28 | City of Watsonville
6. Issues
6.1 Aesthetics
Conclusion: Regarding aesthetics, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. The project would not have a substantial adverse effect on a scenic vista, as the site is located within an industrial area (zoned IP: Industrial Park). Northward up Airport Boulevard from the project site is the Watsonville Municipal Airport (zoned PF: Public Facilities).
To the east are additional industrial areas (zoned IP: Industrial Park). The City of Watsonville has not officially designated any scenic vistas requiring special attention.
The proposed project is the development of one parcel located at 70 Nielson Airport Boulevard (APN 015-111-49), totaling approximately 4.39 acres, and referred to as the Crocker’s Lockers Project (project). The site is a paved parking lot with ornamental landscaping. The proposed self-storage facility would consist of six self-storage buildings, four of which would be single-story, and two of which would be two-story. A seventh building is proposed as a two-story manager's building with an office on the ground floor and the manager’s apartment above. The project would provide 1,072 storage units in approximately 149,796 square feet of building space. Since there are no officially designated scenic vistas in the City of Watsonville, and the site is located within an industrial area, Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Except as provided in Public Resources Code Section 21099, Would the project:
a) Have a substantial adverse effect on a scenic vista? b) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway?
c) In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings? (Public views are those that are
experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project
conflict with applicable zoning and other regulations
governing scenic quality?
d) Create a new source of substantial light or glare which would adversely affect day or nighttime views in the
area? ("Glare" is defined in this EIR as the reflection of harsh bright light sufficient to cause physical discomfort or loss in visual performance and visibility.)
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 29
the project would not have a substantial adverse effect on a scenic vista, and the impact resulting from the project would be less than significant.
b. Less than Significant Impact. State Scenic Highways are designed by the California Department of Transportation (Caltrans) to promote the protection and enhancement of the natural scenic beauty of California’s highways and adjacent corridors. Three designated or eligible for designation State Scenic Highways are within City limits, the closest of which is State Route (SR) 152, which is officially designated as a Scenic Highway from the Merced-Santa Clara County line and is eligible for designation where it intersects with California State Highway 1 approximately 3,000 feet south/southeast of the project site. The project is not visible from any of these State Scenic Highways.
As discussed on page 70 of the City of Watsonville General Plan (Chapter 5, Urban Design and Scenic Resources), Airport Boulevard is a designated scenic street. Airport Boulevard provides views to the north and west of open space areas, as well as offers a route from urban commercial areas to rural agricultural areas. The General Plan states that new developments along Airport Boulevard would contribute to the scenic qualities of the corridor with attractive building design and landscaping. In renderings provided by the applicant, the buildings would be contemporary and have vegetative screening along the street frontages.
The project site is on a relatively flat 4.39-acre site that is developed as a paved parking lot with ornamental landscaping and pole-mounted lighting. Mature trees range from 10 to 50 feet tall, many of which are located along the perimeter of the property. The site slopes from the northeastern corner with an elevation of approximately 133 feet to the southwestern portion with an elevation of approximately 122 feet. Underground utilities connect to storm drain, water, and sewer mains under Airport Boulevard and Nielson Street. The proposed project would not substantially degrade scenic resources because the project (1) would not be visible from a designated State Scenic Highway, (2) would not block views of an identified scenic resource, and (3) would be subject to design review according to City policies, including landscaping requirements. Therefore, the impact would be less than significant.
c. Less than Significant Impact. The project is located within an area developed with industrial uses, and public vantage points are accessed along Airport Boulevard, which offers views of the Santa Cruz Mountains to the north and east. Project buildout would not interfere with these views. The parcel would be redeveloped into, at the highest point, two-story storage units with a maximum building height of twenty-nine feet (29'-0”). The surrounding area is zoned IP: Industrial Park and PF: Public Facilities.
The Watsonville General Plan includes goals that guide development, for example:
• Goal 5.2 Community Appearance: Blend new development with recognized values of community appearance and scenic qualities, and ensure that new development enhances, rather than detracts from, its surroundings.
• Goal 5.6 Urban Design: Achieve high standards of street, site and building design that are both efficient and aesthetically pleasing.
• Policy 5.A Project Design Review: The preservation of visual resources shall be accomplished through the design review process.
• Policy 5.B Design Consistency: The City shall review new development proposals to encourage high standards of urban design and to ensure that elements of architectural design and site orientation do not degrade or conflict with the appearance of existing structures.
Attachment 2.9
30 | City of Watsonville
The proposed project is located in a developed area and would be subject to City design review in accordance with the General Plan goals, policies, and design guidelines regarding landscaping and design. The project would not substantially degrade the existing visual character or quality of the site and its surroundings. The impact would be less than significant. d. Less than Significant Impact. Excessive or inappropriately directed lighting can adversely impact night-time views by reducing the ability to see the night sky and stars. Glare can be caused from unshielded or misdirected lighting sources, or by reflective surfaces (i.e., polished metal, window treatments). The proposed lighting is considered adequate to illuminate the project site and is consistent with typical lighting for an urban setting (see Figure 11). Although the project would increase the overall illumination in the project vicinity, it would not create readily detectable glare along adjacent roads. The impact would be less than significant.
References:
Caltrans. Map Viewer website, “California Scenic Highways,” Available at:
https://www.arcgis.com/home/webmap/viewer.html?layers=f0259b1ad0fe4093a5604c9b838a486a (accessed January 17, 2022).
City of Watsonville, 2005. General Plan, Urban Design and Scenic Resources. Chapter 5. Available at:
https://www.cityofwatsonville.org/160/2005-General-Plan (accessed January 18, 2022).
City of Watsonville, 2020. Zoning Map. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/2561/Zoning-Map (accessed January 25, 2022).
Cubix Construction LLC, May 7, 2021. Floor Plans (Sheet 2-A).
Cubix Construction LLC, May 7, 2021. Project Elevations (Sheet 3-A).
Cubix Construction LLC, May 7, 2021. Project Elevations (Sheet 3-B).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 31
6.2 Agriculture and Forestry Resources
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
In determining whether impacts to agricultural resources are significant environmental effects, lead agencies may refer to the California Agricultural Land Evaluation and Site Assessment Model (1997) prepared by the California Dept. of Conservation as an optional model to use in assessing impacts on agriculture and farmland. In determining whether impacts to forest resources, including timberland, are significant environmental effects, lead agencies may refer to information compiled by the California Department of Forestry and Fire Protection regarding the state’s inventory of forest land, including the Forest and Range Assessment Project and the Forest Legacy Assessment project; and forest carbon measurement methodology provided in Forest protocols adopted by the California Air Resources Board. Would the project:
a) Convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the
maps prepared pursuant to the Farmland Mapping and
Monitoring Program of the California Resources Agency,
to non-agricultural use?
b) Conflict with existing zoning for agricultural use, or a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning of, forest land (as defined in Public Resources Code section 12220(g)), timberland (as defined by Public Resources
Code section 4526), or timberland zoned Timberland
Production (as defined by Government Code section
51140 (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?
Conclusion: Regarding agricultural and forest resources, the proposed project would not result in any significant environmental impacts.
Documentation:
a. No Impact. The project site and vicinity are located within an established, developed urban area that does not allow agriculture or forest uses per the City’s General Plan. The map of Important Farmland in California (2016) prepared by the Department of Conservation does not identify the project site as being Prime Farmland, Unique Farmland, or Farmland of Statewide Importance. The site is classified as “Urban and Built-Up-Land” which is described as “occupied by structures with a building density of at least 1 unit to 1.5 acres, or approximately 6 structures to a 10-acre parcel.” Because the project site is classified as Urban and Built-Up-Land, the project would not result in the conversion of Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to a nonagricultural use. There would be no impact.
Attachment 2.9
32 | City of Watsonville
b. No Impact. No land within the City of Watsonville is zoned for agricultural use. The project site is not under a Williamson Act contract, nor would the project impact any lands under Williamson Act contracts. The proposed project would not impact existing zoning for agricultural use or a Williamson Act contract, and no impact would occur.
c. No Impact. The project site and vicinity are located within an urban area, and there is no forest land or timberland located on or near the project site. The project site is surrounded by land zoned for industrial, residential, and public facilities. There would be no impact. d. No Impact. The project site does not contain any forest land onsite or nearby. The proposed project would not result in the loss of forest land or conversion of forest land to non-forest uses. No impact would occur.
e. No Impact. Refer to Sections 6.2.a and 6.2.c. The project site is currently developed as a parking lot within an urbanized, industrial environment. None of the surrounding sites contain existing forest or agricultural uses. Development of the project would not convert forest land or agricultural land to a non-forest or non-agricultural use. No impact would occur.
References:
California Department of Conservation, California Important Farmland Finder 2016. Available at:
https://maps.conservation.ca.gov/DLRP/CIFF/ (accessed January 5, 2022).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 33
6.3 Air Quality
Summary of Impacts
Potentially
Significant
Impact
Less than Significant
With Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Where available, the significance criteria established by the applicable air quality management district or air pollution control district may be relied upon to make the following determinations. Would the project:
a) Conflict with or obstruct implementation of the applicable air quality plan?
b) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is nonattainment under an applicable federal or state ambient air quality standard?
c) Expose sensitive receptors to substantial pollutant
concentrations?
d) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Conclusion: Regarding air quality, the proposed project would not result in any significant environmental impacts.
Documentation:
This air quality analysis references the CalEEMod outputs developed by MIG (Appendix A). a. No Impact. In May 2017, the Monterey Bay Air Resources District (MBARD) adopted the 2012- 2015 Air Quality Management Plan (AQMP), which assesses and updates the elements of the 2008 AQMP and the Triennial Plan Revision 2009-2011, including the air quality trends analysis, emission inventory, and mobile source programs (MBARD, 2017; MBARD, 2013).
The MBARD’s CEQA Air Quality Guidelines provides a list of actions that are intended to ensure consistency with the AQMP (MBARD, 2008). The most applicable action from the CEQA Air Quality Guidelines is assessing the proposed growth assumptions associated with a proposed project with the population and dwelling unit forecasts adopted by the Association of Monterey Bay Area Governments (AMBAG), since the AMBAG population and dwelling unit forecasts are used to generate emission forecasts upon which the AQMP is based. As such, projects that are consistent with the AMBAG’s regional forecasts would be considered consistent with the AQMP. Another criterion for evaluating project consistency with the AQMP is based on the project’s potential to increase criteria air pollutant emissions. Projects that result in a significant increase in emissions, defined as in excess of MBARD significance thresholds, would also be considered to potentially conflict with or obstruct implementation of the AQMP.
The project is anticipated to house one resident (the onsite manager), which is within the growth forecasts developed by the AMBAG’s 2010 Monterey Bay Area Metropolitan Transportation Plan Attachment 2.9
34 | City of Watsonville
(MTP), Monterey Bay Area Mobility 2035 (AMBAG, 2010).1 As such, the project would not conflict with the AQMP with regard to the first criterion. In addition, as described under Section 6.3(b), the proposed project would not exceed the MBARD’s construction or operational significance thresholds for criteria air pollutant emissions. Therefore, the project would not conflict with nor obstruct implementation of the AQMP. No impact would occur. b. Less than Significant Impact. The project is located within the North Central Coast Air Basin (NCCAB), which encompasses Santa Cruz, San Benito, and Monterey Counties. Efforts to attain state and federal air quality standards in the NCCAB are governed by the MBARD. Both the State of California and the federal government have established health-based ambient air quality standards (AAQS) for seven air pollutants (known as criteria pollutants). These pollutants include ozone (O3), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), inhalable particulate matter with a diameter of 10 microns or less (PM10), fine particulate matter with a diameter of 2.5 microns or less (PM2.5), and lead (Pb). The state has also established AAQS for additional pollutants. The AAQS are designed to protect the health and welfare of the populace within a reasonable margin of safety. Where the state and federal standards differ, California AAQS are more stringent than the national AAQS.
The United States Environmental Protection Agency (U.S. EPA), California Air Resources Board (CARB), and MBARD assess the air quality of an area by measuring and monitoring the amount of pollutants in the ambient air and comparing pollutant levels against NAAQS and CAAQS. Based on these comparisons, regions are classified into one of the following categories:
• Attainment. A region is “in attainment” if monitoring shows ambient concentrations of a specific pollutant are less than or equal to NAAQS or CAAQS. In addition, an area that has been re-designated from nonattainment to attainment is classified as a “maintenance area” for 10 years to ensure that the air quality improvements are sustained. • Nonattainment. If the NAAQS or CAAQS are exceeded for a pollutant, the region is designated as nonattainment for that pollutant. It is important to note that some NAAQS and CAAQS require multiple exceedances of the standard in order for a region to be classified as nonattainment. Federal and state laws require nonattainment areas to develop strategies, plans, and control measures to reduce pollutant concentrations to levels that meet, or attain, standards.
• Unclassified. An area is unclassified if the ambient air monitoring data are incomplete and do not support a designation of attainment or nonattainment. Air pollution levels are measured at monitoring stations located throughout the air basin.
Table 1, North Central Coast Air Basin Attainment Status, summarizes the attainment status in the NCCAB for criteria pollutants.
1 Although there is a new MTP for the region, the 2040 Metropolitan Transportation Plan/Sustainable Communities Strategy, the AQMP’s air quality projections are based on the growth assumptions in the previous MTP. Therefore, consistency with regard to the AQMP is based on the previous iteration of the MTP.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 35
Table 1. North Central Coast Air Basin Attainment Status Pollutant Federal State
Ozone (O3) Nonattainment/Transitional Unclassified/Attainment PM10 Nonattainment Unclassified
PM2.5 Attainment Unclassified/Attainment
Carbon Monoxide (CO) Attainment Unclassified/Attainment Nitrogen Dioxide (NO2) Attainment Unclassified/Attainment Sulfur Dioxide (SO2) Attainment Unclassified
Sulfates Attainment --
Lead Attainment Unclassified/Attainment
Hydrogen Sulfide Unclassified --
Visibility Reducing Particles Unclassified -- Source: CARB, 2017 The proposed project would generate both short-term construction emissions and long-term operational emissions. The project’s potential emissions were estimated using the California Emissions Estimator Model (CalEEMod), Version 2020.4.0. As described in more detail below, the proposed project would not generate short-term or long-term emissions that exceed MBARD-recommended criteria air pollutant thresholds.
Construction Emissions: The proposed project involves the construction of six self-storage buildings, providing 1,072 storage units, in addition to a two-story manager's building with an office on the ground floor and apartment above. Construction activities would disturb the entire site (approximately 4.39 acres,) and would include demolition of the existing parking lot, site preparation, grading, construction, paving, and architectural coating work. The proposed cut is approximately 22,383 cubic yards (CY), and a fill of 331 CY. The excess 22,052 CY of cut would be hauled offsite to a local site for reuse.
The proposed project’s potential construction emissions were estimated using CalEEMod, based on default assumptions, and are shown in Table 2, Construction Activity, Duration, and Typical Equipment.
Table 2. Construction Activity, Duration, and Typical Equipment Construction Activity Duration (days)(A) Typical Equipment Used(B) Demolition 20 Concrete/Industrial Saw, Dozer, Backhoe
Site Preparation 5 Grader, Tractor/Loader/Backhoe
Grading 8 Grader, Dozer, Backhoe
Building Construction 230 Crane, Forklift, Generator, Backhoe, Welder
Paving 18 Cement Mixer, Paver, Roller, Backhoe
Architectural Coating 18 Air Compressor
Source: MIG, 2022 (See Appendix A).
(A) Days refer to total active workdays in the construction phase, not calendar days. (B) The typical equipment list does not reflect all equipment that would be used during the construction phase. Not all equipment would operate eight hours per day each work day.
The proposed project’s maximum daily unmitigated construction emissions are shown in Table 3, Unmitigated Maximum Daily Criteria Air Pollutant Construction Emissions (lbs/day). Please refer to Appendix A for CalEEMod output files and detailed construction emissions assumptions.
Attachment 2.9
36 | City of Watsonville
Table 3. Unmitigated Maximum Daily Criteria Air Pollutant Construction Emissions (lbs/day) Source ROG NOX CO SO2 PM10 PM2.5
Summer
2022 3.4 77.3 26.8 0.2 21.4 11.6
2023 118.1 16.6 19.9 <0.0(A) 1.8 1.0
Winter
2022 3.3 80.4 27.1 0.2 21.4 11.6
2023 118.1 16.7 19.9 <0.0(A) 1.8 1.0
Threshold -- -- -- -- 82 --
Substantial? -- -- -- -- No -- Source: MIG, 2022 (See Appendix A). (A) <0.0 does not mean emissions are zero; rather, it means emissions are greater than 0.00, but less than 0.1.
The proposed project would not result in construction emissions that exceed the MBARD’s only established construction criteria air pollutant emission threshold of 82 lbs/day for PM10. As stated in the MBARD’s CEQA Air Quality Guidelines, “Construction projects using typical construction equipment such as dump trucks, scrapers, bulldozers, compactors, and front-end loaders that temporarily emit precursors of ozone (i.e., volatile organic compounds [VOC] or oxides of nitrogen [NOx]), are accommodated in the emission inventories of State- and federally-required air plans and would not have a significant impact on the attainment and maintenance of ozone AAQS” (MBARD, 2008; pg. 5-3). The project would utilize typical construction equipment, and therefore emissions of VOC/ROG and NOx would not hinder attainment of ozone standards in the NCCAB. In addition, compliance with existing MBARD rules and regulations, such as Rule 426 (Architectural Coatings) and Rule 425 (Use of Cutback Asphalt) would further minimize potential short-term criteria air pollutant emissions.
Although the proposed project would not exceed the MBARD’s only established construction criteria air pollutant emission threshold, construction activities still have the potential to conflict with MBARD Rule 402 (Nuisances). Accordingly, the City would implement the following air quality Best Management Practices (BMPs) to reduce construction-related fugitive dust and exhaust emissions.
Construction Air Quality Best Management Practices: The City shall require the applicant to incorporate the following construction air quality best management practices into all applicable project bid, design, and engineering documents: [Note to staff: These BMPs are not listed as a mitigation measure because the impact is already less than significant. – MIG] 1) All exposed surfaces (e.g., parking areas, staging area, soil piles, graded areas, and unpaved access roads) shall be watered at once per day, at a minimum. 2) All haul trucks transporting soil, sand, or other loose material off-site shall be covered. 3) All vehicle speeds on unpaved roads shall be limited to 15 miles per hour. 4) 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.
5) Idling times shall be minimized either by shutting equipment off when not in use or reducing the maximum idling time to 5 minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations [CCR]). Clear signage shall be provided for construction workers at all access points.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 37
6) All construction equipment shall be maintained and properly tuned in accordance with manufacturer’s specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. 7) Stage construction equipment and materials as far away from residential land uses to the extent feasible.
Operational Emissions: Upon completion of construction activities, the proposed project would operate as a self-storage facility. The operation of this land use would generate emissions of regulated air pollutants from:
• “Area” Sources. The proposed land use would generate emissions from small area sources, including landscaping equipment, and the use of consumer products (e.g., paints, cleaners, and fertilizers) that result in the evaporation of chemicals into the atmosphere during product use. • Energy Use and Consumption. The proposed land uses would generate emissions from the combustion of natural gas in water and space heating equipment. • Mobile Sources. The proposed project site would generate emissions from vehicles traveling to and from the project site.
The proposed project’s operational emissions were estimated using CalEEMod. The operational emissions generated in CalEEMod are based on the project’s full first year of operation (presumed to be 2024) using default data assumptions provided by CalEEMod, with the following project-specific modifications:
• The default weekday and weekend trip generation rates for a self-storage facility were replaced with the trip generation rates provided by W-Trans in an email from February 17, 2022.
According to the Traffic Memorandum, the proposed project would generate approximately 227 daily weekday trips, 275 trips on Saturdays, and 234 trips on Sundays. As such, the mobile source emissions reflect the specific trip generation rates for the proposed project.
The proposed project’s maximum daily unmitigated operational emissions are shown in Table 4, Unmitigated Maximum Daily Criteria Air Pollutant Operational Emissions (lbs/day).
Table 4. Unmitigated Maximum Daily Criteria Air Pollutant Operational Emissions (lbs/day) Source ROG NOX CO SO2 PM10 PM2.5
Summer
Area Sources 3.8 <0.0(A) <0.0(A) <0.0(A) <0.0(A) <0.0(A) Energy Demand <0.0(A) 0.1 0.1 <0.0(A) <0.0(A) <0.0(A)
Mobile Sources 0.9 1.1 8.3 <0.0(A) 1.7 0.5
Summer Total(B) 4.7 1.2 8.4 <0.0(A) 1.7 0.5
Winter
Area Sources 3.8 <0.0(A) <0.0(A) <0.0(A) <0.0(A) <0.0(A) Energy Demand <0.0(A) 0.1 0.1 <0.0(A) <0.0(A) <0.0(A)
Mobile Sources 0.9 1.3 9.0 <0.0(A) 1.7 0.5
Winter Total 4.7 1.4 9.1 <0.0(A) 1.7 0.5
MBARD Daily Threshold 137 137 500 150 82 --
Potentially Significant? No No No No No -- Source: MIG, 2022 (See Appendix A). (B) <0.0 does not mean emissions are zero; rather, it means emissions are greater than 0.00, but less than 0.1. (C) Totals may not equal the sum of aggregate emissions due to rounding.
Attachment 2.9
38 | City of Watsonville
The proposed maximum daily unmitigated operational emissions would be below the MBARD’s operational criteria air pollutant emissions thresholds. Therefore, operation of the proposed project would not generate operational-related emissions that exceed MBARD thresholds, and impacts would be less than significant.
c. Less than Significant Impact. Some populations are more susceptible to the effects of air pollution than the population at large; these populations are defined as sensitive air quality receptors. Sensitive receptors include children, the elderly, the sick, and the athletic. Land uses associated with sensitive receptors include residences, schools, playgrounds, childcare centers, athletic facilities, long-term health care facilities, rehabilitation centers, convalescent centers, and retirement homes. The sensitive air quality receptors adjacent or in close proximity to the perimeter of the project include:
• Watsonville Community Hospital across Nielson Boulevard south of the project site. At the closest, the receptors are approximately 200 feet from the project site.
In addition to criteria air pollutants such as NOx (an ozone precursor), CO, PM10, and PM2.5, the U.S.
EPA and CARB have classified certain pollutants as hazardous air pollutants (HAPs) and toxic air contaminants (TACs), respectively. These pollutants can cause severe health effects at very low concentrations, and many are suspected or confirmed carcinogens. The U.S. EPA has identified 187 HAPs, including such substances as arsenic and chlorine; CARB considers all U.S. EPA designated HAPs, as well as diesel particulate matter (DPM) emissions from diesel-fueled engines and other substances, to be TACs.
During project construction, the heavy-duty, diesel-powered, off-road construction equipment, as well as diesel-powered vendor and haul tucks, would emit DPM as part of their exhaust emissions; however, these emissions would not result in pollutant concentrations that could generate substantial adverse health risks to adjacent sensitive receptors for several reasons.
First, as shown in Table 3, the proposed project’s emissions would be below all MBARD construction emissions thresholds. Second, project construction emission activities would only occur intermittently, between the hours of 7 AM and 7 PM, Monday through Friday, and between the hours of 8 AM and 5 PM on Saturday, in accordance with a standard condition of project approval for all development projects. The intermittent nature of project construction activities would provide time for emitted pollutants to disperse on an hourly and daily basis according to the prevailing wind in the area. Third, the project site is over four acres, and the equipment used for project construction would be mobile – meaning that emission sources would move around the site and not expose the same receptor to pollutant concentrations continuously throughout the day, week, or construction period as a whole. Fourth, the proposed project would be required to comply with applicable MBARD rules and regulations, such as Rule 402 (Nuisances). Fifth, the proposed project would implement BMPs for air quality, which would help reduce fugitive dust emissions, and would require construction equipment be staged as far away from residential receptors as possible, thus reducing the quantity of exhaust emitted in proximity to sensitive receptors.
In summary, the proposed project would not expose sensitive receptors to substantial pollutant concentrations because the project construction period would be relatively short-term (about 12 months); emission sources would be temporary, intermittent, and move throughout the approximately
4.39-acre project site; and the project applicant would comply with applicable MBARD rules and Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 39
regulations. Once operational, the project would not generate substantial pollutant emissions. This impact would be less than significant.
d. Less than Significant Impact. Construction of the project would generate typical odors associated with construction activities, such fuel and oil odors, asphalt paving odors, and painting/coating odors.
The odors generated by the project would be intermittent and localized in nature and would disperse.
Therefore, the project would not create objectionable odors affecting a substantial number of people.
This impact would be less than significant.
References:
Association of Monterey Bay Area Governments (AMBAG), 2010. Monterey Bay Area Mobility 2035.
Available at: https://ambag.org/pdf/MTP%202010%20-
%20Monterey%20Bay%20Area%20Mobility%202035.pdf (accessed March 8, 2022).
California Air Resources Board (CARB), 2017. Area Designations Map/State and National. Available at: http://www.arb.ca.gov/desig/adm/adm.htm (accessed March 8, 2022).
City of Watsonville, 2020. Watsonville Municipal Code. Available at:
https://www.codepublishing.com/CA/Watsonville (accessed March 8, 2022).
Monterey Bay Air Resources District (MBARD), 2008. CEQA Air Quality Guidelines. Available at:
https://www.mbard.org/files/f665829d1/CEQA_full+%281%29.pdf (accessed March 8, 2022).
MBARD, 2017. 2012-2015 Air Quality Management Plan. Available at:
https://www.mbard.org/files/6632732f5/2012-2015-AQMP_FINAL.pdf (accessed March 8, 2022).
Attachment 2.9
40 | City of Watsonville
6.4 Biological Resources
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a
candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Game or U.S. Fish and Wildlife
Service?
b) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations or by the California Department of Fish and Game or U.S. Fish and Wildlife
Service?
c) Have a substantial adverse effect on federally protected wetlands (including, but not limited to marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means?
d) Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with
established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites?
e) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat
conservation plan?
Conclusion: The project would not result in any significant environmental impacts to biological resources after mitigation. The project site is considered developed. Implementation of Mitigation Measures BIO-1 and BIO-2 would reduce potential impacts to less than significant levels.
This biological resources analysis references the Biological Resources Study developed by MIG (Appendix B).
Regulatory Environment: The following describes the regulatory environment that supports the conclusions to the impact questions.
Special-Status Species Regulatory Framework
Federal Endangered Species Act (FESA): The FESA establishes a broad public and federal interest in identifying, protecting, and providing for the recovery of threatened or endangered species. The Secretary of the Interior and the Secretary of Commerce are designated in FESA as responsible for Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 41
identifying endangered and threatened species and their critical habitat, carrying out programs for the conservation of these species, and rendering opinions regarding the impact of proposed federal actions on listed species. The USFWS and the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NOAA Fisheries) are charged with implementing and enforcing the FESA.
USFWS has authority over terrestrial and continental aquatic species, and NOAA Fisheries has authority over species that spend all or part of their life cycle at sea, such as salmonids. Section 9 of FESA prohibits the unlawful “take” of any listed fish or wildlife species. Take, as defined by FESA, means “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or to attempt to engage in any such action.” USFWS’s regulations define harm to mean “an act which actually kills or injures wildlife.” Such an act “may include “significant habitat modification or degradation where it actually kills or injures wildlife by significantly impairing essential behavioral patterns, including breeding, feeding or sheltering” (50 CFR § 17.3). Take can be permitted under FESA pursuant to sections 7 and 10. Section 7 provides a process for take permits for federal projects or projects subject to a federal permit, and Section 10 provides a process for incidental take permits for projects without a federal nexus. FESA does not extend the take prohibition to federally listed plants on private land, other than prohibiting the removal, damage, or destruction of such species in violation of state law.
Critical Habitat: Critical habitat is a term defined in the ESA as a specific geographic area that contains features essential for the conservation of a threatened or endangered species and that may require special management and protection. The ESA requires federal agencies to consult with the USFWS to conserve listed species on their lands and to ensure that any activities or projects they fund, authorize, or carry out will not jeopardize the survival of a threatened or endangered species. In consultation for those species with critical habitat, federal agencies must also ensure that their activities or projects do not adversely modify critical habitat to the point that it will no longer aid in the species’ recovery. In many cases, this level of protection is similar to that already provided to species by the ESA jeopardy standard. However, areas that are currently unoccupied by the species but which are needed for the species’ recovery are protected by the prohibition against adverse modification of critical habitat.
Migratory Bird Treaty Act of 1918 (MBTA): The Federal Migratory Bird Treaty Act (MBTA) (16 USC. 703 et seq.), Title 50 Code of Federal Regulations (CFR) Part 10, prohibits taking, killing, possessing, transporting, and importing of migratory birds, parts of migratory birds, and their eggs and nests, except when specifically authorized by the Department of the Interior. As used in the act, the term “take” is defined as meaning, “to pursue, hunt, capture, collect, kill or attempt to pursue, hunt, shoot, capture, collect or kill, unless the context otherwise requires.” With a few exceptions, most birds are considered migratory under the MBTA. Disturbances that cause nest abandonment and/or loss of reproductive effort or loss of habitat upon which these birds depend would be in violation of the MBTA.
California Endangered Species Act (CESA): Provisions of CESA protect state-listed threatened and endangered species. The California Department of Fish and Wildlife (CDFW) is charged with establishing a list of endangered and threatened species. CDFW regulates activities that may result in “take” of individuals (i.e., “hunt, pursue, catch, capture, or kill, or attempt to hunt, pursue, catch, capture, or kill”). Habitat degradation or modification is not expressly included in the definition of “take” under the California Fish and Game Code, but CDFW has interpreted “take” to include the killing of a member of a species which is the proximate result of habitat modification.
California Fully Protected Species and Species of Special Concern: The classification of California “fully protected” (CFP) was the CDFW’s initial effort to identify and provide additional protection to those animals that were rare or faced possible extinction. Lists were created for fish, amphibians and reptiles, birds, and mammals. Most of the species on these lists have subsequently been listed under Attachment 2.9
42 | City of Watsonville
CESA and/or FESA. The Fish and Game Code sections (fish at §5515, amphibians and reptiles at §5050, birds at §3503 and §3511, and mammals at §4150 and §4700) dealing with “fully protected” species state that these species “…may not be taken or possessed at any time and no provision of this code or any other law shall be construed to authorize the issuance of permits or licenses to take any fully protected species,” although take may be authorized for necessary scientific research. This language makes the “fully protected” designation the strongest and most restrictive regarding the “take” of these species. In 2003, the code sections dealing with “fully protected” species were amended to allow the CDFW to authorize take resulting from recovery activities for state-listed species.
California Species of Special Concern (CSC) are broadly defined as animals not listed under the FESA or CESA, but which are nonetheless of concern to the CDFW because they are declining at a rate that could result in listing or because they historically occurred in low numbers and known threats to their persistence currently exist. This designation is intended to result in special consideration for these animals by the CDFW, land managers, consulting biologist, and others, and is intended to focus attention on the species to help avert the need for listing under FESA and CESA and cumbersome recovery efforts that might ultimately be required.
California Fish and Game Code Sections 3503 and 3513: Nesting birds, including raptors, are protected under California Fish and Game Code Section 3503, which reads, “It is unlawful to take, possess, or needlessly destroy the nest or eggs of any bird, except as otherwise provided by this code or any regulation made pursuant thereto.” In addition, under California Fish and Game Code Section 3503.5, “it is unlawful to take, possess, or destroy any birds in the orders Falconiformes or Strigiformes (birdsof-prey) or to take, possess, or destroy the nest or eggs of any such bird except as otherwise provided by this code or any regulation adopted pursuant thereto”. Passerines and non-passerine land birds are further protected under California Fish and Game Code 3513. As such, CDFW typically recommends surveys for nesting birds that could potentially be directly (e.g., actual removal of trees/vegetation) or indirectly (e.g., noise disturbance) impacted by project-related activities. Disturbance during the breeding season could result in the incidental loss of fertile eggs or nestlings, or otherwise lead to nest abandonment.
Disturbance that causes nest abandonment and/or loss of reproductive effort is considered “take” by CDFW.
Non-Game Mammals: Sections 4150-4155 of the California Fish and Game Code protects non-game mammals, including bats. Section 4150 states “A mammal occurring naturally in California that is not a game mammal, fully protected mammal, or fur-bearing mammal is a nongame mammal. A non-game mammal may not be taken or possessed except as provided in this code or in accordance with regulations adopted by the commission”. The non-game mammals that may be taken or possessed are primarily those that cause crop or property damage. Bats are classified as a non-game mammal and are protected under California Fish and Game Code.
Native Plant Protection Act: The Native Plant Protection Act (NPPA) was created in 1977 with the intent to preserve, protect, and enhance rare and endangered plants in California (California Fish and Game Code sections 1900 to 1913). The NPPA is administered by CDFW, which has the authority to designate native plants as endangered or rare and to protect them from “take.” CDFW maintains a list of plant species that have been officially classified as endangered, threatened or rare. These special-status plants Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 43
have special protection under California law and projects that directly impact them may not qualify for a categorical exemption under CEQA guidelines.
Habitat-Level Regulatory Framework, City of Watsonville Removal of Trees and Other Vegetation: Construction grading and drainage shall not remove or disturb trees and other vegetation except in compliance with the City's best management practices for construction grading and drainage and in compliance with the approved project plans and specifications.
Construction grading and drainage shall be conducted in compliance with the following requirements. a) The limits of work-related ground disturbance shall be clearly identified and delineated on the approved plans and specifications and defined and marked on the site to prevent damage to surrounding trees and other vegetation.
b) Trees and other vegetation within the limits of work-related ground disturbance that are to be retained shall be identified and protected from damage by marking, fencing, or other measures.
Sensitive Natural Vegetation Community Regulatory Framework California Fish and Game Code Section 1600-1603: Streams, lakes, and riparian vegetation, as habitat for fish and other wildlife species, are subject to jurisdiction by the CDFW under Sections 1600-1616 of the California Fish and Game Code. Any activity that will do one or more of the following: (1) substantially obstruct or divert the natural flow of a river, stream, or lake; (2) substantially change or use any material from the bed, channel, or bank of a river, stream, or lake; or (3) deposit or dispose of debris, waste, or other material containing crumbled, flaked, or ground pavement where it can pass into a river, stream, or lake generally require a 1602 Lake and Streambed Alteration Agreement. The term “stream”, which includes creeks and rivers, is defined in the California Code of Regulations (“CCR”) as follows:
“a body of water that flows at least periodically or intermittently through a bed or channel having banks and supports fish or other aquatic life”. This includes watercourses having a surface or subsurface flow that supports or has supported riparian vegetation” (14 CCR 1.72). In addition, the term stream can include ephemeral streams, dry washes, watercourses with subsurface flows, canals, aqueducts, irrigation ditches, and other means of water conveyance if they support aquatic life, riparian vegetation, or stream-dependent terrestrial wildlife (CDFW 1994). Riparian vegetation is defined as, “vegetation which occurs in and/or adjacent to a stream and is dependent on, and occurs because of, the stream itself” (CDFW 1994). In addition to impacts to jurisdictional streambeds, removal of riparian vegetation also requires a Section 1602 Lake and Streambed Alteration Agreement from the CDFW.
Sensitive Natural Communities: Sensitive natural communities are vegetation communities and habitats that are either unique in constituent components, of relatively limited distribution in the region, or of particularly high wildlife value. These communities may or may not necessarily contain special-status species. Sensitive natural communities are usually identified in local or regional plans, policies or regulations, or by the CDFW (i.e., CNDDB) or the USFWS. The CNDDB identifies a number of natural communities as rare, which are given the highest inventory priority. Impacts to sensitive natural communities and habitats must be considered and evaluated under the CEQA California Code of Regulations (CCR): Title 14, Div. 6, Chap. 3, Appendix G.
Documentation:
a. No Impact to Special Status Plants. No special-status plant species were determined to have the potential to occur onsite due to the lack of onsite habitat. A reconnaissance-level field survey was conducted by MIG biologist Alex Broskoff on January 14, 2022. No special-status plants were observed during the visit; therefore, no rare plants were determined to be present onsite.
Attachment 2.9
44 | City of Watsonville
Less than Significant with Mitigation Incorporated to Special Status Wildlife. No special-status bird species were determined to have potential to nest on the project site due to the lack of habitat onsite. However, there is potential for non-status species to be impacted by project activities, including tree removal in the existing parking lot area of the site. Implementation of Mitigation Measure BIO-1 would be required to reduce potential impacts to nesting birds to a less than significant level. A description of onsite resources and mitigation measures follows.
Project Site Plant Communities and Associated Wildlife Habitats:
The project site contains one habitat type: Developed Land, which is described below.
Developed Land (4.39 acres). The project site is composed of disturbed and developed habitat with parking lot islands that have been maintained by a traditional landscape company on a regular basis. Vegetation within the islands is dominated by non-native ornamental species including Deodar cedar (Cedrus deodara), eucalyptus (Eucalyptus sp.) pampas grass (Cortaderia selloana), oleander (Nerium oleander), English ivy (Hedera helix), liquid amber (Liquidambar styraciflua), Chinese pistache (Pistacia chinensis) and wood sorrel (Oxalis sp.). The species are confined to parking lot islands.
The wildlife most often associated with developed and landscaped areas are those that are tolerant of periodic human disturbances, including introduced species such as the European starling (Sturnus vulgaris), rock pigeon (Columba livia), eastern gray squirrel (Sciurus carolinensis), house mouse (Mus musculus), and Norway rat (Rattus norvegicus). Numerous common, native species are also able to utilize these habitats, especially the landscaped areas, including the western fence lizard (Sceloporus occidentalis), and a variety of birds may forage and nest within, including Anna’s hummingbird (Calypte anna), American crow (Corvus brachyrhynchos), bushtit (Psaltriparus minimus), Bewick’s wren (Thryomanes bewickii), mourning dove (Zenaida macroura), and dark-eyed junco (Junco hyemalis). In addition, the mature trees provide potential nesting habitat for raptors such as the Cooper’s hawk (Accipiter cooperii). Wildlife such as striped skunk (Mephitis mephitis) may also move through the site on their way to other habitats.
Special-Status Species with Potential to Occur on Project Site:
Current resource agency database records (e.g., CNDDB, CNPS Electronic Inventory, and USFWS Information for Planning and Consultation (IPaC) databases) within the Watsonville West and eight surrounding USGS 7.5-minute quadrangles were searched. The potential occurrence of these species was then evaluated based on the habitat requirements of each species relative to the conditions observed during the site survey conducted by MIG, Inc. biologists. Potential impacts and associated impact avoidance, minimization, and mitigation measures are discussed below.
Special-Status Plant Species: Special-status plants are defined to include: (1) plants that are federalor state-listed as rare, threatened, or endangered, (2) federal and state candidates for listing, (3) plants assigned a Rank of 1 through 4 by the CNPS Inventory, and (4) plants that qualify under the definition of "rare" in the California Environmental Quality Act Guidelines, section 15380.
The project site was determined to provide no suitable habitat for all special-status plant species that were evaluated for their potential occurrence, based on the distance of the project site to previously recorded occurrences in the region, lack of typical vegetation types, disturbed habitat conditions, topography, elevation, soil types, and other species-specific habitat requirements. One special-status plant species, the Santa Cruz tarplant (Federally Status: Threatened, State Status: Endangered, CNPS Rank: 1B.1), is known to occur within 0.25 miles of the project site. This species occurs in coastal Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 45
prairie and grassland habitats. Although the project site is entirely developed and primarily consists of a paved parking lot, this plant was considered for its potential to occur due to the presence of unpaved areas within the landscaped islands. However, the project site, including the landscaped islands, lack suitable grassland habitat required for the persistence of the Santa Cruz tarplant.
Furthermore, the years of regular landscape maintenance onsite excludes the presence of Santa Cruz tarplant. Therefore, no special-status plants are expected to occur on the project site.
Special-Status Wildlife Species: Special-status wildlife species include those species listed as endangered or threatened under the FESA or CESA; candidates for listing by the USFWS or CDFW; California fully protected and species of special concern; non-game mammals protected by Sections 4150-4155 of the CFGC; and nesting birds protected by the CDFW under CFGC Sections 3503 and 3513.
Special-status wildlife species are considered absent within the project site based on a review of the USFWS, CNDDB, CNPS, NOAA Fisheries, and University of California databases, the biologist’s knowledge of sensitive species within the City of Watsonville, and an assessment of the types of habitats within the project site. No resources to support special-status species are available onsite.
There are multiple California red-legged frog occurrences within 1 mile of the project site including one record as recent as 2017 (CNDDB 2022). Additionally, there is a wetland approximately 0.1 mile south of the project site. The wetland seemingly provides foraging and dispersal habitat for redlegged frog, especially during rain events. However, this wetland is isolated from known red-legged frog occurrences by surrounding roads and development, and red-legged frogs are likely absent from the wetland due to the lack of habitat connectivity. No suitable breeding, foraging, or dispersal habitat is present on the project site. Furthermore, there are no documented occurrences of the redlegged frog in this wetland (CNDDB 2022). Therefore, due the lack of suitable habitat and lack of connectivity to the closest known populations, California red-legged frog is not expected to occur on the project site.
Other Protected Nesting Birds: Nesting birds, including raptors, protected under the MBTA and California Fish and Game Code may potentially occur in the trees and shrubs on the project site and adjacent to the site. Birds nesting in the developed areas within and adjacent to the project site are expected to be acclimated to high levels of disturbance and it is likely that construction activities will not disturb these birds. If construction activities in this area occur during the avian breeding season (February 1 to September 15), injury to individuals or nest abandonment could occur. Noise and increased construction activity could temporarily disturb nesting or foraging activities, potentially resulting in the abandonment of nest sites. However, with the implementation of mitigation measure BIO-1, the impacts from the project would be less than significant.
Mitigation Measure BIO-1: Nesting Bird Avoidance or Conduct Preconstruction Surveys. To avoid impacts to nesting birds and violation of state and federal laws pertaining to birds, all construction-related activities (including but not limited to mobilization and staging, clearing, grubbing, vegetation removal, fence installation, demolition, and grading) should occur outside the avian nesting season (prior to February 1 or after September 15). If construction and construction noise occurs within the avian nesting season (from February 1 to September 15), all suitable habitats located within the project’s area of disturbance including staging and storage areas plus a 250-foot (passerines) and 1,000-foot (raptor nests) buffer around these areas shall be thoroughly surveyed, as feasible, for the presence of active nests by a qualified biologist no more than five days before commencement of any site disturbance activities and equipment mobilization. If project activities Attachment 2.9
46 | City of Watsonville
are delayed by more than five days, an additional nesting bird survey shall be performed. Active nesting is present if a bird is building a nest, sitting in a nest, a nest has eggs or chicks in it, or adults are observed carrying food to the nest. The results of the surveys shall be documented and submitted to the City.
If pre-construction nesting bird surveys result in the location of active nests, no site disturbance and mobilization of heavy equipment (including but not limited to equipment staging, fence installation, clearing, grubbing, vegetation removal, fence installation, demolition, and grading), shall take place within 250 feet of non-raptor nests and 1,000 feet of raptor nests, or as determined by a qualified biologist, until the chicks have fledged. Monitoring shall be required to ensure compliance with MBTA and relevant California Fish and Game Code requirements. Monitoring dates and findings shall be documented and submitted to the City.
b. No Impact. No riparian habitat or other sensitive natural vegetation communities occur onsite. c. Less than Significant with Mitigation Incorporated. The proposed project does not contain any state or federally jurisdictional features or protected wetlands. However, the wetland downstream of the project site could be indirectly affected by project activities. Specifically, construction activities could indirectly cause the degradation of surface or ground water quality due to erosion and transport of fine sediments downstream of the construction area, unintentional release of contaminants into jurisdictional waters, vegetation removal, and soil compaction from access and equipment.
Construction projects in California causing land disturbances that are equal to 1.0 acre or greater must comply with State requirements to control the discharge of stormwater pollutants under National Pollutant Discharge Elimination System (NPDES)/Construction General Permit. Prior to the start of construction/demolition, a Notice of Intent must be filed with the State Water Board describing the project. A Storm Water Pollution Prevention Plan (SWPP) must be developed and maintained during the project, and it must include the use of best management practices (BMPs) to protect water quality until the site is stabilized. Standard permit conditions under the NPDES/Construction General Permit require that the applicant utilize various measures including on-site sediment control best management practices, damp street sweeping, temporary cover of disturbed land surfaces to control erosion during construction, and utilization of stabilized construction entrances and/or wash racks, among other methods. With implementation of Mitigation Measure BIO-2, the impact would be less than significant.
Mitigation Measure BIO-2: The project shall employ Best Management Practices (BMPs) to protect water quality per the National Pollutant Discharge Elimination System (NPDES) permit. A list of example BMPs may include the following:
• Store, handle, and dispose of construction materials and wastes properly to prevent their contact with stormwater.
• Control and prevent the discharge of all potential pollutants, including solid wastes, paints, concrete, petroleum products, chemicals, wash water or sediment, and non-stormwater discharges to storm drains and water courses.
• Avoid cleaning, fueling, or maintaining vehicles on-site, except in a designated area in which run-off is contained and treated.
• Perform clearing and earth moving activities during dry weather to the maximum extent practical.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 47
• Remove spoils promptly and avoid stockpiling of fill materials when rain is forecast.
Cover soil stockpiles and other materials with a tarp or other waterproof material during rain events.
• Trash and construction related solid wastes must be deposited into a covered receptacle to prevent contamination and dispersal by wind.
• In the event of rain, all grading work is to cease immediately. d. No Impact. The project site does not function as a wildlife habitat linkage or movement corridor, nor would project implementation adversely affect any offsite designated wildlife habitat linkage or movement corridor. Regional movement of common wildlife species through the project site is limited due to surrounding development. In addition, the project site does not support any native wildlife nursery sites. Thus, the project would not interfere 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. As a result, construction and operation of the project is not expected to substantially affect breeding productivity or population viability of any common species or cause a change in species diversity locally or regionally. Urban-adapted wildlife occasionally move through the site. As part of the project, most of the site will be developed with the self-storage buildings and paved areas. While fewer species would move across the site due to the presence of buildings, fencing, and reduced vegetation, wildlife movement would not be impeded, and wildlife would be able to continue to move along/around the site following project construction. Thus, the project would not interfere with the movement of any native resident wildlife species or with established native resident or migratory wildlife corridors in the site vicinity.
As noted above, common urban-adapted native species also likely nest in existing trees and other vegetation on the site. The project would implement measures to avoid impacts on nesting birds (see Mitigation Measure BIO-1); thus, the project would not impede the use of native wildlife nursery sites.
e. No Impact. The City of Watsonville does not have a tree removal ordinance, and the project would not conflict with any local policies or ordinances protecting biological resources. The City does apply best management practices regarding the protection of trees during project construction (see “Regulatory Environment” above). There would be no impact. f. No Impact. The project site is not located within the plan area of any adopted Habitat Conservation Plans, Natural Community Conservation Plans, or other approved local, regional, or state Habitat Conservation Plan.
References:
Bulger, J.B., N.J. Scott, Jr., and R.B. Seymour. 2003. Terrestrial activity and conservation of adult California red-legged frogs Rana aurora draytonii in coastal forests and grasslands. Biological Conservation 110: 85-95.
[CNDDB] California Natural Diversity Data Base. 2022. Results of electronic records search. Rarefind
5. California Department of Fish and Wildlife, Biogeographic Data Branch. Accessed March 2022 from https://wildlife.ca.gov/Data/CNDDB/Maps-and-Data.
Fellers, G.M. 2005. Rana draytonii California red-legged frog. In M. Lannoo, ed. Amphibian Declines:
The Conservation Status of United States Species. University of California Press. CA: Berkeley. Pp 552- 554.
Attachment 2.9
48 | City of Watsonville
Fellers, G.M. and P.M. Kleeman. 2007. California red-legged frog (Rana draytonii) movement and habitat use: implications for conservation. Journal of Herpetology 41(2): 276-286.
Jennings, M.R. and M.P. Hayes. 1994. Amphibian and reptile species of special concern in California.
California Department of Fish and Game, Inland Fisheries Division. [USFWS] U.S. Fish and Wildlife Service. 1996. Endangered and Threatened Wildlife and Plants; Determination of Threatened Status for the California Red-legged Frog. Federal Register 61:25813- 26833.
[USFWS] U.S. Fish and Wildlife Service. 2002. Recovery plan for the California red-legged frog (Rana aurora draytonii). U.S. Fish and Wildlife Service, Region 1. [USFWS] U.S. Fish and Wildlife Service. 2010. Endangered and Threatened Wildlife and Plants; Revised Designation of Critical Habitat for California Red-legged Frog; Final Rule. Federal Register 75:12815-12959.
[USFWS] U.S. Fish and Wildlife Service. 2021. Regulations Governing the Take of Migratory Birds; Revocation of Provisions; Final Rule. Federal Register (86): 54642-54656 Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 49
6.5 Cultural Resources
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines
§15064.5?
b) Cause a substantial adverse change in the significance of an archaeological resource as defined in CEQA
Guidelines §15064.5?
c) Disturb any human remains, including those interred
outside of formal cemeteries?
Conclusion: Regarding cultural resources, the proposed project would not result in any significant environmental impacts after mitigation. Implementation of Mitigation Measures CUL-1 and CUL-2 would reduce potential impacts to less than significant levels.
Documentation:
a. No Impact. A cultural resources records search of the California Historical Resources Information System (CHRIS) database was conducted by MIG through the Northwest Information Center (NWIC). The search was returned on February 8, 2022. The search indicates there are six historic structures located within a one-mile radius of the project site. These resources are summarized in Table 5 below:
Table 5. Historic Structure within One Mile of the Project Site Resource Number Resource Name Resource Type Age
P-44-000406 California State Route 1 Structure Historic P-44-000408 California State Route 152 Structure, Other Historic P-44-000644 Historic Golf Fence Structure, Other Historic P-44-000776 The Monument Object Historic
P-44-000777 2013 Freedom Blvd Building Historic
P-44-000778 2141 Freedom Blvd Building Historic
The City of Watsonville keeps its own historic register which contains 14 structures, six of which are on the National Register of Historic Places (NRHP). These are shown in Table 6, below:
Table 6. City of Watsonville Historic Register Entries
Address Resource Name National Register Eligible
261–261A East Beach Street Richard Pearson Home No
332 East Beach Street Bockius-Orr House Yes
128 East Beach Street Julius Lee Home Yes
12 Brennan Street Watsonville Women’s Club No
225 East Lake Ave N/A No
Attachment 2.9
50 | City of Watsonville
305 East Lake Ave Mitchell Resetar Home No
335 East Lake Ave Madison House Yes
280 Main Street Porter Building No
406 Main Street Lettunich Building Yes
418–428 Main Street Mansion House Yes
426–434 Main Street Kalich Building No
Main/Beach/Peck/Union Watsonville City Plaza Yes
139 Maple Street Horgan House No
37 Sudden Street Pajaro Valley Arts Council No
The six historic structures identified by the NWIC, as well as the 14 buildings on the City’s register, are outside of the project’s boundary and are not within line of site of the project site. Furthermore, development within the project site would be consistent with the surrounding environment and would not impact the historic character of historic resources within the study area. According to historic maps and aerial photographs, there has never been a structure built within the project site, other than lighting associated with the parking lot. As there are no identified historical resources, or buildings or structures that could have potential to be considered historical resources, within the project site, and the project has no potential to impact the historic character of nearby resources. The proposed project would have no impact to historical resources.
b. Less than Significant with Mitigation Incorporated. The cultural resources records search results conducted by the NWIC indicates there are no archaeological resources (prehistoric or historic) located within the project’s boundaries. There is one historic period archaeological resource located within one mile of the project boundary, and one prehistoric resource within one mile of the project boundary. These resources are summarized in Table 7 below:
Table 7. Cultural Resources within One Mile of the Project Site Resource Number Resource Name Resource Type Age
P-44-000643 Plowing Golf Balls Site Historic
P-44-000802 BF-2 Site Prehistoric
Resource P-44-000643 is a historic period archaeological site and is comprised of a small collection of historic debris dating from around the beginning of the 20th century, concentrated around a broken iron plow. The site is over 0.5 miles south-west of the project site. It is documented as being likely connected with historic structure P-44-000644 (Historic Golf Fence).
Resource P-44-000802 is a prehistoric period archaeological site and consists of redeposited dark midden soil containing shell fragments and a small mortar bowl. The resource had clearly been redeposited, although the surveyor considered it likely came from the nearby vicinity. The archaeological site is located over 0.75 miles away from the project site.
A Sacred Lands File (SLF) search was conducted through the Native American Heritage Commission (NAHC), with a positive result reported on January 28, 2022. The search indicated that the Costanoan Ohlone Rumsen-Mutsen Tribe had more information on potential resources in the project vicinity. It was also recommended that the Amah Mutsun Tribal Band, Amah Mutsun Tribal Band of Mission San Juan Bautista, Indian Canyon Mutsun Band of Costanoan, and the Wuksache Indian Tribe/Eshom Valley Band be contacted as an extension of the SLF. Emails were sent to the Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 51
tribes on February 9, 2022, which included a topographic map of the project area and details of the proposed project undertaking.
After contacting the Costanoan Ohlone Rumsen-Mutsen Tribe, the tribe requested additional information on the project, which was sent to the tribe. After sending the information, MIG requested that the tribe indicate if the project could impact the resource. Despite several attempts at further communication, no response was received; therefore, MIG has concluded that the tribe does not believe the project could impact the Native American archaeological resource(s) they have specific knowledge of.
The remaining tribes were also contacted, as recommended by the NAHC. The initial contact was made by email. All of the tribes who did not respond were then contacted by follow-up phone calls.
The only tribe who did not provide a response was the Muwekma Ohlone Indian Tribe of the SF Bay Area, who received an email and two voicemails. No specific information on tribal resources was provided by the tribes. However, all these tribes indicated the area was considered sensitive.
Based on the results of the SLF search and Native American outreach, although no specific resources were discovered, cultural resources could be present and project excavation could result in the discovery of prehistoric archaeological resources. In the event that project ground-disturbing activities disturb, damage, or destroy previously unknown buried prehistoric features, sites or artifacts, a significant impact could occur. Implementation of Mitigation Measures CUL-1 and CUL2 would reduce potential impacts to undiscovered archeological resources to a less than significant level.
Mitigation Measure CUL‐1: Conduct Archaeological Sensitivity Training for Construction Personnel. The applicant shall retain a qualified professional archaeologist who meets U.S.
Secretary of the Interior’s Professional Qualifications and Standards to conduct an archaeological sensitivity training for construction personnel prior to commencement of excavation activities. The training session shall be carried out by a cultural resource professional with expertise in archaeology, who meets the U.S. Secretary of the Interior’s Professional Qualifications and Standards. The applicant and/or qualified professional archaeologist shall propose a date for scheduling the training at the pre-construction meeting with City staff. The applicant shall notify the City at least 48 hours before holding the training and keep a log of all attendees. The training session shall include a handout and shall focus on how to identify archaeological resources that may be encountered during earthmoving activities and the procedures to be followed in such an event, the duties of archaeological monitors, and the general steps a qualified professional archaeologist would follow in conducting a salvage investigation, if one is necessary.
Mitigation Measure CUL‐2: Cease Ground‐Disturbing Activities and Implement Treatment Plan if Archaeological Resources are Encountered. In the event archaeological resources are unearthed during ground-disturbing activities, all ground-disturbing activities within 50 feet of the find shall be halted so that the find can be evaluated. Ground-moving activities shall not be allowed to continue until a qualified archaeologist has examined the newly discovered artifact(s) and has evaluated the area of the find. All archaeological resources unearthed by project construction activities shall be evaluated by a qualified professional archaeologist, who meets the U.S. Secretary of the Interior’s Professional Qualifications and Standards. In the event that the newly discovered artifacts are determined to be prehistoric, Native American Tribes/Individuals shall be contacted and consulted, and Native American construction monitoring shall be initiated.
Attachment 2.9
52 | City of Watsonville
Because it is possible for a lead agency to determine that an artifact is considered significant to a local tribe (and thus be a significant resource under CEQA, even if it would not otherwise be considered significant under CEQA), all Native American artifacts (tribal finds) shall be considered as a significant Tribal Cultural Resource, pursuant to PRC 21074 until the lead agency has enough evidence to make a determination of significance. The City shall coordinate with the archaeologist to develop an appropriate treatment plan for the resources. The plan may include implementation of archaeological data recovery excavations to address treatment of the resource along with subsequent laboratory processing and analysis. If appropriate, the archaeologist may introduce archaeological monitoring on the site. An archaeological report will be written detailing all archaeological finds and submitted to the City and the Northwest Information Center. c. Less than Significant Impact. No burial sites - either modern, historic, or prehistoric - are known in the near vicinity of the project site. Background research failed to show any evidence for the presence of burials, either historic or prehistoric. In the event of accidental discovery, adherence to existing laws and regulations (California Health and Safety Code, Sections 7050 and 7052; Chapter 10 of Part 3 of Division 2 of Title 3 of the California Government Code; and Section 5097.98 of the California Public Resources Code) would ensure that any human remains would be protected. The impact would be less than significant.
References:
City of Watsonville, 2012. Historic Register. Available at:
https://cityofwatsonville.org/DocumentCenter/View/3954/City-of-Watsonville-Historic-Register (accessed on February 9, 2022).
County of Santa Cruz, 2022. Assessor’s Office: Search. Available at: https://sccounty01.co.santacruz.ca.us/ASR/ (accessed on February 9, 2022).
Historic Aerials, 2022. Topographic maps and aerial photographs 1914 – 2018. Available at:
https://www.historicaerials.com/viewer.
Native American Heritage Commission, 2022. Scared Lands File Search Prepared in Support of the Crocker’s Lockers Project, Santa Cruz County. January 28, 2022. Unpublished document kept on file with the NAHC and MIG, Inc.
Northwest Information Center, 2022. Cultural Resources Records Search in Support of the 547 Crocker’s Lockers Project (No. File No. 21-1068). Unpublished document kept on file with the NWIC and MIG, Inc.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 53
6.6 Energy Resources
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or
operation?
b) Conflict with or obstruct a state or local plan for
renewable energy or energy efficiency?
Conclusion: Regarding energy resources, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. Construction activities associated with the proposed project would require the use of heavy-duty, off-road equipment and construction-related vehicle trips that would combust fuel, primarily diesel and gasoline. Heavy-duty construction equipment would be required to comply with CARB’s airborne toxic control measures, which restrict heavy-duty diesel vehicle idling to five minutes. Since petroleum use during construction would be temporary and needed to conduct development activities, it would not be wasteful or inefficient. As estimated in CalEEMod, the proposed project is estimated to consume approximately 556,592 kWh of electricity and 515,312 kBTU on an annual basis. Although more electricity and natural gas would be consumed on an annual basis compared to the existing parking lot, the structures would use the energy in an efficient manner and would serve a larger subset of the population in Watsonville. As such, the proposed project’s energy consumption would not be wasteful, inefficient, or unnecessary. This impact would be less than significant.
b. Less than Significant Impact. The proposed project would not conflict with nor obstruct a state or local plan adopted for the purposes of increasing the amount of renewable energy or energy efficiency. As discussed under response a), the proposed self-storage units and manager residence would be constructed to the latest CALGreen Code. Furthermore, the proposed project would not conflict with the City’s Climate Action and Adaptation Plan (CAAP). As described in Section 6.8, CAAP consistency is determined by evaluating: 1) The project’s consistency with the growth projections and land use assumptions that formed the basis of the CAAP’s GHG emissions projections; and 2) The project’s consistency with applicable GHG-reduction and climate adaptation measures contained in the CAAP. As explained in more detail in Section 6.8, the proposed project is consistent with the site’s General Plan land use designation and zoning and, as discussed in Section
6.14, does not conflict with the growth assumptions in the 2040 Metropolitan Transportation Plan/Sustainable Communities Strategy. The project would also be consistent with all applicable measured contained in the City’s CAAP (see Table 8), including measures pertaining to energy efficiency such as reducing natural gas usage and the including solar photovoltaic panels in the project’s roof design. This impact would be less than significant.
Attachment 2.9
54 | City of Watsonville
References:
California Green Building Standards Commission (CalGreen), 2019. Section 4.201. Available at: https://up.codes/viewer/california/ca-green-code-2019/chapter/4/residential-mandatorymeasures#4.201 (accessed March 8, 2022).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 55
6.7 Geology and Soils
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
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 Division of Mines and Geology
Special Publication 42.
ii) Strong seismic ground shaking?
iii) Seismic-related ground failure, including liquefaction? iv) Landslides?
b) Result in substantial soil erosion or the loss of topsoil? c) Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse?
d) Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property?
e) Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of
wastewater?
f) Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?
Conclusion: Regarding geology and soils, the proposed project would not result in any significant environmental impacts after mitigation.
Documentation:
ai. No Impact. The proposed project site is not located in an Alquist-Priolo fault zone, and there would be no impact.
aii. Less than Significant Impact. Much of the region is subject to seismic shaking that results from earthquakes along the San Andreas Fault Zone System. Per the Geotechnical Engineering Study conducted by Earth Systems (Appendix C of this Initial Study), the San Andreas fault is located approximately 5.2 miles to the northeast of the site, the Calaveras fault is located approximately Attachment 2.9
56 | City of Watsonville
17.5 miles to the northeast of the site, and the Hayward fault is located approximately 21.9 miles to the northeast of the site. The Zayante‐Vergeles fault is a minor fault located approximately 1.6 miles to the northeast of the site. Predicting seismic events is not possible, nor is providing mitigation that can entirely reduce the potential for injury and damage that could occur during a seismic event. However, by applying geotechnical evaluation techniques and appropriate engineering practices, potential injury and damage from seismic activity can be diminished by exposing fewer people and less property to the effects of a major earthquake. The design and construction of new structures are subject to engineering standards of the California Building Code (CBC), which consider soil properties, seismic shaking, and foundation type.
Standard conditions of approval require that building permits be obtained for all construction and that the project meet all standard seismic and soil test/compaction requirements.
All construction activities shall meet the CBC regulationsforseismic safety. Construction plans shall be subject to review and approval of the City prior to the issuance of a building permit.
All work shall be subject to inspection by the City and must conform to all applicable code requirements and approved improvement plans prior to final inspection approval or the issuance of a certificate of occupancy. The applicant shall be responsible for notifying construction contractors about CBC regulations for seismic safety. Adherence to the CBC would ensure that potential impacts from strong seismic ground shaking would be reduced to less than significant.
aiii. Less than Significant with Mitigation Incorporated. Strong ground shaking can result in liquefaction, which is the sudden loss of sheer strength in saturated sandy material, resulting in ground failure and displacement. The project Geotechnical Engineering Study (Appendix C) notes that the site is in a zone of low to moderate liquefaction potential. The study notes that should liquefaction occur, the total seismic‐related settlement would generally be less than one inch throughout the site, with a maximum of four inches in the northwest portion of the site.
Impacts from liquefaction and ground failure would be less than significant with implementation of Mitigation Measure GEO-1.
Mitigation Measure GEO-1: Over-Excavate North and Northwestern Soils. Prior to issuance of a grading permit, the applicant, in partnership with a geotechnical engineer, shall implement an over-excavation program to mitigate the possible settlements resulting from dry sand settlement during an earthquake. Potholing throughout the site should occur under the observation of an engineer technician to explore the presence of undocumented fill onsite and guide recommendations for over‐excavation depths. The over‐excavation and placement of excavated material as engineered fill shall be focused on the northeastern and northwestern portions of the site in locations with high calculated settlements. Over-excavation depths shall be kept at least two feet above the water table. Actual depth and limits of over‐excavations shall be determined in the field by a qualified engineering professional. Undocumented fill across the site shall be excavated and placed back as engineered fill if the fill material is deemed to be acceptable by the engineer.
aiv. Less than Significant Impact. The urban and developed areas of Watsonville are primarily characterized by gradual to moderate slopes. In areas underlain by weak or unconsolidated earth materials, landslides are a hazard. The project site is relatively flat, with minimal elevation change. According to the Landslide Hazard Map (Wills et al, 2019), the project site is partially Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 57
mapped in an area of landslides in classes V and VI, which have minimal landslide potential.
The impact would be less than significant.
b. Less than Significant Impact. The project proposes grading on a what is currently a paved parking lot. The project proposes approximately 22,383 cubic yards (CY) of cut, and a fill of 331 CY. The excess 22,052 CY of cut would be hauled offsite to be used at another local site.
The grading, cuts, and fills require the issuance of a grading permit. Improper grading, both during and post-construction, has the potential to increase the volume of runoff from a site and subsequently increase erosion. The RAK Civil Engineer Stormwater Control Plan (Appendix D of this Initial Study) includes standard erosion control measures to be used during construction, such as limiting development areas, and standard pollution control measures for the entire site to prevent discharge of sediment and contaminants into the drainage system. The Plan also includes an inspection program to evaluate if there is any onsite erosion as a result of rainfall. If there are problem areas at the site, recommendations will be made by professional engineers to improve methods to manage onsite erosion as part of the Plan. The impact is less than significant.
c. Less than Significant with Mitigation Incorporated. The project site is subject to seismic shaking, and a discussion of impacts related to landslides and liquefaction is in Section 6.7 (aii, aiv). Lateral spreading occurs when soils liquefy during an earthquake and the liquefied soils, along with the overlying soils, move laterally to unconfined spaces, causing horizontal ground displacements. In the event that onsite soil is saturated at the time of a fault rupture, the isolated layer of sand has a high potential of liquefying, which could potentially result in significant lateral spreading.
The project site is relatively flat, and the project would not include a water well, thereby reducing the probability of onsite subsidence. Implementation of Mitigation Measure GEO1 would reduce the impact to a less than significant level. d. Lessthan Significant. Per the Earth Systems geotechnical report, the project site is mapped as being underlain by Pleistocene fluvial facies, typically consisting of silt, sand, silty clay, and gravel. The NRCS (2020) maps the project’s soils as Tierra-Watsonville Complex, with Watsonville Loam and trace Pinto loam (0 to 2 percent slopes). The geotechnical engineers conducted a subsurface investigation, and the soil was determined to have a low potential for shrinkage and swelling.
Project construction and grading activities must be conducted in compliance with the California Building Code and with Watsonville Municipal Code Chapter 7-6 (Excavations, Grading, Filling and Erosion Control). Compliance with all applicable construction and grading regulations would reduce impacts to life and property created from soil expansion to less than significant levels.
e. No Impact. The proposed project is within City boundaries and would be served by a public sewer system. The project does not include installation of septic tanks or alternate wastewater disposal systems.
f. Less than Significant with Mitigation Incorporated. The site is in a developed area, and geological analysis did not reveal the presence of unique geological features.
Attachment 2.9
58 | City of Watsonville
The geology for the project area, according to a geological map showing the Pajaro Valley, consist of Quaternary alluvium and marine deposits ranging in age from the Holocene to Pleistocene (California Division of Mines and Geology, Geologic Map of California, 1977).
The project area is within the geological area floodplain of the Pajero River, and the geology of the project area is comprised of alluvial fan deposits (Pajaro Valley Water Management Agency, 2020). Based on the pinto loam soil present at the site, this is likely to be at least older Holocene or younger Pleistocene in age.
Although the underlying geology of granitic and metamorphic rocks do not normally yield fossilized material, older alluvial deposits have the potential to contain fossils, especially at depths. Development of the site could encounter previously undisturbed soils. However, as alluvial material is deposited slowly over time, the depths of excavation required for the project are not anticipated to be of a depth where fossilized material is likely to be discovered.
Given the geology of the site and the proposed depth of grading, there is a chance that paleontological resources could be discovered. If project ground-disturbing activities disturb, damage, or destroy previously unknown buried paleontological resources, a significant impact could occur. Implementation of Mitigation Measures GEO-2 and GEO-3 would reduce potential impacts to undiscovered paleontological resources to a less than significant level.
Mitigation Measure GEO-2: Conduct Paleontological Sensitivity Training for ConstructionPersonnel. The applicant shall retain a professional paleontologist, who meets the qualifications set forth by the Society of Vertebrate Paleontology and shall conduct a paleontological sensitivity training for construction personnel prior to commencement of excavation activities. The applicant and/or qualified professional paleontologist shall propose a date for scheduling the training at the pre-construction meeting with City staff. The applicant shall notify the City at least 48 hours before holding the training and keep a log of all attendees.
The training will include a handout and will focus on how to identify paleontological resources that may be encountered during earthmoving activities and the procedures to be followed in such an event, the duties of paleontological monitors, notification and other procedures to follow upon discovery of resources, and the general steps a qualified professional paleontologist would follow in conducting a salvage investigation if one is necessary.
Mitigation Measure GEO-3: Cease Ground-Disturbing Activities and Implement Treatment Planif Paleontological Resources Are Encountered. If paleontological resources and or unique geological features are unearthed during ground-disturbing activities, grounddisturbing activities shall be halted or diverted away from the vicinity of the find so that the find can be evaluated. A buffer area of at least 50 feet shall be established around the find where construction activities shall not be allowed to continue until appropriate paleontological treatment plan has been approved by the applicant and the City. Work shall be allowed to continue outside of the buffer area. The applicant and City shall coordinate with a professional paleontologist, who meets the qualifications set forth by the Society of Vertebrate Paleontology, to develop an appropriate treatment plan for the resources. Treatment may include implementation of paleontological salvage excavations to remove the resource along with subsequent laboratory processing and analysis or preservation in place. At the paleontologist’s discretion and to reduce construction delay, the grading and excavation contractor shall assist in removing rock samples for initial processing.
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Crocker’s Lockers Self-Storage Project IS/MND | 59
References:
California Department of Conservation, 2010. Geologic Map of California. Available at:
http://maps.conservation.ca.gov/cgs/gmc/ (accessed January 20, 2022).
California Division of Mines and Geology, 1977. Jennings, C.W., Strand, R.G., and Rogers, T.H., Geologic map of California: scale 1:750,000., available at:
https://mrdata.usgs.gov/geology/state/state.php?state=CA (Accessed January 20, 2022) City of Watsonville, 2012. General Plan. Liquefaction Potential Map Figure 13.2. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/2564/Liquefaction-PotentialMap?bidId= Plan (accessed January 20, 2022).
Earth Systems Pacific, 2021. Geotechnical Engineering Study for Crocker’s Lockers Self-Storage.
March 22, 2021. (Appendix C)
RAK Civil Engineers, 2021 Stormwater Control Plan Report for Crocker’s Lockers Self-Storage.
June 14, 2021, revised September 29, 2021. (Appendix D) Pajaro Valley Water Management Agency, 2020. Geology. Available at:
https://www.pvwater.org/geology (accessed February 2, 2022) U.S. Department of Agriculture (USDA). Natural Resource Conservation Service (NRCS), Web Soil Survey. https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx (accessed January 20, 2022)
Wills et al, 2019. Landslide Hazard Mapping, California Geological Survey Department of Conservation Sacramento, California. CGS Map Sheet 58. Available online:
https://www.arcgis.com/home/webmap/viewer.html?layers=b6cf689f727340d6b3f8cd869e69c729 (Accessed January 21, 2022)
Attachment 2.9
60 | City of Watsonville
6.8 Greenhouse Gas Emissions
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Generate greenhouse gas emissions, either directly or indirectly, that may have a significant impact on the
environment?
b) Conflict with an applicable plan, policy or regulation adopted for the purpose of reducing the emissions of
greenhouse gases?
Conclusion: Regarding greenhouse gas emissions, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact.
b. Less than Significant Impact.
Gases that trap heat in the atmosphere and affect regulation of the Earth’s temperature are known as greenhouse gases (GHGs). The six most common GHGs are listed below. • Carbon dioxide (CO2)
• Methane (CH4)
• Nitrous oxide (N2O)
• Sulfur hexafluoride (SF6)
• Hydrofluorocarbon (HFCs)
• Perfluorocarbons (PFCs)
GHGs that contribute to climate change are a different type of pollutant than criteria or hazardous air pollutants, as previously discussed in Section 6.3, Air Quality, because climate change is global in scale, both in terms of causes and effects. Some GHGs are emitted to the atmosphere naturally by biological and geological processes such as evaporation (water vapor), aerobic respiration (carbon dioxide), and off-gassing from low oxygen environments such as swamps or exposed permafrost (methane); however, GHG emissions from human activities such as fuel combustion (e.g., carbon dioxide) and refrigerants use (e.g., hydrofluorocarbons) significantly contribute to overall GHG concentrations in the atmosphere, which affects climate regulation and results in a changing climate globally. Examples of the effects of global climate change include rising temperatures and increased severe weather events such as drought and flooding.
GHGs can remain in the atmosphere long after they are emitted. The potential for a GHG to absorb and trap heat in the atmosphere is considered its global warming potential (GWP). The reference gas for measuring GWP is CO2, which has a GWP of one. By comparison, CH4 has a GWP of 25, which means that one molecule of CH4 has 25 times the effect on global warming as one molecule of CO2.
Multiplying the estimated emissions for non-CO2 GHGs by their GWP determines their carbon dioxide equivalent (CO2e), which enables a project’s combined global warming potential to be expressed in terms of mass CO2 emissions. Most often, GHG emissions associated with projects are referred to in terms of metric tons of CO2e, or MTCO2e.
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61 | City of Watsonville
In 1997, the United Nations’ Kyoto Protocol was adopted in Kyoto, Japan, establishing an international treaty that set targets for reductions in emissions of four specific GHGs – CO2, CH4, N2O, and SF6 – and two groups of gases – HFCs and PFCs. As previously mentioned, these GHGs are the primary GHGs emitted into the atmosphere by human activities. The United States is, and has been, a participant in the United Nations Framework Convention on Climate Change.
The State of California has numerous regulations and executive directives aimed at reducing GHG emissions. In 2005, for instance, the governor issued Executive Order S-3-05, establishing statewide GHG emissions reduction targets. Executive Order S-3-05 provides that by 2010, emissions shall be reduced to 2000 levels; by 2020, emissions shall be reduced to 1990 levels; and by 2050, emissions shall be reduced to 80 percent below 1990 levels (CalEPA 2006). In 2006, the California Global Warming Solutions Act (AB 32) was signed into law. AB 32 codifies the statewide GHG emission reduction targets and required CARB to prepare a Scoping Plan that outlines the main State strategies for reducing GHGs to meet the 2020 deadline, which was approved in 2008 and updated in 2014.
Executive Order B-30-15, 2030 Carbon Target and Adaptation, issued by Governor Brown in April 2015, sets a target of reducing GHG emissions by 40 percent below 1990 levels in 2030. By directing state agencies to take measures consistent with their existing authority to reduce GHG emissions, this order establishes coherence between the 2020 and 2050 GHG reduction goals set by AB 32 and seeks to align California with the scientifically established GHG emissions levels needed to limit global warming below two degrees Celsius.
To reinforce the goals established through Executive Order B-30-15, Governor Brown went on to sign SB 32 and AB 197 on September 8, 2016. SB 32 made the GHG reduction target to reduce GHG emissions by 40 percent below 1990 levels by 2030 a requirement as opposed to a goal. AB 197 gives the Legislature additional authority over CARB to ensure the most successful strategies for lowering emissions are implemented, and requires CARB to, “protect the state’s most impacted and disadvantaged communities …[and] consider the social costs of the emissions of greenhouse gases.”
On December 14, 2017 CARB adopted the second update to the Scoping Plan, the 2017 Climate Change Scoping Plan Update (2017 Scoping Plan Update; CARB 2017). The primary objective of the 2017 Scoping Plan Update is to identify the measures needed to achieve the mid-term GHG reduction target for 2030 (i.e., reduce emissions by 40 percent below 1990 levels by 2030), as established under Executive Order B-30-15 and SB 32. The 2017 Scoping Plan Update identifies an increasing need for coordination among state, regional, and local governments to achieve the GHG emissions reductions that can be gained from local land use planning and decisions. It notes emission reduction targets set by more than one hundred local jurisdictions in the state could result in emissions reductions of up to 45 million MTCO2e and 83 million MTCO2e by 2020 and 2050, respectively. To achieve these goals, the 2017 Scoping Plan Update includes a recommended planlevel efficiency threshold of six metric tons or less per capita by 2030 and no more than two metric tons by 2050.
MBARD, as the regional air agency for the Basin, has air-permitting authority in Santa Cruz County.
As of March 2020, MBARD has not adopted recommended GHG significance thresholds applicable to development projects.
Attachment 2.9
62 | City of Watsonville
To evaluate the significance of the proposed project’s GHG emissions, this analysis demonstrates consistency with the City of Watsonville’s Climate Action and Adaptation Plan (CAAP), which is a qualified reduction plan pursuant to CEQA Guidelines, Section 15183.5. A project that demonstrates consistency with the CAAP is considered not to have a cumulatively considerable impact related to GHG emissions. As described in more detail below, the proposed project would be consistent with the City’s CAAP and would not conflict with CARB’s Scoping Plan or AMBAG’s 2040 Metropolitan Transportation Plan/Sustainable Communities Strategy.
Watsonville 2030 Climate Action and Adaptation Plan
In 2015, the City of Watsonville prepared a Climate Action Plan that set forth 13 actions to help reduce GHG emissions in 2020 and 2030. In 2021, the City prepared an updated Climate Action and Adaptation Plan intended to meet California state targets and reduce Watsonville’s GHG emissions to 80% below 1990 levels by 2030. It also sets a goal of achieving net-negative GHG emissions by 2030, in line with the City Council’s 2021 Resolution Endorsing Climate Safe California. The CAAP contains 19 strategies, 33 implementation measures, and 61 supporting actions to achieve these emission reduction goals. Many of the actions identified in the CAAP consist of items the City will pursue, such as expanding transit service, installing public electric vehicle charging stations, and incentivizing natural gas appliance retrofits (City of Watsonville 2021a).
CAAP consistency is determined by evaluating: 1) The project’s consistency with the growth projections and land use assumptions that formed the basis of the CAAP’s GHG emissions projections; and 2) The project’s consistency with applicable GHG-reduction and climate adaptation measures contained in the CAAP.
The proposed project is consistent with the site’s General Plan land use designation and zoning. In addition, as discussed in Section 6.14, population and housing, the project does not conflict with the growth assumptions in the 2040 Metropolitan Transportation Plan/Sustainable Communities Strategy. The project, therefore, would be consistent with the growth projections and land use assumptions used to develop the CAAP’s GHG emission projects.
The proposed project also would be consistent with all applicable measures contained in the City’s CAAP. The proposed project would generate GHG emissions from both short-term construction and long-term operational activities. Construction activities would generate GHG emissions primarily from equipment fuel combustion as well as worker, vendor, and haul trips to and from the project site during demolition, site preparation, grading, building construction, paving, and architectural coating activities. Construction activities would cease to emit GHGs upon completion, unlike operational emissions that continue year after year until the commercial buildings constructed as part of building of the project close or cease operation. Once operational, the proposed project would generate GHG emissions from area, mobile, water/wastewater, and solid waste sources. An analysis of the proposed project’s consistency with applicable measures from the City’s CAAP is provided in Table 8.
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Crocker’s Lockers Self-Storage Project IS/MND | 63
Table 8: Project Consistency with the City of Watsonville’s CAAP Applicable Measures Consistency Analysis
Transportation and Land Use
Strategy T2: Increase Multimodal Transportation Facilities Measure T2-A: New Pedestrian Improvements.
Require new development projects, residential
and nonresidential, to provide pedestrian
improvements along street frontages; and
strongly encourage connection to the nearest
existing pedestrian facilities, such as sidewalks
or trails. Developments shall also include
internal pedestrian connections between all
uses.
Consistent. The project would provide an
accessible path of travel to the existing
sidewalk along Nielson Street.
Existing sidewalks are present on both sides of
Airport Boulevard, Nielson Street, and Hangar
Way, linking the project site to the surrounding
pedestrian network and providing pedestrian
access between the project site and the
surrounding residential and commercial uses.
Strategy T5: Increase Community Commute Trip Reduction
Measure T5-A: Commute Trip Reduction
Programs. Update the City’s Green Business
Program to include commute trip reduction
programs. Provide incentives and education to
existing and future employers to participate in
the program, particularly to implement
commute trip reduction programs. The City
shall track participating businesses to achieve a
20 percent participation City-wide. Commute
trip reduction programs may include but not be
limited to ride-sharing programs, subsidized
transit, vanpool/shuttles, and alternative work
schedules.
This measure would take place at the City
level and would not directly apply to the
project. In addition, the project would have one
employee, the onsite manager, both resulting
in low commute trips and limiting the
commute trip reduction actions that would
apply to the project.
Measure T5-B: End-of-Trip Facilities. Update
Watsonville Municipal Code, Section 14-
17.113, to require new non-residential
development to provide end-of-trip facilities
for employee use in addition to bicycle
parking. End-of-trip facilities will include bike
parking, bike lockers, showers, and personal
lockers to the extent feasible.
Consistent. The project would include the
installation of a bike rack next to the
manager’s building.
Attachment 2.9
64 | City of Watsonville
Table 8: Project Consistency with the City of Watsonville’s CAAP Applicable Measures Consistency Analysis
Energy
Strategy E1: Reduce Natural Gas Use
Measure E1-A: Natural Gas Reduction in New
Development. Require a 50 percent reduction
in natural gas consumption compared to BAU
in all new development through electric-only
development and installation of electric or
more efficient natural gas home heating and
cooling systems, appliances, or water heaters.
Explore implementation of an all-electric
ordinance to achieve all electric new
development by 2030.
Consistent. The project would be all electric
with no natural gas service.
Strategy E3: Increase 3CE Prime Participation
Measure E3-B: City 3CE Prime Participation.
Increase participation in 3CE Prime, with the
goal of 50 percent of all residential and nonresidential customers choosing 3CE Prime by 2030.
Supporting Effort E3-S1: Collaborate with
Central Coast Community Energy (3CE) to
develop an outreach program to encourage and
incentivize switching to 3CE Prime.
This measure would take place at the City
level and would not directly apply to the
project.
In addition, the purpose of Measure E3-B is to
facilitate the switch to carbon-free electricity.
The project meets this goal by installing solar
panels, which will fully power the building.
Strategy E4: Incorporate Cool Roof Technology
Measure E4-A: Cool Roofs for New
Development. Require installation of cool roof
technology for new commercial, municipal,
and multi-family residential projects to achieve
at least 50 percent cool roofs in new
development. A cool roof treatment, green
space, or photovoltaic panels would qualify for
compliance with this measure.
Consistent. The roofs for the storage buildings
would be light grey color standing seam metal
and the manager’s building roof would be a
white Thermoplastic Polyolefin (TPO). The
project would install photovoltaic panels,
which would fully power the facility.
Source: City of Watsonville, 2021
CARB Scoping Plan
The 2017 Climate Change Scoping Plan is CARB’s primary document used to ensure State GHG reduction goals are met. The plan identifies an increasing need for coordination among State, regional, and local governments to achieve the GHG emissions reductions that can be gained from local land use planning and decisions. The major elements of the 2017 Climate Change Scoping Plan, which is designed to achieve the State’s 2030 GHG reduction goal include:
• Continued implementation of SB 375.
• Implementing and/or increase the standards of the Mobile Source Strategy, which include increasing zero emission vehicle (ZEV) buses and trucks. • Low Carbon Fuel Standard (LCFS), with an increased stringency (18 percent by 2030).
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Crocker’s Lockers Self-Storage Project IS/MND | 65
• Implementation of SB 350, which expands the Renewable Portfolio Standard (RPS) to 50 percent and doubles energy efficiency savings by 2030.
• California Sustainable Freight Action Plan, which improves freight system efficiency, utilizes near-zero emissions technology, and deployment of ZEV trucks. • Implementing the proposed Short-Lived Climate Pollutant Strategy, which focuses on reducing CH4 and hydrocarbon emissions by 40 percent and anthropogenic black carbon emissions by 50 percent by year 2030.
• Post-2020 Cap-and-Trade Program that includes declining caps. • 20 percent reduction in GHG emissions from refineries by 2030. • Development of a Natural and Working Lands Action Plan to secure California’s land base as a net carbon sink.
Nearly all of the specific measures identified in the 2017 Climate Change Scoping Plan would be implemented at the state level, with CARB and/or another state or regional agency having the primary responsibility for achieving required GHG reductions. The proposed project, therefore, would not directly conflict with any of the specific measures identified in the 2017 Climate Change Scoping Plan. The project is consistent with vehicle miles traveled (VMT) guidelines outlined in Senate Bill (SB) 743 and discussed in section 6.17, Transportation. 2040 Metropolitan Transportation Plan/Sustainable Communities Strategy AMBAG is the Metropolitan Planning Organization responsible for preparing the region’s Sustainable Communities Strategy (SCS), in compliance with SB 375. The SCS is developed as part of regional transportation planning and is incorporated in the Metropolitan Transportation Plan (MTP) prepared for the AMBAG region. The most recent plan adopted by AMBAG is the 2040 MTP/SCS (AMBAG, 2018). The 2040 MTP/SCS sets forth a forecasted development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, is intended to reduce GHG emissions from passenger vehicles and light duty trucks to achieve the regional GHG reduction targets set by CARB.
CARB set targets for the AMBAG region as “not to exceed 2005 per capita levels of GHGs” by 2020 and a five percent reduction from 2005 levels by 2035 (CAP). These targets applied to the AMBAG region as a whole for all on-road light duty trucks and passenger vehicles emissions, and not to individual cities or sub-regions. Therefore, AMBAG, through the 2040 MTP/SCS, must maintain or reduce these levels to meet the 2020 target and reduce these levels to meet the 2035 targets.
As described under Section 6.14, Population and Housing, the proposed project is within the growth forecasts of the 2040 MTP/SCS. Therefore, the growth (and associated traffic) facilitated under implementation of the proposed project has been accounted for in the 2040 MTP/SCS’s growth projections, and the project would be consistent with the 2040 MTP/SCS.
Conclusion
As described above, the proposed project would be consistent with the Watsonville CAAP and would not conflict with any other applicable plan, policy or regulation adopted for the purpose of reducing GHG emissions. The City’s CAAP provides a streamlined review process for projects that require review under CEQA because the CAAP is a “qualified” reduction plan pursuant to CEQA Guidelines, Section 15183.5. Consistency with the CAAP is the threshold of significance to evaluate GHG impacts. The proposed project would be consistent with the CAAP and, therefore, is considered Attachment 2.9
66 | City of Watsonville
not to have a cumulatively considerable impact related to GHG emissions. No additional projectspecific GHG analysis is required. This impact would be less than significant.
References:
Association of Monterey Bay Area Governments (AMBAG), 2018. 2040 Metropolitan Transportation Plan/Sustainable Communities Strategy.
Bay Area Air Quality Management District (BAAQMD), 2017. CEQA Air Quality Guidelines.
Available at: http://www.baaqmd.gov/~/media/files/planning-andresearch/ceqa/ceqa_guidelines_may2017-pdf.pdf?la=en (accessed March 8, 2022).
California Air Resources Board (CARB). 2017. California’s 2017 Climate Change Scoping Plan.
Available at: https://ww3.arb.ca.gov/cc/scopingplan/scoping_plan_2017.pdf (accessed March 8, 2022).
California Environmental Protection Agency (CalEPA). 2006. Climate Action Team Report to Governor Schwarzenegger and the Legislature. Available at:
https://www.climatechange.ca.gov/climate_action_team/reports/2006report/2006-04- 03_FINAL_CAT_REPORT.PDF (accessed March 8, 2022).
City of Watsonville, 2015. City of Watsonville Climate Action Plan (CAP).
Sacramento Metro Air Quality Management District (SMAQMD), 2018. CEQA Guidance & Tools.
Chapter 6: Greenhouse Gases. Available at:
http://www.airquality.org/LandUseTransportation/Documents/Ch6GHGFinal5-2018.pdf (accessed March 8, 2022).
City of Watsonville, 2021. Watsonville 2030 Climate Action and Adaptation Plan (CAAP). Available at: https://www.cityofwatsonville.org/1764/Learn-About-Climate-Action-Plan (accessed June 2, 2022).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 67
6.9 Hazards and Hazardous Materials
Conclusion: Regarding hazards and hazardous materials resources, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. Construction of the proposed project, as well as ongoing maintenance, may involve the intermittent transport, use and disposal of potentially hazardous materials, including fuels and lubricants, paints, solvents, and other common materials. To maintain the health and safety of the public and environment during construction, any on-site hazardous materials that may be used, stored, or transported would be required to follow protocols determined by the U.S. EPA, California Department of Health and Safety, and City of Watsonville.
The Watsonville General Plan Public Safety Element (Chapter 12) has goals that guide development in compliance with hazardous material management:
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset and
accident conditions involving the release of hazardous
materials into the environment?
c) Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within onequarter mile of an existing or proposed school?
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code §65962.5 and, as a result, would it
create a significant hazard to the public or the
environment?
e) For a project located within an airport land use plan, or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area?
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
g) Expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires?
Attachment 2.9
68 | City of Watsonville
• Goal 12.1 Land Use Safety: Plan for and regulate the uses of land in order to provide a pattern of urban development which will minimize exposure to hazards from either natural or human related causes.
• Goal 12.5 Hazardous Materials: Reduce the potential danger related to the use, storage, transport, and disposal of hazardous materials to an acceptable level of risk for city residents. • Goal 12.7 Emergency Preparedness: Anticipate the potential for disasters, maintain continuity or life support functions during an emergency, and maximize efforts for post-emergency recovery.
Project construction may also involve short-term transport, storage, and use of hazardous materials.
Any hazardous substances generated, stored, transported, used, or disposed during construction would be subject to applicable federal, State, and local regulations. Given the existing General Plan goals, Federal, State, and local regulation and oversight of hazardous materials, the threat to public health and safety and the environment would be less than significant. b. Less than Significant Impact. A Phase I Environmental Site Assessment (ESA) was performed for the project site by AECOM (report dated August 27, 2020, Appendix E of this Initial Study).
Construction of the proposed project would require the use and possible release of hazardous materials, such as paints and other solvents. However, the project would be required to comply with standard construction safety practices to prevent, contain, or clean-up spills and contamination from fuels, solvents, concrete wastes, and other potentially hazardous materials, such as asbestoscontaining materials and lead-based paint. Because the use and transport of hazardous materials would be required to follow federal, State, and local regulations, the risk of releasing hazardous materials from accidents would be less than significant with mitigation incorporated. c. Less than Significant Impact. The closest schools are more than one-quarter mile from the project site. The schools are Duncan Hobert School (0.42 miles southeast of the project site) and Rolling Hills Middle (0.47 miles to the southeast of the project site). The construction and operation of the project would not generate hazardous emissions, nor result in the storage, handling, production, or disposal of acutely hazardous materials. Therefore, the impacts to schools from the project’s production or emission of hazardous materials or substances would be less than significant. d. Less than Significant Impact. The project is not located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code 65962.5 (Cortese List). The Phase I ESA performed a regulatory database search and the project site is not listed on any environmental databases. No visual evidence of underground storage tanks (USTs) (e.g., vent pipes, fill ports) was observed onsite during the site visit, and no USTs were reported by the site contact to have been historically or currently located at the subject property. Additionally, the subject property was not listed in connection with a UST database in the site-specific environmental database report or based on AECOM’s review of the online GeoTracker database maintained by the California State Water Resources Control Board (SWRCB).
According to the environmental database report, approximately 30 sites were identified within identified radii from the project site. Based on AECOM’s review of these database listings, none of the below sites are expected to present a significant impact to the subject property, based on their distance from the project site, regulatory status, type of media impacted, and/or topographical position from the project site.
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Crocker’s Lockers Self-Storage Project IS/MND | 69
• Watsonville Community Hospital at 75 Nielson Street is located adjacent to the south of the site.
The site has a “No Action Required” ENVIROSTOR status with “no contaminants found” during an investigation conducted in 1995 due to the previous site use as a disk drive manufacturing facility and prior to the current hospital facility.
• Maggiora Bros Drilling, Inc. at 595 Airport Boulevard is located adjacent to the north of the site.
The site is listed on ENVIROSTOR as a “Historical” status and was referred as a Leaking Underground Storage Tank (LUST) case for the unauthorized release of petroleum hydrocarbons to groundwater from an unleaded gasoline UST and a diesel UST, which were both removed in 2000. According to the case closure summary dated July 24, 2015, obtained from the GeoTracker database, the remaining groundwater plume does not extend offsite. The clean-up at this adjacent property has been completed, and the LUST case was granted a “completed – case closed” status in 2015.
• Pacific Coast Circuits at 26 Hangar Way is located adjacent to the east-northeast of the project site. Pacific Coast Circuits has a ”Historical” ENVIRSTOR status. This address was also identified as Eden Infusions LLC in the RCRA-NonGen/NLR database. No current violations were found pertaining to their generator status. Based on this information and the compliancerelated nature of these listings, AECOM concluded that these facilities do not present a risk to the project site.
• Souza S Cabinets, Inc., at 34 Hangar Way is located adjacent to the east of the site and is listed in the RCRA NonGen/ NLR databases. No current violations were found. • Toxscan Inc. at 42 Hangar Way (also listed as Soil Control Lab) is located adjacent to the east of the site. No current violations were found.
• E&C Shikuma/Shikuma Farm at 581 Airport Boulevard is located approximately 500 feet north of the site. According to information provided in the AECOM Phase 1 ESA, the site is listed on the Cortese List, but has a “completed – case closed” status since 2004, following post-remedial action monitoring.
While there are open and closed status Cortese List sites in the general project vicinity, the project site is not located on a hazardous materials site pursuant to Government Code 65962.5 (Cortese List). Therefore, this impact would be less than significant. e. Less than Significant Impact. The project is within two miles of the Watsonville Municipal Airport, which is a public airport located on the same street as the project site. Santa Cruz County has been identified as a “no procedures county” as there is only one public use airport—the Watsonville Municipal Airport, where the most stringent criteria in the California Airport Land Use Planning Handbook apply (see below). In accordance with Public Utilities Code (PUC) Section 21670.1(e), the preparation of an airport land use compatibility plan is not required; however, the City must submit future general and specific plans for review by the Caltrans Division of Aeronautics.
The California Airport Land Use Planning Handbook (CalTrans, 2011) provides guidance for airport land use compatibility planning, as required by PUC Section 21670-21679.5. The Handbook is intended to ensure compatible airport land uses by ensuring the safe and efficient operation of airports and the safety of people living or working near airports. The Handbook defines six Airport Safety Zones, ranging from Zone 1 (Runway Protection Zone) to Zone 6 (Traffic Pattern Zone), and outlines land use restrictions for each zone. As shown in Figure 12 below, the project site lies within Watsonville Municipal Airport Safety Zones 2, 5, and 6.
Attachment 2.9
70 | City of Watsonville
Figure 12: Airport Safety Zones
Appendix G of the California Airport Land Use Planning Handbook also provides guidance to lead agencies in methods to estimate the number of people who would potentially be on a site. Appendix G indicates the calculation method is dependent upon the type of use and likely occupancy of a project. The amount of parking required may be one method where vehicle travel would be expected to be required for a project, combined with an estimate of the average number of occupants per vehicle. Maximum occupancy as calculated, and allowed, by the California Building Code is another method, using building square footage.
Each safety zone includes average-acre and single-acre intensity limitations which are not to be exceeded. Local parking standards can serve as a guide to calculate average-acre intensities for nonresidential uses, and can be estimated by multiplying local parking requirements by the estimated number of persons per vehicle. According to a 2017 survey conducted by the Federal Highway Administration titled, “National Household Travel Survey,” the average light-occupancy vehicle carries 1.67 passengers. The project would include a total of 22 onsite parking spaces, consisting of 21 spaces located throughout the site and along the drive aisles plus one space in the manager’s apartment garage. Watsonville’s average household size (3.63, according to the US Census) may be used to calculate the average acre density for the residential use (manager’s unit).
Usage on any one single acre can be calculated based on the California Building Code, by dividing the total building square footage by the typical square footage occupied by each person (i.e., Occupancy Load Factor). For sites having both site size and building square footage of more than
1.0 acre, the single-acre intensity is calculated as the total number of building occupants divided by the building square feet in acres. For sites less than 1.0 acre, the single-acre intensity equals the total number of people on the site divided by the site size in acres. For a storage facility, the Occupancy Load Factor ratio is 1 person for every 300 square feet of gross floor area, which is the maximum number of occupants which could be accommodated under Building and Fire codes, rather than the average busy period. The Handbook states that most non-residential buildings are not fully occupied 2 5 6
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Crocker’s Lockers Self-Storage Project IS/MND | 71
at all times. Therefore, the Handbook allows for reducing the total occupancy using these codes by a set factor, 50 percent for most uses.
Based on parking standards for the non-residential storage use and the household size for the residential use, the project would average ten (10) persons per acre.1 This average density would be consistent with Handbook standards for average-acre intensities which allow 40, 70, and 200 people per average-acre in Zones 2, 5, and 6, respectively. Based on the building square footages in each safety zone, the adjusted Occupancy Load Factor, and the site acreage in each safety zone, the project is estimated to accommodate 73 people in a single acre within Zone 2, 72 people in Zones 5, and 73 people in Zone 6. The proposed single-acre intensities comply with Handbook limitations for Zones 2, 5, and 6 which limit single-acre usage to 80, 210, and 800 people, respectively. The project’s compliance with the Handbook’s intensity limitations is summarized in Table 9 below.
Table 9: Summary of Relevant Airport Land Use Handbook Intensity Limitations Airport
Safety
Zone
Average Intensity (People/Acre) Single Acre Intensity (People/Acre) Occupancy Handbook
Limitation
Meets
Requirements? Occupancy Handbook
Limitation
Meets
Requirements?
2 10 40 Yes 73 80 Yes
5 10 70 Yes 72 210 Yes
6 10 200 Yes 73 800 Yes
The criteria for determining the acceptability of a project with respect to height is based upon the standards set forth in Federal Aviation Regulations (FAR) Part 77, Subpart C, Standards for Determining Obstructions to Air Navigation and applicable airport design standards published by the Federal Aviation Administration (FAA). Since the project is located within the Airport Influence Area, it is subject to Title 14 of the Code of Federal Regulations, part 77, concerning the safe and efficient use of airspace. The FAA conducted an aeronautical study on the site and issued a letter on February 25, 2022 which determined “no hazards would result to air navigation” and that the project’s structures will not exceed obstruction standards. The applicant would be required to file a Notice of Actual Construction or Alteration within 5 days of construction reaching its greatest height.
Additionally, Caltrans Division of Aeronautics Staff identified two trees as penetrating one of the Airport’s Part 77 surfaces. Conditions of approval would require the project to trim or remove these trees (T15 and T17 on the existing tree plan, Sheet T1). The project, therefore, would not pose a risk to air navigation. The impact would be less than significant.
Based on an Aircraft Noise Monitoring Report prepared by WJV acoustics in 2018, the project-site is located outside of the airport’s 65 CNEL noise contour zone under both existing (2016) and future (2036) conditions. The western portion of the site, within approximately 125 feet of the Airport Boulevard right-of-way, may be exposed to airport noise levels up to 60 CNEL under existing and future conditions; the rest of the site is outside of the Aircraft Noise Monitoring Report’s contour lines and would be exposed to noise levels less than 60 CNEL (WJV Acoustics, 2018). Ambient noise monitoring indicates individual aircraft approaches, departures, and fly overs at the site may generate noise levels up 85 dBA Lmax. Such single event noise levels are short in duration and do not approach noise levels that would be considered excessive on a short-term basis. Refer to Section
6.13 for additional information on why the project would not expose the onsite manager or people 1 Calculation: 41 people ÷ 4.4-acre site = 9.3 persons per acre (rounded up to 10) Attachment 2.9
72 | City of Watsonville
visiting the self-storage facility to excessive public or private airport-related noise levels. This impact is less than significant.
f. Less than Significant Impact. On January 19, 2021, the City adopted the Local Hazard Mitigation Plan (LHMP) and incorporated the LHMP by reference into the General Plan (Resolution 42-21, in accordance with the federal Disaster Mitigation Act of 2000. FEMA formally approved the LHMP on January 28, 2021. The LHMP identifies and assesses: 1) natural hazards, including those that are created or exacerbated by climate change; 2) people and facilities that are at risk to hazard impacts; and 3) mitigation actions that reduce or eliminate hazard impacts. Many LHMP policies and programs require City actions that apply to new development include reducing risks associated with earthquakes, flooding, and stormwater management.
The project is not located within a major Faultline or Flood Zone. The driveways along Nielsen Street and the internal access roads would be designed to current City standards and are therefore expected to accommodate access requirements for both emergency and passenger vehicles. The project would not create physical, social, or environmental vulnerabilities for the City and people of Watsonville. The impact would be less than significant. g. Less than Significant Impact. The project site is in a developed area and located in a local responsibility area according to the CalFire FRAP Map. The City’s General Plan maps a high fire hazard zone in Watsonville west of the project site in a wildland-dominated area. The project is not within the high fire hazard severity zone, and impacts to people or structures involving wildland fires would be less than significant (also see Section 6.20 Wildfire of this Initial Study for further discussion).
References:
AECOM. Phase I Environmental Site Assessment. August 2020. (Accessed January 26, 2022) (Appendix E)
CalFire, 2022 Fire Hazard Severity Zones Viewer. https://egis.fire.ca.gov/FHSZ/ (Accessed January 27, 2022)
CalTrans, 2011. California Airport Land Use Planning Handbook. https://dot.ca.gov/-/media/dotmedia/programs/aeronautics/documents/californiaairportlanduseplanninghandbook-a11y.pdf (accessed January 24, 2022)
City of Watsonville, 2003. Watsonville Municipal Airport Master Plan 2001-2020. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/987/CM-Resolution-179-03-AirportMaster-Plan-PDF (accessed January 26, 2022). https://www.cityofwatsonville.org/DocumentCenter/View/14031/Kimley-Horn--AIRPORTMASTER-PLAN-UPDATE-Overview City of Watsonville, 2020. Local Hazard Mitigation Plan. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/15463/City-of-Watsonville-Local-HazardMitigation-Plan (accessed February 14, 2022) City of Watsonville, 2022. Emergency Evacuation Route Analysis. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/15452/Appendix-D-EmergencyEvacuation-Route-Analysis (accessed February 14, 2022) Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 73
County of Santa Cruz, 2015. Local Hazard Mitigation Plan. Available at: http://www.co.santacruz.ca.us/Portals/0/Local%20Hazard%20Mitigation%20Plan%202015-2020.pdf (accessed January 26, 2022)
U.S. Department of Transportation, 2017. National Travel Survey. Available at: FOTW #1040, July 30, 2018: Average Vehicle Occupancy Remains Unchanged From 2009 to 2017 | Department of Energy (accessed June 1, 2022)
Attachment 2.9
74 | City of Watsonville
6.10 Hydrology and Water Quality
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality?
b) Substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that the
project may impede sustainable groundwater
management of the basin?
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious
surfaces in a manner which would:
i. Result in a substantial erosion or siltation on- or offsite;
ii. Substantially increase the rate or amount of surface runoff in a manner which would result in flooding onor offsite:
iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater
drainage systems or provide substantial additional
sources of polluted runoff; or
d) In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
Conclusion: Regarding hydrology and water quality, the proposed project would not result in any significant environmental impacts.
Documentation:
This hydrology analysis references the Stormwater Control Plan developed by RAK Civil Engineers (Appendix C).
a. Less than Significant Impact. The proposed project is located on a relatively flat 4.39-acre site that is developed as a paved parking lot with ornamental landscaping and pole-mounted lighting.
Underground utilities connect to storm drain, water, and sewer mains under Airport Boulevard and Nielson Street. Project construction would involve grading, and the preliminary grading plan is shown on Figure 10. The proposed cut is approximately 22,383 cubic yards (CY), with a fill of 331 CY. The excess 22,052 CY of cut would be hauled offsite. After grading activities are complete, there would be the potential for wind and water erosion to discharge construction contaminants, Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 75
sediment, and other urban pollutants into stormwater runoff. In general, stormwater runoff may degrade surface or groundwater quality and may transport pollutants into streams or creeks. Other pollutants suspended in runoff, if not controlled, could be carried from the project site or accumulate downstream and potentially degrade existing surface water quality. However, violations of water quality standards due to urban runoff can be prevented through implementation of existing regional water quality regulations and plans, including compliance with the City of Watsonville Stormwater Post-Construction Standards (Resolution No. 4-14, Adopted January 14, 2014, WMC Section 6-
3.535), and the City’s Sewer Services (WMC Section 6-3.501 et seq.). As currently designed, project runoff from impervious surfaces would be directed to two new onsite bioretention areas, in accordance with the City of Watsonville Stormwater Post-Construction Standards.
A Stormwater Control Plan has been prepared for the applicant by RAK Civil Engineers, dated September 29, 2021 (included as Appendix D). The plan proposes onsite storm drainage improvements, and low impact development (LID) design strategies. Project-specific components would include the construction of bioretention areas with appropriately sized filters, plant selection to minimize the use of fertilizers and pesticides, and project design so that stormwater drains from impervious surfaces to integrated management practices (IMPs). The preliminary Storm Water Control Plan prescribes two Demand Management Areas (DMAs):
• DMA BR-1 is 5,465 square feet and located near the southwestern portion of the site near the intersection of Airport Boulevard and Nielson Street. The bioretention area would treat runoff from Buildings A through E, paved areas associated with these buildings, and a portion of pervious landscaped areas. Runoff would flow into onsite drains then be conveyed to BR1 through storm drain lines. Treated stormwater then would exit BR-1 through a drain that would connect to an existing 15-inch storm drain line underneath Nielson Street. • DMA BR-2 is 1,215 square feet and located near the southeastern portion of the site, south of Building B and adjacent to Nielson Street. The bioretention area would treat runoff from Building F, paved areas associated with Building F, and a portion of pervious landscaped areas. Runoff would flow into onsite drains, then be conveyed to BR-2 through storm drain lines. Treated stormwater then would exit BR-2 through a drain that would connect to an existing 27-inch storm drain line underneath Nielson Street.
The State Water Resources Control Board (SWRCB) is responsible for regulating stormwater discharge associated with project construction activities - such as clearing, grading, and excavation - should they result in land disturbance of one or more acres. The City has a Small Municipal Separate Storm Sewer Systems (MS4) National Pollutant Discharge Elimination System (NPDES) permit (WQ Order No. 2013-0001-DWQ, General Permit CAS000004) and is required to implement all pertinent regulations of the program to control pollution discharges from new development. These regulations reduce non-point source pollutants through the implementation of Best Management Practices (BMPs) and other control measures that minimize or eliminate pollutants from urban runoff, thereby protecting downstream water sources. BMPs implemented to address commercial pollutant sources generally involve maintenance of storm drain facilities, parking lots, and vegetated areas, and dissemination of educational materials. Construction of the proposed project would be subject to the City’s NPDES permit requirements during construction activities, in addition to standard NPDES operational requirements.
As standard protocol, prior to issuance of the grading permit, the applicant is required to prepare a Storm Water Pollution Prevention Plan (SWPPP). The applicant shall also file a Notice of Intent (NOI) and associated fee to the State Water Resources Control Board (SWRCB). The project SWPPP Attachment 2.9
76 | City of Watsonville
shall be utilized as a framework to prescribe and implement BMPs. Construction and project operations shall implement BMPs to reduce pollutants within stormwater discharges to the maximum extent possible. The applicant shall submit the project SWPPP for review and approval by the City Engineer. The approved SWPPP shall be maintained throughout the construction period. The City shall verify that all post-construction BMPs are installed and functioning properly prior to issuing a certificate of occupancy. As a uniformly applied standard regulation, the project applicant would be required to prepare a final SWPPP that would control and minimize pollutants from construction and operation of the project. These standard requirements would ensure that project impacts to surface and groundwater quality would be less than significant. b. Less than Significant Impact. The project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge. The project site is currently connected to existing stormwater infrastructure, and the project is not anticipated to contribute substantially to groundwater recharge. The project would decrease impervious surfaces onsite by approximately 9,646 square feet. Because the project would not involve the extraction of groundwater and would not substantially interfere with groundwater recharge such that there would be a net deficit in aquifer volume or lowering of the local groundwater table, the impact would be less than significant. BMPs would be implemented and are discussed in Section 6.10(ci-ciii) below. The estimated amount of water that would be used by the project is described in Section 6.19, Utilities and Service Systems. ci. Less than Significant Impact. The project would create approximately 148,801 square feet (3.41 acres) of impervious surfaces. Compared with existing conditions, the project would result in a net reduction of approximately 9,646 square feet (0.22 acres) of impervious surface area. The site is currently developed as a parking lot with pole-mounted lighting and landscaping. Runoff from all proposed impervious surfaces would be directed to the bioretention facilities where water quality treatment would begin.
The project design includes several features that would minimize erosion or siltation onsite and offsite, such as vegetated drainage features to filter runoff and landscaped areas to limit the project's impervious area. The project Stormwater Control Plan (included as Appendix D) also outlines several BMPs for construction and post-construction.
During construction, the following standard BMPs shall be implemented:
• Planting within bioretention areas shall be selected to flourish in climates experienced at the site and be suitable for well-drained soils located in the bioretention areas, as well as withstand occasional inundation during large storm events. Avoid smearing of the soils on the bottom and side slope of the bioretention areas during excavation. Minimize compaction of native soils and rip soils if clayey and/ or compacted. • Protect the adjacent area from construction site runoff.
The project must also comply with post-construction requirements, including:
• Performance Standard #3: Runoff Retention Performance Requirements using Low Impact Development (LID) Standards apply because the project proposes impervious surfaces exceeding 15,000 square feet.
• Performance Standard #4: Peak Management applies because the project proposes impervious surfaces exceeding 22,500 square feet. The project buildout would result in less impervious surface, which means that the performance standard would be met.
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Crocker’s Lockers Self-Storage Project IS/MND | 77
As uniformly applied development regulations, the BMPs outlined above involve maintenance of storm drain facilities, parking lots, and vegetated areas, and adherence to development standards.
Additionally, an Erosion Prevention and Sediment Control Plan shall be prepared by the project civil engineer to identify locations and details of the required construction and post-construction BMPs.
The impact would be less than significant.
cii. Less than Significant Impact. The project design incorporates several strategies to reduce runoff, including minimizing impervious surfaces and installation of vegetated bioretention areas. The total area of impervious surfaces would be less after project completion than existing conditions. The project is also required to conform with the California Building Code (CBC). All runoff from new impervious surfaces would be directed to the bioretention facilities, and the project would comply with the following CBC design measures:
• Direct roof runoff onto vegetated areas safely away from building foundations and footings, consistent with the CBC.
• Direct runoff form sidewalks, walkways, and/or patios onto vegetated areas safely away from building foundations and footings.
• Direct runoff from driveways and/or uncovered parking lots onto vegetated areas safely away from building foundations and footings.
BMPs would be implemented to prevent surface runoff and flooding onsite and offsite. The City will require the project’s use of BMPs, as listed in the post-construction requirements. BMPs preventing flooding and runoff include protection of storm drains through vegetated filter traps and/or catch basins. Compliance with the uniformly applied standard regulations and BMPs would result in a less than significant impact.
ciii. Less than Significant Impact. The proposed project would not create or contribute runoff water that would exceed the capacity of existing or planned stormwater drainage systems. In order to satisfy water quality requirements, runoff from events up to the 95th percentile 24-hour rainfall event (1.3 inches) shall be retained onsite. Per the Stormwater Control Plan, the project’s required stormwater capacity is divided into two DMAs. DMA BR-1 requires 13,070 cubic feet (cf) of storage volume, with 14,755 cf of storage volume provided. DMA BR-2 requires 2,039 cf, and would provide 2,066 cf capacity, which is in excess of the required amount, as shown in the Stormwater Control Plan:
Section IV.D. Sizing Calculations of BMPs.
Discharge generated from project development would be less than the existing discharge for the site [see answers c.i and c.ii). The proposed bioretention areas have adequate capacity for the proposed development. Drainage patterns would not be altered, and the impact would be less than significant. d. No impact. The project is not located in a tsunami zone, nor seiche zone. The project is not located within a 100‐ or 500-year floodplain, as mapped by the Federal Emergency Management Agency (FEMA). The parcel is rated by FEMA as Zone X, defined as an “area of minimal flood hazard.” e. Less than Significant Impact. As a result of planned onsite treatment features, impacts related to violation of water quality standards would be less than significant. A Stormwater Control Plan was prepared by RAK engineers Engineering, in accordance with Watsonville Municipal Code Section 6-3.535 post-construction requirements. The stormwater control measures proposed for this development are the bioretention facilities for stormwater quality and runoff retention. The bioretention facilities would comply with the City of Watsonville's Standard Bioretention Facility LID-001. The bioretention facility specification is also used by the Central Coast Regional Water Attachment 2.9
78 | City of Watsonville
Quality Control Board (RWQCB). In addition, temporary BMPs and erosion control measures would be implemented during construction to reduce construction and post‐construction siltation.
The Pajaro Valley Water Management Agency is responsible for sustainable groundwater management in the region. The City of Watsonville obtains potable water from the Pajaro Valley Groundwater Subbasin. Per the 2020 Urban Water Management Plan, the City of Watsonville use accounts for about 14 percent of the total annual pumping from the Subbasin, which is designated as “critically overdrafted.”
The Department of Water Resources (DWR) provided 10 recommended actions for Pajaro Valley Water (PV Water) to address in the 5-Year Update of the PV Groundwater Sustainability Plan Alternative (DWR, 2019). These 10 actions recommended to improve groundwater quality are as follows:
1. Non-Jurisdictional Area Assessment: PV Water must define how it will assess the nonjurisdictional portion of the Subbasin and demonstrate that activities in that area are not impacting successful implementation of the Plan.
2. Depletions of Interconnected Surface Waters: PV Water must quantify depletions of interconnected surface waters as of January 1, 2015, which will be used as the threshold.
3. Groundwater Dependent Ecosystems: PV Water must provide an identification of groundwater dependent ecosystems in the Subbasin.
4. Projected Water Budgets: PV Water must update the Basin Management Plan to include a projected water budget that includes the response to Plan implementation.
5. Sustainable Management Criteria for Groundwater Levels and Interconnected Surface Water:
PV Water shall define quantitative criteria for groundwater levels and depletions of surface water that can be used to determine Plan compliance with the objectives of SGMA. Specific recommended actions related to individual undesirable results are provided below:
a. Groundwater Levels: Provide groundwater-level criteria that represent the planned improvements in groundwater.
b. Depletions of Interconnected Surface Water: As noted in Action 2, PV Water must define the depletions of interconnected surface water occurring as of January 1, 2015, to use as its operational criteria.
6. Sustainable Management Criteria for Seawater Intrusion: PV Water must define a specific location to assess management actions’ progress toward eliminating seawater intrusion.
7. Sustainable Management Criteria for Seawater Intrusion (Section 2): “Staff recommend that the Alternative should be updated to set objective criteria consistent with achieving the stated goal that a 100% reduction in annual seawater intrusion rate is the operation goal for the Basin or to provide quantify the extent to which additional seawater intrusion would not be significant and unreasonable.”
8. Monitoring Plan: PV Water must finalize the Draft Monitoring Network Review Memo, which assesses the monitoring network in the Pajaro Valley Subbasin; and incorporate those findings into a monitoring plan.
9. Land Subsidence: PV Water must determine a means by which the Subbasin may be assessed to confirm that no significant land subsidence has occurred.
10. Drought Resiliency Actions: PV Water must update its Plan to describe drought management, ensuring resiliency of the Plan to Achieve the sustainability goal.
The project’s main water use will be from irrigating landscaped areas. The State’s 2015 Model Water Efficient Landscape Ordinance (MWELO) applies to projects requiring a planning-level Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 79
permit that contain over 500 square feet of new or rehabilitated landscape areas. MWELO requires the use of highly efficient irrigation methods and is predicted to reduce landscape water use in new projects by 30 percent or more. The proposed project would not conflict with sustainable groundwater management in the area because the project’s uses are consistent with those anticipated in the City’s Urban Water Management Plan, and the project would be subject to any water reduction requirements imposed by the City. The impact would be less than significant.
References:
City of Watsonville, 2021. 2020 Urban Water Management Plan. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/16377/2020-Watsonville-Urban-WaterManagement-Plan (accessed February 8, 2022) City of Watsonville, 2014. Watsonville Municipal Code, Post-Construction Requirements. Available at: https://www.codepublishing.com/CA/Watsonville/#!/Watsonville06/Watsonville0603.html#6-3.535 (accessed February 8, 2022)
Federal Emergency Management Administration (FEMA). 100 and 500 Year Flood Zones for the City of Watsonville. Available at: https://www.cityofwatsonville.org/DocumentCenter/View/1088/FederalEmergency-Management-Administration-FEMA-100--500-Year-Flood-Zones-A?bidId= (accessed February 7, 2022)
State of California Department of Conservation, 2009. Tsunami Inundation Map for Emergency Planning. Available at:
https://www.conservation.ca.gov/cgs/Documents/Tsunami/Maps/Tsunami_Inundation_WatsonvilleWe st_Quad_SantaCruz.pdf (accessed February 14, 2022)
RAK Civil Engineers, 2021 Stormwater Control Plan Report for Crocker’s Lockers Self-Storage.
June 14, 2021, revised September 29, 2021. (Appendix D) Pajaro Valley Water Management Agency, 2021. Pajaro Valley Basin Groundwater Sustainability Update 2022 (GSU22). Available at: https://www.pvwater.org/images/aboutpvwma/assets/SGM/GSU22_20211229_MainBody-web.pdf (Accessed February 8, 2022) Pajaro Valley Water Management Agency, 2020. Geology. Available at:
https://www.pvwater.org/geology (accessed February 2, 2022) Attachment 2.9
80 | City of Watsonville
6.11 Land Use and Planning
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Physical divide an established community?
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating an
environmental effect?
Conclusion: Regarding land use and planning, the proposed project would not result in any significant environmental impacts.
Documentation:
a. No Impact. The project would not physically divide an established community. The self-storage facility would consist of six total self-storage buildings, four of which would be single-story, and two would be two-story. A seventh building is proposed as a two-story manager's building with an office on the ground floor and the manager’s apartment above. The project does not include the construction of a physical structure or removal of a primary access route that would limit mobility within an established community or between a community and outlying areas. There would be no impact.
b. Less than Significant Impact. The proposed project is within an industrial land use designation and would not require amendments to the any land use plans, policies, or regulations. The project would not cause a significant environmental impact due to conflict with any applicable land use plan adopted for the purpose of avoiding or mitigating an environmental effect, including the City’s 2005 General Plan and Zoning Ordinance. The project is not consistent with the General Plan’s Land Use and Community Development Policy 4.D, which calls for the protection of industrial lands to meet the long-term job creation goals of the City and maximize the City’s economic opportunities.
However, the project is generally consistent with the site’s General Plan land use designation of Industrial, which includes a wide range of allowed uses, including but not limited to: storage, warehousing, wholesale sales, heavy commercial; construction, fabrication and trade shops; and general manufacturing. (The project is not located within an adopted specific plan area.) The project is also consistent with the purpose of the Industrial Park (IP) Zoning District. The purpose of the IP District is to provide a separate and exclusive district for light industry, business, service, and research work, including storage. WMC § 14-16.500. A self-storage facility (DLU 114) is allowed conditionally with issuance of a Special Use Permit. WMC §§ 14-16.503(b), 14-36.040.
While the type of industrial use—a self-storage facility—has a single employee and therefore would not contribute a large number of jobs, as discussed further in Section 6.9.e, because the project is located in Airport Safety Zones 2, 5 and 6, the number of people that may be present onsite is limited so as to not result in a safety hazard for people residing or working in the project area. These airport safety zones, in effect, constrain the development potential of the site. As mentioned in Section 6.9.e, safety zones have average-acre and single-acre intensity limitations which are not to be exceeded. For Airport Safety Zone 2, no more than 40 people can be on the average acre of land. In Airport Zone 5 and Zone 6, intensity levels cannot exceed 70 and 200 people on average, respectively. The project will be consistent with Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 81
these intensity limitations. The project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The impact is less than significant.
References:
City of Watsonville, 2005. General Plan. Available at: https://www.cityofwatsonville.org/160/2005- General-Plan (accessed January 25, 2022).
City of Watsonville, 2021. Zoning Ordinance. Available at:
https://www.codepublishing.com/CA/Watsonville/ (accessed February 17, 2022).
City of Watsonville, 2021. Zoning Map. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/2561/Zoning-Map (accessed January 18, 2022)
Attachment 2.9
82 | City of Watsonville
6.12 Mineral Resources
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the State?
b) Result in the loss of availability of a locally important mineral resource recovery site delineated on a local
general plan, specific plan or other land use plan?
Conclusion: Regarding mineral resources, the proposed project would not result in any significant environmental impacts.
Documentation:
a. No Impact. The State Board of Mining and Geology has adopted regulations to protect lands classified as MRZ-2 (i.e., lands where information indicates that significant stone, sand, and/or gravel deposits are present, or where a high likelihood for their presence exists; and lands otherwise designated as areas of statewide or regional significance relative to mineral resources). Mapping conducted in 1986 and 1987 of the project site area by the State Division of Mines and Geology did not indicate that the City of Watsonville contained any MRZ-2 designated resource zones.
The General Plan designates a Regionally Significant Construction Aggregate Resources site along the south side of Buena Vista Drive and southwest of Harkins Slough Road, over one mile east of the proposed project. The proposed project would not result in the loss of availability of a known mineral resource of value to the region and the residents of the State and no impact would occur. b. No Impact. Refer to Section 6.12.a, above. The project would have no impact on mineral availability.
References:
City of Watsonville, 2005. General Plan, Chapter 9, Environmental Resources page 118. Available at:
https://www.cityofwatsonville.org/160/2005-General-Plan (accessed January 5, 2022).
State of California Department of Conservation, 1987. Division of Mines and Geology Mineral Land Classification: Aggregate Materials in the San Francisco-Monterey Bay Area. Page 49.
State of California Department of Conservation, 1987. Division of Mines and Geology Mineral Land Classification: Report No.7, Designation of Regionally Significant Construction Aggregate Resource Areas in the South San Francisco Bay, North San Francisco Bay, Monterey Bay ProductionConsumption Regions.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 83
6.13 Noise
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project result in:
a) Generation of substantial temporary or permanent
increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies?
b) Generation of excessive groundborne vibration or
groundborne noise levels?
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people
residing or working in the project area to excessive noise levels?
Conclusion: Regarding potential noise and vibration impacts, the proposed project would not result in any significant environmental impacts. Standard Best Management Practices (BMPs) for the control of temporary construction noise levels are identified and incorporated into the project.
Documentation:
a. Less than Significant Impact. As described below, the proposed project would not generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project site.
This impact would be less than significant.
Noise Fundamentals: “Sound” is a vibratory disturbance created by a moving or vibrating source and is capable of being detected. For example, airborne sound is the rapid fluctuation of air pressure above and below atmospheric pressure. “Noise” may be defined as unwanted sound that is typically construed as loud, unpleasant, unexpected, or undesired by a specific person or for a specific area.
Sound has three properties: frequency (or pitch), amplitude (or intensity or loudness), and duration.
Pitch is the height or depth of a tone or sound and depends on the frequency of the vibrations by which it is produced. Sound frequency is expressed in terms of cycles per second, or Hertz (Hz).
Humans generally hear sounds with frequencies between 20 and 20,000 Hz and perceive higher frequency sounds, or high pitch noise, as louder than low-frequency sound or sounds low in pitch.
Sound intensity or loudness is a function of the amplitude of the pressure wave generated by a noise source combined with the reception characteristics of the human ear. Atmospheric factors and obstructions between the noise source and receptor also affect the loudness perceived by the receptor.
The frequency, amplitude, and duration of a sound all contribute to the effect on a listener, or receptor, and whether or not the receptor perceives the sound as “noisy” or annoying. Despite the ability to measure sound, human perceptibility is subjective, and the physical response to sound complicates the analysis of its impact on people. People judge the relative magnitude of sound sensation in subjective terms, such as “noisiness” or “loudness.” Attachment 2.9
84 | City of Watsonville
Sound pressure levels are typically expressed on a logarithmic scale in terms of decibels (dB). A dB is a unit of measurement that indicates the relative amplitude (i.e., intensity or loudness) of a sound, with 0 dB corresponding roughly to the threshold of hearing for the healthy, unimpaired human ear.
Since decibels are logarithmic units, an increase of 10 dBs represents a ten-fold increase in acoustic energy, while 20 dBs is 100 times more intense, 30 dBs is 1,000 times more intense, etc. In general, there is a relationship between the subjective noisiness or loudness of a sound and its intensity, with each 10 dB increase in sound level perceived as approximately a doubling of loudness. Due to the logarithmic basis, decibels cannot be directly added or subtracted together using common arithmetic operations:
50 𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑 + 50 𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑 ≠ 100 𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑 Instead, the combined sound level from two or more sources must be combined logarithmically. For example, if one noise source produces a sound power level of 50 dBA, two of the same sources would combine to produce 53 dB as shown below.
10 ∗ 10 𝑙𝑙𝑙𝑙 �10�
50 10� + 10�
50 10�
� = 53 𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑𝑑
In general, when one source is 10 dB higher than another source, the quieter source does not add to the sound levels produced by the louder source because the louder source contains ten times more sound energy than the quieter source.
Although humans generally can hear sounds with frequencies between 20 and 20,000 Hz most of the sound humans are normally exposed to do not consist of a single frequency, but rather a broad range of frequencies perceived differently by the human ear. In general, humans are most sensitive to the frequency range of 1,000–8,000 Hz and perceive sounds within that range better than sounds of the same amplitude in higher or lower frequencies. Instruments used to measure sound, therefore, include an electrical filter that enables the instrument’s detectors to replicate human hearing. This filter known as the “A-weighting” or “A-weighted sound level” filters low and very high frequencies, giving greater weight to the frequencies of sound to which the human ear is typically most sensitive.
Most environmental measurements are reported in dBA, meaning decibels on the A-scale.
Sound levels are usually not steady and vary over time. Therefore, a method for describing either the average character of the sound or the statistical behavior of the variations over a period of time is necessary. The continuous equivalent noise level (Leq) descriptor is used to represent the average character of the sound over a period of time. The Leq represents the level of steady-state noise that would have the same acoustical energy as the sum of the time-varying noise measured over a given time period. Leq is useful for evaluating shorter time periods over the course of a day. The most common Leq averaging period is hourly, but Leq can describe any series of noise events over a given time period.
When considering environmental noise, it is important to account for the different responses people have to daytime and nighttime noise. In general, during the nighttime, background noise levels are generally quieter than during the daytime but also more noticeable due to the fact that household noise has decreased as people begin to retire and sleep. Accordingly, a variety of methods for measuring and normalizing community environmental noise have been developed. The California Office of Planning and Research’s General Plan Noise Element Guidelines identifies the following common metrics for measuring noise (OPR, 2017):
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 85
• Ldn (Day-Night Average Level): The average equivalent A-weighted sound level during a 24- hour day, divided into a 15-hour daytime period (7 AM to 10 PM) and a 9-hour nighttime period (10 PM to 7 AM). A 10 dB “penalty” is added to measure nighttime noise levels when calculating the 24-hour average noise level. For example, a 45-dBA nighttime sound level (e.g., at 2 AM) would contribute as much to the overall day-night average as a 55-dBA daytime sound level (e.g., at 7 AM).
• CNEL (Community Noise Equivalent Level): The CNEL descriptor is similar to Ldn, except that it includes an additional 5 dBA penalty for noise events that occur during the evening time period (7 PM to 10 PM). For example, a 45-dBA evening sound level (e.g., at 8 PM) would contribute as much to the overall day-night average as a 50-dBA daytime sound level (e.g., at 8 AM).
The artificial penalties imposed during Ldn and CNEL calculations are intended to account for a receptor’s increased sensitivity to noise levels during quieter nighttime periods. As such, the Ldn and CNEL metrics are usually applied when describing longer-term ambient noise levels because they account for all noise sources over an extended period of time and account for the heightened sensitivity of people to noise during the night. In contrast, the Leq metric is usually applied to shorter reference periods where sensitivity is presumed to remain generally the same.
The energy contained in a sound pressure wave dissipates and is absorbed by the surrounding environment as the sound wave spreads out and travels away from the noise generating source. The strength of the source is often characterized by its “sound power level.” Sound power level is independent of the distance a receiver is from the source and is a property of the source alone.
Knowing the sound power level of an idealized source and its distance from a receiver, sound pressure level at the receiver point can be calculated based on geometrical spreading and attenuation (noise reduction) as a result of distance and environmental factors, such as ground cover (asphalt vs. grass or trees), atmospheric absorption, and shielding by terrain or barriers.
For an ideal “point” source of sound, such as mechanical equipment, the energy contained in a sound pressure wave dissipates and is absorbed by the surrounding environment as the sound wave spreads out in a spherical pattern and travels away from the point source. Theoretically, the sound level attenuates, or decreases, by 6 dB with each doubling of distance from the point source. In contrast, a “line” source of sound, such as roadway traffic or a rail line, spreads out in a cylindrical pattern and theoretically attenuates by 3 dB with each doubling of distance from the line source; however, the sound level at a receptor location can be modified further by additional factors. The first is the presence of a reflecting plane such as the ground. For hard ground, a reflecting plane typically increases A-weighted sound pressure levels by 3 dB. If some of the reflected sound is absorbed by the surface, this increase will be less than 3 dB. Other factors affecting the predicted sound pressure level are often lumped together into a term called “excess attenuation.” Excess attenuation is the amount of additional attenuation that occurs beyond simple spherical or cylindrical spreading. For sound propagation outdoors, there is almost always excess attenuation, producing lower levels than what would be predicted by spherical or cylindrical spreading. Some examples include attenuation by sound absorption in air; attenuation by barriers; attenuation by rain, sleet, snow, or fog; attenuation by grass, shrubbery, and trees; and attenuation from shadow zones created by wind and temperature gradients. Under certain meteorological conditions, like fog and low-level clouds, some of these excess attenuation mechanisms are reduced or eliminated due to noise reflection.
Noise Effects on Human Beings: Human response to sound is highly individualized because many factors influence a person’s response to a particular noise, including the type of noise, the variability Attachment 2.9
86 | City of Watsonville
of the sound level, the presence of tones or impulses, and the time of day of the noise occurs. In addition, non-acoustical factors, such as the person’s opinion of the noise source, the ability to adapt to the noise, the attitude towards the source and those associated with it, and the predictability of the noise, all influence a person’s response. As such, response to noise varies widely from one person to another and with any particular noise, individual responses will range from “not annoyed” to “highly annoyed” with annoyance being an expression of negative feelings resulting from interference with activities, the disruption of one’s peace of mind, or degradation of the enjoyment of one’s environment.
Noise effects on human beings are generally categorized as:
• Subjective effects of annoyance, nuisance, and/or dissatisfaction • Interference with activities such as speech, sleep, learning, or relaxing • Physiological effects such as startling and hearing loss Most environmental noise levels produce subjective or interference effects. Noise can mask important sounds and disrupt communication between individuals in a variety of settings, resulting in a slight irritation to a serious safety hazard, depending on the circumstance. Noise-induced sleep interference is a critical factor in community and personal annoyance. Sound level, frequency distribution, duration, repetition, and variability can make it difficult to fall asleep and may cause momentary shifts in the natural sleep pattern, or level of sleep resulting in short-term adverse effects such as mood changes, job/school performance, etc.
Physiological effects are usually limited to prolonged and/or repeated exposure to high noise environments at facilities such as, but not limited to, industrial and manufacturing facilities or airports.
Predicting the subjective and interference effects of noise is difficult due to the wide variation in individual thresholds of annoyance and past experiences with noise; however, an accepted method to determine a person’s subjective reaction to a new noise source is to compare it to the existing environment without the noise source, or the “ambient” noise environment. In general, the more a new noise source exceeds the ambient noise level, the more likely it is to be considered annoying and to disturb normal activities.
Under controlled conditions in an acoustical laboratory, the trained, healthy human ear is able to discern 1‐dB changes in sound levels when exposed to steady, single‐frequency (“pure‐tone”) signals in the mid‐frequency (1,000–8,000 Hz) range. In typical noisy environments, changes in noise of 1 to 2 dB are generally not perceptible; however, it is widely accepted that people are able to begin to detect sound level increases of 3 dB in typical noisy environments. Further, a 5-dB increase is generally perceived as a distinctly noticeable increase, and a 10 dB increase is generally perceived as a doubling of loudness that would almost certainly cause an adverse response from community noise receptors.
Existing Noise and Vibration Environment: The project is located in an industrial area of Watsonville, bordered on the north and east by industrial properties, and by the Watsonville Community Hospital to the south. West of the project, across Airport Boulevard, is the Watsonville Municipal Airport.
The General Plan Public Safety Element identifies that transportation-related noise is the predominant source of noise in the city. Highway 1 and State Route 129 are specifically identified Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 87
as major sources of noise in the city due to their high traffic volumes and high vehicle travel speed (City of Watsonville, 1990, pgs. 185 and 191); however, the project site is located approximately 1,600 feet from Highway 1 and over two miles from State Route 129. The northern end of the project site is located adjacent to and approximately 50 feet from the centerline of Airport Boulevard, a twoway, undivided, five-to-six lane roadway with a posted speed limit of 45 miles per hour (mph).
The General Plan Public Safety Element also identifies portions of the city affected by airport and railroad noise sources. The project site is approximately 140 feet from the centerline of the Watsonville Municipal Airport runway and does not have any rail lines in proximity. Based on an Aircraft Noise Monitoring Report prepared by WJV acoustics in 2018, the western portion of the project site was mapped in the 2016 60dB CNEL noise contour (WVJ Acoustics, 2018: Figure 3).
Ambient noise measurements were collected at the site over a one-hour period from 9:00 AM to approximately 10:00 AM on January 12, 2022 (see Appendix F). The ambient noise levels were digitally measured and stored using one Larson Davis SoundTrack LxT sound level meters that meet American National Standards Institute requirements for a Type 1 integrating sound level meter. Each sound meter was calibrated immediately before the monitoring period using a reference onekilohertz (1kH) check frequency and 114 dB sound pressure level and found to be operating within normal parameters for sensitivity. Measurements were continuously collected over the sample periods in one-minute intervals. Weather conditions during the monitoring were clear. Temperatures ranged were in the mid 50’s for the duration of the monitoring. Winds were generally light and variable and ranged from calm conditions to approximately 5-miles per hour during the monitoring period.
The ambient noise monitoring conducted included two short-term (ST) measurement locations, which were selected to:
• Provide direct observations and measurements of existing noise sources at and in the vicinity of the existing parking lot; and
• Determine typical, ambient noise levels at and in the vicinity of the proposed Crocker’s Lockers project.
The ambient noise monitoring locations are shown on Figure 13, and described below. • Location ST-1 was located on the western property line, approximately 50 feet from the centerline of Airport Boulevard. Ambient noise levels at this location were measured from approximately 9:00 AM to approximately 9:30 AM on January 12, 2022. The meter was attended by a qualified field monitor for the duration of the monitoring. The ambient noise levels measured at location ST-1 are considered representative of the day-time ambient noise levels along the project site’s western property line that borders Airport Boulevard. • Location ST-2 was located in the southern portion of the site, where the proposed manager’s unit would be located. Ambient noise levels at this location were measured from approximately 9:35 AM to 10:05 AM on January 12, 2022. The ambient noise levels measured at location ST2 are considered representative of the daytime noise levels at the proposed site of the manager’s unit north of Nielson Street. ST-2 was taken on the property line, which is topographically higher than the street frontage.
Attachment 2.9
88 | City of Watsonville
Figure 13: Ambient Sound Monitoring Locations
Note: The center of the sound meter icon reflects the location of the ambient noise measurement.
Based on observations made during the ambient noise monitoring, the existing noise environment in the project vicinity consists primarily of roadway noise associated with vehicular activity on Airport Boulevard and airport noise. Table 10: Summary of Measured Ambient Short-Term Noise Levels (dBA), summarizes the results of the ambient noise monitoring. Please refer to Appendix F for detailed ambient noise monitoring results.
Table 10: Summary of Measured Short-Term Ambient Noise Levels (dBA) Day/Site Duration Measured Noise Level (dBA)
Leq Lmin Lmax
Wednesday, January 12, 2022(A)
ST-1 30 minutes 68.3 48.8 85.3
ST-2 30 minutes 60.7 47.7 82.7
(A) Source: MIG (See Appendix F)
(B) Measurements occurred from 9:00 to 10:00 AM.
Based on observations made during the noise monitoring, traffic on Airport Boulevard and, to a lesser degree, Nielson Street, are the primary contributor to measured ambient noise levels. As shown in Table 10, the average noise level at ST-1 (68.3 dBA Leq) was higher than at ST-2 (60.7 dBA Leq).
This is because ST-1 is closer to Airport Boulevard than ST-2. The lowest measured noise level at both sites was similar (48 to 49 dBA Lmin) and representative of quiet conditions when there is no nearby traffic or local land use activities occurring. Maximum measured noise levels at both ST-1 (85.3 dBA Lmax) and ST-2 (82.7 dBA Lmax) were associated with aircraft approaches into Watsonville airport.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 89
Noise Sensitive Receptors: Noise sensitive receptors are buildings or areas where unwanted sound or increases in sound may have an adverse effect on people or land uses. Hospitals, residential areas, schools, and parks are examples of noise sensitive receptors that could be sensitive to changes in existing environmental noise levels. The noise sensitive receptors adjacent or in close proximity (within 1,000 feet) of the perimeter of the proposed project include the Watsonville Community Hospital across Nielson Boulevard south of the project site. At the closest, the receptors are approximately 200 feet from the project site.
Applicable Noise Standards: The California Building Standards Code is contained in Title 24 of the California Code of Regulations and consists of 11 different parts that set various construction and building requirements. Part 2, California Building Code, Section 1207, Sound Transmission, establishes sound transmission standards for interior walls, partitions, and floor/ceiling assemblies.
The California Green Building Standards Code is Part 11 to the California Building Standards Code.
Chapter 5, Nonresidential Mandatory Standards, Section 5.507 establishes the following requirements for non-residential development that may be applicable to the proposed project. • 5.507.4.1.1 sets forth that buildings exposed to a noise level of 65 dB Leq (1-hour) during any hour of operation shall have exterior wall and roof-ceiling assemblies exposed to the noise source meeting a composting sound transmission class (STC) rating of at least 45 (or an outdoor indoor transmission class (OITC) of 35), with exterior windows of a minimum STC of 40. • Section 5.507.4.2 sets forth that wall and roof assemblies for buildings exposed to a 65 dBA Leq pursuant to Section 5.507.4.1.1, shall be constructed to provide an interior noise environment attributable to exterior sources that does not exceed 50 dBA Leq in occupied areas during any hour of operation. This requirement shall be documented by preparing an acoustical analysis documenting interior sound levels prepared by personnel approved by the architect or engineer of record.
Watsonville General Plan Chapter 12, Public Safety, of the Watsonville General Plan includes the following goals and policies relevant to the proposed project:
• Goal 12.8 Noise Hazard Control. Evaluate new and existing land uses in the city for compatibility related to noise effects and require, as appropriate, mitigation where harmful effects can be identified, and measurable improvement will result. • Policy 12.M Noise. The City shall utilize land use regulations and enforcement to ensure that noise levels in developed areas are kept at acceptable levels, and that future noise-sensitive land uses are protected from noise that is harmful.
The Public Safety Element also identifies the City’s noise compatibility guidelines for different land uses. According to Figure 12-6 of the General Plan, the normally acceptable noise limit for industrial land use is 80 CNEL and the conditionally acceptable noise limit is 85 CNEL (Watsonville, 2005; Figure 12-6).
Attachment 2.9
90 | City of Watsonville
Figure 14: Land Use Compatibility for Community Noise Environments Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 91
Watsonville Municipal Code. To implement the City’s noise policies, in part, the City adopted Chapter 8, Noise, in Title 5, Public Welfare, Morals, and Conduct, of the Watsonville Municipal Code (WMC).
WMC Chapter 5-8 prohibits specific types of noises, such as continuous or unusually loud noise which disturbs residential property or public ways within the City. Specifically, it is unlawful for any person to generate noise which either annoys, disturbs, injures, or endangers the comfort, repose, health, peace, or safety of others on residential property or public ways within the City, including, but not limited to:
• The use of radios, music instruments, stereos, televisions, or other similar devices that disturb the peace and quiet of neighboring residential inhabitants, including the use of such devices between the hours of 7 PM and 7 AM that are plainly audible at a distance of 50 feet from the structure in which the device is located (WMC Section 5-8.02(a)). • Yelling, shouting, hooting, whistling, or singing originating from any residential property or upon any public way at any time so as to annoy or disturb the quiet comfort and repose of nearby persons (WMC Section 5-8.02(c)).
The City has not adopted an ordinance regulating construction noise levels.
Noise Impact Analysis
Temporary Construction Noise: As described in Section 6.3, Air Quality, the proposed project involves the construction of a self-storage facility on an existing parking lot over an approximately 12-month period. Construction activities would disturb approximately 4.39 acres, and would include demolition, site preparation, grading, construction, paving, and architectural coating work. Project construction activities, duration, and typical equipment usage are shown in Table 2: Construction Activity, Duration, and Typical Equipment, of this Initial Study (Section 6.3, Air Quality).
Project construction would require the use of heavy-duty construction equipment that could temporarily increase noise levels at adjacent property lines near work areas. The type of equipment used would include bulldozers, backhoes, a grader, a scraper, compactors/rollers, small cranes, and material handlers, lifts, and trucks. Table 11: Typical Construction Equipment Noise Levels (dBA) presents the estimated, worst-case noise levels that could occur from operation of typical construction equipment used to develop the project. Potential construction noise levels are estimated for worst-case equipment operations at a distance of 50 feet (reference noise level) and 200 feet (the approximate distance from the construction work area to the adjacent hospital property line).
Table 11: Typical Construction Equipment Noise Levels (dBA) Equipment
Reference Noise
Level at 50 Feet
(Lmax)
(A)
Percent
Usage
Factor(B)
Predicted Noise Levels (Leq)
at Distance(C)
50 Feet 100 Feet 200 Feet 250 Feet
Backhoe 80 0.4 76 70 64 80
Bulldozer 85 0.4 81 75 69 85
Compact Roller 80 0.2 73 67 61 80
Concrete Mixer 85 0.4 81 75 69 85
Crane 85 0.16 77 71 65 85
Delivery Truck 84 0.4 80 74 68 84
Excavator 85 0.4 81 75 69 85
Front End Loader 80 0.4 76 70 64 80
Attachment 2.9
92 | City of Watsonville
Table 11: Typical Construction Equipment Noise Levels (dBA) Equipment
Reference Noise
Level at 50 Feet
(Lmax)
(A)
Percent
Usage
Factor(B)
Predicted Noise Levels (Leq)
at Distance(C)
50 Feet 100 Feet 200 Feet 250 Feet
Generator 82 0.5 79 73 67 82
Grader 85 0.4 81 75 69 85
Man Lift 85 0.2 78 72 66 85
Paver 85 0.5 82 76 70 85
Pneumatic tools 85 0.5 82 76 70 85
Roller 85 0.2 78 72 66 85
Scraper 85 0.4 81 75 69 85
Tractor 84 0.4 80 74 68 84
Sources: Caltrans 2013, FHWA, 2010.
(A) Lmax noise levels based on manufacturer’s specifications. (B) Usage factor refers to the amount of time the equipment produces noise over the time period. (C) Estimate does not account for any atmospheric or ground attenuation factors. Calculated noise levels based on Caltrans 2013:
Leq (hourly) = Lmax at 50 feet – 20log (D/50) + 10log (UF), where: Lmax = reference Lmax from manufacturer or other source; D = distance of interest; UF = usage fraction or fraction of time period of interest equipment is in use.
The worst-case Leq noise levels associated with the operation of the typical heavy equipment that would be used at the site (e.g., bulldozer, scraper, paver) would be approximately 82 dBA at a distance of 50 feet from the equipment operating area. At an active construction site, it is not uncommon for two or more pieces of construction equipment to operate at the same time and in close proximity. If two pieces of equipment were to operate concurrently, the noise level would increase to 85 dBA Leq, and when three identical sound levels are combined, the noise level would to 87 dBA Leq. At a distance 200 feet, noise levels would reduce to 70 dBA Leq for single piece of equipment, 73 dBA Leq for two pieces of equipment, and 75 dBA Leq for three pieces of equipment. These estimates assume no shielding or other noise control measures are in place at or near the work areas.
These maximum noise levels would occur for a short period time, while site preparation and grading is completed. The majority of activities at the site (i.e., building construction) would likely involve less operation of heavy-duty off-road equipment and, as the buildings are developed, would provide shielding from on-site noise levels at nearby sensitive receptor locations.
The noise generated from project construction would be temporary and would not produce the same sound levels every day. In addition, the City does not maintain numeric thresholds for the purposes of evaluating construction noise levels. Neither the General Plan nor the Watsonville Municipal Code specify a noise level for construction activities. Project construction noise, therefore, would not exceed an applicable standard and would not result in a significant impact. Nonetheless, noise levels of 75 dBA Leq on an hourly basis could be considered intrusive and would have the potential to interfere with the quiet and comfort of patient at the adjacent Watsonville Community Hospital south of the site. The City will require the implementation of BMPs as conditions of project approval to reduce the potential for construction noise levels to annoy and intrude upon adjacent hospital areas.
Although construction noise levels would not exceed applicable City standards, MIG recommends the project implement the following BMPs to reduce noise levels at the residential receptors adjacent Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 93
to the project site:
Construction Noise Control BMPs: To reduce potential construction noise levels from project construction activities, the City shall require the applicant:
1) Restrict Work Hours: All construction-related work activities, including deliveries, shall follow more restrictive noise measures than those required in Watsonville Municipal Code. a. Construction activities shall not take place between the hours of 7PM and 7 AM on weekdays, nor prior to 8AM or after 5PM on Saturday. No work shall occur on Sundays or holidays. b. A sign shall be posted at a conspicuous location near the main entry to the site, prominently displaying these hour restrictions and identifying the phone number of the job superintendent. 2) Control Construction Traffic and Site Access. Construction traffic, including soil and debris hauling, shall follow City-designated truck routes and shall avoid routes that contain residential dwelling units to the maximum extent feasible given specific Project location and access needs. 3) Construction Equipment Selection, Use, and Noise Control Measures. The following measures shall apply to Project construction equipment:
a. Contractors shall use the smallest size equipment capable of safely completing necessary work activities.
b. Construction staging shall occur as far away from residential and other noise-sensitive land uses as possible.
c. All stationary noise-generating equipment such as pumps, compressors, and welding machines shall be shielded and located as far from noise-sensitive land uses as practical.
Shielding may consist of structures or three- or four-sided enclosures provided the structure/enclosure breaks the line of sight between the equipment and the noise-sensitive land use and provides for proper ventilation and equipment operation. d. Heavy equipment engines shall be equipped with standard noise suppression devices such as mufflers, engine covers, and engine/mechanical isolators, mounts, etc. Equipment shall be maintained in accordance with manufacturer’s recommendations during active construction activities.
e. Pneumatic tools shall include a noise suppression device on the compressed air exhaust. f. The Project shall connect to existing electrical service at the site to avoid the use of stationary power generators (if feasible and approved by the electric service provider). g. Sequence demolition activities to take advantage of existing shielding/noise reduction by existing buildings or parts of buildings and use methods that minimize noise and vibration, such as sawing concrete blocks and prohibiting on-site hydraulic breakers, crushing, or other pulverization activities.
h. No radios or other amplified sound devices shall be audible beyond the Project property line. 4) Prepare a Construction Noise Complaint Plan. The Construction Noise Complaint Plan shall:
a. Identify the name and/or title and contact information (including phone number and email) for a designated Project and City representative responsible for addressing constructionrelated noise issues. The Project representative shall be the property owner or construction job superintendent. The City representative shall be the City Engineer or designee. b. Include procedures describing how the designated Project representative will receive, respond, and resolve construction noise complaints. At a minimum, upon receipt of a noise complaint, the Project representative shall notify the City contact, identify the noise source generating the complaint, determine the cause of the complaint, and take steps to resolve the complaint.
Attachment 2.9
94 | City of Watsonville
For the reasons outlined above, the proposed project’s construction activities would not generate noise levels that exceed standards or otherwise result in a substantial, temporary increase in ambient noise levels at sensitive receptor locations.
Exterior Noise / Land Use Compatibility: The proposed project consists of a six self-storage buildings and a manager’s unit at a self-storage facility. According to the Watsonville Municipal Airport Master Plan’s land use noise compatibility guidelines, land use and related structures for residential and commercial use are compatible without restrictions below 65 CNEL and 70 CNEL, respectively (Watsonville Municipal Airport 2003, Table 36). In addition, the City's General Plan considers noise levels below 75 CNEL and 80 CNEL to be normally acceptable for commercial and industrial land uses, respectively (City of Watsonville 2005). Based on the ambient noise monitoring and Airport noise contours (see impact discussion “c” below), noise exposure levels at the site are expected to be less than 65 CNEL. The proposed project, therefore would be compatible with the existing noise environment at the project site.
Potential On-Site Operational Noise Levels: Once constructed, the proposed project would generate noise from daily activities typical of self-storage facilities, including on-site vehicle trips, opening and closing of roll-up metal door, and waste-disposal truck traffic. Specifically, the proposed project’s on-site noise sources would include:
• Automobile travel along interior access roads, automobile parking, and other miscellaneous automobile noise sources such as doors closing and engine start-up and revving. The project’s potential mobile noise sources would not operate continuously. Once parked and engines shut off, noise would cease to be generated.
• Waste collection services, which would occur between the manager’s unit and building B.
The project noise sources described above would not have the potential to generate substantial noise levels that could exceed the City’s noise compatibility guidelines for adjacent areas (80 CNEL for industrial land use). The project site plan shows buildings would be located around the perimeter of the site, and noise-generating activities would be distributed throughout the site and would not affect any one receptor, or the Watsonville Community Hospital, located across Nielson Street. The project’s potential on-site noise levels would be less than significant.
Potential Off-Site Traffic Noise Levels: The proposed project would generate traffic that would be distributed onto the local roadway system and potentially increase noise levels along travel routes.
Caltrans considers a doubling of total traffic volume to result in a three dBA increase in trafficrelated noise levels (Caltrans, 2013a). If the proposed project would not result in a doubling of traffic volumes on the local roadway system, it would not result in a substantial permanent increase in traffic-related noise levels.
The W-Trans transportation study prepared for the proposed project (Appendix G of this Initial Study) indicates that the project would result in 227 weekday trips per day, including 15 and 24 trips during the AM and PM peak hours, respectively. All these trips would be added to Airport Boulevard and Nielson Street before dispersing to their final destinations. The proposed project would result in substantially less than a doubling of peak hour and daily traffic volumes on Airport Boulevard and, therefore, would not result in a substantial, permanent increase in noise levels along the roadways used to access the project.
Attachment 2.9
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b. Less than Significant Impact. As described further below, the proposed project would not generate excessive groundborne vibration or groundborne noise levels. This impact would be less than significant.
Vibration Background Information: Vibration is the movement of particles within a medium or object such as the ground or a building. Vibration may be caused by natural phenomena (e.g., earthquakes, volcanic eruptions, sea waves, landslides) or humans (e.g., explosions, machinery, traffic, trains, construction equipment). Vibration sources are usually characterized as continuous, such as factory machinery, or transient, such as explosions.
As is the case with airborne sound, groundborne vibrations may be described by amplitude and frequency; however, unlike airborne sound, there is no standard way of measuring and reporting amplitude. Vibration amplitudes can be expressed in terms of velocity (inches per second) or discussed in dB units in order to compress the range of numbers required to describe vibration. As with airborne sound, the groundborne velocity can also be expressed in decibel notation as velocity decibels, or dBV (FTA, 2018). The vibration of floors and walls may cause perceptible vibration, rattling of items such as windows or dishes on shelves, or a low-frequency rumble noise, referred to as groundborne noise. This report uses peak particle velocity (PPV) to describe vibration effects.
Vibration impacts to buildings are usually discussed in terms of PPV in inches per second (in/sec).
PPV represents the maximum instantaneous positive or negative peak of a vibration signal and is most appropriate for evaluating the potential for building damage. Vibration can impact people, structures, and sensitive equipment. The primary concern related to vibration and people is the potential to annoy those working and residing in the area. Vibration with high enough amplitudes can damage structures (e.g., crack plaster or destroy windows). Groundborne vibration can also disrupt the use of sensitive medical and scientific instruments, such as an electron microscope.
Common sources of vibration within communities include construction activities and railroads.
Groundborne vibration generated by construction projects is usually highest during pile driving, rock blasting, soil compacting, jack hammering, and demolition-related activities. Next to pile driving, grading activity has the greatest potential for vibration impacts if large bulldozers, large trucks, or other heavy equipment are used.
Caltrans’ Transportation and Construction Vibration Guidance Manual provides a summary of vibration criteria that have been reported by researchers, organizations, and governmental agencies (Caltrans, 2020). Chapter six of this manual provides Caltrans’ guidelines and thresholds for evaluation potential vibration impacts on buildings and humans from transportation and construction projects.
Vibration Impact Analysis: The potential for groundborne vibration is typically greatest when vibratory or large equipment such as rollers, impact drivers, or bulldozers are in operation. For the proposed project, the largest earthmoving equipment would primarily operate during demolition, site preparation, grading, and paving work. This equipment would, at worst-case, operate adjacent to the site’s property lines and within approximately 240 feet of the Watsonville Community Hospital south of the project site across Nielson Street. Potential groundborne vibration levels are shown in Table
12. Conservatively using a distance of 200 feet from the hospital, the worst-case equipment operations would have a peak particle velocity of 0.021 inches per second. This is below Caltrans’ vibration threshold of 2.00 inches/second for building damage for modern industrial and commercial buildings, as well as below Caltrans’ threshold criteria for potential human annoyance response, which categorizes transient vibration as barely perceptible at 0.35 inches/second (Caltrans 2020).
Attachment 2.9
96 | City of Watsonville
Standard construction equipment would result in lower vibration levels than the worst-case equipment and would be below Caltrans thresholds.
Table 12: Potential Groundborne Vibration Levels
Equipment Peak Particle Velocity(A) (Inches/Second) at Distance 50 Feet 200 Feet 400 Feet
Vibratory Roller 0.098 0.021 0.010
Large Bulldozer 0.042 0.009 0.004
Small Bulldozer 0.014 0.003 0.001
Loaded Truck 0.035 0.008 0.004
Jackhammer 0.016 0.004 0.002
Sources: Caltrans, 2013 and FTA 2018.
(A) Estimated PPV calculated as: PPV(D)=PPV(ref*(25/D^1.3)) where PPV(D)= Estimated PPV at distance; PPVref= Reference PPV at 25 ft; D= Distance from equipment to receiver; and n= ground attenuation rate (1.3 for competent sands, sandy clays, silty clays, and silts).
Construction-related groundborne vibration levels, therefore, would not be excessively perceptible or annoying to nearby properties. Once operational, the proposed project would not result in the operation of sources that would generate substantial groundborne vibration levels. c. Less than Significant Impact. The project site is located across the street from Watsonville Municipal Airport, but is not located under the recommended flight paths as shown on the Watsonville Municipal Airport Noise Abatement Map (City of Watsonville, 2019). Based on an Aircraft Noise Monitoring Report prepared by WJV acoustics in 2018, the project-site is located outside of the airport’s 65 CNEL noise contour zone under both existing (2016) and future (2036) conditions. The western portion of the site, within approximately 125 feet of the Airport Boulevard right-of-way, may be exposed to airport noise levels up to 60 CNEL under existing and future conditions; the rest of the site is outside of the Aircraft Noise Monitoring Report’s contour lines and would be exposed to noise levels less than 60 CNEL (WJV Acoustics, 2018). It is noted the on-site manager’s residence would be located in the eastern part of the site, outside of all noise contour zones identified for Watsonville Municipal Airport. According to the WJV Acoustics report (pg. 11), “The State of California and the FAA consider areas outside the CNEL 65 dB contour to have an acceptable aircraft noise exposure under normal conditions for noise compatibility planning purposes.”
Ambient noise monitoring indicates individual aircraft approaches, departures, and fly overs at the site may generate noise levels up 85 dBA Lmax. Such single event noise levels are short in duration and do not approach noise levels that would be considered excessive on a short-term basis. Most environmental noise levels produce subjective or interference effects; physiological effects are usually limited to high noise environments such as industrial manufacturing facilities. Such physiological effects occur when the human ear is subjected to extremely high short-term noise levels (i.e., 140 dBA from an explosion) or from a prolonged exposure to high noise environments. For example, to protect workers from noise-induced hearing loss, the U.S. Occupational Safety and Health Administration (OSHA) limits worker noise exposure to 90 dBA as averaged over an 8-hour period (29 CFR 1910.95). Individual aircraft activities, therefore, would not generate noise levels at the project site that would be physiologically harmful to site visitors or occupants.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 97
For the reasons described above, the proposed project would not expose the onsite manager or people visiting the self-storage facility to excessive public or private airport-related noise levels, and the impact is less than significant.
References:
California Office of Planning and Research, 2017. State of California General Plan Guidelines.
Sacramento, CA.
Caltrans, 2013. Peak Hours Volume Data: Technical Noise Supplement to the Traffic Noise Analysis Protocol. Sacramento, CA.
Caltrans, 2013. Transportation and Construction Vibration Guidance Manual. Sacramento, CA.
City of Watsonville, 2005. General Plan. Available at: https://www.cityofwatsonville.org/160/2005- General-Plan (accessed February 4, 2022).
City of Watsonville, 2019. Flying Quietly. Available at:
https://www.cityofwatsonville.org/332/Flying-Quietly (accessed March 7, 2022).
W-Trans, March 21, 2022. Focused Transportation Study for the 70 Nielson Street Project (included as Appendix G).
WJV Acoustics, August 29, 2018. Aircraft Noise Monitoring Report Watsonville Municipal Airport. https://www.cityofwatsonville.org/DocumentCenter/View/12654/Watsonville-Airport-Noise-Report-8- 29-18 (accessed February 4, 2022)
U.S. Department of Transportation, Federal Highway Administration (FHWA), 2017. “Construction Noise Handbook, Chapter 9 Construction Equipment Noise Levels and Ranges.” Available at:
http://www.fhwa.dot.gov/environment/noise/construction_noise/handbook/handbook09.cfm (accessed March 10, 2022).
Attachment 2.9
98 | City of Watsonville
6.14 Population and Housing
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Induce substantial unplanned population growth in an area, either directly (for example, by proposing new
homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
b) Displace substantial numbers of existing people or
housing, necessitating the construction of replacement
housing elsewhere?
Conclusion: Regarding population and housing, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. The project proposes development of a single bedroom apartment unit, which would be occupied by the onsite manager. The single housing unit would not induce substantial unplanned population growth in the area. The proposed self-storage facility is intended to serve the local population. During construction, there would be a short-term increase in construction jobs. It is anticipated that the workers already live in Watsonville or in nearby towns and/or adjacent counties. Construction impacts would be short-term and less than significant.
The project does not include any major infrastructure expansion such as new roads or utilities and would not result in any indirect population growth. As a result, impacts on City population growth from employment and residential population growth would be less than significant. b. Less than Significant Impact. There are no existing residences or other habitable structures onsite.
No people or houses would be displaced by the proposed project. Therefore, no replacement housing is needed. There would be no impact.
References:
City of Watsonville, 1994. 2005 General Plan, Land Use Diagram. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/106/2005-General-Plan-Land-UseDiagram- (accessed January 21, 2022).
City of Watsonville, 2012. Draft 2030 General Plan Update, Land Use and Community Development Element. Available at: https://www.cityofwatsonville.org/DocumentCenter/View/139/03-Land-Use--- June-2012-PDF (accessed January 21, 2022).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 99
6.15 Public Services
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
Result in substantial adverse physical impacts associated with the provision of new or physically altered
governmental facilities or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or
other performance objectives for any of the public
services:
a) Fire protection
b) Police protection
c) Schools
d) Parks
e) Other Public Facilities
Conclusion: Regarding public services, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. Project buildout would result in an increase of development fees for the City. Using FY21-22 fees, the applicant would pay a total of $76,398. 1 An additional $29,9592
would be collected for school fees applied to commercial developments. The total fees of $106,3573 are intended to offset the costs of additional public services required for the proposed project.
The City of Watsonville is served by the Watsonville Fire Department. The Department includes Fire Suppression, Emergency Medical Services, Fire Training, and Fire Prevention Divisions. The Department provides services related to fire prevention, training and safety, which include public education and inspection services, and standard fire department operations, which include emergency response and development of hazard pre-incident plans. The Department serves the 6.6 square miles of Watsonville and its 54,142 residents. In addition, the Department provides service to unincorporated areas near Watsonville, which increases the service area to approximately 14 square miles and a population of 60,000.
The Watsonville Fire Department currently operates two fire stations, Station 1 and Station 2.
Station 1 is staffed with 6-7 rotating fire fighters with one engine. Station 2 is staffed with 3-4 rotating fire fighters and one engine. Both stations have paramedics on call. 1 Calculation: $1,500 + ($.50*149,796 sq ft) = $76,398
2 Calculation: $.20*149,796 sq ft = $29,959
3 Calculation: $29,959 + $76,398 = $106,357
Attachment 2.9
100 | City of Watsonville
Fire Station 2 would likely be the first to respond to calls from the project site, as it located less than one mile to the northeast at 370 Airport Boulevard. The proposed project is anticipated to marginally increase demand for fire protection services, but it is not expected to compromise response times, exceed planned staffing levels or equipment, nor require the construction of additional fire facilities.
Additionally, the Watsonville Fire Department and Fire Inspector would review the design of project plans prior to the issuance of a building permit to ensure incorporation of adequate fire and life safety features in the project.
The proposed project must comply with the City 2005 General Plan Safety Element policies related to fire protection. These policies, listed below, would help ensure that the proposed project does not impact fire services to a degree that new or expanded facilities would be required.
The following Fire Department areas of review are from the 2005 General Plan Public Safety Element, Policy 12.F Fire Safety Standards:
• 12.F.1 Access
• 12.F.2 Cul-de-Sacs
• 12.F.3 Private Access Roads
• 12.F.4 Road Construction
• 12.F.5 Width & Vertical Clearance
• 12.F.6 Alleys
• 12.F.7 Emergency Access
• 12.F.8 Fire Flow
• 12.F.9 Open Area
• 12.F.10 Building Safety
• 12.F.11 Built-In Fire Protection
• 12.F.12 Street Name & Numbering
• 12.F.13 Fire Cause Investigation
The City has also adopted the California Fire Code (Chapter 9 of Title 8 of the municipal code) with modifications for local conditions. Applicable policies from the code include:
• 8-9.304 Combustible waste material: Including weeds, grass, vines or other growth capable of being ignited and endangering property, will be removed by the owner or occupant. • 8.9-903 Automatic sprinkler systems: All buildings will be required to have approved automatic sprinkler systems in new buildings and structures.
The project could increase demand for fire services. The project’s location near Station 2, compliance with the California Fire Code, and additional project review by the Fire Department would result in a less than significant impact on fire protection.
b. Less than Significant Impact. The City of Watsonville is under the jurisdiction of the City of Watsonville Police Department (WPD). WPD provides police protection services throughout the city.
WPD headquarters are located at 215 Union Street, approximately 2.49 miles southeast of the proposed project and roughly 10-15 minutes away driving.
The proposed project could increase demand for police protection services. The potential for security concerns could create the need more police presence, but the project is not expected to compromise response times, exceed planned staffing/equipment levels, or directly require the construction of additional police facilities. The impact would be less than significant. c. No Impact. The project would be a self-storage development, including a single apartment for the facility manager. The site is in the service area of the Pajaro Valley Unified School District (PVUSD).
The District operates seven alternative and charter schools, 16 elementary schools, nine secondary Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 101
schools, and one adult education school. The proposed project would result in no increase in PVUSD school population. There would be no impact.
d. Less than Significant Impact. The proposed project would include a single residence that would result in very little to no population growth and would minimally increase demand on local and regional recreation facilities. The city operates 26 parks (see Section 6.16 Recreation) totaling 143 acres. Parks managed by Santa Cruz County, Monterey County, Santa Clara County, and the state are located within 20 miles of the project. The impact would be less than significant. e. Less than Significant Impact. With one apartment, the project would not result in population growth that would incrementally affect other public services such as libraries, public transit, public meeting places. In the past several years, the City has expanded library facilities and increased funding to accommodate increased demand and a growing population. The additional resident generated by the project would not warrant new or physically altered public facilities. Impacts would be less than significant.
References:
City of Watsonville, 2022. Development Fees. 2021-2022 Fee Schedule. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/17011/Impact-Fees-FY-2021-2022-PDF (Date Accessed: January 19, 2022)
City of Watsonville, 2005. Draft Environmental Impact Report, General Plan and Sphere of Influence Amendment. December 1992. Page 3-83. https://cityofwatsonville.org/DocumentCenter/View/1154/6- Pubhttps://cityofwatsonville.org/DocumentCenter/View/7078/2005-General-Plan-EIR-1-of-3 (accessed January 17, 2020)
City of Watsonville, 2005. General Plan: Public Safety Element. Available at:
https://www.cityofwatsonville.org/160/2005-General-Plan (accessed January 17, 2022).
City of Watsonville, 2005. General Plan: Public Services Element. Available at:
https://www.cityofwatsonville.org/160/2005-General-Plan (accessed January 17, 2022).
City of Watsonville, 2021. Development Fee Summary 2021-2022. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/9187/Impact-Fees-2019-20- PDF#:~:text=Residential%20new%20construction%20%24990.00%20per,ft (accessed January 17, 2022)
City of Watsonville, 2019 6c. Watsonville Fire Department. Available at:
https://www.cityofwatsonville.org/430/Fire (accessed January 17, 2022).
City of Watsonville, 2019 6d. Watsonville Police Department. Available at:
https://www.cityofwatsonville.org/197/Police (accessed January 17, 2022).
City of Watsonville. Recirculated Draft EIR 2030 General Plan, Public Facilities and Services. https://cityofwatsonville.org/DocumentCenter/View/1154/6-Public-Facilities-PDF (accessed January 17, 2022)
Education Data Partnership (EdData), 2019. Pajaro Valley Unified. Available at: https://www.eddata.org/district/Santa-Cruz/Pajaro-Valley-Unified (accessed January 17, 2022).
Attachment 2.9
102 | City of Watsonville
My School Locator, 2019. Pajaro Valley Unified School District. Available at:
https://betalocator.decisioninsite.com/?StudyID=136986 (accessed January 17, 2022).
Total School Solutions, 2012. Pajaro Valley Unified School District: Comprehensive Facilities Master Plan 2012-2022. Available at: http://pps-pajaroca.schoolloop.com/file/1310009033866/1309101273857/1514939043896199031.pdf (accessed January 17, 2022).
United States Census Bureau, 2019. City of Watsonville, California. Available at:
https://www.census.gov/quickfacts/fact/table/watsonvillecitycalifornia/PST045218 (Accessed January 17, 2022).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 103
6.16 Recreation
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial physical
deterioration of the facility would occur or be
accelerated?
b) Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?
Conclusion: Regarding recreation, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. The project proposes one manager’s apartment at the self-storage facility. That resident could use recreation facilities but would not increase the park use so that substantial deterioration would occur. The project would generate property taxes that would go into the City’s General Fund to help finance park maintenance and future park production. The project would not significantly increase the use of existing parks and recreational facilities, and the impact would be less than significant.
b. Less than Significant Impact. The project does not propose offsite recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. There would be no impact.
References:
City of Watsonville, 2021. Development Fee Summary 2021-2022. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/9187/Impact-Fees-2019-20- PDF#:~:text=Residential%20new%20construction%20%24990.00%20per,ft (accessed January 17, 2022)
Attachment 2.9
104 | City of Watsonville
6.17 Transportation
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Conflict with a program, plan, ordinance, or policy
addressing the circulation system, including transit,
roadway, bicycle and pedestrian facilities?
b) Conflict or be inconsistent with CEQA Guidelines
15064.3, subdivision(b)?
c) Substantially increase hazards due to a geometric design feature (e,g., sharp curves or dangerous intersections) or incompatible uses (e.g. farm equipment)?
d) Result in inadequate emergency access?
Conclusion: Regarding transportation, the proposed project would not result in any significant environmental impacts after mitigation.
W-Trans, professional transportation engineers and consultants, prepared a Focused Transportation Study for the project (Appendix G of this Initial Study). This section summarizes the analysis and conclusions in the W-Trans study.
Documentation:
a. Less than Significant Impact. The Focused Transportation Study (Appendix G), completed by WTrans (March 21, 2022), evaluated transit, roadway, bicycle, and pedestrian facilities at the project site and surrounding areas. The project does not conflict with any programs, plans, ordinances, or policies regarding circulation systems.
Alternative Modes
Although the proposed project’s use as a self-storage facility does not lend itself to trips other than by personal vehicle, it is still reasonable to assume that some pedestrian, bicycle, and transit trips may be generated by the project.
Pedestrian Facilities
In general, pedestrian facilities include sidewalks, crosswalks, pedestrian signal phases, curb ramps, curb extensions, and various streetscape amenities such as lighting and benches. In the project vicinity, sidewalks exist on both sides of Airport Boulevard, Nielson Street, and Hangar Way, effectively linking the project site to the surrounding pedestrian network. Signalized crosswalks are present on the north and east legs of the Airport Boulevard/Nielson Way intersection. Overhead streetlights exist along Airport Boulevard, Nielson Street, and Hangar Way. The existing facilities provide adequate pedestrian access and connections between the project site and surrounding residential neighborhoods and commercial uses.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 105
Bicycle Facilities
There are existing Class II bike lanes along Airport Boulevard between Westgate Drive and Green Valley Road. According to the Watsonville Trails & Bicycle Master Plan (2012), additional bike lanes are planned along Airport Boulevard between Highway 1 and Westgate Drive, and along Loma Prieta Avenue between Airport Boulevard and South Green Valley Road. Cyclists would also be able to share the travel lanes with motorists on minor residential streets surrounding the project site.
As a result, adequate access for bicyclists is currently provided and would be improved upon completion of the planned facilities identified in the Trails & Bicycle Master Plan.
Transit
The nearest transit stops are located on Nielson Street fronting the project site. These stops are served by Santa Cruz METRO Routes 69 and 72. Route 69 provides connectivity between Santa Cruz and Downtown Watsonville and operates on weekdays from 6:40 a.m. to 4:40 p.m. and on weekends from 8:40 a.m. to 6:40 p.m., with one-hour headways. Route 72 operates on weekdays only from 6:55 a.m. to 5:55 p.m., with headways of one hour, providing connectivity between the northern and southern parts of the city. The existing transit facilities provide adequate connections between the project site and areas in and around the city.
Existing pedestrian, bicycle, and transit facilities provide adequate access to and from the project site for alternative modes of transportation. The proposed project would not disrupt or interfere with these facilities. The impact would be less than significant. b. Less than Significant Impact. The Focused Transportation Study (Appendix G), completed by WTrans (March 21, 2022), evaluated VMT for the proposed project. As explained below, transportation-related impacts per CEQA Guidelines section 15064.3(c) would be less than significant.
Trip Generation
The anticipated trip generation for the proposed project was estimated using standard rates published by the Institute of Transportation Engineers (ITE) in Trip Generation Manual, 11th Edition, 2021. A review of available land use descriptions contained in the ITE manual identified the rates most closely aligned with the existing and proposed uses would be “Mini-Warehouse” (Land Use #151) and “Single-Family Detached Housing” (Land Use #210). The standard rates for “Mini-Warehouse” includes all vehicle trips related to the operation of a personal storage facility for the maintenance, office operations, and other services. The project is not anticipated to generate any pass-by trips or trip reductions resulting from nearby land use or transportation options. To provide a conservative analysis, trip reductions associated with the existing land use and any internal capture trips were not included.
The expected trip generation potential for the proposed project is indicated in Table 13. The proposed project is expected to generate an average of 227 new trips per day, including 15 trips during the a.m. peak hour and 24 trips during the p.m. peak hour; these new trips represent the anticipated increase in traffic associated with the project.
Congestion / Level of Service (LOS)
The Focused Transportation Study includes a LOS evaluation to understand congestion on nearby streets. Because measures of automobile delay can no longer be considered significant environmental impacts under CEQA, pursuant to CEQA Guidelines section 15064.3, the LOS Attachment 2.9
106 | City of Watsonville
evaluation of the proposed project is included separately in the W-Trans report in Appendix G of this Initial Study for informational purposes only and not for evaluating transportation-related impacts.
Table 13. Trip Generation Summary
Land Use Units Daily AM Peak Hour PM Peak Hour
Rate Trips Rate Trips In Out Rate Trips In Out
Mini-Warehouse 149.796 ksf 1.45 217 0.09 14 8 6 0.15 23 11 12 Single Family Detached
Housing
1 du 9.43 10 0.70 1 0 1 0.94 1 1 0
Total 227 15 8 7 24 12 12
Note: ksf = 1,000 square feet; du = dwelling unit
Vehicle Miles Traveled (VMT)
Consideration was given to the project’s potential generation of Vehicle Miles Traveled (VMT).
Because the City of Watsonville has not yet adopted a standard of significance for evaluating VMT, guidance provided by the California Governor’s Office of Planning and Research (OPR) in the publication Technical Advisory on Evaluating Transportation Impacts in CEQA, 2018, as well as recommendations provided by the Santa Cruz County Planning Department in the document titled Analyzing Vehicle Miles Traveled for CEQA Compliance, updated in May 2021, were used.
Guidance provided in these documents suggests that development projects consisting of multiple land uses may be evaluated based on the dominant use, which is the self-storage facility. This guidance also suggests that a self-storage facility may be considered local-serving if the demand for self- storage services in the area is constant and the addition of a new self-storage site would redistribute existing self-storage-based trips within and surrounding Watsonville, instead of creating new trips. The guidance states that local-serving projects are presumed to have a less than significant transportation impact on VMT since these kinds of land uses tend to shorten trips and reduce VMT.
For the purpose of this study, a quantitative approach was developed to evaluate the potential change in project-related VMT for the self-storage land use and to determine whether the project would be local-serving. This method is summarized in the following steps:
1. Determine the average self-storage trip length in the immediate area by measuring the distance between existing self-storage facilities and a common point in Watsonville (in this case, City Hall was used as the common point).
2. Measure the trip length from the project site to the common point (Watsonville City Hall).
3. If the project trip length is less than the average self-storage trip length for existing self-storage facilities, then the project may be presumed to reduce the average distance traveled for this type of use and is considered to have a less than significant VMT impact.
There are currently seven similar self-storage facilities in the study area vicinity within a 10-mile radius of Watsonville City Hall. The average distance between these facilities and the Watsonville City Hall is 4.9 miles. The distance between the project site and City Hall is 4.4 miles. Because the length of travel from the common reference point to the project site is less than the average distance Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 107
to other existing similar self-storage facilities, the project is presumed to have a local-serving effect and therefore have a less than significant VMT impact. A list of nearby existing self-storage facilities along with the corresponding distances between each location and Watsonville City Hall is provided in Table 14 (see Appendix G of this Initial Study for a corresponding map).
Table 14. Vehicles Miles Traveled (VMT) Estimate
Site
No.
Name Street Address, City Distance to City
Hall (miles)
1. StorageMart 6 Westgate Dr, Watsonville 2.4
2. AAA Mini Storage 20 Westgate Dr, Watsonville 2.3
3. Anbar Self Storage Moving Center 44 Ross Avenue, Freedom 3.0
4. Extra Space Storage 1478 Freedom Blvd, Watsonville 1.6
5. Rob Roy Storage 10405 Soquel Dr, Aptos 8.4
6. Aptos Security Storage 7525 Freedom Blvd, Aptos 8.2
7. Store More America Self Storage 9687 Soquel Dr, Aptos 8.5 Average of all facilities within 10 miles of City Hall 4.9 Project 70 Nielson St, Watsonville 4.4
The project would have a less than significant impact in terms of the VMT it would generate. c. Less Than Significant Impact with Mitigation Incorporated. A significant impact would occur if the proposed project considerably increased hazards due to a design feature or introduced incompatible uses to the existing circulation system.
Collision History
The collision history for the study area was reviewed to determine any trends or patterns that may indicate a safety issue. Collision rates were calculated based on records available from the California Highway Patrol as published in their Statewide Integrated Traffic Records System (SWITRS) reports. The most current five-year period available is from December 11, 2016, to December 10, 2021.
The calculated collision rate for the study intersection was compared to the average collision rate for similar facilities statewide, as indicated in 2018 Collision Data on California State Highways, California Department of Transportation (Caltrans). These average rates statewide are for intersections in the same environment (urban, suburban, or rural), with the same number of approaches (three or four), and the same controls (all-way stop, two-way stop, or traffic signal). With nine crashes reported during the 5-year study period, the study intersection had a collision rate of
0.25 collisions per million vehicles entering (c/mve), which is lower than the statewide average of
0.29 c/mve. An additional collision was documented to have taken place in the vicinity of the study intersection but was not included in the collision rate calculation since this crash location was more than 300 feet away from the intersection which is outside of what is commonly considered to be the intersection’s area of influence.
Site Access and Circulation
The project site would be accessed via two driveways on Nielson Street, which would provide full access to vehicle parking spaces. The western driveway would be located approximately 300 feet Attachment 2.9
108 | City of Watsonville
east of the crosswalk on the east leg of the intersection with Airport Boulevard. Nielson Street is a local street with a speed limit of 25 miles per hour (mph) and is approximately 40 feet wide with one travel lane in each direction; on-street parking is generally permitted on both sides of the street.
Airport Boulevard has a posted speed limit of 45 mph and is approximately 60 feet wide with two travel lanes in each direction.
Sight Distance
Sight distances along Nielson Street at the two proposed driveways serving the project site were evaluated using sight distance criteria contained in the Highway Design Manual published by Caltrans. The recommended sight distance for driveways is based on stopping sight distance with approach travel speed used as the basis for determining the recommended sight distance.
For the posted 25-mph speed limit on Nielson Street, the minimum stopping sight distance needed is 150 feet. Based on a review of field conditions, sight lines to and from the western project driveway extend over 200 feet to the west and to the east, which is more than adequate for the posted speed limit. The sight lines from the eastern project driveway are more limited due to adjacent street parking on the north side of Nielson Street. Sight lines to and from the eastern driveway extend 170 feet to the west, which is adequate for the posted speed limit. However, sight lines from this driveway only extend 119 feet to the east which does not meet the minimum requirement of 150 feet. If the street parking directly adjacent to the driveway was prohibited, sight distances over the 150-foot minimum would be met. To maintain this sight distance, it is noted that any vegetation near the project’s driveways should be trimmed to an appropriate height of three feet or less and trees trimmed so that no piece of a tree hangs below a height of seven feet from the surface of the roadway.
Additionally, it is recommended that on-street parking on Nielson Street be restricted within 25 feet (approximately one parking spot) on either side of the eastern driveway.
For a motorist traveling eastbound on Nielson Street intending to turn left into either project driveway, the stopping sight distance looking east along Nielson Street is also greater than 150 feet, providing adequate visibility to allow a following driver to observe and react to a vehicle that may stop in the roadway before making a left turn into the driveway.
Sight lines at the western project driveway are adequate to accommodate all turns into and out of the project site. However, sight lines at the eastern project driveway are inadequate due to vehicles parked in adjacent street parking. Mitigation Measure TRANS-1 would reduce this impact to a less than significant level.
Mitigation Measure TRANS-1: Sight Distances. To achieve a minimum sight distance of 150 feet at each project driveway access point, on-street parking shall be restricted on Nielson Street for 25 feet on either side of the eastern driveway. Vegetation along the project frontage on Nielson Street shall be trimmed to a height of three feet or less and trees trimmed so that no piece of a tree hangs below a height of seven feet from the surface of the roadway.
The project would generate traffic that is consistent with existing traffic from land uses in the area, which are industrial, commercial, and residential. The project would not result in incompatible uses as it relates to transportation and traffic.
Construction activities may create temporary hazardous conditions for pedestrians, bikers, and drivers. Construction-related impacts would cease upon project completion. Mitigation Measure Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 109
TRANS-2 would reduce the impact of temporary construction activities to a less than significant level.
Mitigation Measure TRANS-2: Construction Period Transportation Impacts. The applicant shall submit a Construction Period Traffic Control Plan to the City for review and approval. The plan shall include traffic safety guidelines compatible with Section 12 of the Caltrans Standard Specifications (“Construction Area Traffic Control Devices”) to be followed during construction.
The plan shall also specify provision of adequate signage and other precautions for public safety to be provided during project construction. In particular, the plan shall include a discussion of bicycle and pedestrian safety needs, including ADA accessibility standards, due to project construction and later, project operation. In addition, the plan shall address emergency vehicle access during construction. The applicant or their general contractor for the project shall notify the Public Works & Utilities Department and local emergency services (i.e., the Police and Fire Departments) prior to construction to inform them of the proposed construction schedule and that traffic delays may occur.
Prior to approval of a grading permit, the City shall review and approve the project Construction Period Traffic Control Plan. During construction, the City shall periodically verify that traffic control plan provisions are being implemented.
d. Less than Significant Impact. A significant impact would occur if the proposed project would not satisfy emergency design and access requirements of the City of Watsonville Fire Department. A significant impact would also occur if the project would inhibit the ability of emergency vehicles to serve the project site or adjacent uses.
Emergency response vehicles would be able to access the project site via the driveways on Nielson Street as illustrated on the Fire Access Plan (previous Figure 7). The proposed driveways and drive aisles would meet current City standards and so can be expected to accommodate the access requirements for both emergency and passenger vehicles. Since all roadway users must yield the right-of-way to emergency vehicles when using their sirens and lights, the added project-generated traffic is not expected to increase response times for emergency vehicles.
Emergency access would be adequate since all driveways and internal roadways would be designed to accommodate emergency vehicles in accordance with Fire Department regulations. The impact would be less than significant.
Summary of Transportation Conclusions and Recommendations • The proposed project is expected to generate an average of 227 trips per day, including 15 trips during the weekday a.m. peak hour and 24 during the p.m. peak hour. • Pedestrian, bicycle, and transit facilities are adequate to serve the proposed project. • The proposed project is expected to have a less than significant impact on vehicle miles traveled (VMT).
• The project’s driveways and internal roadway would be designed to current City standards and are therefore expected to accommodate the access requirements for both emergency and passenger vehicles.
• Sight distances are adequate at the western driveway. To achieve a minimum sight distance of 150 feet at the eastern driveway, Mitigation TRANS-1 shall be implemented. • Construction traffic impacts would be less then significant with implementation of Mitigation Measure TRANS-2.
Attachment 2.9
110 | City of Watsonville
References:
W-Trans, March 21, 2022. Draft Focused Transportation Study for the 70 Nielson Street Project.
Included as Appendix G.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 111
6.18 Tribal Cultural Resources
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant
With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Would the project cause a substantial adverse change in the significance of a tribal cultural resource define in Public Resources Code 21074 as either a site, feature, place,
cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in a local register or
historical resources as defined in Public Resources
Code section 6020.1(k), or
ii. A resource determined by the lead agency, in its
discretion and supported by substantial evidence to be
significant pursuant to criteria set forth in subdivision (c) of Public Resources Code 5024.1. In applying the
criteria set forth in subdivision (c) of Public Resource Code 5024.1, the lead agency shall consider the
significance of the resource to a California Native
American Tribe.
Conclusion: Implementation of Mitigation Measures CUL-1 and CUL-2 (in Section 6.5 of this Initial Study) would reduce potential impacts on tribal cultural resources to less than significant levels.
Documentation:
ai. Less Than Significant with Mitigation Incorporated. As detailed in Section 6.5,Cultural Resources, the California Historical Resources Information System (CHRIS) search at the Northwest Information Center (NWIC) did not report any known archaeological resources relating to tribal cultural resources located within the project’s boundaries. The nearest prehistoric archaeological site (P-44-000802: redeposited midden) is located about 0.75 miles of the project site and will not be impacted by the proposed project (Northwest Information Center 2022).
A Sacred Lands File (SLF) search was conducted through the Native American Heritage Commission (NAHC), which was returned with a positive result on January 28, 2022. The search indicated that the Costanoan Ohlone Rumsen-Mutsen Tribe had more information on potential resources in the project vicinity. It was also recommended that the Amah Mutsun Tribal Band, Amah Mutsun Tribal Band of Mission San Juan Bautista, Indian Canyon Mutsun Band of Costanoan, and the Wuksache Indian Tribe/Eshom Valley Band be contacted as an extension of the SLF. Emails Attachment 2.9
112 | City of Watsonville
were sent to the tribes on 02/09/2022, which included a topographic map of the project area and details of the proposed project undertaking.
Based on the results of the SLF search and Native American outreach, although no specific resources were discovered, cultural resources could be present and project excavation could result in the discovery of prehistoric archaeological resources. In the event that project ground-disturbing activities disturb, damage, or destroy previously unknown buried prehistoric features, sites or artifacts, a significant impact could occur. Implementation of Mitigation Measures CUL-1 and CUL2 would reduce potential impacts to undiscovered tribal cultural resources to a less than significant level (see Section 6.5 of this Initial Study for more detail). aii. Less Than Significant with Mitigation Incorporated. Some Native American artifacts may not be considered unique archaeological resources under definitions included in the CEQA Guidelines (i.e., if there is not a demonstrable public interest in that information, it does not possess a special and particular quality such as being the oldest of its type or the best available example of its type, or it is not directly associated with a scientifically recognized important prehistoric event or person).
However, it is possible for a lead agency to determine that an artifact is considered significant to a local tribe, and therefore be considered a significant resource under CEQA. Mitigation measures included in Section 6.5, Cultural Resources, of this Initial Study include language that all Native American artifacts are to be considered significant until the lead agency has enough evidence to determine an artifact not significant. This ensures that the default assumption is that all Native American artifacts are significant resources under CEQA.
Implementation of Mitigation Measures CUL-1 and CUL-2 (See Section 6.5) would reduce impacts to tribal cultural resources to a less than significant level.
References:
Native American Heritage Commission, 2022. Scared Lands File Search Prepared in Support of the Crocker’s Lockers Project, Santa Cruz County. January 28, 2022. Unpublished document kept on file with the NAHC and MIG, Inc.
Northwest Information Center, 2022. Cultural Resources Records Search in Support of the 547 Crocker’s Lockers Project (No. File No. 21-1068). Unpublished document kept on file with the NWIC and MIG, Inc.
Attachment 2.9
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6.19 Utilities and Service Systems
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
Would the project:
a) Require or result in the relocation or construction of new or expanded water, wastewater treatment or storm water
drainage, electric power, natural gas, or telecommunication facilities, the construction or relocation of which could cause significant environmental effects?
b) Have sufficient water supplies available to serve the project and reasonably foreseeable future development during
normal, dry and multiple dry years?
c) Result in a determination by the wastewater treatment provider which serves or may serve the project area that it has adequate capacity to serve the project’s projected
demand in addition to the provider’s existing
commitments?
d) Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
e) Comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Conclusion: Regarding utilities and service systems, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. The proposed project would not result in the relocation or construction of new or expanded water supply, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunication facilities that would cause a significant environmental effect.
Water
According to the Watsonville 2020 Urban Water Management Plan (UWMP), the City owns, operates, and maintains 190 miles of water supply pipelines and, as of 2020, has 65,231 customers.
Construction of water supply infrastructure is required for new development, and the project would connect to the existing water main underneath Nielson Street. As a standard requirement, prior to issuance of building permits, the developer would be required to provide the City with a detailed study indicating specifications of the new water infrastructure and any minor modifications needed to the existing municipal conveyance system to accommodate project needs. Construction of new water supply infrastructure would be conducted in compliance with the City’s Public Improvement Standards and City-approved utilities construction Best Management Practices (BMPs); therefore, project construction would not cause significant environmental impacts. Also, no new public water Attachment 2.9
114 | City of Watsonville
supply facilities would be needed to serve the proposed project. Impacts would be less than significant.
Wastewater
The City owns, operates, and maintains a sanitary sewer system of approximately 170 miles of pipelines that collect and transfer wastewater to the City’s Wastewater Treatment Facility (WWTF).
According to the 2020 UWMP, the WWTF is permitted to treat a maximum of 12 million gallons per day. In 2020 the plant treated a total of 1,795 million gallons, or 5,510 acre-feet (AF) from the Watsonville, Pajaro, Freedom, and Salsipuedes Sanitary Districts.
The project would connect to an existing public sewer main underneath Nielson Street south of the project site. The proposed connection would enter the property to connect the proposed manager’s apartment. Completion of the proposed project would require new wastewater infrastructure to convey wastewater from the project’s facilities to existing City sewer mains. As a standard requirement, prior to issuance of building permits, the applicant would be required to provide the City with a detailed study indicating specifications of the new wastewater infrastructure and any minor modifications needed to the existing municipal conveyance system to accommodate projectgenerated wastewater.
Anticipated project wastewater generation was calculated using a conservative industry standard in which wastewater generated equals 95 percent of water use (see section 6.19.b below for projected project water demand). Using the 2020 UWMP per-capita factor, the project is expected to use 31,755 gallons of water per year, or 0.1 AFY. As a result, the project would produce approximately 30,167.3 gallons (0.09 AF) of wastewater per year.1 This equates to 82.7 gallons of wastewater generated per day,
2 compared to the WWTF’s daily wastewater permitted intake of 12 million gallons per day.
3 The WWTF would have adequate capacity to treat project wastewater in addition to its existing commitments. No new public wastewater conveyance or treatment facilities would be needed to serve the proposed project. Similar to water infrastructure construction impacts for wastewater infrastructure would be less than significant.
Stormwater
The project site comprises a paved parking lot with ornamental landscaping and pole-mounted lighting. Runoff is collected by existing storm drain inlets located along Nielson Street and Airport Boulevard and is conveyed via underground storm drainage facilities to Nielson Street in an existing 36-inch storm drain line. The proposed project would generate less stormwater runoff than existing conditions onsite by removing approximately 9,949 square feet of impervious surfaces. A Stormwater Control Plan has been prepared for the applicant by RAK Civil Engineers, dated June 14, 2021 Revised September 29, 2021 (included as Appendix D). The plan proposes onsite storm drainage improvements and low impact development (LID) design strategies. Project-specific components would include the construction of bioretention areas with appropriately sized filters, plant selection to minimize the use of fertilizers and pesticides, and project design so that stormwater drains from impervious surfaces to integrated management practices (IMPs). Refer to Section 6.10, Hydrology and Water Quality, for a further discussion of project stormwater infrastructure and runoff treatment.
1 Calculation: 31,755 gallons of water annually x 0.95 = 30,167.3 gallons wastewater annually. 2 Calculation: 30,167.3 gallons wastewater annually / 365 = 82.7 gallons of wastewater per day. 3 Calculation: 87.2 / 6,000,000 gallons wastewater per day = >0.00% of WWTF daily intake Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 115
Electric Power
The proposed project would generate demand for electric power. The project would connect to and be served by existing electricity infrastructure owned and operated by PG&E. Multiple PG&E transmission poles and power lines are located adjacent to the project site running parallel to Airport Boulevard. The process of connecting the project to existing infrastructure is expected to be standard for conveying electrical power to a similar development. Construction would be conducted in compliance with City-approved best management practices for utility infrastructure improvements.
No new electric power generation facilities would be needed to serve the project. The impact would be less than significant.
Natural Gas
The proposed project would generate demand for natural gas. The project would connect to and be served by existing natural gas infrastructure owned and operated by PG&E. Several PG&E natural gas pipelines run through the city and north of the project site (PG&E Pipe Locator). Natural gas improvements would be required to connect project components to existing natural gas pipelines.
The process of connecting the project to existing infrastructure is expected to be standard for conveying natural gas to a similar development. Construction would be conducted in compliance with City-approved best management practices for utility infrastructure improvements. The impact would be less than significant.
Telecommunications
Utility poles are located along the western boundary of the project site along Airport Boulevard. The proposed project would connect to this existing telecommunications infrastructure. A telecommunications provider for the project has not yet been selected. Telecommunications infrastructure is often grouped with electric power infrastructure on utility poles and transmission towers; therefore, it can be reasonably assumed the project would connect to telecommunications infrastructure on existing utility poles. The process of connecting the project to existing infrastructure is standard for transmitting internet and other telecommunications services to a similar development. Construction would be conducted in compliance with City-approved best management practices for utility infrastructure improvements. The impact would be less than significant.
In summary, the project would not require or result in the construction of new or expanded public utilities and service facilities. Infrastructure improvements would occur to connect project components to existing public and private utilities infrastructure. City standards include undergrounding all new connections to overhead facilities, including electric, telephone, and television lines. Construction would comply with City standards, and the impact would be less than significant.
b. Less than Significant Impact. The City of Watsonville’s primary source of potable water is groundwater from the Pajaro Valley Groundwater Basin. The City’s water supply and distribution system is composed of nine hydraulic pressure zones, 14 groundwater wells, eight reservoirs and water storage facilities, nine booster stations, 190 miles of pipelines, and the Corralitos Filter Plant (CFP). The City’s Water Service Area (WSA) includes the City limits and several unincorporated areas of Santa Cruz County. Potable water is provided by the City of Watsonville Public Works & Utilities Department. The City works cooperatively with the Pajaro Valley Water Management Agency (PVWMA), the administrative boundaries of which overlay the City’s WSA.
Attachment 2.9
116 | City of Watsonville
According to the City’s 2020 UWMP, the City supplied approximately 7,205 AF of potable water to 65,231 customers in 2020. The City forecasts that potable water demand will increase to 8,375 AF in 2040. The City’s WSA population is expected to increase to 73,576 in 2040. In 2020, customers consumed an average of 87 gallons per capita per day (GCPD).
The project would generate water demand for one dwelling unit for the facility manager. Using the 2020 UWMP per capita average consumption of 87 GPCD results in 87 gallons of water per day.
Annually, this equals 31,755 gallons per year.1 The project also proposes irrigated areas throughout the property. Compliance with the City’s Model Water Efficient Landscape Ordinance (MWELO) would require the project to use efficient irrigation methods and is predicted to reduce landscape water use in new projects by at least 30 percent or more. The Watsonville Municipal Code also requires that existing irrigation systems be maintained to avoid run-off, over-spray, low head drainage, and other inefficient water use.
Drip irrigation methods would service the 30,884 square feet of landscaped areas. Irrigation consumption is expected to total 268,985 gallons per year and would adhere to MWELO and the maximum allowed water allowance for the project of 324,847 gallons per year. The 2020 UWMP concludes that the City will continue to be able to provide water to customers in normal, dry, and multiple dry years. Considering existing and future projected groundwater supplies and City groundwater consumption, the City has adequate water supplies to serve the proposed project. No new water supply source or entitlements would be necessary, and impacts would be less than significant.
c. Less than Significant Impact. The WWTF would have adequate capacity to treat project wastewater in addition to existing commitments. No new public wastewater conveyance or treatment facilities would be needed to serve the proposed project. See the wastewater discussion in section
6.19.a.
d. Less than Significant Impact. According to CalRecycle’s Disposal Reporting System (DRS), the city produced 42,979 tons of disposed solid waste in 2019; for an average of 0.79 pounds per person per day, or 291 pounds per person per year. Waste generated in the city is sent to several landfills.Four landfills accepted over 97 percent (41,385 tons) of the city’s solid waste: Monterey Peninsula Landfill, City of Watsonville Landfill, Buena Vista Sanitary Landfill, and Fink Road Landfill.
According to CalRecycle’s SWIS Facility Detail, Monterey Peninsula Landfill, as of 2004, had remaining capacity for 48,560,000 cubic yards and is permitted to intake a maximum of 3,500 tons of solid waste per day. The City of Watsonville Landfill, as of 2018, had remaining capacity for 1,417,561 cubic yards of waste and can intake 275 tons of solid waste per day. The Buena Vista Drive Sanitary Landfill, as of 2018, had remaining capacity for 2,206,541 cubic yards of waste and is permitted to intake 838 tons per day. The Fink Road Landfill, as of 2017, had a remaining capacity of 7,184,701 cubic yards and can intake 2,400 tons per day (CalRecycle SWIS).
The project’s one employee, assuming the per capita rate of 13.82 pounds per employee per day would generate approximately 5,044 pounds (2.5 tons)2 of solid waste annually. The proposed 1 Calculation: 87 GPCD x 365 = 231,755 gallons per year = 0.1 AFY. 2 Calculation: 13.82 x 365 = 5,044.3 pounds of solid waste generated annually Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 117
project would generate minimal solid waste compared to the existing landfills’ capacity. The impact would be less than significant.
e. Less than Significant Impact. The primary State legislation regarding solid waste is AB939, the Integrated Waste Management Act, was adopted in 1989. AB939 required local jurisdictions to achieve a minimum 50 percent solid waste diversion rate by 2020. The project would not conflict with State laws governing construction or operational solid waste diversion and would comply with local implementation requirements.
The project would include construction and demolition as well as materials disposal and recycling.
The City requires all projects that include demolition and/or construction of structures to submit a Construction Waste Management Plan (Watsonville Construction and Demolition Recycling). The diversion requirements for all projects is 65 percent of the materials generated by a construction and demolition project. When the project is completed, the applicant must submit quantities of recycled or diverted materials and all weight receipts to the City Community Development Department.
Compliance with existing solid waste regulations would ensure a less than significant impact.
References:
RAK Civil Engineers, 2021 Stormwater Control Plan Report for Crocker’s Lockers Self-Storage. June 14, 2021, revised September 29, 2021. (Appendix D)
Pajaro Valley Water Management Agency, 2020. Geology. Available at:
https://www.pvwater.org/geology (accessed February 2, 2022) California Department of Resources Recycling and Recovery (CalRecycle), 2021. Estimated Solid Waste Generation Rates. Available at:
https://www2.calrecycle.ca.gov/WasteCharacterization/General/Rates (accessed on February 8, 2022).
California Department of Resources Recycling and Recovery (CalRecycle), 2019. SWIS Facility Detail (Monterey Peninsula Landfill, City of Watsonville Landfill, Buena Vista Drive Sanitary Landfill, and Fink Road Landfill). Available at:
https://www2.calrecycle.ca.gov/swfacilities/Directory/27-AA-0010/Index (accessed February 8, 2022).
City of Watsonville, 2021. 2020 Urban Water Management Plan. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/16377/2020-Watsonville-Urban-WaterManagement-Plan (accessed February 8, 2022).
City of Watsonville, 2019. Public Works & Utilities, Construction and Demolition Recycling.
Available at: https://www.cityofwatsonville.org/1490/Construction-Demolition-Recycling (accessed on April 29, 2020).
City of Watsonville, 2019. Public Works & Utilities, Engineering Division. Available at:
https://www.cityofwatsonville.org/821/Public-Improvement-Standards (accessed on April 29, 2020).
City of Watsonville, 2019. Public Works & Utilities, Wastewater Division. Available at:
https://www.cityofwatsonville.org/812/Wastewater-Division (accessed on April 29, 2020).
Attachment 2.9
118 | City of Watsonville
City of Watsonville, 2019. Public Works & Utilities, Water Division. Available at:
https://cityofwatsonville.org/714/Water-Division (accessed on April 29, 2020).
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 119
6.20 Wildfire
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, Would the project:
a) Substantially impair an adopted emergency response plan or emergency evacuation plan?
b) Due to scope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose project
occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire?
c) Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
d) Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a
result of runoff, post-fire slope instability, or drainage changes?
Conclusion: Regarding wildfire, the proposed project would not result in any significant environmental impacts.
Documentation:
a. Less than Significant Impact. The proposed project would not impair the emergency response or emergency evacuation plan. The proposed project would also not result in a significant change in existing circulation patterns. See section 6.9, Hazards and Hazardous Materials, for information on emergency response and evacuation. Previous Figure 7 details the project’s routes and access for fire vehicles. The impact would be less than significant.
b. Less than Significant Impact. The project site is relatively flat, and located in a local responsibility area according to the Fire Hazard Severity Zone Viewer. According to the City’s General Plan, a high fire hazard zone occurs in Watsonville approximately five miles west of the project site in a wildland-dominated area. The project area is industrial and urban, and the impact would be less than significant.
c. Less than Significant Impact. The project site is located in a developed industrial area that is equipped with emergency water sources and power lines that conform with City standards. The proposed project involves the installation of driveway approaches and internal aisles for ingress and egress to and from existing public rights-of-way. The existing transmission lines located along publicly accessible roads would continue to be maintained by PG&E. The impact would be less than significant.
Attachment 2.9
120 | City of Watsonville
While the use of construction equipment for installation, maintenance, and improvements could temporarily increase fire risk on the property, compliance with all applicable code standards, including but not limited to City Construction Grading and Drainage Ordinance and City Fire Safety Ordinance requirements, would ensure that impacts would be less than significant. d. Less than Significant Impact. The project is relatively flat and not located in a high fire severity zone. The project would not exacerbate wildfire risk. The impact would be less than significant.
References:
CalFire, 2022 Fire Hazard Severity Zone Viewer. Available at: https://egis.fire.ca.gov/FHSZ/ (Accessed February 15, 2022)
Watsonville Fire Safety Code. Title 8, Chapter 9. Available at:
https://www.codepublishing.com/CA/Watsonville/html/Watsonville08/Watsonville0809.html (Accessed January 20, 2022)
Watsonville Construction Grading and Drainage Ordinance. January 14, 2014. Available at:
https://www.cityofwatsonville.org/DocumentCenter/View/2684/Stormwater-Post-ConstructionStandards-PDF?bidId= (Accessed January 21, 2022) Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 121
6.21 Mandatory Findings of Significance
Summary of Impacts
Potentially
Significant
Impact
Less than
Significant With
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
a) Does the project have the potential to substantially degrade the quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self-sustaining levels, threaten to eliminate a plant or animal community, substantially
reduce the number or restrict the range of a rare or
endangered plant or animal or eliminate important
examples of the major periods of California history or
prehistory?
b) Does the project have impacts that are individually limited, but cumulatively considerable? (“Cumulatively
considerable” means that the incremental effects of a
project are considerable when viewed in connection with the effects of past projects, the effects of other projects, and the effects of probable future projects.)
c) Does the project have environmental effects which will cause substantial adverse effects on human beings, either directly or indirectly?
Conclusion: The proposed project would not result in any significant environmental impacts after mitigation.
Documentation:
a. Less than significant with mitigation incorporated. The project would be built on an industrial area. Potential cumulative impacts on fish and wildlife species would be less than significant with incorporation of Mitigation Measures BIO‐1 and BIO-2.
The project site is not known to have any association with an important example of California’s history or prehistory. Construction‐phase procedures would be implemented in the event any archaeological or paleontological resources are discovered during grading and excavation, as described in Mitigation Measures CUL‐1 and CUL‐2. Implementation of these mitigation measures would reduce impacts related to cultural resources to a less than significant level. b. Less than Significant Impact. Cumulative impacts can result from the interactions of environmental changes resulting from one proposed project with changes resulting from other past, present, and future projects that affect the same resources, utilities and infrastructure systems, public services, transportation networks, air basin, watershed, or other physical conditions. Such impacts could be short‐term and temporary, usually consisting of overlapping construction impacts, as well as longterm, due to the permanent land use changes involved in a project.
Attachment 2.9
122 | City of Watsonville
Short‐term impacts related to noise and pollutant emissions would be at less than significant levels and therefore would not contribute substantially to any other concurrent construction programs that may be occurring in the vicinity. The project’s contribution to long‐term, cumulative impacts would not be significant. In particular, the project is subject to development impact fees and property taxes to offset project related impacts to public services and utility systems such as fire protection services, traffic control and roadways, storm drain facilities, water and wastewater facilities, and other public facilities and equipment. The impacts would be less than significant. No substantial impact on scenic vistas, scenic resources, or the visual character of the area, or from light and glare, would result, as discussed in Section 6.1.
c. Less than Significant Impact. Potential impacts were analyzed in Sections 6.1 thru 6.20, and no evidence is presented that this project would degrade the quality of the environment. The City hereby finds that, with implementation of the incorporated mitigation measures listed in this IS/MND, there would be no substantial, adverse impacts on human beings, directly, or indirectly, with mitigation incorporated.
References:
Identified in individual sections of this document.
Attachment 2.9
Crocker’s Lockers Self-Storage Project IS/MND | 123
7. Lead Agency and Consultants
Lead Agency:
City of Watsonville
Community Development Department
Planning Division
250 Main Street
Watsonville, California 95076
Justin Meek, AICP, Principal Planner
Consultants:
MIG, Inc.
800 Hearst Avenue
Berkeley, California 94710
W-Trans
505 17th Street, 2nd Floor
Oakland, California, 94612
Attachment 2.9
Response to Comments on the 70 Nielson Street
Crockers Lockers Project
Initial Study/Mitigated Negative Declaration
SCH No. 2022070219
Prepared for:
City of Watsonville
Department of Community Development
250 Main Street
Watsonville, CA 95076
Prepared by:
MIG, Inc.
800 Hearst Ave
Berkeley, CA 94710
October 2022
Attachment 2.10
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Attachment 2.10
The City received two Comment letters on the 70 Nielson Street – Crockers Lockers Initial Study and Mitigated Negative Declaration (IS/MND) during the 30-day public review period, which ended on August 13, 2022, and was extended to August 26, 2022. The Commenters are listed below. William P. Parkin, of WITTWER PARKIN LLP representing the Watsonville Pilots Association (“WPA”)
Erin Chappell, Regional Manager, Bay Delta Region with the CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE (“CDFW”)
The written response to the two Comment letters is attached. The Comment letter is included first and the response is provided after. The Errata for the Initial Study/Mitigated Negative Declaration follows each section.
Attachment 2.10
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Attachment 2.10
WPA COMMENT LETTER
Wittwer Parkin LLP
Representing the Watsonville Pilots Association (“WPA”) August 12, 2022
70 Nielson Street
Crockers Lockers Project
City of Watsonville, California
Attachment 2.10
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Attachment 2.10
August 12, 2022
VIA EMAIL
Justin Meek, AICP
Principal Planner
City of Watsonville
Community Development Department
Planning Division
250 Main Street
Watsonville, California 95076
[email protected]
Re: Comment on Mitigated Negative Declaration for
Crocker’s Lockers Self-Storage Project—70 Nielson Street (APN 015-111-49) Dear Mr. Meek:
This law firm represents the Watsonville Pilots Association (“WPA”), one of the prevailing parties in Watsonville Pilots Association, et al. v. City of Watsonville (2010) 183 Cal.App.4th 1059 (WPA I). WPA is dedicated to protecting the safety of pilots and members of the public on the ground in and around the Watsonville Airport. WPA objects to the proposed construction of the Crocker’s Lockers Self Storage project, which involves the development of six self-storage buildings, four of which would be single-story and two of which would be twostory, and a seventh two-story building, which would be a manager’s building (“Project”). The Mitigated Negative Declaration (“MND”) that has been prepared for this Project is inadequate as a matter of law, as it essentially ignores the Project’s impacts on the Watsonville Airport and the airport safety zones. In addition, this letter is to remind the City that it does not currently have the authority to issue permits for this application as the City’s General Plan does not yet comply with the Public Utilities Code as required by WPA I. Therefore, the Project must be denied.
I. Preparation of an Environmental Impact Report is Required for this Project As an initial and foremost matter, courts review negative declarations favorably to challengers. Because the City has only prepared a negative declaration for the Project, rather than an EIR, WPA need only make a “fair argument” that the Project causes a significant environmental impact. Courts have firmly established that the fair argument standard is a “low threshold test.” The Pocket Protectors v. City of Sacramento (“Pocket Protectors”) (2004) 124 Cal.App.4th 903, 928; No Oil Inc. v. City of Los Angeles (1974) 13 Cal.3d 68, 86; Laurel Heights Improvement Association v. Regents of the University of California (1993) 6 Cal.4th 1112, 1123- 1126. John R. Lawson Rock & Oil, Inc. v. State Air Resources Bd. (2018) 20 Cal.App.5th 77, 108- 109. “There is ‘a low threshold requirement for preparation of an EIR’, and a ‘preference for resolving doubts in favor of environmental review.’” Mejia v. City of Los Angeles (2005) 130 Attachment 2.10
page 7 of 36
WPA
Comment 1.1 Page 698 of 965
Justin Meek
Re: Crocker’s Locker Self-Storage
August 12, 2022
Cal.App.4th 322, 332. “With certain limited exceptions, a public agency must prepare an EIR whenever substantial evidence supports a fair argument that a proposed project ‘may have a significant effect on the environment.’” Protect Niles v. City of Fremont (2018) 25 Cal.App.5th 1129, 1138-1139. Whether the administrative record contains “substantial evidence” in support of a “fair argument” sufficient to trigger a mandatory EIR is a question of law, not a question of fact. League for Protection of Oakland’s Architectural and Historic Resources v. City of Oakland (1997) 52 Cal.App.4th 896, 905; Architectural Heritage Association v. County of Monterey (2004) 122 Cal.App.4th 1095, 1122 (overruled in part on other grounds in Friends of Willow Glen Trestle v. City of San Jose (2016) 2 Cal.App.5th 457, 460). Therefore, under the fair argument standard, “deference to the agency’s determination is not appropriate and its decision not to require an EIR can be upheld only when there is no credible evidence to the contrary.” Sierra Club v. County of Sonoma (1992) 6 Cal App 4th 1307, 1318; see also, Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144; Quail Botanical Gardens v. City of Encinitas (1994) 29 Cal.App.4th 1597 (rejecting an approval of a negative declaration prepared for a golf course holding that “[a]pplication of [the fair argument] standard is a question of law and deference to the agency’s determination is not appropriate.”) Evidence supporting a fair argument need not be overwhelming, overpowering or uncontradicted. Friends of the Old Trees v. Department of Forestry and Fire Protection (1997) 52 Cal.App.4th 1383, 1402. Instead, substantial evidence to support a fair argument simply means “information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached.” 14 Cal.
Code Regs. § 15384; Pocket Protectors, supra 124 Cal.App.4th at 927-928; League for Protection of Oakland’s Architectural and Historic Resources v. City of Oakland, supra, 52 Cal.App.4th at 905.
A negative declaration is proper “only if project revisions would avoid or mitigate the potentially significant effects identified in an initial study ‘to a point where clearly no significant effect on the environment would occur, and ... there is no substantial evidence in light of the whole record before the public agency that the project, as revised, may have a significant effect on the environment.’” Mejia v. City of Los Angeles, supra, 130 Cal.App.4th at 331. Here, the MND is an inadequate environmental document because it fails to sufficiently analyze airportrelated safety and noise impacts as required by CEQA. A “negative declaration is inappropriate where the agency has failed either to provide an accurate project description or to gather information and undertake an adequate environmental analysis.” City of Redlands v. County of San Bernardino (2002) 96 Cal.App.4th 398, 406. As a result, the MND fails to provide the public and the decisionmakers adequate information regarding the Project’s potential environmental impacts. Thus, an EIR must be prepared. Cleveland National Forest Foundation v. San Diego Assn. of Governments (2017) 3 Cal.5th 497, 503.
Attachment 2.10
page 8 of 36
WPA
Comment 1.1 Page 699 of 965
Justin Meek
Re: Crocker’s Locker Self-Storage
August 12, 2022
II. The Mitigated Negative Declaration Fails to Adequately Analyze AirportRelated Impacts The Mitigated Negative Declaration states that the Project is located within two miles of the Watsonville Municipal Airport and is within Watsonville Municipal Airport Safety Zones 2, 5, and 6. (MND, p. 69.) However, despite this acknowledgement, the Mitigated Negative Declaration glosses over the actual risk levels associated with the Project’s location within these safety zones.
As the California Airport Land Use Planning Handbook (“Handbook”) states that “Maintaining a high degree of safety as lands near airports are developed is clearly an important planning objective.” (Handbook, Appendix F, p. F-1.) Furthermore, While measurement of risks provides essential input to the making of public policy, it is not the only consideration. In our society, decisions about how to respond to many risks—particularly ones affecting many people or whole communities—are not the sole purview of experts. Moreover, such decisions are not based simply on technical analyses and data. The public’s perception of risks plays a major role as well. Perception is a key component in any assessment of societal risk.
(Handbook, Appendix F, p. F-3.) However, the MND fails to truly analyze the levels of risks posed by the Project’s proximity to the Watsonville Airport. “Ultimately, the decisions we—as individuals or as a society—make in response to hazards come down to a question of our tolerance for or acceptance of the risks which are known or believed to be involved.” (Handbook, Appendix F, p. F-6.) Therefore, without such information it is impossible to know the risks that are being accepted, thus thwarting the central purpose of CEQA: “The ultimate inquiry, as case law and the CEQA guidelines make clear, is whether the EIR includes enough detail ‘to enable those who did not participate in its preparation to understand and to consider meaningfully the issues raised by the proposed project.’” Sierra Club v. County of Fresno (2018) 6 Cal.5th 502, 515.
The MND fails to acknowledge that the Handbook concludes that the risk level is “High” in Safety Zone 2. Moreover, the Handbook states that “Multi-story uses” should be avoided in Safety Zone 2. The Project will include at least one two-story building in Safety Zone 2.
Furthermore, the MND takes liberties with the intensity limitations in the Handbook.
The MND concludes that “The Handbook states that most non-residential buildings are not fully occupied at all times. Therefore, the Handbook allows for reducing the total occupancy using these codes by a set factor, 50% for most uses.” (MND, p. 70-71.) This is an overstatement.
The Handbook actually limits the 50% reduction to retail and office uses. (Handbook, p. G-1.) The Project is neither a retail nor an office use. Therefore, the MND’s assumptions are incorrect.
Attachment 2.10
page 9 of 36
WPA
Comment 1.2
WPA
Comment 1.3
WPA
Comment 1.4
WPA
Comment 1.5 Page 700 of 965
Justin Meek
Re: Crocker’s Locker Self-Storage
August 12, 2022
In addition, the MND does not apply the strictest standards in the Handbook for occupancy levels. Each of the Handbook intensity limitations listed in Table 9 of the MND use the upper limit in each safety zone as stated in the Handbook. However, since Santa Cruz County is a no procedure county, the strictest standards must be applied. For instance, in Safety Zone 2, the Maximum Single Acre intensity is 50-80 people per gross acre. Table 9 uses 80 people, when the lower limit is 50 people. If the lower limit is used, then the project violates the handbook standard since Table 9 admits that in Safety Zone 2 the occupancy is 73 people per gross acre using the more conservative California Building Code standard, which must be used by the City of Watsonville here. Moreover, there is no explanation of why the MND uses the Maximum Single Acre intensity instead of the more restrictive Maximum Nonresidential Intensity with respect to the California Building Code calculations since the nonresidential intensity is stricter. Under the Maximum Nonresidential Intensity, the number of persons per gross acre is limited to 10 people.1
The MND’s discussion of potential safety hazards is not only cursory, but also entirely flawed because the City has not yet incorporated the Handbook into its General Plan, as required by the State Aeronautic Act and the holding in WPA I. The court in Resource Defense Fund v.
County of Santa Cruz (1982) 133 Cal.App.3d 800, 806, held that “[s]ince consistency with the general plan is required, absence of a valid general plan, or valid relevant [] elements or components thereof, precludes enactment of zoning ordinances and the like.” Thus, without a valid general plan, the City cannot conclude the Project complies with the State Aeronautics Act and the Handbook. Therefore, a fair argument exists that the Project will create a significant impact.
It also comes as no surprise that the Handbook points out “Noise is sometimes perceived to be the most significant concern generated by aircraft operations, and it can be audible for miles from an airport.” (Handbook, p. xi.) Therefore, “With regard to noise and overflight, the goal of airport compatibility planning is to reduce annoyance and to minimize the number of people exposed to excessive levels of aircraft noise.” (Handbook, p. xi.) The noise and overflight analysis must be done in accordance with the Handbook, which the MND does not dutifully follow.
The Mitigated Negative Declaration makes the following conclusions in its noise analysis:
1 The range in Safety Zone 2 is 10-40 acres per gross acre in the Handbook. But again, the City must employ the strictest standard.
Attachment 2.10
page 10 of 36
WPA
Comment 1.5
WPA
Comment 1.6
WPA
Comment 1.7
WPA
Comment 1.8 Page 701 of 965
Justin Meek
Re: Crocker’s Locker Self-Storage
August 12, 2022
(MND, p. 88.) As shown in the above table, “Maximum measured noise levels at both ST-1 (85.3 dBA Lmax) and ST-2 (82.7 dBA Lmax) were associated with aircraft approaches into Watsonville airport.” (MND, p. 33.)
While the MND states that the average noise levels at each site were under 70 dBA, the maximum noise levels at each site were over 80 dBA. Furthermore, the MND merely measures the noise levels at the Project site for 30 minutes on a Wednesday. Choosing this short amount of time on a weekday is not an accurate reflection of the actual average anticipated noise levels of the Project site. Moreover, while the MND discloses a noise level average, it does not disclose the frequency at which the Project site experienced noise levels above 75 dBA.
Alarmingly, the Handbook states that exposure to noise levels at and above 75dBA can begin to cause hearing loss to occur. (Handbook, p. D-34.) This exposure understandably elicits a “very severe” average community reaction, and the general community attitude that “noise is likely to be the most important of all adverse aspects of the community environment.” (Handbook, Appendix D, p. D-34.) Therefore, a fair argument can be made that the Project will create a significant impact.
III. The City Cannot Issue Land Use Approvals because the General Plan is Noncompliant with the State Aeronautics Act
The City cannot approve the Project, which is within Airport Safety Zones, because the City’s General Plan violates the State Aeronautics Act. The City must update its General Plan to comply with the Public Utilities Code before it can approve this Project.
The Public Utilities Code outlines requirements for the “orderly expansion of airports and the adoption of land use measures that minimize the public’s exposure to excessive noise and safety hazards within areas around public airports to the extent that these areas are already not devoted to incompatible uses.” Pub. Util. Code § 21670(a)(2). In 2006, WPA filed a petition for writ of mandate challenging the City’s adoption of an updated City General Plan (the 2030 General Plan). (Santa Cruz Superior Court Case No. 154571.) The Santa Cruz Superior Court found that the City had violated both the State Aeronautics Act and the California Environmental WPA
Comment
1.10 Attachment 2.10
page 11 of 36
WPA
Comment 1.9
WPA
Comment 1.10 Page 702 of 965
Justin Meek
Re: Crocker’s Locker Self-Storage
August 12, 2022
Quality Act (CEQA), because, inter alia, the 2030 General Plan unlawfully modified Airport Safety Zone 3 and land use compatibility guidelines, and the EIR inadequately analyzed aviation impacts and traffic impacts and failed to consider a reasonable range of alternatives. The Court of Appeal upheld this judgment in WPA I.
The Court of Appeal explained that the Watsonville Airport is in a “no-procedure” county and that “an affected city in a no-procedure county must ‘accept’ and ‘put into effect’ the Handbook’s criteria by ‘unit[ing]’ the criteria with the city’s general plan, a very strong mandate.” WPA I at 1072. The Court further explained that “what we can glean from the legislative history” of the applicable “1994 amendment of Public Utilities Code Section 21670.1” is “perfectly consistent with requiring an affected city in a no-procedure county to adopt all of the Handbook’s criteria and inconsistent with allowing such city to choose to adopt only some of those criteria.” WPA I at 1073.
The Court of Appeal also stated that the City’s contention “lacks merit” when it claimed that “the Legislature did not intend to mandate that an affected city in a no-procedure county adopt the specific criteria in the Handbook but intended to require only that such a city adopt some subset of those criteria.” Id. The Court also explicitly rejected the City’s claim that “the contours of the[] zones and the nature of the compatibility criteria [both of which ‘chapter 9 of the Handbook contains’] are left to the discretion of the local agency because the criteria ‘depend on each locality’s answer to the basic questions’ about how much risk it is willing to accept [Italics added by Court.],” holding that “[t]his claim directly conflicts with the Legislature’s intent in enacting the 1994 legislation.” WPA I at 1076. The Court further stated that “it would defy the Legislature’s intent to conclude that the City has discretion to modify the criteria to suit itself based on the City’s own determination.” WPA I at 1077.
The Project cannot be approved until the City has converted the Handbook into mandatory provisions in its General Plan. State law establishes Airport Safety Zones around airports and makes compliance mandatory as to the Watsonville Airport. The WPA has successfully defended these mandatory Airport Safety Zones in Court twice to date: in WPA I and in Watsonville Pilots Association v. City of Watsonville, Case No. CV176416 (“WPA II”) where the Superior Court found that a revised 2030 General Plan again violated the Aeronautics Act because, among other reasons, it granted the City discretion in a no procedure county.
In fact, the City itself has admitted the lack of incorporation of the Handbook into the General Plan prohibits the City from approving development within the Airport Safety Zones. As City staff explained in a February 28, 2017, staff report for the Pajaro Valley High School Auditorium Project:
In 2010, the Court of Appeal found that the City did not comply with the SAA, because it did not include the Handbook compatibility standards in its general plan. (Watsonville Pilots Ass’n v. City of Watsonville (2010) 183 Cal.App.4th 1059, 1079.) Santa Cruz County has been identified as being a “no procedures county.” (Handbook, p. 1-4.) This means that the County has not: (1) established an Airport Land Use Commission (ALUC) Attachment 2.10
page 12 of 36
WPA
Comment 1.10 Page 703 of 965
Justin Meek
Re: Crocker’s Locker Self-Storage
August 12, 2022