion
No No No NA, impact would
be less than
significant

4.6.1 Discussion
The City of Sunnyvale as well as the cities of Campbell, Cupertino, Gilroy, Los Altos, Los Altos Hills, Los Gatos, Milpitas, Monte Sereno, Morgan Hill, Mountain View, Saratoga, and unincorporated Santa Clara County are members of Silicon Valley Clean Energy (SVCE), which serves as the community choice aggre gation (CCA) for its member jurisdictions. SVCE was established in March 2016 following the adoption of the City of Sunnyvale’s 2014 CAP and works in partnership with Pacific Gas and Electric Company (PG&E) to deliver low-GHG electricity to customers within its member jurisdictions. Consistent with state law, all electricity customers in the city of Sunnyvale were automatically enrolled in SVCE; however, customers can choose to opt out and be served by PG&E. According to th e Sunnyvale Climate Action Plan Biennial Progress Report released in 2019, 98 percent of residential and commercial accounts received clean electricity from SVCE and 100 percent of City facilities were powered by renewable energy (City of Sunnyvale 2018). Currently, all power supplied by SVCE is carbon-free. PG&E supplies natural gas service to the City of Sunnyvale through state-regulated public utility contracts.

On August 13, 2019, the City of Sunnyvale adopted the Climate Action Playbook (Playbook) which builds upon the City’s previous Climate Action Plan (CAP 1.0) prepared in 2014. Through implementation of measures in the CAP 1.0, the City experienced a 12 percent decrease below 1990 emissions levels in 2016. As of 2020, the City emitted 564,827 metric tons of carbon dioxide equivalent (MTCO
2e), which was 15 percent below 2008 emissions. To demonstrate compliance with the state’s long-term climate change reduction goals, the City set targets to achieve an interim target of a 56 percent reduction below 1990 levels by 2030 (SB 32) with the goal of meeting the state’s target of 80 percent below 1990 emissions by 2050 (Executive Order [EO] S-3-05). The Playbook includes a Game Plan 2020 which contains the “next moves” for the City and contains 46 actions that are planned for implementation over three years (2019–2022). Several Playbook next moves are directly applicable to land use development projects. The City requires land use development projects to adhere to the Playbook as a condition of approval.

The E xtension Site is located in the City of Santa Clara and would be subject to the City of Santa Clara’s rules and regulations regarding energy, as well as the City of Santa Clara’s CAP (2022). The CAP sets goals for near term, interim, and long-term GHG emissions reductions. To achieve these goals, the CAP includes strategies which apply to multiple sectors (e.g. buildings and energy, transportation and land use, water resources) meant to increase energy efficiency and therefore reduce the amount of GHGs emitted. The City of Santa Clara owns and operates its own electric, water and sewer utilities. Silicon Valley Power (SVP) is the city-owned electric utility. As of December 2023, SVP provided power to 60,685 accounts. SVP totaled approximately 4,588 GWh of electricity between purchased and Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-33 generated power (SVP 2024). In 2022, SVP sourced 34.6 percent of its electricity from eligible renewable sources (i.e., biomass and biowaste, geothermal, eligible hydroelectric, solar, and wind) and 65.4 percent of its electricity from large hydroelectric. SVP did not source any electricity from coal- or natural-gas-powered sources in 2022 (SVP 2023).

Except as noted above, the regulatory setting provided in the LSAP Update SEIR remains applicable to this analysis. a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation?
North Site
Construction
Energy use related to construction of the ISI Project was addressed in Section 3.5 “Energy” of the LSAP Update SEIR.

The previous analysis concluded that impacts related to energy consumption during construction of the ISI Project would be less than significant because the consumption of energy during construction activities would be temporary and are not anticipated to require additional capacity or substantially increase peak or base period demands for electricity and other forms of energy.

Energy demand for construction of the North Site was accounted for in the LSAP Update SEIR analysis as the North Site accounts for a fraction of the estimated energy demand for construction of the LSAP . The energy needs for construction of the North Site would be temporary and are not anticipated to require additional capacity or substantially increase peak or base period demands for electricity and other forms of energy , beyond what was assumed in the LSAP Update SEIR because there would be no increases in square footage for buildings on the North Site. Non-renewable energy would not be consumed in a wasteful, inefficient, and unnecessary manner when compared to other construction activity in the region. Construction energy consumption from implementation of the North Site would be less than what was analyzed in the LSAP Update SEIR as the previously approved below-ground parking structure would be eliminated from the project and a parking structure would be constructed on the Extension Site. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to energy the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid .

Operational
Energy use related to operation of the ISI Project was addressed in Section 3.5 “Energy” of the LSAP Update SEIR. The previous analysis concluded that impacts related to energy consumption during operation of the ISI Project would be less than significant because the ISI Project would be built to meet current Building Title 24 Building Energy Standards and would consist of infill development and be built with a range of land uses in proximity to a transit station, which will reduce transportation-related energy demand compared to buildings in locations not close to high quality transit.

Energy demand during operation of the North Site was accounted for in the previous analysis as the North Site accounts for only a portion of the total estimated energy demand during operation of the ISI Project. The North Site would increase electricity consumption in the region relative to existing conditions. However, the new facilities would, at a minimum, be built to 2022 Title 24 Building Energy Efficiency Standards, which are more efficient than 2019 Standards, as the 2022 Energy Code encourages efficient electric heat pumps, expands solar photovoltaic and battery storage standards, and strengthens ventilation standards. Similar to what was accounted for in the LSAP Update SEIR, the project would be all electric, with no natural gas. Energy demand during project operation would be similar to what was accounted for in the LSAP Update SEIR because variables used to estimate energy demand such as land Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-34 Intuitive North Site Modification Project Environmental Checklist use type, building size, and employee trip rate would not vary from what was accounted for in the SEIR and would therefore not require additional energy consumption. It is likely that energy demand associated with operation of the North Site would be less than what was estimated in the LSAP Update SEIR because the project would not include the previously approved underground parking structure. This would result in decreased electricity and fuel consumption on the North Site. For these reasons, the project would not result in the wasteful or inefficient use of energy beyond what was addressed in the LSAP Update SEIR. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to energy the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension
Site
Construction
Similar to the North Site, the project applicant would be required to operate and maintain construction equipment and transport construction materials. The one-time energy expenditure required to construct the parking structure and related infrastructure associated with the proposed Extension Site would be nonrecoverable. Most energy consumption would result from operation of off-road construction equipment and on-road vehicle trips associated with commutes by construction workers and haul trucks trips.

The energy needs for construction of the proposed Extension Site would be temporary and are not anticipated to require additional capacity or substantially increase peak or base period demands for electricity and other forms of energy. Although the energy required to construct the above-ground parking structure on the Extension Site was not analyzed in the LSAP Update SEIR, it is expected that the energy expenditure would be similar to what would have been required to construct the below-ground parking structure included in the previously approved land uses for the project. The types of construction equipment would be similar to construct the p roposed Extension Site. However, it is likely that energy consumption during project construction would be less than what was accounted for in the previous analysis because the parking structure is no longer proposed to be located underground and would thus not require significant excavation and associated hauling trips. There would still be excavation for footings, utilities, and foundation of the above-ground parking structure, but it is minimal compared to a full excavation for a below- ground parking structure.

The associated energy consumption would be typical of that associated with parking projects of this size in an urban setting. The one-time energy expenditure required to construct the physical infrastructure associated with the project would be nonrecoverable. There is no atypical construction related energy demand associated with the p roposed Extension Site. Non-renewable energy would not be consumed in a wasteful, inefficient, and unnecessary manner when compared to other construction activity in the region. Therefore, the portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to energy the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-35 Operation
The Extension Site would increase electricity consumption in the region relative to existing conditions. However, the new facilities would, at a minimum, be built to 2022 Title 24 Building Energy Efficiency Standards, which are more efficient than 2019 Standards, as the 2022 Energy Code expands solar photovoltaic and battery storage standards , strengthens ventilation standards, and requires energy-efficient lighting (CEC 2022). The parking garage would have no natural gas use and would be all electric. Title 24 Building Energy Efficiency Standards would be integrated into the Proposed Extension Site to reduce the projects energy demands.

The estimated amount of energy to be consumed during operational activities for the Extension Site would be similar to the previously proposed North Site underground parking structure. Operating the parking garage on the Extension Site would not result in increases in project related VMT, trip rate, or electricity use because relocating the parking structure above ground, as opposed to being located underground as was analyzed in the LSAP Update SEIR, would not result in an increase in these variables which are typically associated with the consumption of energy.

Impacts related to operational energy consumption would not be greater than what was accounted for in the LSAP Update SEIR. For these reasons, the portion of the project proposed on the Extension Site would not result in wasteful, inefficient, or unnecessary consumption of energy. Therefore, the portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to energy the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.
b) Conflict with or obstruct a state or local plan for renewable energy or energy efficiency?
Since the adoption of the LSAP, CARB adopted the Final 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) on December 16, 2022, which traces the State’s the pathway to achieve its carbon neutrality and an 85 percent reduction in 1990 emissions goal by 2045. It identifies the reductions needed by each GHG emission sector (e.g., transportation [including off-road mobile source emissions], industry, electricity generation, agriculture, commercial and residential, pollutants with high global warming potential, and recycling and waste) to achieve these goals.

As noted above, the project would comply with the 2022 version of the Title 24 Building Energy Efficiency Standards, which increase the energy efficiency of new development projects in the state and move the State closer to its zero - net energy goals outlined in the 2022 Scoping Plan. The respective portions of the project site (North Site and Proposed Extension Site) would be automatically enrolled as a member of the SVCE, which serves as the CCA for the City of Sunnyvale, and SVE, which is the utility providing electricity to the City of Santa Clara. SVCE works in partnership with PG&E to deliver low-GHG electricity to customers within its member jurisdictions. According to the Sunnyvale Climate Action Plan Biennial Progress Report released in 2018, 98 percent of residential and commercial accounts received electricity from SVCE, and 100 percent of City facilities were powered by renewable energy (City of Sunnyvale 2018). SVP provides electricity services to the City of Santa Clara and has provided 100 percent carbon-free energy to its customers as of 2017. By complying with Title 24 2022 Building Energy Efficiency Standards and participating in the CCA, the project would comply with the State’s 2022 Scoping Plan Update, the City of Sunnyvale’s local Climate Action Plan Playbook, and the City of Santa Clara’s CAP, to increase energy efficiency and reduce energy use from fossil fuel sources. Additionally, the prepared parking garage on the Extension Site would include electric vehicle charging stations and conduits, which promotes electric vehicle use to displace less fuel efficient and more polluting gas-powered vehicles. Implementation of the project would not conflict with or obstruct a State or local plan for renewable energy or energy efficiency (see discussion under Item B in Section 4.8, “Greenhouse Gas Emissions”) because the project would comply with applicable state rules (e.g., Title 24, parts 6 and 11) and local plans (e.g., each city’s respective climate action plan) that promote use of renewable energy and energy efficiency. The Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-36 Intuitive North Site Modification Project Environmental Checklist project would not result in new significant impacts or substantially more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to energy than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to energy the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Mitigation Measures from LSAP Update EIR
No mitigation measures were identified in the certified LSAP EIR and the LSAP Update SEIR regarding energy, nor are any additional mitigation measures required for the project.

Conclusion
No new circumstances or project changes related to energy have occurred that would result in new or substantially more severe energy impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-37

4.7 GEOLOGY AND SOILS
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and
Final SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

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

i) Rupture of a known earthquake
fault, as delineated on the most
recent Alquist-Priolo Earthquake
Fault Zoning Map issued by the
State Geologist for the area or
based on other substantial
evidence of a known fault? (Refer to
California Geological Survey Special
Publication 42.)
Draft SEIR page

3.6-2
No No No NA, no impact
would occur.
ii) Strong seismic ground shaking? Draft SEIR page

3.6-2
No No No NA, no impact
would occur.
iii) Seismic-related ground failure,
including liquefaction?
Draft SEIR page

3.6-2
No No No NA, no impact
would occur.
iv) Landslides? Draft SEIR page

3.6-2
No No No NA, no impact
would occur.
b) Result in substantial soil erosion or the
loss of topsoil?
Draft SEIR pages

3.6-2 and 3.6-3
No No No NA, no impact
would occur.
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?
Draft SEIR page

3.6-3
No No No NA, no impact
would occur.
d) Be located on expansive soil, as defined
in Table 18-1-B of the Uniform Building
Code (1994, as updated), creating
substantial direct or indirect risks to life
or property?
Draft SEIR page

3.6-3
No No No NA, no impact
would occur.
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?
Draft SEIR page

3.6-3
No No No NA, no impact
would occur.
f) Directly or indirectly destroy a unique
paleontological resource or site or
unique geologic feature?
Draft SEIR Impact

3.6-1
No No No Yes, impacts would
be less than
significant with the
application of the
adopted mitigation
measure.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-38 Intuitive North Site Modification Project Environmental Checklist

4.7.1 Discussion
No substantial change in the environmental and regulatory settings related to geology and soils, described in the LSAP Update SEIR Section 3.6, “Geology, Soils, and Paleontological Resources,” has occurred since certification of the LSAP Update SEIR. The regional and local settings remain the same as stated in the LSAP Update SEIR . In addition, the City of Santa Clara City Code Chapter 15.55 contains provisions to control erosion and ensure geologic and soil stability for all development in the City of Santa Clara.

The effects of the environment on a project are generally outside the scope of CEQA unless the project would exacerbate these conditions, as concluded by the California Supreme Court (see [2015] 62 Cal.4 th 369, 377 [“we conclude that agencies generally subject to CEQA are not required to analyze the impact of existing environmental conditions on a project’s future users or residents. But when a project risks exacerbating those environmental hazards or conditions that already exist, an agency must analyze the potential impact of such hazards on future residents or users.”]). Changes to the CEQA Guidelines to reflect this decision were adopted on December 28, 2018. Local agencies are not precluded from considering the impact of locating new development in areas subject to existing environmental hazards; however, CEQA cannot be used by a lead agency to require a developer or other agency to obtain an EIR or implement mitigation measures solely because the occupants or users of a new project would be subjected to the level of hazards specified. However, previous discussions of effects of the environment related to geology and soils on future residents are included herein for disclosure purposes. a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving:
i) Rupture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? (Refer to California Geological Survey Special Publication 42.)
As discussed in the LSAP Update SEIR, the LSAP area is not located within an Alquist-Priolo Earthquake Fault Zone and would therefore not be subject to hazards associated with substantial fault-rupture. The North Site is located within the LSAP area, which was determined not to be subject to hazards associated with fault-rupture. Similarly, the Extension Site is not located within an Alquist-Priolo Earthquake Fault Zone and thus would not be subject to hazards associated with fault-rupture (CGS 2023a). The project also would not alter or exacerbate the risk of earthquake fault ruptures in the area. The project would not result in new significant impacts or substantially more severe impacts related to an earthquake fault than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to an earthquake fault than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to eart hquake faults the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. ii) Strong seismic ground shaking?
See item a- III) below.
iii) Seismic-related ground failure, including liquefaction? North Site
As discussed in the LSAP Update SEIR, the ISI Project is located in a seismically active area and could experience strong seismic ground shaking and seismic-related ground failure from earthquakes on active faults located outside of the LSAP plan area. Implementation of the project could thus result in the exposure of people, structures, and infrastructure to seismic-related hazards such as ground shaking, and seismic-related ground failure such as Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-39 liquefaction and settlement. Updates to the North Site would include refinements to the design of the North Site building to ensure consistency with the building on the South Site, such as adding an internal courtyard, changing vision and spandrel glazing in similar locations, extending the trellis element, and relocating mechanical equipment to the rooftop with screening structures. The portion of the project on the North Site would not include any increases in the floor area ratio or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. Further, there are no changes in the soil conditions on the North Site that would alter its performance in the event of an earthquake. Therefore, impacts from seismic ground shaking, ground failure, and liquefaction would be similar to those analyzed in the LSAP Update SEIR. The portion of the project on the North Site would be required to adhere to existing regulations and building standards, such as the CBC implemented through Chapter 16.16 of the City’s Municipal Code. The CBC includes design criteria for seismic loading and other geologic hazards to minimize impacts of ground shaking on buildings. The project would also be subject to the geotechnical recommendations made by the geotechnical study for the ISI Project. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to seis mic ground failure than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to seismic ground failure than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to seismic ground failure the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
The Extension Site is located in the same seismically active area as the LSAP and could experience strong seismic ground shaking and seismic-related ground failure from earthquakes on active faults. Increases in population and development over time could result in the exposure of people, structures, and infrastructure to seismic- related hazards such as ground shaking, and seismic-related ground failure such as liquefaction and settlement.

Similar to the North Site and as considered in the LSAP Update EIR, the Extension Site is located in the Coast Ranges geomorphic province of California that is characterized by northwest-trending valleys and ridges. These topographic features are controlled by folds and faults that resulted from the collision of the Farallon plate and North American plate and subsequent strike-slip faulting along the San Andreas Fault system. The San Andreas Fault is more than 600 miles long from Point Arena in the north to the Gulf of California in the south. The major active faults in the area are the San Andreas, Hayward, Calaveras, and San Gregorio Faults. According to the US Geologic Survey, there is a high risk of earthquakes and liquefaction potential at the Extension Site (USGS 2006). During a major earthquake on a segment of one of the nearby faults, very strong shaking could occur at the Extension Site and impact the proposed above ground parking structure. Strong shaking during an earthquake can result in ground failure such as that associated with soil liquefaction. Intensity of earthquake ground motion at the Extension Site would depend on the characteristics of the generating fault, distance to earthquake epicenter, and magnitude and duration of the earthquake.

Implementation of existing regulations and building standards included in Santa Clara Municipal Code Chapter 15.55 would address seismic hazard impacts on the proposed parking garage. Local regulations include design criteria for seismic loading and other geologic hazards to minimize impacts of ground shaking on buildings. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to seismic ground failure than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to seismi c ground failure than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to seismic ground failure the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid .

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-40 Intuitive North Site Modification Project Environmental Checklist iv) Landslides?
As discussed in the LSAP Update SEIR, the LSAP area is not located within a landslide hazard zone and would therefore not be subject to hazards associated with landslides. The North Site is located within the LSAP area evaluated in the LSAP Update SEIR, which was determined not to be subject to hazards associated with fault-rupture or landslides. Similarly, the Extension Site is not located within a landslide hazard zone and would not be subject to landslides (CGS 2023b). The project would not result in new significant impacts or substantially more severe impacts related to a landslide than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a landslide than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to landslides the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Projec t, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt.

The findings of the LSAP Update SEIR for the ISI Project remain valid. b) Result in substantial soil erosion or the loss of topsoil? North Site
LSAP Update SEIR stated that implementation of the project would include development of new uses, redevelopment, and infrastructure improvements. Grading and site preparation activities associated with such development could temporarily remove buildings and pavement potentially disturbing the soils, which could result in additional potential for wind and water erosion. However, construction within the LSAP area would be required to comply with CBC Chapter 70 standards, which would ensure implementation of appropriate site-specific measures during grading and other construction activities to reduce and minimize the potential for soil erosion to a less than significant level.

Additionally, any development involving clearing, grading, or excavation that causes soil disturbance of one or more acres, such as the project, would be required to prepare and implement a stormwater pollution prevention plan (SWPPP), which includes specific requirements related to the installation and maintenance of erosion control measures.

The North Site is approximately 15.6 acres and would require the preparation of a SWPPP. The SWPPP would consider the full range of erosion control best management practices (BMPs), including any additional site-specific and seasonal conditions. As further discussed in LSAP Update SEIR the State Water Resources Control Board has adopted a Construction General Permit (Order No. 20090009-DWQ, as amended by Order No. 2010-0014-DWQ and Order 2012- 0006-DWQ) that provides additional standards and requirements to avoid soil erosion. Compliance with existing standards and BMPs would minimize soil erosion and loss of topsoil. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to soil erosion than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to soil erosion than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to soil erosion the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
The portion of the project on the Extension Site would include construction, demolition, and landscaping activities for the proposed parking garage. Grading and site preparation activities associated with such development would remove pavement potentially disturbing the soils, which could result in additional potential for erosion from wind and water. However, project construction would be required to comply with CBC Chapter 70 standards, which would ensure implementation of appropriate site-specific measures during grading and other construction activities to reduce and minimize the potential for soil erosion.

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Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-41 The Extension Site is approximately 2.5 acres and would require the preparation of a SWPPP. The SWPPP would consider the full range of erosion control BMPs, including any additional site -specific and seasonal conditions. The State Water Resources Control Board has adopted a Construction General Permit (Order No. 20090009- DWQ, as amended by Order No. 2010-0014-DWQ and Order 2012-0006-DWQ) that provides additional standards and requirements to avoid soil erosion. Post construction National Pollutant Discharge Elimination System (NPDES) Permit requirements include ensuring the project would not include areas of exposed topsoil .

Compliance with existing standards and BMPs would minimize soil erosion and loss of topsoil on the Extension Site.

The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to soil erosion than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to soil erosion than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to soil erosion the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. 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?
North Site
The LSAP Update SEIR stated that future structures and improvements that could be developed under the LSAP could experience stresses on various sections of foundations and connected utilities, as well as structural failure and damage to infrastructure if located on expansive or unstable soils. The City of Sunnyvale requires preparation of geotechnical reports for all development projects, which include soil sampling and laboratory testing to determine the soil’s susceptibility to expansion and differential settlement and provide recommendations for design and construction methods to reduce potential impacts, as necessary.

The geotechnical investigation completed for the ISI Project during preparation of the LSAP Update SEIR identified potentially expansive and settlement-prone soils within the project site (Cornerstone Earth Group 2019). The report recommended design recommendations to reduce potential impacts of lateral spreading. In addition to the design recommendations, the CBC requires the incorporation of special design and construction methods to reduce potential site conditions related to expansive soil and settlement. Updates to the North Site would include refinements to the design of the North Site building to ensure consistency with the building on the South Site, such as adding an internal courtyard, changing vision and spandrel glazing in similar locations, extending the trellis element, and relocating mechanical equipment to the rooftop with screening structures. The project would not include any increases in the number of employees, density, floor area ratio, or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. As such, compliance with recommendations in the previously prepared geotechnical report and with CBC regulations and standards would ensure the adequate design and construction of building foundations, and ground preparation to resist soil movement.

For a discussion of impacts relating to landslides, see analyses under section a-IV) above.

The portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to unstable soil than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to unstable soil than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to unstable soils the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-42 Intuitive North Site Modification Project Environmental Checklist are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
New structures and improvements completed in the project area could experience stresses on various sections of foundations and connected utilities, as well as structural failure and damage to infrastructure if located on expansive or unstable soils. The Extension Site is located above potentially expansive and settlement-prone soils. The CBC requires the incorporation of special design and construction methods to reduce potential site conditions related to expansive soil and settlement. The Extension Site would be subject to compliance with City of Santa Clara Municipal City Code Chapter Compliance with these recommendations, regulations and standards would ensure the adequate design and construction of building foundations, and ground preparation to resist soil movement. R ecommended designs to reduce potential impacts of lateral spreading are discussed under section a-iii. For a discussion of impacts relating to landslides, see analyses under section a-IV) above.

Therefore, with continued compliance with all applicable regulations related to soil instability impacts from the project impacts would remain less than significant. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to unstable soil than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to unstable soil than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to unstable soils the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994, as updated), creating substantial risks to life or property? See analyses under item c) above.
e) Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? As described in the LSAP and consistent with the analyses in the LSAP Update S EIR, the projects in the LSAP plan area would use the City’s existing wastewater conveyance and treatment systems. The project would result in a new parking garage on the Extension Site which would only require water for fire services as a safety precaution and would not require generate wastewater. The project would not include any increases in the number of employees, density, floor area ratio, or square footage of buildings approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. The project would not result in new significant impacts or substantially more severe impacts related to a septic system than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a septic system than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to septic systems the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid . f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
As described in the LSAP Update SEIR, the underlying geology of the ISI Project site consists of basin and alluvial deposits that have the potential to contain fossils, based on previously reported finds in similar materials in other Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-43 locations in the Bay Area. The project would involve the installation of footings and foundations and/or excavations.

Because the North Site and Extension Site are developed, it is likely that a substantial amount of ground disturbance and placement of fill has altered the subsurface soils and underlying geologic materials at varying depths. I f the project site were excavated to depths greater than 10 feet, it is possible the excavation could be within Holocene age deposits or older Pleistocene alluvial materials, which could contain fossils. Paleontological resources are classified as nonrenewable scientific resources. The inadvertent damage or destruction during excavation and grading activities at construction sites could further reduce this finite resource base. Therefore, there is the potential to uncover paleontological resources during construction on the North Site and eastern site extension. However, since the project would no longer include an underground parking garage on the North Site, excavation depths would be reduced. The likelihood of uncovering paleontological resources would be lower than anticipated in the LSAP Update SEIR. Nonetheless, in the case paleontological resources are uncovered during construction, the implementation of Mitigation Measure MM 3.7.4 that would require halting construction activities and protecting any discovered paleontological resources. LSAP Mitigation Measure MM 3.7.4 would be required on the Extension Site and the applicant has agreed to implement this measure. Implementation of LSAP Mitigation Measure MM 3.7.4 for the project would reduce this impact to a less than significant level.

The project would not result in new significant impacts or substantially more severe impacts related to a paleontological resource than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to a paleontological resource than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to paleontological resources the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

This impact would remain less than significant with implementation of adopted LSAP Mitigation Measure MM 3.7.4.

Mitigation Measures from LSAP Update EIR
Mitigation Measure MM 3.7.4 was adopted as part of the LSAP EIR to ensure proper treatment of paleontological resources uncovered during project construction. The following adopted mitigation measures referenced in the LSAP EIR and LSAP Update SEIR analysis and would continue to be applicable for the North Site if the project was approved. ISI has also agreed to implement these mitigation measures on the Extension Site in a letter dated December 20, 2023 and as included on the project site development plans.

Mitigation Measure MM 3.7.4
All subsequent projects within the LSAP plan area shall be required to include information on the improvement plans that if, during the course of grading or construction fossils are discovered, work shall be halted immediately within 50 feet of the discovery, the Sunnyvale Community Development Department shall be notified, and the significance of the find and recommended actions must be determined by a qualified paleontologist. In addition, before the commencement of project site preparation, all construction personnel shall be informed of the potential to discover fossils and the procedures to follow.

Conclusion
No new circumstances or project changes related to geology and soil have occurred that would result in new or substantially more severe geology and soils impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

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Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-44 Intuitive North Site Modification Project Environmental Checklist

4.8 GREENHOUSE GAS EMISSIONS
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and
Final SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

8. Greenhouse Gas Emissions. Would the project:
a) Generate greenhouse gas emissions,
either directly or indirectly, that may
have a significant impact on the
environment?
Draft SEIR Impact

3.7-1;
Final SEIR
identified no
change in impact
conclusion
No No No NA, impact would
be less than
significant
b) Conflict with an applicable plan, policy
or regulation adopted for the purpose
of reducing the
emissions of greenhouse
gases?
Draft SEIR Impact

3.7-1;
Final SEIR
identified no
change in impact
conclusion
No No No NA, impact would
be less than
significant

4.8.1 Discussion
The LSAP Update SEIR determined that the regulatory setting of the 2016 LSAP EIR remained applicable to the LSAP Update SEIR analysis. Several new laws, plans, regulations, and guidelines have been introduced that related to GHGs and have become effective since the writing of the LSAP Update SEIR. These laws, regulations, plans, and guidelines are summarized below:
 Scoping Plan Update: EO B-30-15 and SB 32 require CARB to prepare updates to the Scoping Plan to address the 2030 target for the state. On December 24, 2017, CARB approved the 2017 Climate Change Scoping Plan Update, which outlines potential regulations and programs, including strategies consistent with Assembly Bill (AB) 197 requirements, to achieve the 2030 target. CARB released the Final 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan) on November 16, 2022, pursuant to AB 1279 (summarized below). The 2022 Scoping Plan traces the pathway for the state to achieve its carbon neutrality goal by 2045 using a combined top down, bottoms up approach using various scenarios. CARB adopted the 2022 Scoping Plan on December 16, 2022. The 2022 Scoping Plan readjusted the previous SB 32 target of reducing statewide GHG emissions by 40 percent below a 1990 inventory to 48 percent in consideration of the more aggressive targets established by AB 1279.  AB 1279: On September 16, 2022, the State legislature passed AB 1279 which codified stringent emissions targets for the State of achieving carbon neutrality and an 85 percent reduction in 1990 emissions level by no later than 2045 (this superseded the previous GHG emissions reduction target set forth by EO S-3- 05 and SB 32).  SB 379: SB 379 was passed by the State on September 16, 2022. This bill requires every city and county to implement an online permitting platform that verifies code compliance and issues permits in real time for a residential solar system. The bill would require the Energy Commission to set guidelines, adopted through a specified public process to report the number of permits issued for residential solar energy system and residential energy storage systems paired with residential solar energy systems and the relevant characteristics of those systems.  California Renewables Portfolio Standard: SB X1-2 of 2011 requires all California utilities to generate 33 percent of their electricity from renewables by 2020. SB 100 of 2018 sets a three-stage compliance period requiring all California utilities, including independently owned utilities, energy service providers, and community choice aggregators, to generate 52 percent of their electricity from renewables by December 31, 2027; 60 percent by December 31, 2030; and 100 percent carbon-free electricity by December 31, 2045. On September 16, 2022, SB Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-45 1020 was signed into law. This bill supersedes the goals of SB 100 by requiring that eligible renewable energy resources and zero-carbon resources supply 90 percent of all retail sales of electricity to California end-use customers by December 31, 2035, 95 percent of all retail sales of electricity to California end-use customers by December 31, 2040, 100 percent of all retail sales of electricity to California end-use customers by December 31, 2045, and 100 percent of electricity procured to serve all state agencies by December 31, 2035.  Bay Area Air Quality Management District Justification Report: In April 2022, the BAAQMD released the Justification Report: CEQA Thresholds for Evaluating the Significance of Climate Impacts (Justification Report). This report includes guidance for determining a project’s consistency with California’s long-term climate goal of achieving carbon neutrality by 2045. The report recommends using the approach endorsed by the California Supreme Court in Center for Biological Diversity v. Department of Fish & Wildlife (2015) (62 Cal.4th 204), which evaluates a project based on its effect on California’s efforts to meet the State’s long term climate goals. As the Supreme Court held in that case, a project that would be consistent with meeting those goals can be found to have a less than significant impact on climate change under CEQA. If a project would contribute its “fair share” of what will be required to achieve those long-term climate goals, then a reviewing agency can find that the impact will not be significant because the project will help to mitigate the effects of global climate change (62 Cal.4th 220–223) (BAAQMD 2022).
 Building Energy Efficiency Standards: Energy conservation standards for new residential and non- residential buildings were adopted by the California Energy Resources Conservation and Development Commission (now the CEC) in June 1977 and most recently revised in 2022 (Title 24, Part 6, of the California Code of Regulations).

Title 24 requires the design of building shells and building components to conserve energy. The standards are updated every three years to allow for consideration and possible incorporation of new energy efficiency technologies and methods. The 2022 Building Energy Efficiency Standards, which were recently adopted on August 11, 2021, became effective on January 1, 2023.
 CALGreen Updates: CALGreen established planning and design standards for sustainable site development, energy efficiency (in excess of the California Energy Code requirements), water conservation, material conservation, and internal air contaminants and CALGreen standards are updated every three years. The 2022 standards became effective on January 1, 2023 and replace the 2019 standards that are current as of the writing of this analysis. Each iteration of the CALGreen standards improves the energy efficiency and sustainability of new development from the prior iteration.
 Advanced Clean Cars program: In January 2012, CARB approved the Advanced Clean Cars program which combines the control of GHG emissions and criteria air pollutants, as well as requirements for greater numbers of zero-emission vehicles, into a single package of standards for vehicle model years 2017 through 2025. The program’s zero-emission vehicle regulation requires battery, fuel cell, and/or plug-in hybrid electric vehicles to account for up to 15 percent of California’s new vehicle sales by 2025. In August 2022, CARB adopted the Advanced Clean Cars II program, which sets sales requirements for zero emission vehicles (ZEVs) to ultimately reach the goal of 100 percent ZEV sales in the state by 2035.  City of Sunnyvale 2020 Greenhouse Gas Emissions Inventory. The City of Sunnyvale tracks and reports its sources of GHG emissions through a regularly updated emissions inventory. The most recent inventory was created for the year 2020. Table 4.8-1 summarizes Sunnyvale’s GHG emissions by sector in 2020.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-46 Intuitive North Site Modification Project Environmental Checklist Table 4.8-1 City of Sunnyvale 2020 Greenhouse Gas Emissions Inventory Sector MTCO2e Percent
Transportation 268,180 47
Commercial/Industrial Gas 130,080 23
Residential Gas 101,838 18
Commercial/Industrial Electric 2,259 <1
Residential Electric 678 <1
Solid Waste 41,684 7
Off Road Equipment 18,244 3
Total 1 564,827 100
1 Total may not sum due to rounding.

Notes: MTCO2e = metric tons of carbon dioxide-equivalent Source: City of Sunnyvale 2019a.
 City of Santa Clara 2016 Greenhouse Gas Emissions Inventory. The City of Santa Clara tracks and reports its sources of GHG emissions through an emissions inventory which details the annual emissions of GHGs by sector for the inventory year. The most recent inventory was created for the year 20 16 and is included in the City of Santa Clara’s 2018 CAP. Table 4.8-2 summarizes the city’s GHG emissions by sector in 2016.

Table 4.8-2 City of Santa Clara 2016 Greenhouse Gas Emissions Inventory Sector MTCO2e Percent
Commercial and Industrial 1,080,261 61
Transportation and Mobile Sources 505,989 29
Residential 132,912 8
Solid Waste 25,724 1
Water and Wastewater 24,292 1
Total 1 1,769,178 100
1 Total may not sum due to rounding.

Notes: MTCO2e = metric tons of carbon dioxide-equivalent Source: City of Santa Clara (2018).
 City of Santa Clara Climate Action Plan. The City of Santa Clara adopted the Climate Action Plan 2022 in June 2022. The Climate Action Plan 2022 sets new targets for reaching emissions reductions across five main focus areas including: building and energy, transportation and land use, materials and consumption, natural systems and water resources, and community resilience and wellbeing. The new targets of the Climate Action Plan 2022 include a near term target of 40 percent reduction in GHG emissions by 2030; interim target of 80 percent reduction in GHG emissions by 2035; and long-term target of carbon neutrality no later than 2045. a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the environment?
North Site
Impact 3.7-1 in Section 3.7, “Greenhouse Gas Emissions and Climate Change,” of the LSAP Update SEIR evaluated whether the ISI Project would generate GHG emissions that may have a significant impact on the environment or conflict with an applicable plan adopted for the purpose of reducing GHG emissions. It was noted that the LSAP Update includes the expansion of the LSAP boundary designated for the construction and operation of the ISI Project. Thus, the total net emissions from the ISI Project are considered a subset of the total LSAP Update emissions and the ISI Project emissions were evaluated in the LSAP Update’s net emissions analysis. The analysis stated that Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-47 construction and operation of the ISI Project would generate a total of 17,421 MTCO2e over the 3-year construction period and annual operational emissions of 9,644 MTCO2e. The LSAP Update SEIR concluded that the ISI Project would not exceed the City’s updated GHG efficiency metric threshold of 1.27 metric tons of carbon dioxide equivalent per year per service population (MTCO2e/yr/SP) and would therefore not result in a new or substantially more severe impact to climate change beyond what was identified in the 2016 LSAP EIR.

Construction
The project would result in construction-related exhaust GHG emissions from the use of heavy-duty off-road construction equipment, material transport and hauling, and worker commutes. Construction on the North Site would not involve changes to construction activities, phasing, duration, equipment type/number, worker commute trips, or intensity that would be greater than those that were analyzed in the LSAP Update S EIR because the land use type and size of the project would be similar to what was analyzed in the LSAP Update SEIR. Emissions of GHGs associated with construction of the North Site would be less than what was analyzed in the SEIR because the parking garage previously proposed to be located under the North Site building would not be constructed on the North Site. GHG emissions that would have occurred as a result of excavation and hauling activities from the underground parking garage would not occur on the North Site. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a GHGs than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to GHGs than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to GHGs the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Operations
Emissions of GHGs associated with North Site operations would not substantially differ from those addressed in the LSAP Update SEIR because the project would not include any increases in the number of employees, building square footage, electricity demand, water demand, waste generation, or employee trip rate approved by the ISI Special Development Permit and analyzed in the LSAP Update SEIR. Therefore, the GHG emissions from these sources were accounted for in the LSAP SEIR analysis. Additionally, GHG emissions associated with operation of the North Site account for a portion of the total operation-related GHG emissions from the ISI Project, which did not exceed the City’s updated GHG efficiency metric threshold of 1.27 MTCO
2e/yr/SP. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a GHGs than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to GHGs than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to GHGs the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Extension Site
Construction
The project would result in construction-related exhaust GHG emissions from the use of heavy-duty off-road construction equipment, material transport and hauling, and worker commutes from construction of the parking garage. Emissions of GHGs related to construction of the proposed parking garage were accounted for as part of the ISI Project analysis in the LSAP Update SEIR as the below-ground parking structure previously proposed to be constructed on North Site. Relocating the parking structure above-ground would not result in more intensive use of heavy-duty off-road construction equipment, material transport and hauling, or worker commutes as compared to what was addressed in the LSAP Update SEIR analysis. Construction activities would be less intense than what was analyzed in the LSAP Update SEIR because significant excavation would not be required for the above-ground Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-48 Intuitive North Site Modification Project Environmental Checklist parking structure, whereas the previous analysis included excavation to accommodate the previously planned below - ground parking structure. There would still be excavation for footings, utilities, and foundation of the above-ground parking structure, but it would be minimal compared to a full excavation for a below-ground parking structure.

Excavation typically involves the use of additional off road equipment and numerous hauling trips to export excavated soil. These activities typically result in increased emissions of GHGs, especially those relating to diesel exhaust from offroad equipment.

The parking garage would be located in the City of Santa Clara and is not subject to the City of Sunnyvale’s GHG efficiency metric which was used in the LSAP Update SEIR to determine impact significance relating to GHG emissions that would result from construction of the ISI Project. Therefore, because the project is under the jurisdiction of the BAAQMD, BAAQMD guidance regarding construction-related GHGs can be utilized. The BAAQMD states in the Justification Report, from “Land Use Projects and Plans,” that “There is no proposed construction-related climate impact threshold at this time. Greenhouse gas emissions from construction represent a very small portion of a project’s lifetime GHG emissions. The proposed thresholds for land use projects are designed to address operational GHG emissions which represent the vast majority of project GHG emissions” (BAAQMD 2022). In the absence of a numerical threshold for GHGs, BAAQMD states that a project would not result in a significant impact related to GHG’s if the project is determined to be consistent with a local GHG reduction strategy that meets the criteria under CEQA Guidelines Section 15183.5(b) (BAAQMD 2022). In accordance with BAAAQMD’s recommendation, Table 4.8-4 under Item (b) below provides a comparison of the project’s consistency with the Santa Clara CAP. As stated in Item (b), the portion of the project on the Extension Site would be consistent with the goals and policies of the Santa Clara CAP.

Because the project would be consistent with the applicable local GHG reduction strategy, as recommended by the BAAQMD, impacts would remain less than significant. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a GHGs than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to GHGs than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to GHGs the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Operations
Emissions of GHGs that would occur from operation of the Extension Site parking garage were accounted for under Impact 3.7-1 of the LSAP Update SEIR analysis; however, these emissions would have been generated from the previously proposed North Site underground parking structure. The parking garage on the Extension Site would result in similar VMT and electricity use as the underground parking garage analyzed in the LSAP Update SEIR. VMT and electricity are the main contributors of a parking garage’s GHG emissions and therefore the GHG emissions accounted for in the LSAP Update SEIR for the underground parking garage cover the proposed above-ground parking structure.

Additionally, as stated above, the ISI Project would be required to implement a TDM Plan that achieves a 35 percent peak hour and 20 percent daily trip reduction as required by the LSAP.. The project falls under the jurisdiction of the BAAQMD, which includes guidance for determining a project’s consistency with California’s long-term climate goals which specifies in the BAAQMD Justification Report. The Justification Report presents BAAQMD’s recommended thresholds of significance for use in determining whether a proposed project will have a significant impact on climate change and provides a detailed discussion of the basis for the thresholds. The Air District recommends that these thresholds of significance be used by public agencies to comply with the California Environmental Quality Act (CEQA). recommends using the approach endorsed by the California Supreme Court in Center for Biological Diversity v.

Department of Fish & Wildlife (2015) (62 Cal.4th 204), which evaluates a project based on its effect on California’s efforts to meet the State’s long term climate goals. As the Supreme Court held in that case, a project that would be consistent with meeting those goals can be found to have a less than significant impact on climate change under CEQA. As shown in Item (b) below, the project would be consistent with the goals and policies of the City of Santa Clara’s CAP. Impacts would remain less than significant. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a GHGs than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to GHGs than Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-49 were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to GHGs the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid. b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of greenhouse gases?
North Site
The LSAP Update SEIR determined that the ISI Project would be consistent with the City of Sunnyvale’s 2019 Climate Action Playbook. Table 4.8-3 below provides a detailed summary of project consistency with the 2019 Sunnyvale Climate Action Playbook for development on the North Site (strategies and plays which are not applicable to the project were not included in the consistency analysis).

Table 4.8-3 Project Consistency with the 2019 Sunnyvale Climate Action Playbook Strategies and Play Project Consistency
Strategy 1: Promoting Clean Electricity Consistent. The proposed project would meet the standards to be classified as LEED Gold, which would include the use of solar PV (photovoltaic) panels.

Play 1.1: Promote 100 percent clean electricity.

The City is committed to working with SVCE to expand 100 percent clean energy services to 100 percent of our community. Supporting and protecting this clean electricity supply is critical to other Strategies from this Playbook that rely on decarbonization (namely, Strategies 2 and 3).

Consistent. SVCE, the area’s electricity provider, delivers 100 percent carbon-free electricity. As a result, the project would operate on clean energy at initiation.

Play 1.2: Increase local PV.

Targeted incentives, regulations and educational resources will be essential to increasing adoption of distributed solar resources in Sunnyvale. These will help ensure local supply but also help to offset demands on the electricity grid during peak demand periods.

Consistent. The project would be equipped with a solar PV system consistent with the City of Sunnyvale Municipal Code.

Strategy 2: Decarbonizing Buildings Consistent. This all-electric building development meets decarbonizing goals years in advance of the City’s target date.

Play 2.3: Achieve all-electric new construction.

While the state requires moving toward ZNE for new construction, the City will work towards also incentivizing and promoting all -electric new construction options for deep decarbonization.

Consistent. The proposed project would be developed as an all - electric powered building.

Strategy 3: Decarbonizing Transportation and Sustainable Land Use Consistent. The project is in close proximity to the Caltrain Lawrence Station. The walking distance to the platforms is less than one mile. Station proximity would promote public transit use, leading to reduced GHG emissions. Furthermore, the project would include bicycle parking spaces and dedicated EV parking stalls with charging stations. The latter promote the use of electric vehicles and further supports the push for increased zero-emission vehicles in the area.

Play 3.2: Increase transportation options and support shared mobility.

Multimodal transportation choices need to be enhanced to offer a variety of travel options in and around the city that are connected to regional transportation systems and destinations. Advocating for and increasing transportation options and shared mobility will create safer, healthier, and more convenient movement throughout Sunnyvale.

Consistent. The project would include dedicated bike parking to encourage bike transportation per City of Sunnyvale
requirements for new development. Additionally, the project is in a major transit corridor and in close proximity to the Lawrence Caltrain Station, located within walking distance.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-50 Intuitive North Site Modification Project Environmental Checklist Strategies and Play Project Consistency
Play 3.3: Increase zero-emission vehicles.

Shifting to electric or alternatively fueled (e.g., hydrogen) vehicles has significant potential to reduce GHG emissions related to transportation.

Since SVCE provides 100 percent carbon-free electricity, promoting a shift to electric vehicles away from fossil fuels would significantly reduce emissions. Other priorities include electrification of public transportation, car sharing, and electric bikes and scooters, and also improving availability of alternative fueling stations (e.g., EV charging facilities, hydrogen fueling stations). Currently (as of October 1, 2018) 2.4 percent of vehicles registered in Sunnyvale are battery -electric vehicles and 1.3 percent are plug-in hybrid electric vehicles.
a. 2030 Target: 20 percent of all vehicles on road are zero-emission vehicles by 2030 and 75 percent of all vehicles on road are zero- emission by 2050
Consistent. The proposed project would include EV parking space as well as clean air and vanpool spaces. These project features would promote the adoption of zero -emission vehicles by providing infrastructure to facilitate their use.

Strategy 4: Managing Resources Sustainably Consistent. This project would include the preservation of existing on-site trees as well as the installation of new on-site trees in the landscaping, which would enhance natural carbon sequestration at the site, aligning with the City’s Urban Forest Management Plan and benefiting stormwater infiltration
capacity.

Play 4.1: Achieve Zero Waste goals for solid waste.

Diverting waste away from landfills, either to recycling, energy recovery or composting facilities, is critical for the City to realize its Zero Waste goals as outlined in its Zero Waste Strategic Plan. This can be accomplished by waste prevention – consuming and throwing away less – and being smarter about the items that must be thrown away. Expanding Sunnyvale’s food scraps collection program (FoodCycle) will help to increase the amount of organic material diverted away from the landfill.

However, state laws and policies limit access to diversion technologies so that 75 percent diversion is the current limit. Increasing diversion to 90 percent will require changes at the state level to allow use of technologies that recover energy from unrecyclable resident waste, primarily plastic and paper.

Consistent. The portion of the project on the North Site would not conflict with implementation of the City’s Zero Waste Strategic Plan and the entire project would be served by municipal waste companies that must comply with SB 1383, which set statewide targets to reduce organic waste disposed of in landfills of 50% by 2020 and 75% by 2025 . Although the project would generate additional waste, the portion of the project on the North Site (which would generate the majority of the project’s waste) would comply with City’s Zero Waste goals and state laws and policies to reduce solid waste.

Play 4.2: Ensure resilience of water supply.

As the region faces water supply challenges driven by recurring droughts and population growth, it will be critical to find ways to reduce the amount of water consumed and increase the sustainability of water supplies. Water conservation and water reuse, i n the form of recycled and purified water, will help Sunnyvale reduce the stress placed on Northern California’s water resources.

Consistent. This project would comply with all water
conservation requirements.

Play 4.3: Enhance natural carbon sequestration capacity. The natural environment, including plants and soil, have an immense capacity to store carbon dioxide that would otherwise be released into the atmosphere.

Through implementation of the City’s Urban Forest Management Plan and Green Stormwater Infrastructure Plan, Sunnyvale can continue to capture carbon by expanding its urban tree canopy and designing landscape features to address stormwater pollution and flood risk.

Consistent. The landscape design for this project would incorporate new trees and shrubs to support carbon
sequestration and reduce urban heat island effect.

Notes: LEED = Leadership in Energy and Environmental Design; ZNE = Zero Net Energy; SVCE = Silicone Valley Clean Energy; PV = Photovoltaic; GHG = greenhouse gases; EV = Electric Vehicle.

Source: Ascent 2023.

The North Site project demonstrates consistency with the City’s 2019 Climate Action Playbook to meet updated City and State targets. Therefore, the portion of the project on the North Site would not result in new significant impacts or substantially more severe impacts related to a GHGs than were identified for the ISI Project in the LSAP Update Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-51 SEIR, no changes in circumstances would result in new or substantial more severe impacts related to GHGs than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to GHGs the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI P roject remain valid.

Extension Site
As stated in Item (a), according to BAAQMD’s Justification Report, a project would be considered to have a less than significant impact on climate change under CEQA if it can be determined that the project is consistent with the California’s long-term climate goals and does not impede the State’s efforts to meet those goals. One option provided in the Justification Report is demonstrating consistency with a CEQA-qualified CAP. Table 4.8-4 below provides a detailed summary of the proposed Extension Site parking garage project’s consistency with the City of Santa Clara’s CAP (strategies and plays which are not applicable to the project were not included in the consistency analysis).

Table 4.8-4 Proposed Extension Site Project Consistency with the City of Santa Clara Climate Action Plan Climate Action Plan Strategies Project Consistency
Strategy B1: Shift to Electric Fuels in New and Existing Buildings to Achieve Net-zero Carbon Buildings
B-1-5 Reach codes for new construction Consistent. The project would be all-electric and include electric vehicle EV chargers, consistent with the City of Santa Clara’s Reach Code Ordinance No. 2056, Chapter 15.36 Energy Code and Chapter 15.38 Green Building Code. Although all-electric local reach codes likely are preempted by federal law, the project would continue to be all electric.

Strategy B2: Improve Energy Efficiency
B-2-3 Energy-efficient and electric-ready building
code
Consistent. The project would include the use of highly efficient lighting that would promote energy efficiency in accordance with California Energy Code and CalGreen requirements.

Strategy T1: Transition Vehicles to Electric Alternatives T-1-2 EV charging for all new construction Consistent. The project design would provide Level 2 electric vehicle (EV) charging stations for a minimum of 35 percent of the total garage parking spaces , while an additional 35 percent of the total spaces would be EV capable. This would be consistent with the City of Santa Clara’s reach codes and would promote the adoption of electric vehicles by providing infrastructure to facilitate their use.

T3: Advance Sustainable Land Use
T-3-1 TDM plan requirements Consistent. The project would be required to implement a TDM Plan that achieves 25 percent daily trip reduction per the Santa Clara CAP. However, this requirement would be superseded by the 35 percent peak hour and 20 percent daily trip reduction required by the LSAP.

T-3-2 Sustainable development in underutilized non -
residential areas
Consistent. The project would be constructed on an existing surface parking lot which does not include EV charging spaces. The project would provide 937 parking spaces, 35 percent of which would be Day 1 EV ready, meaning that these spaces would be available to charge electric vehicle immediately upon the start of project operation. An additional 35 percent of total parking structure spaces would be EV capable. Because the project would provide EV charging spaces and provide substantially more parking spaces than what is currently provided on the existing parking lot, it would provide sustainability-based development in a currently underutilized nonresidential area.

T-3-3 Transit-oriented development Consistent. The project is in close proximity to the Caltrain Lawrence Station. The walking distance to the platforms is less than one mile, thus promoting the use of public transit.

Notes: EV = electric vehicle.

Source: Ascent 2023.

Attachment 13

Environmental Checklist Administrative Draft – For Internal Review Only Ascent City of Sunnyvale
4-52 Intuitive North Site Modification Project Environmental Checklist As shown in Table 4.8-4, the project demonstrates consistency with the City of Santa Clara’s CAP and would therefore be consistent with the California’s long-term climate goals and would not impede the State’s efforts to meet those goals. Impacts would remain less than significant. The portion of the project on the Extension Site would not result in new significant impacts or substantially more severe impacts related to a GHGs than were identified for the ISI Project in the LSAP Update SEIR, no changes in circumstances would result in new or substantial more severe impacts related to GHGs than were identified for the ISI Project in the LSAP Update SEIR, and no new information shows that as to GHGs the project would have one or more significant effects not discussed in the LSAP Update SEIR for the ISI Project, significant effects previously examined would be substantially more severe than shown in the LSAP Update SEIR for the ISI Project, or that there would be feasible mitigation measures or alternatives that were previously found to be infeasible or that are considerably different than measures in the LSAP Update SEIR for the ISI Project that reduce impacts but that ISI declines to adopt. The findings of the LSAP Update SEIR for the ISI Project remain valid.

Mitigation Measures from LSAP Update EIR
No significant GHG impacts were identified in the LSAP Update SEIR, and no mitigation measures were required.

Conclusion
No new circumstances or project changes related to greenhouse gas emissions have occurred that would result in new or substantially more severe greenhouse gas emissions impacts than were identified in the LSAP Update SEIR, nor is there new information of substantial importance that shows the project will have one or more significant effects not previously discussed or that the discussed effects would be substantially more severe or there would be newly feasible mitigation measures or alternatives or substantially different mitigation measures or alternatives that would substantially reduce impacts but that ISI declines to adopt. Therefore, the findings of the certified LSAP Update SEIR remain valid, and no additional analysis is required.

Attachment 13

Ascent Administrative Draft – For Internal Review Only Environmental Checklist City of Sunnyvale
Intuitive North Site Modification Project Environmental Checklist 4-53

4.9 HAZARDS AND HAZARDOUS MATERIALS
Environmental Issue Area
Where Impact Was
Analyzed in the LSAP
Update Draft and
Final SEIR.

Do Project Changes
Involve New or
Substantially More
Severe Significant
Impacts?
Do Any New
Circumstances Involve
New or Substantially
More Severe
Significant Impacts?
Any New
Information of
Substantial
Importance?
Do Prior Environmental
Documents Mitigations
Address/Resolve
Impacts?

9. Hazards and Hazardous Materials. Would the project:
a) Create a significant hazard to the public
or the environment through the routine
transport, use, or disposal of hazardous
materials?
Draft SEIR
Impacts 3.8-1 and

3.8-2;
Final SEIR
identified no
change in impact
conclusions
No No No NA, impact would
be less than
significant
b) Create a significant hazard to the public
or the environment through reasonably
foreseeable upset and/or accident
conditions involving the release of
hazardous materials into the
environment?
Draft SEIR
Impacts 3.8-1 and

3.8-2;
Final SEIR
identified no
change in impact
conclusions
No No No NA, impact would
be less than
significant
c) Emit hazardous emissions or handle
hazardous or acutely hazardous
materials, substances, or waste within
one-quarter mile of an existing or
proposed school?
Draft SEIR Impact

3.8-3;
Final SEIR
identified no
change in impact
conclusion
No No No NA, No impact
would occur
d) Be located on a site which is included
on a list of hazardous materials sites
compiled pursuant to Government
Code Section 65962.5 and, as a result,
would it create a significant hazard to
the public or the environment?
Draft SEIR Impact

3.8-4;
Final SEIR
identified no
change in impact
conclusion
No No No Yes. Impacts would
be less than
significant with
application of the
adopted mitigation
measures.
e) For a project located within an airport
land use plan or, where such a plan has
not been adopted, within two miles of a
public airport or public use airport,
would the project result in a safety
hazard or excessive noise for people
residing or working in the project area?
Draft SEIR page

3.8-15
No No No NA, no impact
would occur.
f) Impair implementation of or physically
interfere with an adopted emergency
response plan or emergency evacuation
plan?
Draft SEIR Impact

3.8-5;
Final SEIR
identified no
change in impact
conclusion
No No No No, impact would
be less than
significant
g) Expose people or structures, either
directly or indirectly, to a significant risk
of loss, injury, or death involving
wildland fires?
Draft SEIR page

3.8-15
No No No NA, no impact
would occur.

Attachment 13