Watsonville City Council
October 10, 2023

Executive Summary
Draft Environmental Impact Report ES-17
Impact Mitigation Measure (s) Residual Impact
impacted wastes, and reduce hazards to construction
workers and offsite receptors during construction. The
plan shall be submitted to the lead agency and must
establish remedial measures and/or soil management
practices to ensure construction worker safety, the health of future workers and visitors, and the off-site migration of contaminants from the site. These measures and
practices may include, but are not limited to:
 Stockpile management including stormwater pollution
prevention and the installation of BMPs
 Proper disposal procedures of contaminated materials
 Monitoring and reporting
 A health and safety plan for contractors working at the site that addresses the safety and health hazards of
each phase of site construction activities with the
requirements and procedures for employee protection
 The health and safety plan shall also outline proper
soil handling procedures and health and safety
requirements to minimize worker and public exposure
to hazardous materials during construction.

The lead agency shall review and approve the
development site Soil Management Plan for Impacted
Soils prior to demolition and grading (construction).

Soil Remediation Requirements: If soil present within the construction envelope at the development site contains
chemicals at concentrations exceeding hazardous waste
screening thresholds for contaminants in soil (California Code of Regulations [CCR] Title 22, Section 66261.24), the project proponent shall retain a qualified environmental consultant (PG or PE), to conduct additional analytical testing and recommend soil disposal recommendations,
or consider other remedial engineering controls, as
necessary.

The qualified environmental consultant shall utilize the development site analytical results for waste
characterization purposes prior to offsite transportation or disposal of potentially impacted soils or other impacted wastes. The qualified environmental consultant shall
provide disposal recommendations and arrange for
proper disposal of the waste soils or other impacted
wastes (as necessary), and/or provide recommendations
for remedial engineering controls, if appropriate.

Remediation of impacted soils and/or implementation of
remedial engineering controls, may require additional
delineation of impacts; additional analytical testing per landfill or recycling facility requirements; soil excavation; and offsite disposal or recycling.

The City shall review and approve the development site
disposal recommendations prior to transportation of
waste soils offsite and review and approve remedial
engineering controls, prior to construction.

HAZ-1(b) Phase I/II Environmental Site Assessment. If
groundwater is encountered during construction on
properties included on a list compiled pursuant to
Exhibit B
61 of 343

City of Watsonville
Downtown Watsonville Specific Plan
ES-18
Impact Mitigation Measure (s) Residual Impact
Government Code Section 65962.5 or through a Phase I or Phase II ESA pursuant to Mitigation Measure HAZ-1, an
Environmental Professional shall be called to the site to determine safe handling procedures. The groundwater
shall be pumped into appropriate containers and samples shall be obtained for chemical analysis of the
Contaminants of Potential Concern in accordance with the requirements of the waste disposal facility to which the material would be sent. If water sample analytical results indicate the water is free of all detectable concentrations of Contaminants of Potential Concern, such water can be re-used at the site if deemed appropriate by the RWQCB.

If water sample analytical results indicate the water
contains concentrations of Contaminants of Potential
Concern above appropriate RWQCB screening levels, such
water shall not be re-used at the site. The contractor and the Environmental Professional shall elect to: (a) treat the groundwater onsite to render it free of detectable
concentrations of Contaminants of Potential Concern
(e.g., by activated carbon filtration); or, (b) transport the groundwater to a local treatment or disposal facility for appropriate handling.

Noise
Impact NOI-1. Construction of
development envisioned by the
DWSP would temporarily increase
noise levels at nearby noise-sensitive
receptors. Operation of development
envisioned by the DWSP would
introduce new onsite noise sources
and contribute to increases in traffic
noise. Construction and onsite
operational noise could exceed
standards. This impact would be
significant and unavoidable even with
mitigation.

NOI-1(a) Conduct Construction Noise Analysis. The City
shall require future projects that are subject to
discretionary approval and that are not found to be
exempt from CEQA review to evaluate potential
construction noise impacts on nearby sensitive uses as
part of project-level CEQA analysis and implement
respective mitigation measures to minimize impacts on
these uses. Examples of mitigation measures to reduce
construction noise include, but are not limited to:
 Mufflers. During excavation and grading construction
phases, construction equipment, fixed or mobile, shall
be operated with closed engine doors and shall be
equipped with properly operating and maintained
mufflers consistent with manufacturers’ standards.
 Stationary Equipment. Stationary construction
equipment shall be placed so that emitted noise is
directed away from the nearest sensitive receptors.
 Equipment Staging Areas. Equipment staging shall be
located in areas that will create the greatest distance feasible between construction-related noise sources
and noise-sensitive receptors.
 Electrically-Powered Tools and Facilities. Electrical power shall be used to run air compressors and similar
power tools and to power any temporary structures,
such as construction trailers or caretaker facilities.
 Smart Back-up Alarms. Mobile construction
equipment shall have smart back-up alarms that
automatically adjust the sound level of the alarm in
response to ambient noise levels. Alternatively, backup alarms shall be disabled and replaced with human Significant and
unavoidable.

Exhibit B
62 of 343

Executive Summary
Draft Environmental Impact Report ES-19
Impact Mitigation Measure (s) Residual Impact
spotters to ensure safety when mobile construction
equipment is moving in the reverse direction.
 Signage. For the duration of construction, the
applicant or contractor shall post a sign in a
construction zone that includes contact information
for individuals who desire to file a noise complaint.
 Temporary Noise Barriers. Where necessary to meet
the FTA criterion of 80 dBA Leq(8 Hr) for daytime
construction affecting residential uses, erect
temporary noise barriers at a height of 12 feet
minimum to block the line-of-sight between
construction equipment and receptors. Barriers shall
be constructed with a solid material that has a density of at least 1.5 pounds per square foot with no gaps
from the ground to the top of the barrier.
 Noise Disturbance Coordinator. The project applicant
shall designate a “noise disturbance coordinator”
responsible for responding to any local complaints
about construction noise. The disturbance coordinator
shall determine the cause of any noise complaint (e.g., starting too early, bad muffler, etc.) and shall require that reasonable measures be implemented to correct
the problem. A telephone number for the disturbance
coordinator shall be posted at the construction site.

The City shall confirm that these measures are
implemented during construction by monitoring the
project at least once per month.

NOI-1(b) Conduct Stationary Operational Noise Analysis.

The City shall require future development projects that are subject to discretionary approval to evaluate potential onsite operational noise impacts as part of project-level CEQA analysis on nearby noise-sensitive uses and to
implement any required mitigation measures to minimize
impacts on these uses. Examples of mitigation measures
to reduce onsite noise include, but are not limited to, operational restrictions, selection of quiet equipment, equipment setbacks, enclosures, silencers, and/or
acoustical louvers. The effectiveness of noise reducing measures shall be monitored to confirm effectiveness.

Impact NOI-2. Construction of
development envisioned by the
DWSP would temporarily generate
groundborne vibration. If required for
construction, pile driving or use of a
vibratory roller could potentially
exceed FTA vibration thresholds and
impact people or buildings. This
impact would be significant and
unavoidable even with mitigation.

NOI-2 Vibration Control Plan. Based on the attenuation
distances of vibration from standard construction
equipment, prior to issuance of a building permit for a project requiring pile driving during construction within 135 feet of fragile structures such as historical resources, 100 feet of non-engineered timber and masonry buildings (e.g., most residential buildings), or within 75 feet of engineered concrete and masonry (no plaster); a vibratory roller within 25 feet of any structure; or a dozer or other heavy earthmoving equipment within 15 feet of any
structure, the project applicant shall prepare a vibration analysis to assess and mitigate potential vibration impacts related to these activities. This vibration analysis shall be conducted by a qualified and experienced acoustical
consultant or engineer. The vibration levels shall not
exceed FTA architectural damage thresholds (e.g., 0.12
Significant and
unavoidable.

Exhibit B
63 of 343

City of Watsonville
Downtown Watsonville Specific Plan
ES-20
Impact Mitigation Measure (s) Residual Impact
in/sec PPV for fragile or historical resources, 0.2 in/sec PPV for non-engineered timber and masonry buildings,
and 0.3 in/sec PPV for engineered concrete and masonry).

If vibration levels would exceed this threshold, alternative uses such as drilling piles as opposed to pile driving, static rollers as opposed to vibratory rollers, and lower
horsepower dozers shall be used. If necessary,
construction vibration monitoring shall be conducted to ensure vibration thresholds are not exceeded.

Where vibration monitoring is determined to be
necessary, a pre-construction baseline survey shall be
conducted at buildings and structures within the
screening distances by a licensed structural engineer. The condition of existing potentially affected properties shall be documented by photos and description of existing
condition of building facades, noting existing cracks. A vibration monitoring and construction contingency plan
shall be developed to identify where monitoring would be conducted, set up a vibration monitoring schedule, and
define structure-specific vibration limits. Construction contingencies would be identified for when vibration
levels approach the limits. If vibration levels approach limits, the contractor shall suspend construction and
implement contingencies to either lower vibration levels or secure the affected structure.

Where historic structures are involved, the engineer shall provide a shoring design or other methods to protect such buildings and structures from potential damage. At the
conclusion of vibration causing activities, the qualified structural engineer hired by the applicant shall issue a follow-up letter describing damage, if any, to impacted buildings. The letter shall include recommendations for repair, as may be necessary, in conformance with the
Secretary of the Interior Standards. Repairs shall be
undertaken and completed by the contractor and
monitored by a qualified structural engineer in
conformance with all applicable codes including the
California Historical Building Code (Part 8 of Title 24).

A Statement of Compliance signed by the applicant and
owner is required to be submitted to the City of
Watsonville Building Division at plan check and prior to the issuance of any permit. The Vibration Control Plan, prepared as outlined above, shall be documented by a
qualified structural engineer, and shall be provided to the City upon request. A Preservation Director shall be
designated, and this person’s contact information shall be posted in a location near the project site that is clearly visible to the nearby receptors most likely to be disturbed.

The Director would manage complaints and concerns
resulting from activities that cause vibrations. The severity of the vibration concern should be assessed by the
Director, and if necessary, evaluated by a qualified noise and vibration control consultant.

Exhibit B
64 of 343

Executive Summary
Draft Environmental Impact Report ES-21
Impact Mitigation Measure (s) Residual Impact
Impact NOI-C1. The construction
activities for the development
envisioned in the DWSP would have a
cumulatively considerable
contribution toward a significant
cumulative impact on noise.

Implementation of mitigation measures NOI-1(a), NOI1(b) is required.Significant and unavoidable.

Population and Housing
Impact POP-1. The DWSP is a plan for
population growth in the downtown
area of Watsonville. Therefore, the
project would not induce unplanned
population growth, and impacts
would be less than significant.

No mitigation is required. Less than
significant.

Transportation
Impact TRA-1. The DWSP would not
conflict with a program, plan,
ordinance or policy addressing the
circulation system, including transit,
roadway, bicycle and pedestrian
facilities such that substantial
physical environmental effects would
occur. Impacts would be less than
significant.

No mitigation is required. Less than
significant.

Impact TRA-2. Development
envisioned in the DWSP would
conflict with or be inconsistent with
CEQA Guidelines Section 15064.3,
subdivision (b). Impacts would be
significant and unavoidable.

TRA-1 Transportation Demand Management Program.

Each individual office and industrial development project in the DWSP plan area shall have a corresponding
transportation demand management (TDM) plan and
monitoring program developed by the applicant or
developer of the project. This plan shall identify the TDM reductions specific to their project. The monitoring
program shall establish goals and policies to ensure the efficient implementation of the TDM plan and
demonstrate its effectiveness at reducing VMT such that VMT is below the significance thresholds presented in
Table 4.8-2, above. Examples of TDM measures that could be employed, depending on specific project conditions
and circumstances, include reduced parking supply, new
transit stops, emergency ride home programs, bike-share programs, and traffic calming improvements.

Significant and
unavoidable.

Impact TRA-C1. The DWSP would
have a cumulatively considerable
contribution to a significant
cumulative VMT impact related to a
conflict or inconsistency with CEQA
Guidelines section 15064.3,
subdivision (b).

Implementation of mitigation measure TRA-1 is required. Significant and unavoidable.

Exhibit B
65 of 343

City of Watsonville
Downtown Watsonville Specific Plan
ES-22
Impact Mitigation Measure (s) Residual Impact
Tribal Cultural Resources
Impact TCR-1. Development
envisioned in the DWSP would have
the potential to adversely change
tribal cultural resources.

Implementation of Mitigation
Measure TCR-1 would reduce the
impact to less than significant.

TCR-1 Suspension of Work In The Area of Potential Tribal Cultural Resources. In the event that potential tribal
cultural resources, such as archaeological resources of Native American origin or tribal traditional tangible spaces or artifacts (historic-era and pre-contact era), are
identified during implementation of a development
project within the DWSP plan area, onsite project
activities within 50 feet of the find shall be temporarily suspended or redirected until either an archaeologist has evaluated the nature and significance of the find (if
archaeological) as a pre-contact or Native Americanassociated resource and an appropriate local Native American representative is consulted, or an appropriate local Native American representative is consulted
regarding the significance of the resource (if not
archaeological). If the City of Watsonville, in consultation with local Native Americans, determines that the resource is a tribal cultural resource and thus significant under CEQA, a mitigation plan shall be prepared and
implemented for the specific development project in
accordance with state guidelines and in consultation with local Native American group(s). The plan shall include
avoidance of the resource or, if avoidance of the resource is infeasible, the plan shall outline the appropriate
treatment of the resource in coordination with the
appropriate local Native American tribal representative and, if applicable, a qualified archaeologist. Examples of appropriate mitigation for tribal cultural resources
include, but are not limited to, protecting the cultural character and integrity of the resource, protecting
traditional use of the resource, protecting the
confidentiality of the resource or providing Tribal cultural sensitivity training about the resource to applicable City staff if it will be managed, appropriate public outreach regarding the resource, or heritage recovery (recovering items of tribal cultural heritage according to established tribal customs).

Less than
significant.

Exhibit B
66 of 343

Introduction
Draft Environmental Impact Report 1-1
Introduction
This document is an Environmental Impact Report (EIR) for the proposed Downtown Watsonville Specific Plan (DWSP). The City of Watsonville, as the Lead Agency, has prepared this EIR in compliance with the California Environmental Quality Act (CEQA) and the State CEQA Guidelines.

This section discusses: (1) EIR background; (2) project history; (3) the legal basis for preparing an EIR; (4) the scope and content of the EIR; (5) issue areas determined not to be significant; (6) the lead, responsible, and trustee agencies; and (7) the environmental review process required pursuant to CEQA. The proposed project, which is the DWSP, is described in detail in Section 2, Project Description.

1.1 Environmental Impact Report Background
The City of Watsonville distributed a Notice of Preparation (NOP) of the EIR and the Initial Study for a 30-day agency and public review period starting on October 27, 2022 and ending on November 25, 2022. Although the public review period ended on November 25, the City chose to accept comments submitted as late as November 29 due to November 25 being the day after Thanksgiving holiday. The City received letters from four agencies in response to the NOP. The NOP and the responses received are presented in Appendix A of this EIR. Table 1-1 summarizes the content of the letters and where the issues raised are addressed in the EIR.

Table 1-1 NOP Comments and EIR Response
Commenter Comment/Request (Summarized) How and Where it was Addressed California Department of Fish and Wildlife (CDFW)
Erin Chappell CDFW is a responsible agency if the project requires a discretionary approval by CDFW,
and a trustee agency if the project could
impact fish, wildlife, and/or plants.

Please see Section 1.1, Lead, Responsible, and
Trustee Agencies, for a complete description of
responsible and trustee agencies in context
with the DWSP. As described therein, because
the DWSP is a plan for development and
mobility in Watsonville and does not propose
specific projects requiring permits or approvals
other than adoption of the DWSP, there are no
responsible or trustee agencies.

Erin Chappell Please include a complete description of the project in the EIR.

A complete project description is provided in
Section 2, Project Description, of the EIR.

Erin Chappell Please be advised that a California Endangered Species Act incidental take permit must be
obtained if the project would result in take of
applicable plants or animals.

Please see Section 4.3, Biological Resources, for
a discussion of the California Endangered
Species Act and an assessment of potential
impacts to special-status plant and animal
species.

Erin Chappell The plan area is adjacent to the Pajaro River and impacts to the river or associated riparian
habitat would likely require a Lake and
Streambed Alteration Notification.

Potential impacts to wetlands and other
jurisdictional waters are discussed in Section

4.2, Biological Resources, of the EIR. Likewise,
potential DWSP impacts to riparian habitat are
also discussed in Section 4.2.

Exhibit B
67 of 343

City of Watsonville
Downtown Watsonville Specific Plan
1-2
Commenter Comment/Request (Summarized) How and Where it was Addressed Erin Chappell CDFW has authority over actions impacting migratory birds and their nests, and these birds
and their nests are protected under state and
federal regulations.

Please see Section 4.3, Biological Resources, for
a discussion of potential impacts to specialstatus plant and animal species, including migratory nesting birds.

Erin Chappell Fully protected species may not be taken at any time.

Please see Section 4.3, Biological Resources, for
a discussion of potential impacts to specialstatus plant and animal species, which includes fully protected species.

Erin Chappell CDFW recommends that a site-specific analysis provide baseline habitat assessments for
special-status plant, fish, and wildlife species
located and potentially located within the plan
area and surrounding area. The site-specific
analysis should be prepared by a qualified
biologist and provide sufficient information
regarding the environmental setting
(“baseline”) to understand potentially
significant impacts on the environment
Please see Section 4.3, Biological Resources, for
a discussion of the existing setting and
potential impacts to special-status plant and
animal species. Additionally, a list of the
special-status species with records of
occurrence in or near the plan area and their
potential to occur within or near the plan area
is provided as Appendix C to the EIR.

Erin Chappell A site-specific analysis should discuss all direct and indirect impacts of the DWSP on biological
resources, including reasonably foreseeable
impacts, that may occur with implementation
of the DWSP.

The DWSP articulates a community vision and
planning framework that would serve as a
guide for the City and other public agency
decision-makers, community members, and
stakeholders over the next 20 to 30 years. The
DWSP would provide a comprehensive land
use and mobility plan, along with development
and design regulations, to guide future public
and private development in the downtown
area of Watsonville. The DWSP does not
propose specific projects on specific sites.

Accordingly, potential impacts of the DWSP are
evaluated at a program level throughout this
EIR. Potential impacts to biological resources
are evaluated in both the Initial Study
(Appendix A) and Section 4.3, Biological
Resources.

Erin Chappell The EIR should evaluate cumulative impacts on the DWSP and other reasonably foreseeable
projects on biological resources.

Cumulative impacts of the DWSP on biological
resources are evaluated in Section 4.3,
Biological Resources.

Erin Chappell The EIR should provide enforceable mitigation measures to reduce potentially significant
impacts to biological resources.

Please see Section 4.3, Biological Resources, for
a discussion of the potentially significant
impacts of the DWSP on biological resources
and the mitigation measures to reduce or avoid
those impacts.

Erin Chappell The project has potential to impact riparian zones and riparian setbacks should be provided
in the EIR to avoid or reduce this impact.

Potential impacts to riparian zones and
vegetation are discussed in Section 4.3,
Biological Resources, of the EIR. As described
therein, riparian zones do not occur in the plan
area. No significant impacts to riparian zones
have been identified. Therefore, no mitigation
measures to reduce potentially significant
impacts to riparian zones are required or
necessary.

Exhibit B
68 of 343

Introduction
Draft Environmental Impact Report 1-3
Commenter Comment/Request (Summarized) How and Where it was Addressed Erin Chappell The project would increase impervious surface, which could in turn affect stormwater runoff
and the hydrology of waterways supporting
fish and wildlife. The EIR should mitigate this
impact with low impact development,
bioswales, and providing more permeable
solutions to stormwater on project sites.

Potential impacts to hydrology and stormwater
water runoff, including impacts resulting from
changes in impervious surfaces and
stormwater runoff are analyzed in the Initial
Study (see Appendix A). As described therein,
no significant impacts to drainage patterns or
hydrology and water quality have been
identified. Therefore, no mitigation measures
to reduce potentially significant impacts
related to hydrology and water quality are
necessary or identified in this EIR.

Erin Chappell The project has the potential increase artificial lighting and adversely impact wildlife. CDFW
recommends mitigating this impact by
eliminating artificial lighting, shielding lights,
and limiting times of the day and night lights
are used.

Potential impacts wildlife, including indirect
lighting impacts, are discussed in Section 4.3,
Biological Resources, of the EIR. As described
therein, the City’s municipal code contains
requirements for exterior lighting, which would
reduce lighting impacts of the DWSP, and
impacts would be less than significant.

Therefore, no mitigation measures to reduce
potentially significant impacts related to
lighting on wildlife are necessary or identified
in this EIR.

Erin Chappell The project has the potential increase noise and adversely impact wildlife. CDFW
recommends mitigating this impact by
restricting construction to daylight hours and
protecting birds with nesting bird surveys and
avoidance of identified active nests, as well as
conducting construction outside of the nesting
season.

Please see Section 4.3, Biological Resources, for
a discussion of the potentially significant
impacts of the DWSP on biological resources,
including indirect noise impacts and migratory
nesting bird impacts. Section 4.3 provides
applicable mitigation measures to reduce or
avoid these impacts.

Erin Chappell Please report occurrences of special-status species detected during project surveys to the
CDFW California Natural Diversity Database.

The DWSP articulates a community vision and
planning framework that would serve as a
guide for the City and other public agency
decision-makers, community members, and
stakeholders over the next 20 to 30 years. The
DWSP would provide a comprehensive land
use and mobility plan, along with development
and design regulations, to guide future public
and private development in the downtown
area of Watsonville. The DWSP does not
propose specific projects on specific sites. No
project site surveys are proposed.

Erin Chappell The CDFW filing fees for environmental review are likely required for this EIR.

This comment pertains to a required fee
payment at the time the Notice of
Determination is filed. The Notice of
Determination is only filed after a project is
approved or adopted, which first requires
certification of the EIR. Therefore, because this
comment pertains to requirements occurring
after preparation and certification of the EIR,
this comment does not pertain to the contents
of the EIR.

Exhibit B
69 of 343

City of Watsonville
Downtown Watsonville Specific Plan
1-4
Commenter Comment/Request (Summarized) How and Where it was Addressed California Department of Transportation (Caltrans)
Chris Bjornstad Caltrans supports local development that is consistent with State planning priorities
intended to promote equity, strengthen the
economy, protect the environment, and
promote public health and safety. Projects that
support smart growth principles which include
improvements to pedestrian, bicycle, and
transit infrastructure (or other key
Transportation Demand Strategies) are
supported by Caltrans and are consistent with
our mission, vision, and goals.

This comment explains the types of urban
development preferred by Caltrans. This
comment does not pertain to impacts or
mitigation measures for the DWSP and EIR.

Accordingly, this comment is not evaluated in
the EIR. However, Section 2.5.1, DWSP
Objectives, of the EIR describes objectives of
the DWSP. As described therein, objectives
include concepts listed in this comment, such
as promoting equity in housing and mobility.

Chris Bjornstad The DWSP would help achieve goals of Senate Bill 743.

Potential transportation impacts of the project,
including consistency with SB 743 goals, are
analyzed in Section 4.8, Transportation.

Chris Bjornstad Caltrans looks forward to continuing working with the City of Watsonville on transportation
concepts within state right-of-way. This
includes the feasibility of converting the
existing couplet portion of SR 152 from a oneway street into a two-way street.

This comment describes a desire to continue
working with the City on transportation plans
and improvements within SR 152. Accordingly,
this comment is not evaluated in the EIR.

California Department of Toxic Substances Control
Gavin McCreary A state environmental regulatory agency such as Department of Toxic Substances Control, a
Regional Water Quality Control Board
(RWQCB), or a local agency should provide
regulatory concurrence that project site is safe
for construction and the proposed use.

The DWSP is a plan that envisions the future of
the downtown area of Watsonville. Specific
projects on specific sites are not proposed at
this time. However, a programmatic analysis of
potential impacts related to development
within the plan area in context with hazardous
materials and contamination is provided in
Section 4.5, Hazards and Hazardous Materials.

Gavin McCreary The EIR should acknowledge the potential for historic or future activities on or near the plan
area to result in the release of hazardous
wastes/substances. The EIR should also identify
the mechanism(s) to initiate required
investigation and/or remediation and the
government agency responsible for providing
appropriate regulatory oversight.

Potential impacts of the DWSP related to
hazardous wastes and releases and applicable
mitigation measures are provided in Section

4.5, Hazards and Hazardous Materials.

Gavin McCreary Due to the potential for lead-contaminated soil, soil samples should be collected and
analyzed for lead prior to performing any
intrusive activities for the project described in
the EIR.

The DWSP does not propose specific projects
on specific sites. No project site soil sampling is
proposed at this time. However, potential
impacts of the DWSP related to hazardous
wastes and releases, including through
exposure to contaminated soils, generally, and
applicable mitigation measures to reduce these
impacts are provided in Section 4.5, Hazards
and Hazardous Materials.

Gavin McCreary If buildings or other structures are to be demolished, surveys should be conducted for
the presence of lead-based paints or products,
mercury, asbestos containing materials, and
polychlorinated biphenyl caulk.

Potential impacts related to release of
hazardous materials during potential
demolition are evaluated in Section 4.5,
Hazards and Hazardous Materials.

Exhibit B
70 of 343

Introduction
Draft Environmental Impact Report 1-5
Commenter Comment/Request (Summarized) How and Where it was Addressed Gavin McCreary If any projects initiated as part of the DWSP require the importation of soil to backfill
excavated areas, proper sampling should be
conducted to ensure that the imported soil is
free of contamination.

No specific projects or grading permits are
proposed as part of the DWSP. It is unknown if
soil imports would be required because no
projects have been proposed or designed.

However, potential impacts related to
exposure to hazardous materials, including
soils, and mitigation measures to reduce these
impacts are provided in Section 4.5, Hazards
and Hazardous Materials.

Gavin McCreary If any sites included as part of the proposed project have been used for agricultural, weed
abatement or related activities, proper
investigation for organochlorinated pesticides
should be discussed in the EIR.

The DWSP does not propose specific projects
on specific sites. No project site soil sampling is
proposed because there are no specific project
sites at this time. The plan area is the
urbanized downtown area of Watsonville,
which is developed and not used for
agriculture. Regardless, please see Section 4.5,
Hazards and Hazardous Materials, for
mitigation measures to ensure potentially
contaminated soils in the plan area do not
result in significant impacts.

California Native American Heritage Commission
Cody Campagne The project may require the City to conduct tribal consultation pursuant to either Assembly
Bill (AB) 52 or Senate Bill (SB) 18, or both. The
commenter provides a detailed summary of
how to conduct consultation pursuant to AB 52
and SB 18.

The City has conducted the required tribal
consultation for the DWSP EIR, including both
AB 52 and SB 18 consultation. Please see
Section 4.9, Tribal Cultural Resources, for a
discussion of the consultation that occurred
between the City and applicable tribes or other
Native American representatives.

The City also held a public scoping meeting on November 30, 2022, to hear and collect public input on the contents of the EIR, especially as it relates to impacts and potential mitigation measures or alternatives to reduce impacts. The public scoping meeting was held in virtual format (i.e., online) due to the continued COVID-19 pandemic. No formal comments on the EIR were submitted during the scoping meeting. However, a representative from Pajaro Valley Water Management Agency spoke and indicated their comment was informal. The comment from Pajaro Valley Water Management Agency pertained to water supply and associated groundwater withdrawal as it related to cumulative impacts. Cumulative impacts to water supply as discussed in Section 19, Utilities and Service Systems, of the Initial Study. The Initial Study is included as Appendix A to this EIR.

1.2 Statement of Purpose and Legal Authority
This EIR has been prepared in compliance with the CEQA Statutes and State CEQA Guidelines (see Section 15121(a)). In general, the purpose of an EIR is to:
 Analyze the environmental effects of the adoption and implementation of the project;  Inform decision-makers, responsible and trustee agencies, and members of the public as to the range of the environmental impacts of the project;
 Recommend a set of measures to mitigate significant adverse impacts; and  Analyze a range of reasonable alternatives to the proposed project.

Exhibit B
71 of 343

City of Watsonville
Downtown Watsonville Specific Plan
1-6
As the lead agency for preparing this EIR, the City of Watsonville will rely on the EIR analysis of environmental effects in their review and consideration of the proposed DWSP prior to acting on the project.

This EIR fulfills the requirements for a Program EIR. Although the legally required contents of a Program EIR are the same as those of a Project EIR, Program EIRs are by necessity more general and may contain a more wide-ranging discussion of impacts, alternatives, and mitigation measures than a Project EIR. As provided in Section 15168 of the State CEQA Guidelines, a Program EIR may be prepared on a series of actions that may be characterized as one large project. Use of a Program EIR provides the City of Watsonville in its role as lead agency with the opportunity to consider broad alternatives and program-wide mitigation measures. It also provides the City with greater flexibility to address environmental issues and/or cumulative impacts on a comprehensive basis. Agencies generally prepare Program EIRs for programs or a series of related actions that are linked geographically, are logical parts of a chain of contemplated events, rules, regulations, or plans that govern the conduct of a continuing program, or are individual activities carried out under the same authority and having generally similar environmental effects that can be mitigated in similar ways.

By its nature, a Program EIR considers the broad effects associated with implementing a program (such as a Specific Plan or General Plan) and does not, and is not intended to, examine the specific environmental effects associated with specific projects that may be accommodated by the provisions of Specific or General Plans.

Once a Program EIR has been certified, subsequent activities within the program must be evaluated to determine what, if any, additional CEQA documentation needs to be prepared. Depending on how detailed the Program EIR addresses the program’s effects, subsequent activities may be found to be within the Program EIR scope and additional environmental documentation may not be required or may be minimal (State CEQA Guidelines Section 15168(c)). When a lead agency relies on a Program EIR for a subsequent activity, it must incorporate applicable mitigation measures and alternatives developed in the Program EIR into the subsequent activities (State CEQA Guidelines Section 15168(c)(3)). If a subsequent activity would have effects not contemplated or not within the scope of the Program EIR, the lead agency must prepare a new Initial Study leading to a Negative Declaration, Mitigated Negative Declaration, or a project-level EIR. In this case, the Program EIR still serves a valuable purpose as the first-tier environmental analysis. Section 15168(b) of the State CEQA Guidelines encourages the use of Program EIRs, citing five advantages:

Provision of a more exhaustive consideration of impacts and alternatives than would be practical in an individual EIR;
Focus on cumulative impacts that might be slighted in a case-by-case analysis; Avoidance of continual reconsideration of recurring policy issues; Consideration of broad policy alternatives and programmatic mitigation measures at an early stage when the agency has greater flexibility to deal with them; and Reduction of paperwork by encouraging the reuse of data (through tiering).

As a wide-ranging environmental document, the Program EIR uses expansive thresholds as compared to the project-level thresholds that might be used for an EIR on a specific development project. It should not be assumed that impacts determined not to be significant at a program level would not be significant at a project level. In other words, determination that implementation of the proposed project as a program would not have a significant environmental effect does not necessarily mean that an individual project would not have significant effects based on project-level CEQA thresholds, even if the project is consistent with the DWSP.

Exhibit B
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Introduction
Draft Environmental Impact Report 1-7
This EIR has been prepared to analyze potentially significant environmental impacts associated with future development resulting from implementation of the DWSP, and identifies appropriate and feasible mitigation measures or project alternatives that would minimize or eliminate these impacts.

Additionally, this EIR provides the primary source of environmental information for the City of Watsonville, which is the lead agency, to use when considering the proposed project.

This document is also intended to provide decision-makers and the public with information that enables intelligent consideration of the environmental consequences of the proposed DWSP. It identifies significant or potentially significant environmental effects, as well as ways in which those impacts can be reduced to less-than-significant levels, whether through the imposition of mitigation measures or through the implementation of specific alternatives to the proposed project. In a practical sense, this document functions as a tool for fact-finding, allowing concerned citizens and City staff an opportunity to collectively review and evaluate baseline conditions and project impacts through a process of full disclosure.

1.3 Scope and Content
This EIR incorporates by reference and as inclusion as Appendix A the Initial Study prepared for the proposed project. This EIR addresses and evaluates impacts identified in the Initial Study to be potentially significant. Potentially significant impacts were identified in the following issue areas and are therefore studied in the EIR:
 Aesthetics
 Air Quality
 Biological Resources
 Cultural Resources
 Hazards and Hazardous Materials
 Noise
 Population/Housing
 Transportation
 Tribal Cultural Resources
In preparing the EIR, use was made of pertinent City policies and guidelines, certified EIRs and adopted CEQA documents, and other background documents. A full reference list is contained in Section 7, References.

Section 5, Alternatives, of the EIR was prepared in accordance with Section 15126.6 of the State CEQA Guidelines and focuses on alternatives that can eliminate or reduce significant adverse effects associated with the project while feasibly attaining most of the basic project objectives. In addition, the alternatives section identifies the environmentally superior alternative among the alternatives assessed. The alternatives evaluated include the CEQA-required No Project Alternative and two other alternative scenarios for the plan area.

The level of detail contained throughout this EIR is consistent with the requirements of CEQA and applicable court decisions. Section 15151 of the State CEQA Guidelines provides the standard of adequacy on which this document is based. The State CEQA Guidelines state:

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
1-8
An EIR should be prepared with a sufficient degree of analysis to provide decision-makers with information which enables them to make a decision which intelligently takes account of environmental consequences. An evaluation of the environmental effects of the proposed project need not be exhaustive, but the sufficiency of an EIR is to be reviewed in light of what is reasonably feasible. Disagreement among experts does not make an EIR inadequate, but the EIR should summarize the main points of disagreement among the experts. The courts have looked not for perfection, but for adequacy, completeness, and a good faith effort at full disclosure.

1.4 Issue Areas Determined Not to be Significant
Table 1-2 summarizes the issues from the environmental checklist that were addressed in the Initial Study (Appendix A). As indicated in the Initial Study, there is no substantial evidence that significant impacts would occur in these issue areas.

Table 1-2 Summary of Issue Areas Determined Not to Be Significant Issue Area Initial Study Findings
Aesthetics; CEQA
Checklist Question ‘b’
Because the plan area in not within a state scenic highway, the proposed project would have no impacts to state scenic highways.

Agricultural and
Forestry Resources;
CEQA Checklist
Question ‘a’
The plan area is not zoned for agricultural use and does not contain any Williamson Act lands.

There would be no impacts to agricultural zoning or Williamson Act contracts.

Agricultural and
Forestry Resources;
CEQA Checklist
Question ‘b’
The plan area does not contain Prime Farmland, Unique Farmland, and Farmland of Statewide Importance. There would be no impacts to Farmland.

Agricultural and
Forestry Resources;
CEQA Checklist
Question ‘c’
The plan area is not zoned as forest land, timberland, or timberland production. There would be no impacts on forestry resources or forest land.

Agricultural and
Forestry Resources;
CEQA Checklist
Question ‘d’
The plan area is not zoned for agricultural use, forest land, timberland, or timberland production. Therefore, the proposed project would not result in the conversion of agriculture or timberland property to non-agricultural or non-forest uses.

Biological Resources;
CEQA Checklist
Question ‘f’
There are no adopted Habitat Conservation Plans, Natural Community Conservation Plans, or other approved local, regional, or state habitat conservation plans applicable to the plan area.

The proposed DWSP would have no impacts related to conflicts with these types of plans.

Cultural Resources;
CEQA Checklist
Question ‘b’
Construction of development envisioned in the DWSP would have the potential to impact archaeological resources, if present below ground surface. The combination of mitigation measures CUL-1 through CUL-3 in the Initial Study and compliance with existing regulations would reduce impacts to less than significant.

Cultural Resources;
CEQA Checklist
Question ‘c’
Construction of development envisioned in the DWSP would have the potential to impact unknown human remains, if present below ground surface. Mandatory adherence to state regulations would ensure impacts to human remains, if any, would be less than significant.

Energy; CEQA Checklist
Question ‘a’
Development envisioned in the DWSP would increase energy use on the site compared to existing conditions. However, energy use would be in conformance with the latest version of CALGreen and the Building Energy Efficiency Standards. Moreover, the DWSP envisions placing people and jobs, as well as other commercial uses, in proximity to each other to reduce vehicle trips and associated gasoline consumption. Therefore, the DWSP would not result in wasteful or unnecessary energy consumption, and impacts would be less than significant.

Exhibit B
74 of 343

Introduction
Draft Environmental Impact Report 1-9
Issue Area Initial Study Findings
Energy; CEQA Checklist
Question ‘b’
The plan would not conflict with the energy-related policies of the City’s Climate Action and Adaptation Plan or City’s General Plan, and would also be required to comply with the energy standards in the California Building Energy Efficiency Standards. Therefore, impacts would be less than significant.

Geology and Soils;
CEQA Checklist
Question ‘a’
The plan area is subject to earthquakes and seismic-related hazards, such as strong ground shaking. The City has adopted the California Building Code (CBC) and incorporated it into the Watsonville Municipal Code as Chapter 2 to Title 8, Sections 8-2.01 through 8-2.05. All new development would be constructed compliant to the CBC to reduce the impacts resulting from seismic hazards. Additionally, the City’s Municipal Code requires preparation of project-specific geotechnical investigations, and recommendations in the geotechnical investigation must be incorporated into the project design. Incorporation of geotechnical recommendations would prevent or reduce seismic damage and risks in new development. Impacts would be less than significant.

Geology and Soils;
CEQA Checklist
Question ‘b’
Construction of development envisioned in the DWSP would disturb soils and increase the potential for erosion and loss of topsoil. However, mandatory compliance with the NPDES requires implementation of best management practices to prevent erosion of loss of topsoil from project sites. Impacts would be less than significant.

Geology and Soils;
CEQA Checklist
Question ‘c’
The plan area is not located on a geologic unit or soil that is unstable or would result in landslide, lateral spreading, subsidence, liquefaction, or collapse. However, all new development would be constructed compliant to the CBC to reduce the impacts resulting from seismic hazards. Additionally, the City’s Municipal Code requires preparation of project-specific geotechnical investigations, and recommendations in the geotechnical investigation must be incorporated into the project design. Incorporation of geotechnical recommendations would prevent or reduce seismic damage and risks in new development. Impacts would be less than significant.

Geology and Soils;
CEQA Checklist
Question ‘d’
The plan area is underlain by soils considered not expansive. Impacts related to expansive soils would be less than significant.

Geology and Soils;
CEQA Checklist
Question ‘e’
The plan area is fully served by the City’s sanitary sewer system. Septic tanks or alternative wastewater disposal systems would not be required for new development envisioned in the DWSP. The DWSP would have no impacts related to septic tanks or alternative wastewater disposal systems.

Geology and Soils;
CEQA Checklist
Question ‘f’
Construction of development envisioned in the DWSP could impact subsurface paleontological resources. However, implementation of mitigation measure GEO-1 in the Initial Study would be required. Mitigation measure GEO-1 requires construction to stop if resources are uncovered, and activities near the resource must continue to be stopped until a paleontologist investigates the resources and treated, as applicable. Impacts would be less than significant with implementation of mitigation.

Greenhouse Gas
Emissions; CEQA
Checklist Question ‘a’
The DWSP would be consistent with the Watsonville Climate Action and Adaptation Plan, and accordingly. would not generate greenhouse gas (GHG) emissions that result in significant impacts. Impacts related to GHG would be less than significant.

Greenhouse Gas
Emissions; CEQA
Checklist Question ‘b’
The DWSP would be consistent with policies from the City’s Climate Action and Adaptation Plan, which is a qualified Climate Action Plan. Impacts would be less than significant.

Hazards and Hazardous
Materials; CEQA
Checklist Question ‘a’
Future development envisioned in the DWSP is a mix of industrial, commercial, civic, and residential uses. Residential and civic uses generally would not require the routine handling or disposal of hazardous materials in quantities substantial enough to result in significant hazards to the public. Other uses, such as industrial, could require the hazardous materials to be used, stored, and disposed of in more substantial quantities. However, the routine use of hazardous materials would be in compliance with existing regulations that reduce hazards and risks.

Impacts would be less than significant.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
1-10
Issue Area Initial Study Findings
Hazards and Hazardous
Materials; CEQA
Checklist Question ‘c’
Mandatory compliance with regulations would also reduce risks of hazardous materials routinely used within 0.25 mile of schools. Impacts associated with the routine transport, use, or disposal of hazardous materials and within proximity to schools would be less than significant.

Hazards and Hazardous
Materials; CEQA
Checklist Question ‘e’
The project would have no impact related to safety hazards within the planning area of an airport land use plan because the DWSP plan area is not within such a planning area and the nearest airport is more than two miles away from the plan area.

Hazards and Hazardous
Materials; CEQA
Checklist Question ‘f’
Future development envisioned in the DWSP could require temporary street or roadway lane closures during construction. However, the City and Watsonville Fire Department must be made aware of closures to ensure emergency response operations are not hindered. Road diets and modifications envisioned in the DWSP would include center turning lanes and parallel parking that vehicles could use as pullouts to allow emergency vehicles to safely pass.

Therefore, the project would not impair implementation of or physically interfere with an adopted emergency response plan. Impacts would be less than significant.

Hazards and Hazardous
Materials; CEQA
Checklist Question ‘g’
The plan area is located in the downtown area of Watsonville, which is characterized by buildings, sidewalks, roads, and other urban development. Wildfire fuels, such as forest or brushland are not present in the plan area. The proposed project would have no impact related to risks associated with wildfire hazards.

Hydrology and Water
Quality; CEQA Checklist
Question ‘a’
Future development envisioned in the DWSP would require ground disturbance and excavation that could increase the potential for soil erosion and subsequent siltation of surface waters.

Mandatory implementation of a Stormwater Pollution Prevention Plan (SWPPP) and its best management practices would prevent erosion and siltation. The plan area is served by existing storm drain that would capture and treat runoff. Accordingly, the DWSP would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade surface or ground water quality. Impacts would be less than significant.

Hydrology and Water
Quality; CEQA Checklist
Question ‘b’
The plan area does not coincide with groundwater recharge areas, and water demand for the future development envisioned in the DWSP would be met with the City’s unused water supplies. Therefore, the DWSP would not substantially decrease groundwater supplies or interfere substantially with groundwater recharge, and impacts would be less than significant.

Hydrology and Water
Quality; CEQA Checklist
Question ‘c’
The DWSP would not substantially alter the existing drainage pattern of the plan area, because the plan area is urbanized and largely developed with impervious surfaces in its existing condition. Impacts related to altered drainages in context with increased flooding, exceeding storm drain capacity, or impede flood flows would be less than significant.

Hydrology and Water
Quality; CEQA Checklist
Question ‘d’
The plan area is not subject to tsunami, but portions of the plan area could be inundated by floodwaters or seiche. However, the DWSP would primarily facilitate infill development and redevelopment, and would therefore not substantially increase the risk of the release of pollutants during inundation. Additionally, Section 9-2.502 of the Watsonville Municipal Code prohibits the storage of materials which in the time of a flood are buoyant, flammable, explosive, or could otherwise be injurious to human, animal, or plant life. For these reasons, impacts related to release of pollutants due to inundation would be less than significant.

Hydrology and Water
Quality; CEQA Checklist
Question ‘e’
The City’s water supply is primarily from groundwater sources. The future development envisioned in the DWSP would increase demand for water. However, the City does not utilize its full allotment of water supplies. Water demand generated from the future development in the DWSP would be met with the existing water supply. The DWSP would not conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Land Use and Planning;
CEQA Checklist
Question ‘a’
The plan area is currently developed with existing residential and commercial uses. Therefore, the addition of buildout of the DWSP would not generate additional barriers to community connectivity compared to existing conditions on the site. The Specific Plan does not include the construction of barriers such as roadways or other dividing features that would physically divide an established community. Therefore, the DWSP would have no impact related to physically dividing an established community.

Exhibit B
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Introduction
Draft Environmental Impact Report 1-11
Issue Area Initial Study Findings
Land Use and Planning;
CEQA Checklist
Question ‘b’
The land use components of the DWSP would help the City achieve its objective of incorporating higher density commercial and housing opportunities by accommodating additional residential uses in a compact and active mixed-use environment through both new construction and adaptive reuse of historic or existing buildings. Because the plan area is mostly developed with commercial buildings and established residential neighborhoods, the DWSP directs future potential growth toward a limited number of vacant or under-utilized sites that could be redeveloped in the downtown area. This would prevent conflicts with land use plans, policies, and regulations adopted for the purpose of avoiding or mitigating environmental effects, and impacts would be less than significant.

Mineral Resources;
CEQA Checklist
Question ‘a’
The plan area contains no known or mapped mineral resources. Therefore, the DWSP would have no impact to mineral resources.

Mineral Resources;
CEQA Checklist
Question ‘b’
The plan area contains no active mineral extraction operations. Additionally, the DWSP would facilitate development within the previously developed downtown of Watsonville and would not result in a loss of available minerals. Thus, the DWSP would have no impact to mineral resources.

Noise; CEQA Checklist
Question ‘c’
The plan area is not within an airport land use plan boundary or within two miles of an airport.

Therefore, the DWSP would not expose people residing or working in the project area to excessive noise levels within or proximate to an airport.

Population and
Housing; CEQA
Checklist Question ‘b’
The DWSP includes strategies to prevent housing displacement, such as Policy 7.1 and Policy

7.2, which look to reinvest in existing affordable housing and stabilize existing neighborhoods.

Furthermore, the intent of the DWSP is to create more housing units within Downtown Watsonville over the next 25 years, while maintaining existing neighborhoods. Therefore, the proposed project would not displace substantial numbers of existing people or housing. There would be no impact.

Public Services; CEQA
Checklist Question ‘a’
The plan area consists of the downtown area of Watsonville, which is served by existing public services, such a fire and police. The DWSP envisions modification to fire department facilities, but the modifications would occur as infill on a site that is already developed downtown.

Therefore, the DWSP would have less than significant environmental impacts related to expansion or construction of new public services.

Recreation; CEQA
Checklist Question ‘a’
The DWSP would not result in substantial adverse physical effects or accelerated deterioration of recreational facilities. Given the proximity of the Watsonville City Plaza, Marinovich Park and Community Center, Callaghan Park, Ramsay Park, and the Pajaro River Park, most residents would likely walk to existing parks, and given the nature of the downtown land uses, there would not be demand for new parks. Parks would continue to be routinely maintained, consistent with existing conditions. Impacts related to recreation would be less than significant.

Recreation; CEQA
Checklist Question ‘b’
The DWSP does not envision new or expanded recreational facilities that would have an adverse physical effect on the environment. Impacts would be less than significant.

Transportation; CEQA
Checklist Question ‘c’
The DWSP would not alter roadways to include new sharp curves or new dangerous intersections. Further, the DWSP would facilitate residential, commercial, and industrial development, uses that already exist within the downtown area; therefore, the DWSP would not introduce new types of vehicle traffic or incompatible uses. Transportation impacts related to hazards or incompatible uses would be less than significant.

Transportation; CEQA
Checklist Question ‘d’
Development facilitated by the DWSP would be required to comply with the City’s standards for emergency vehicle access (including providing adequate points of access, vertical clearance, and turning radius). Road diets and modifications envisioned in the DWSP would include center turning lanes and parallel parking that vehicles could use as pullouts to allow emergency vehicles to safely pass. Therefore, the project would not result in inadequate emergency access, and impacts would be less than significant.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
1-12
Issue Area Initial Study Findings
Utilities and Service
Systems; CEQA
Checklist Question ‘a’
Future development envisioned in the DWSP would not require the relocation of water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunication facilities. These utilities exist within the plan area. Impacts related to the relocation or provision of new utilities would be less than significant.

Utilities and Service
Systems; CEQA
Checklist Question ‘b’
The City’s water supply is primarily from groundwater sources. The future development envisioned in the DWSP would increase demand for water. However, the City does not utilize its full allotment of water supplies. Water demand generated from the future development in the DWSP would be met with the existing water supply. The future development would have sufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years, and impacts would be less than significant.

Utilities and Service
Systems; CEQA
Checklist Question ‘c’
The wastewater generated from development envisioned in the DWSP would be treated at the existing wastewater treatment facility, which has adequate capacity for the DWSP development. Impacts related to wastewater treatment capacity would be less than significant.

Utilities and Service
Systems; CEQA
Checklist Question ‘d’
The solid waste generated by development envisioned in the DWSP would be sent to local landfills, which have adequate capacity for the DWSP development. Impacts related to solid waste would be less than significant.

Utilities and Service
Systems; CEQA
Checklist Question ‘e’
Solid waste generated by the DWSP would be required to comply with federal, state, and local management and reduction statutes and regulations related to solid waste. Impacts would be less than significant.

Wildfire; CEQA
Checklist Question ‘a’
The plan area is not within or near state responsibility areas or lands classified as very high fire hazard severity zones and would the project substantially impair an adopted emergency response plan or emergency evacuation plan. There would be no impact.

Wildfire; CEQA
Checklist Question ‘b’
The plan area is not within or near state responsibility areas or lands classified as very high fire hazard severity zones. The plan area is located in the downtown area of Watsonville, which is characterized by buildings, sidewalks, roads, and other urban development. The DWSP would not expose plan area occupants to pollutants from a wildfire. There would be no impact.

Wildfire; CEQA
Checklist Question ‘c’
The plan area is not within or near state responsibility areas or lands classified as very high fire hazard severity zones and would not require the installation of infrastructure that might exacerbate fire risk. There would be no impact.

Wildfire; CEQA
Checklist Question ‘d’
The plan area is not within or near state responsibility areas or lands classified as very high fire hazard severity zones and would not expose people or structures to flooding or landslides as a result of post-fire instability. There would be no impact. .

1.5 Lead, Responsible, and Trustee Agencies
The State CEQA Guidelines define lead, responsible and trustee agencies. The City of Watsonville is the lead agency for the project because it holds principal responsibility for approving the DWSP.

Section 15381 of the State CEQA Guidelines defines responsible agencies as a public agency other than the lead agency that has discretionary approval over the project.

Section 15386 of the State CEQA Guidelines designates four agencies as trustee agencies:
 CDFW with regards to fish and wildlife, native plants designated as rare or endangered, game refuges, and ecological reserves;
 State Lands Commission with regard to state-owned “sovereign” lands, such as the beds of navigable waters and State school lands;
 California Department of Parks and Recreation with regard to units of the State park system; and
Exhibit B
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Introduction
Draft Environmental Impact Report 1-13
 The University of California with regard to sites within the Natural Land and Water Reserves System.

Because there DWSP is a plan for development and mobility in Watsonville and does not propose specific projects requiring permits or approvals other than adoption of the DWSP there are no responsible or trustee agencies. Additionally, resources or land under the jurisdiction may not occur with the DWSP plan area, such as land within the State park system.

1.6 Environmental Review Process
The environmental impact review process, as required under CEQA, is summarized below and illustrated in Figure 1-1. The steps are presented in sequential order.  Notice of Preparation (NOP) and Initial Study. After deciding that an EIR is required, the lead agency (City of Watsonville) must file a NOP soliciting input on the EIR scope to the State Clearinghouse, other concerned agencies, and parties previously requesting notice in writing (State CEQA Guidelines Section 15082; Public Resources Code Section 21092.2). The NOP must be posted in the County Clerk’s office for 30 days. The NOP may be accompanied by an Initial Study that identifies the issue areas for which the project could create significant environmental impacts.
 Draft EIR Prepared. The Draft EIR must contain: a) table of contents or index; b) summary; c) project description; d) environmental setting; e) discussion of significant impacts (direct, indirect, cumulative, growth-inducing and unavoidable impacts); f) a discussion of alternatives; g) mitigation measures; and h) discussion of irreversible changes.  Notice of Completion (NOC). The lead agency must file a NOC with the State Clearinghouse when it completes a Draft EIR and prepare a Public Notice of Availability of a Draft EIR. The lead agency must place the NOC in the County Clerk’s office for 30 days (Public Resources Code Section 21092) and send a copy of the NOC to anyone requesting it (State CEQA Guidelines Section 15087). Additionally, public notice of Draft EIR availability must be given through at least one of the following procedures: a) publication in a newspaper of general circulation; b) posting on and off the project site; and c) direct mailing to owners and occupants of contiguous properties. The lead agency must solicit input from other agencies and the public and respond in writing to all comments received (Public Resources Code Sections 21104 and 21253). The minimum public review period for a Draft EIR is 30 days. When a Draft EIR is sent to the State Clearinghouse for review, the public review period must be 45 days unless the State Clearinghouse approves a shorter period (Public Resources Code 21091).  Final EIR. A Final EIR must include: a) the Draft EIR; b) copies of comments received during public review; c) list of persons and entities commenting; and d) responses to comments.  Certification of Final EIR. Prior to making a decision on a proposed project, the lead agency must certify that: a) the Final EIR has been completed in compliance with CEQA; b) the Final EIR was presented to the decision-making body of the lead agency; and c) the decision making body reviewed and considered the information in the Final EIR prior to approving a project (State CEQA Guidelines Section 15090).
 Lead Agency Project Decision. The lead agency may a) disapprove the project because of its significant environmental effects; b) require changes to the project to reduce or avoid significant environmental effects; or c) approve the project despite its significant environmental Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
1-14
effects, if the proper findings and statement of overriding considerations are adopted (State CEQA Guidelines Sections 15042 and 15043).
 Findings/Statement of Overriding Considerations. For each significant impact of the project identified in the EIR, the lead agency must find, based on substantial evidence, that either: a) the project has been changed to avoid or substantially reduce the magnitude of the impact; b) changes to the project are within another agency's jurisdiction and such changes have or should be adopted; or c) specific economic, social, or other considerations make the mitigation measures or project alternatives infeasible (State CEQA Guidelines Section 15091). If an agency approves a project with unavoidable significant environmental effects, it must prepare a written Statement of Overriding Considerations that sets forth the specific social, economic, or other reasons supporting the agency’s decision.
 Mitigation Monitoring Reporting Program. When the lead agency makes findings on significant effects identified in the EIR, it must adopt a reporting or monitoring program for mitigation measures that were adopted or made conditions of project approval to mitigate significant effects.
 Notice of Determination (NOD). The lead agency must file an NOD after deciding to approve a project for which an EIR is prepared (State CEQA Guidelines Section 15094). A local agency must file the NOD with the County Clerk. The NOD must be posted for 30 days and sent to anyone previously requesting notice. Posting of the NOD starts a 30-day statute of limitations on CEQA legal challenges (Public Resources Code Section 21167[c]).

Exhibit B
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Introduction
Draft Environmental Impact Report 1-15
Figure 1-1 Typical CEQA Process
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
1-16
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Exhibit B
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Project Description
Draft Environmental Impact Report 2-1
2 Project Description
This section describes the proposed project, including the lead agency, project objectives, project characteristics, and discretionary actions needed for approval.

2.1 Project Title and Brief Description
The project title is the “Downtown Watsonville Specific Plan Project” (hereinafter referred to as ‘DWSP’ or ‘project’). The DWSP articulates a community vision and planning framework that would serve as a guide for the City and other public agency decision-makers, community members, and stakeholders over the next 20 to 30 years. The DWSP would provide a comprehensive land use and mobility plan, along with development and design regulations, to guide future public and private development in the downtown area of Watsonville.

2.2 Lead Agency Name, Address, and Contact Person
City of Watsonville
Planning Division
250 Main Street
Watsonville, California 95076
Justin Meek, AICP Principal Planner
831-768-3050

2.3 Project Location
Watsonville is located in the southern area of Santa Cruz County, approximately 14 miles southeast of the city of Santa Cruz, approximately 16 miles north of the city of Salinas, and approximately 22 miles northeast of the city of Monterey. Watsonville is bordered by the unincorporated communities of Freedom to the north, Interlaken to the east, and Pajaro to the south. The Monterey Bay/Pacific Ocean is approximately three miles west of the City.

The Downtown Watsonville Specific Plan Area (plan area) encompasses approximately 195.5 acres within Downtown Watsonville, located in the southeastern portion of the City. Approximately 55.5 acres (28 percent) of the plan area is dedicated to streets and rights-of-way. Downtown is centered on Main Street and extends west to the edge of existing neighborhoods and the industrial district, south to Pajaro, and several blocks east to the existing neighborhoods. State Route (SR) 152 runs through the approximate center of the plan area and operates along portions of Main Street and as a one-way couplet along E Lake Avenue and E Beach Street. Riverside Drive on the south end of the plan area is a part of SR 129. The location of the plan area is shown in Figure 2-1, and the plan area boundary is shown in Figure 2-2.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-2
Figure 2-1 Project Vicinity Map
Exhibit B
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Project Description
Draft Environmental Impact Report 2-3
Figure 2-2 Plan Area Boundaries
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-4

2.4 Existing Setting and Surrounding Land Uses
The plan area includes a mix of uses which include retail, commercial, civic, religious, industrial, and residential. City Hall and the Police Station, Civic Plaza with Council Chambers, Library and County Courthouse, U.S. Post Office, and Cabrillo College are the major civic and institutional anchors in the plan area. The Watsonville City Plaza is an important Downtown public open space that supports civic and community activities. At the center of Downtown is Main Street, along which some historic and large mixed-use buildings are located with ground-floors consisting of local retail and services while the upper levels accommodate office and residential uses. Along Walker Street, single-story industrial buildings provide much of employment opportunities in the plan area.

The General Plan land use designations in the plan area include Central Commercial, General Commercial, Industrial, Public/Quasi-Public, Residential High Density, and Residential Low Density.

The General Plan existing land use designations within the plan area are shown Figure 2-3.

The Watsonville Zoning Ordinance is found in Chapter 14-16 of the Watsonville Municipal Code (WMC). According to the City of Watsonville Zoning Map, the plan area includes Central Commercial, Central Commercial Core Area, General Industrial, Institutional, Multiple ResidentialHigh Density, Neighborhood Commercial, Office, Public Facilities, Single Family Residential-Low Density, and Thoroughfare Commercial zoning districts. The existing zoning districts within the plan area are shown in Figure 2-4.

The existing roadway network in the Downtown area consists of a multitude of varying block lengths, several curvilinear streets, and some one-way streets. The Downtown roadway network accommodates local access through SR 152 and SR 129 while they also serve as conduits of regional travel which includes heavy truck use. Approximately 55.5 acres of Downtown Watsonville are dedicated to streets and right-of-way. The existing roadway network in the plan area is shown in Figure 2-5.

Exhibit B
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Project Description
Draft Environmental Impact Report 2-5
Figure 2-3 Existing General Plan Land Use Designations
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-6
Figure 2-4 Exisiting Zoning Districts
Exhibit B
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Project Description
Draft Environmental Impact Report 2-7
Figure 2-5 Exisiting Plan Area Roadway Network
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-8

2.5 Project Characteristics

2.5.1 DWSP Objectives
The DWSP would encourage higher-intensity, mixed-use neighborhoods by coalescing the City’s Downtown with adjacent industrial and residential areas to create walkable and complete neighborhoods with a mix of retail, services, amenities, employment, and residential uses that would help to activate the Downtown area. The DWSP establishes the following guiding principles and objectives for Downtown Watsonville:
 Preserve key elements that make Downtown unique
 Establish a varied choice of uses and experiences for our diverse community  Create diverse and inclusive housing opportunities
 Promote local economic prosperity
 Create a vibrant, safe, and active Downtown
 Foster a healthy, inclusive, and culturally connected community where all can thrive  Re-imagine and innovate mobility options and connections  Incorporate sustainable design elements to improve community health

2.5.2 DWSP Vision
The overarching vision of the DWSP supported by the goals and policies of the plan, which demonstrate the intentions for the physical development, redevelopment, conservation, and growth of the Downtown. The vision of the DWSP is to facilitate housing production and preservation; increase retail entertainment activity; encourage higher-density mixed-use residential projects; add visitor-oriented uses; support a greater range of civic and cultural activities; improve the safety and comfort of pedestrians; enhance bicycle infrastructure and connections; and target uses and activities that appeal to a wide range of Watsonville’s residents and employees.

The urban design framework is based on major strategies identified by the community. Each of these strategies is intended to support the implementation of the DWSP’s vision with the creation of new housing, jobs, and improvements to transportation and public spaces for residents and businesses in the Downtown. These major strategies guiding the urban design vision include:
 Retaining Downtown’s charming historic architecture and character  Building on and extending Downtown’s walkable scale
 Activating Downtown with new uses, special events, and programming  Providing improvements to the public realm, such as streetscape, public art, and murals  Re-imagining the Main Street right-of-way to address traffic calming and walkability goals  Providing more housing choices and maintain affordability  Improving bicycle and pedestrian connectivity and safety  Addressing traffic speed and congestion concerns
Exhibit B
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Project Description
Draft Environmental Impact Report 2-9

2.5.3 Proposed Zoning and Development Standards
The DWSP would establish new zones, overlays, and development standards and guidelines to guide development and to achieve the physical outcomes envisioned for the plan area. Chapter 6 of the DWSP outlines proposed development standards and guidelines for the plan area; unless otherwise specified in the DWSP, the zoning outlined in Chapter 6 would replace existing zoning for all property within the plan area. The DWSP would establish four zoning districts and three zoning overlays within the plan area, which are described below. Figure 2-6 shows the proposed zones and overlays within the plan area.

Zones
Downtown Core
Areas zoned as Downtown Core would be intended to be active, walkable environments, characterized by buildings of up to six stories. The Downtown Core would be the heart of the Downtown area, where the most active and intense development patterns and uses would be anticipated. Upper floors of development in the Downtown core could contain residential uses or office space, and buildings would be close to the sidewalk with little to no side setbacks.

Downtown Neighborhood
Downtown Neighborhood zones would be characterized by buildings smaller in scale than those in the Downtown Core zone and would generally include a similar mix of active and residential uses.

Downtown Industrial
Areas zoned as Downtown Industrial would allow existing industrial uses to continue to operate, while allowing for adaptive reuse of existing buildings and infill of mixed uses to occur over time.

Pursuant to WMC Chapter 14-12, new industrial development would be subject to required findings of compatibility between adjacent uses related to traffic, noise, odors, visual nuisances, and other similar adverse effects.

Public Facilities
Development proposed for parcels zoned as Public Facilities would be subject to development and use standards established by WMC Section 14-16.800-803, which outlines permitted land uses and associated development requirements for Public Facilities zones.

Overlays
Main Street
The Main Street Overlay would be located in areas intended to have the most active ground floor uses. The Main Street Overlay would be contiguous so that the “main street” environment is concentrated, and not interrupted by areas containing less active environments.

Gateway
The Gateway Overlay would extend some of the characteristics of the Main Street Overlay further down Main Street and onto select cross-streets, with some flexibility.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-10
Figure 2-6 Proposed Zones and Overlays
Exhibit B
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Project Description
Draft Environmental Impact Report 2-11
Neighborhood Transition
Development within the Neighborhood Transition Overlay would provide a transition between the commercial and mixed-use areas of Downtown and surrounding predominantly residential areas next to Downtown. For example, within the Neighborhood Transition Overlay, buildings height and massing would be sized down in scale compared to the Downtown Core, to be consistent with and provide a transition into the adjoining residential neighborhoods, which typically have smaller structures.

2.5.4 DWSP Buildout
The plan area is currently developed with primarily commercial buildings and established residential neighborhoods. Hence, future potential growth is likely to be directed to a limited number of vacant or under-utilized sites that could be redeveloped. As shown in Table 2-1, the Specific Plan envisions the maximum addition of approximately 231,151 square feet of commercial space, 376,827 square feet of industrial space, and 114,572 square feet of civic space to the plan area. In addition, the DWSP envisions the addition of up to 3,886 new residential units to the plan area over the next 25 years.

Table 2-1 Maximum Growth Projections for Specific Plan Area Land Use Residential (du) Commercial (sf) Industrial (sf) Civic (sf) Residential 3,886
Dining Establishment 150,248 7,537
Retail 57,788
Office/Research Development 23,115 94,207
Civic 114,572
Industrial 275,084
Total 3,886 231,151 376,827 114,572
Note: ‘du’ equal dwelling unit and ‘sf’ equals square feet, and values presented in table are approximate Source: City of Watsonville 2022

2.5.5 Downtown Transportation and Mobility
Chapter 4 of the DWSP contains the mobility and transportation vision and strategies for the plan area. The DWSP provides standards, guidelines, and design concepts to implement the following in the plan area:
 Install improvements to enhance pedestrian safety and access, bicycle connectivity, and revitalize downtown streetscape.
 Provide bicycle infrastructure that connects downtown to key locations and provides a low stress environment for bicycle riding.
 Provide widened and enhanced facilities for walking.
 Enhance parking, travel demand, and curb management to support an environmentally and fiscally sustainable downtown that increases quality of life in Watsonville.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-12
The DWSP includes several roadway improvements to support multimodal travel, increase safety, and improve access to local amenities and businesses. The future improvements are designed to reduce potential conflict points between motorists, people who walk, and people who bike within the plan area. Key roadway improvements include:
 Reducing the number of travel lanes on Main Street from four to three with a center running left turn lane (or landscaped median) and one lane in each direction between Riverside Drive and Freedom Boulevards (aka “road diet”);
 Converting East Lake Avenue and East Beach Street, which currently operate as one-way couplets, into two-way streets;
 Squaring off the connection between Union Street and Alexander Street from East Lake Avenue to East Beach Street and vacating that portion of Union Street for private development; and  Installing a roundabout at Freedom Boulevard and Main Street.

Further roadway improvements included in the DWSP are summarized in Table 2-2 and shown in Figure 2-7.

Table 2-2 Summary of Key Roadway Improvements in the Plan Area Roadway Segment Summary of Improvements
Main Street
(E Lake Avenue to E. Beach Street)
 Reduce travel lanes from four to three with a center running left turn lane and one lane in each direction.
 Reallocate additional on-street right-of-way for parklets, sidewalk furniture, and widened sidewalks where feasible.
 Maintain on-street parking.
 Improve pedestrian crossings at intersections.
 Provide medians at midblock locations where feasible.

Main Street
(Central Avenue to 1st Street)
 Maintain total right-of-way of 78 feet.
 Require a public easement of 6 feet at the front property line to expand the sidewalk.
 Reduce travel lanes from four to two with one vehicular travel lane in each direction and maintain or widen the existing landscaped median and/or center running left turn lanes where applicable.
 Replace outside travel lanes with on-street parking and 2-foot buffers.  Consider expanding the pedestrian realm with bulb-outs and planters at intersections.

E Lake Avenue  Maintain existing right-of-way.
 Maintain number of vehicular travel lanes.
 Replace two westbound through lanes and dedicated right turn lane at intersections with one through lane in each direction and dedicated center turn lane at intersections or along the full length of commercial blocks as needed for local access.
 Preserve on-street parking.
 Center left turn lane may not be necessary through the length of the corridor and parking may be feasible where no left turn is needed.

Exhibit B
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Project Description
Draft Environmental Impact Report 2-13
Roadway Segment Summary of Improvements
East Beach Street  Maintain existing right-of-way.
 Maintain number of vehicle travel lanes.
 Replace two eastbound through lanes with one through lane in each direction.  Preserve on-street parking where feasible.
 Dedicate 7 feet of curb-to-curb right-of-way for parklets on north side or widened sidewalks on both sides.

Rodriguez Street  Maintain existing right-of-way and vehicle lane widths.  Maintain only one vehicle travel lane in each direction.  Increase northbound bicycle lane from 4 feet to 6 feet and maintain best practice bicycle lane widths of 6 feet minimum where feasible.  Increase east and west side buffer widths and add vertical separation such as planters or flexible bollards where feasible.

Union Street  Maintain existing right-of-way.
 Maintain vehicle lane widths.
 Minimize impacts to on-street parking.
 Add Class III marked sharrows with signage.
 Integrate traffic calming measures such as chicanes or planter boxes.

Walker Street  Maintain existing curb-to-curb dimensions and one vehicle travel lane in each direction.
 Integrate flexible delineators within existing buffers.  Maintain and/or add a clear path of travel for pedestrians and complete sidewalks where possible.

West 5th Street  Maintain existing right-of-way and number of vehicle travel lanes, maintain 11-foot vehicle lanes.
 Reduce parking lane width by 1 foot, from 8 feet to 7 feet.  Add Class III marked sharrows with signage.
 Provide a 2-foot buffer between the parking lane and Class III sharrows.  Preserve residential on-street parking.
 Integrate traffic calming measures such as bulb-outs at intersections, and chicanes or planter boxes at midblock locations where feasible.

Source: City of Watsonville 2022
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-14
Figure 2-7 DWSP Roadway Network Improvements
Exhibit B
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Project Description
Draft Environmental Impact Report 2-15
Chapter 4 of the DWSP also contains a complete list of bicycle improvements within the plan area, which are shown on Figure 2-8. Some examples of key bicycle improvements contained in the DWSP include:
 New signed bicycle route on Marchant Street between East Beach Street and the Levee Trail  New signed bicycle route on Sudden Street between Freedom Boulevard and East Beach Street  New signed bicycle route on Brennan Street/Union Street between Freedom Boulevard and the Levee Trail
 Improved wider bicycle lanes, with an enhanced buffer between adjacent vehicular travel lanes and the bicycle lane, on Rodriguez Street between West Lake Avenue and West Beach Street  New bicycle lanes on Walker Street from West Riverside Drive to the Pajaro River  New shared-use path from West Front Street along Rodriquez Street to the Levee Trail  New signed bicycle route on Ford Street between Walker Street and Main Street  New signed bicycle route on West 5th Street between Walker Street and Rodriguez Street  New bicycle lanes on 5th Street between Rodriguez Street and Brennan Street  New signed bicycle route on 2nd Street/Maple Avenue between Walker Street to Lincoln Street  New signed bicycle route on East Front Street between Main Street and Marchant Street Examples of pedestrian mobility standards provided in the DWSP include continuous sidewalks; design and maintenance of pedestrian facilities; complete streets; traffic calming measures; and tactile warning measures. Tactile warning measures enhance navigation for travelers with vision impairments.

2.6 Relationship to Other Plans
The DWSP considers existing and adopted plans, policies, and regulations at the city, regional, state, and federal levels. The DWSP’s relationship to existing planning documents is outlined below.

Watsonville 2005 General Plan
The City of Watsonville’s 2005 General Plan, adopted in 1991, establishes land uses and policies for development in the City, including within the plan area. Pursuant to California General Plan law, specific plans must be internally consistent with the jurisdiction’s existing general plan. The City’s General Plan is being updated concurrently with the DWSP, and the General Plan shall be updated in instances where DWSP zoning is inconsistent with land uses established by the General Plan.

Watsonville General Plan Housing Element
The City’s current Housing Element, prepared for the 5th planning cycle for the planning period of 2015 to 2023, is a required element of the City’s General Plan and includes citywide strategies to address housing. The 6th cycle Housing Element, which would cover the planning period of 2023 to 2031, would plan for the City’s Regional Housing Needs Allocation of 2,053 housing units. Some or all these units could be built in Downtown Watsonville.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-16
Figure 2-8 DWSP Future Bicycle Network
Exhibit B
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Project Description
Draft Environmental Impact Report 2-17
Watsonville Zoning Ordinance
The land use and development standards established by the DWSP would supersede the land use and development standards established by the City’s Zoning Ordinance for properties within the Downtown area. Regulations not addressed in the DWSP, including but not limited to standards for specific land uses, would still be regulated by the City’s Zoning Ordinance.

Watsonville Complete Streets Plan
The Complete Streets Plan, adopted in 2019, provides a vision of a multi-modal, revitalized Downtown area that is accessible by users of all modes of transportation, including pedestrians, cyclists, transit riders, and motorists. The recommendations in the Complete Streets Plan would be superseded by provisions of the DWSP.

Watsonville Urban Greening Plan
The Urban Greening Plan, adopted in 2012, was developed to identify and facilitate the design of projects that address greenhouse gas (GHG) emissions or help residents adapt to challenges posed by climate change. Three of the Urban Greening Plan’s six elements, including the Citywide Street Tree Program, Landscape Guidelines and Policy, and Green Roof Design Report & Criteria, are referenced in the DWSP.

Watsonville Climate Change and Adaptation Plan
The Watsonville Climate Action and Adaptation Plan was adopted in 2021 to reduce the community’s GHG emissions below certain targets. As the transportation sector contributes the greatest amount of GHG emissions, the Climate Action and Adaptation Plan calls for implementing a range of strategies to reduce the number and length of vehicle trips, including facilitating smart growth, increasing multimodal transportation facilities, managing better available parking, and supporting passenger rail service. The DWSP would support these strategies through fostering highdensity, infill development near transit, identifying pedestrian and bicycle enhancements, and revising parking and other development standards to reduce the transportation sector’s GHG contribution by reducing single-occupant vehicle driving and encouraging alternative modes of transportation.

2.7 Project Related Approvals, Permits, and
Discretionary Actions
Because the Specific Plan is a conceptual vision for the downtown area and not a formal site plan or construction application, no permits are needed for its adoption. However, the City of Watsonville City Council must formally certify the EIR and adopt the Specific Plan, and then implement the vision and changes identified in the Specific Plan. Implementation of the Specific Plan would also require an amendment to the City’s General Plan.

Individual projects pursuant to the DWSP would require permits and approvals such as, but not limited to, City of Watsonville demolition and building permits and design review. Future approvals from the City of Watsonville may require additional environmental review with the City of Watsonville as the lead agency.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
2-18
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Exhibit B
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Environmental Setting
Draft Environmental Impact Report 3-1
3 Environmental Setting
This section provides a general overview of the environmental setting for the proposed project.

More detailed descriptions of the environmental setting for each environmental issue area can be found in Section 4, Environmental Impact Analysis.

3.1 Regional Setting
Watsonville is in the southern area of Santa Cruz County, approximately 14 miles southeast of the city of Santa Cruz, 16 miles north of the city of Salinas, and 22 miles northeast of the city of Monterey. The City is bordered by the unincorporated communities of Freedom to the north, Interlaken to the east, and Pajaro to the south. The Monterey Bay/Pacific Ocean is approximately three miles west of the City.

3.2 Project Site Setting
The DWSP plan area encompasses approximately 195.5 acres within Downtown Watsonville, located in the southeastern portion of the City. Downtown is centered on Main Street and extends west to the edge of existing neighborhoods and the industrial district, south to Pajaro, and several blocks east to the existing neighborhoods. Downtown Watsonville consists of a mix of old and newer buildings styles and architecture, sidewalks, pocket parks, and roadways. The streetscape throughout the plan area varies in terms of design features, amenities, and sidewalk width and condition as it transitions from the Downtown core to the north and west into residential and commercial shopping centers, and to the east as it transitions to industrial and agricultural uses.

Most of the plan area is developed with small sections of non-native vegetation and bare ground.

The plan area does not contain natural or rural areas.

The plan area includes a mix of uses which include retail, commercial, civic, religious, industrial, and residential. City Hall and the Police Station, Civic Plaza with Council Chambers, Library and County Courthouse, U.S. Post Office, and Cabrillo College are the major civic and institutional anchors in the Downtown. The historic City Plaza is an important Downtown public open space that supports civic and community activities. At the center of Downtown is Main Street, along which many historic and large mixed-use buildings are located with ground-floors consisting of local retail and services while the upper levels accommodate office and residential uses. Along Walker Street, single-story industrial buildings provide employment.

The existing roadway network in the downtown area consists of a multitude of varying block lengths, several curvilinear streets, and some one-way streets. The downtown roadway network accommodates local access through State Route (SR) 152 and SR 129 while they also serve as conduits of regional travel which includes heavy truck use. SR 152 runs through the center of the plan area and operates along portions of Main Street and as a one-way couplet along E Lake Avenue and E Beach Street. Main Street is a four-lane landscaped gateway roadway that provides a variety of views of developed commercial shopping centers, Ramsay Park, historic buildings, the Watsonville Plaza, and the Pajaro River. Riverside Drive on the south end of the plan area is a part of SR 129. Riverside Drive from the Highway 1 interchange eastward provides travelers with a crosssectional view of Watsonville. The landscaped portion of this entry into the plan area continues Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
3-2
across the railroad tracks to Main Street, passing through older residential areas and ending Salsipuedes Creek. The plan area is shown in Section 2, Project Description.

3.3 Cumulative Development
In addition to the specific impacts of individual projects, CEQA requires EIRs to consider potential cumulative impacts of the proposed project. CEQA defines “cumulative impacts” as two or more individual impacts that, when considered together, are substantial or will compound other environmental impacts. Cumulative impacts are the combined changes in the environment that result from the incremental impact of development of the proposed project and other nearby projects. For example, noise impacts of two nearby projects may be less than significant when analyzed separately, but could have a significant impact when analyzed together. Cumulative impact analysis allows the EIR to provide a reasonable forecast of future environmental conditions and can more accurately gauge the effects of a series of projects.

CEQA requires cumulative impact analysis in EIRs to consider either a list of planned and pending projects that may contribute to cumulative effects or a forecast of future development potential.

Currently planned and pending projects in Watsonville are listed in Table 3-1.

Table 3-1 Cumulative Projects List
Project No. Project Name
Land Use and/or Brief
Description
Under Review
1 950 West Beach Street Industrial
2 200 Manabe Ow Road Distribution Facility Industrial with Office 3 100 Manabe Ow Road Industrial Building Industrial
4 Crockers Lockers at 750 Nielson Street Self-Storage
5 Ramsay Park Renaissance Project Park
6 Freedom Campus Master Plan (in Watsonville but under review by County of Santa Cruz)
Medical/Civic
Approved Projects
7 1 Western Drive Retail/Commercial
8 Triplex Residential
9 230 Riverside Drive Residential
10 65 Hangar Way #3 Retail/Commercial
11 21 Townhouse Project at 547 Airport Boulevard Residential 12 Biodiesel Facility Modification at 860 West Beach Street Industrial 13 Pajaro Valley High School Auditorium Project at 500 Harkins Slough Road
Educational
14 The Residence Four-Story Mixed-Use Building
Under Construction
15 Eden Housing Project at 1482 Freedom Boulevard Residential 16 49 Townhouse Project at 221 Airport Boulevard Residential 17 1715 West Beach Street Retail/Commercial
18 Evans Circle Residential
Exhibit B
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Environmental Setting
Draft Environmental Impact Report 3-3
Project No. Project Name
Land Use and/or Brief
Description
19 Hillcrest Estates Residential
20 Sunshine Gardens Residential
21 Commercial Redevelopment Project at 975 Main Street Retail/Commercial 22 Miles Lane Project Residential/Medical
1 Cumulative project details were sourced from the City of Watsonville’s Community Development and Planning Viewer (City of Watsonville 2023).

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City of Watsonville
Downtown Watsonville Specific Plan
3-4
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Exhibit B
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Environmental Impact Analysis
Draft Environmental Impact Report 4-1
4 Environmental Impact Analysis
This section discusses the possible environmental effects of the proposed DWSP for the issue areas that were identified through the scoping process and Initial Study as having the potential to experience significant effects. A “significant effect,” as defined by the CEQA Guidelines §15382:
means a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance. An economic or social change by itself shall not be considered a significant effect on the environment. A social or economic change related to a physical change may be considered in determining whether the physical change is significant.

The assessment of each issue area begins with a discussion of the environmental setting related to the issue, which includes the existing regulatory setting. The existing setting is followed by the impact analysis. In the impact analysis, the first subsection identifies the methodologies used and the “significance thresholds,” which are those criteria adopted by the City and other agencies, universally recognized, or developed specifically for this analysis to determine whether potential effects are significant. The next subsection describes each impact of the proposed project, mitigation measures for significant impacts, and the level of significance after mitigation. Each effect under consideration for an issue area is separately listed in bold text with the discussion of the effect and its significance. Each bolded impact statement also contains a statement of the significance determination for the environmental impact as follows:
 Significant and Unavoidable. An impact that cannot be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires a Statement of Overriding Considerations to be issued if the project is approved per §15093 of the CEQA Guidelines.
 Less than Significant with Mitigation Incorporated. An impact that can be reduced to below the threshold level given reasonably available and feasible mitigation measures. Such an impact requires findings under §15091 of the CEQA Guidelines.
 Less than Significant. An impact that may be adverse but does not exceed the threshold levels and does not require mitigation measures. However, mitigation measures that could further lessen the environmental effect may be suggested if readily available and easily achievable.  No Impact. The proposed project would have no effect on environmental conditions or would reduce existing environmental problems or hazards.

Following each environmental impact discussion is a list of mitigation measures, if required, and the residual effects or level of significance remaining after implementation of the measure(s). In cases where the mitigation measure(s) for an impact could have a significant environmental impact in another issue area, this impact is discussed and evaluated as a secondary impact. The impact analysis concludes with a discussion of cumulative effects, which evaluates the impacts associated with the proposed project in conjunction with other planned and pending developments in the area listed in Section 3, Environmental Setting.

The Executive Summary of this EIR summarizes all impacts and mitigation measures that apply to the proposed project.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan
4-2
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Exhibit B
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Environmental Impact Analysis
Aesthetics
Draft Environmental Impact Report 4.1-1

4.1 Aesthetics
This section describes the aesthetic and visual resources conditions within the plan area and vicinity and assesses the potential aesthetic impacts that may result with implementation of the proposed DWSP.

4.1.1 Setting
Regional Setting
The City is located in the Pajaro Valley along the southern limits of Santa Cruz County. The City is surrounded by agricultural land and rangeland, which is offset by the ridgeline of the Santa Cruz Mountains to the north and east. The wooded nature of these mountains provides both color and textural contrast to the agricultural land and urban development in the valley below. The agricultural land and undeveloped ridgeline encircling Watsonville add a distinct rural character to the urban viewsheds in the City. The City’s western edge is defined by Highway 1 and agricultural land that extends to the Monterey Bay. Landscape features within and surrounding the City are diverse and exhibit substantial visual variety. Representative visual features include the overall urban landscape, major arterial thoroughfares, scenic corridors, agricultural lands, open space, and ridgelines. The plan area is visible from areas outside of Watsonville that some people might consider scenic corridors, such as the “Sand Point Overlook” in or near the Forest of Nisene Marks, approximately 12 miles northwest of the plan area. However, characteristics of individual buildings or roadways are not visible due to the distance.

Plan Area and Surrounding Area Setting
Downtown Watsonville, which comprises the plan area, is a mix of old and newer buildings styles and architecture, sidewalks, pocket parks, and roadways (Watsonville 2022). The Main Street corridor, generally considered the core of downtown, is characterized by a mix of single-story retail buildings and multi-story buildings up to 4 or 5 stories with ground-floor retail and residences or offices on upper floors. Many of the buildings on Main Street have historic architecture, such as Renaissance Revival and Spanish Colonial architectural styles, however not all buildings on Main Street are officially designated as historic buildings or properties. As discussed in Section 4.4, Cultural Resources, much of Main Street was established in the late 1800s. Other parts of the plan area contain similar low-rise buildings, such as industrial warehouse buildings along Walker Street.

Single-family homes in the plan area are generally one to two stories in height and cover much of the lot or property they are located on. Many of the residential neighborhoods in plan area were also established in the late 1800s, and retain some of the original architecture, in Queen Anne Victorian architectural styles which include decorative eaves and awnings and trellis trim.

The streetscape throughout the plan area varies in terms of design features, amenities, and sidewalk width and condition as it transitions from the Downtown core to the north and west into residential and commercial shopping centers, and to the east as it transitions to industrial and agricultural uses. Street trees and landscaping add to the aesthetic character of the plan area, while overhead power lines detract from the visual quality. Pedestrian activity is generally low, although pedestrian activity can be moderate in select areas of the plan area, such as along Main Street in the downtown core. Downtown events, such as the farmers market, also increase pedestrian activity in the plan area.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.1-2
Scenic Roadways
Scenic routes and roadways provide access to scenic resources, which include the broad sweep of the Pajaro Valley, the hills and mountains which frame the valley floor, coastal lands, and the urban skyline. According to the Urban Design and Scenic Resources Element of the Watsonville 2005 General Plan, each scenic route must satisfy a minimum of four of the following criteria: 1) presence of views and vistas; 2) absence of clutter; 3) presence of interesting features; 4) presence of significant vegetation; 5) visual variety; and 6) service as a gateway. Roadways or segments of roadway that occur within the plan area and are classified as scenic routes in the General Plan include the following:
 E Lake Avenue - from State Route (SR) 152 from Main Street to Carlton. This stretch of SR 152 provides views of the surrounding hills, mountains, and passes by several notable historic structures.
 East Beach Street – Main Steet to Beck Street. East Beach Street affords views of historic structures and areas, including Watsonville Plaza and the central commercial center, Watsonville High School, and three designated historic houses.  Main Street – Highway 1 to the Pajaro River. Main Street is a four-lane landscaped gateway roadway that provides a variety of views of developed commercial shopping centers, Ramsay Park, historic buildings, the Watsonville Plaza, and the Pajaro River.  Riverside Drive (SR 129) – Highway 1 to Salsipuedes Creek. Riverside Drive from the Highway 1 interchange eastward provides travelers with a cross-sectional view of Watsonville. Riverside Drive emerges from the fields adjacent to Highway 1 and the Pajaro River. The roadway then passes the food processing warehouses which have been the backbone of the City. The landscaped portion of this entry into the plan area continues across the railroad tracks to Main Street, passing through older residential areas and ending (or beginning) Salsipuedes Creek.

The roadways listed above are classified as scenic routes by the City in its 2005 General Plan.

However, these routes are not designated state scenic highways. There are no designated state scenic highways within the plan area (Caltrans 2022).

Light and Glare
Sources of nighttime lighting in the plan area include lighting of signs, buildings, walkways, parking lots, and parking structures, as well as indoor lighting visible through windows. Lighting conditions vary throughout the plan area from heavily lit developed areas to low-intensity residential night lighting.

4.1.2 Regulatory Setting
a. State Regulations
State Designated Scenic Routes
The California Scenic Highway Program was created by the Legislature in 1963 with the purpose to preserve and protect scenic highway corridors from change, which would diminish the aesthetic value of lands adjacent to highways. The California Department of Transportation (Caltrans) manages the California Scenic Highway Program, provides guidance, and assists local government agencies, community organizations, and citizens with the process to officially designate scenic Exhibit B
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Environmental Impact Analysis
Aesthetics
Draft Environmental Impact Report 4.1-3
highways. A highway may be designated scenic depending upon how much of the natural landscape ban be seen by travelers, the scenic quality of the landscape, and the extent to which development intrudes upon the traveler’s enjoyment of the view. The California Scenic Highway Program includes a list of highways that are either eligible for designation as scenic highways or have been so designated. The highways are identified in Section 263 of the Streets and Highways Code.

State highways nominated for scenic designation must first be on the statutory list of highways eligible for scenic designation in the Sate Scenic Highway System. A process for adding eligible highways to the statutory list is described in Section III: Obtaining Eligibility of the Caltrans’ Scenic Highway Guidelines. Scenic highway nominations are evaluated using the following criteria:
 The State or county highway consists of a scenic corridor that is comprised of a memorable landscape that showcases the natural scenic beauty or agriculture of California.  Existing visual intrusions do not significantly impact the scenic corridor.  Demonstration of strong local support for the proposed scenic highway designation.  The length of the proposed scenic highways is not less than a mile and is not segmented.

The status of a State scenic highway changes from eligible to officially designated when the local jurisdiction adopts a scenic corridor protection program, applies to Caltrans for scenic highway approval, and receives notification from Caltrans that the highway has been designated as a Scenic Highway. According to the Caltrans California Scenic Highway Program, Highway 1 and SR 152, which traverse the City, are eligible for the official State Scenic Highway designation. However, there are no officially designated State scenic highways in Watsonville (Caltrans 2022). b. Local Regulations
City of Watsonville Municipal Code
The City’s Municipal Code includes several regulations associated with protection of the City’s visual character and control of light and glare. For example, Chapter 11 of Title 7, Street Trees, prevents trees from being planted along streets without a permit, and Chapter 13 of Title 7, Preservation of Historical Trees, states the City Council, by ordinance, may designate an individual tree or other feature, or an integrated group of trees and features on a single lot or site, having a special character or special historical or aesthetic interest or value as a designated tree and shall further describe a site sufficient for each designated tree to maintain its growth and preservation.

City of Watsonville 2005 General Plan
The preservation of the City’s rich historical and cultural resources, combined with the preservation of the natural beauty and rural backdrop of the Pajaro Valley, are the central issues and purposes of the Urban Design and Scenic Resources Element of the Watsonville 2005 General Plan. According to the General Plan, in reviewing new projects, the City considers the following design review guidelines:
 Site Planning. Guidelines emphasize suitability of the site for its proposed use and proposed building, efficiency of circulation and parking design, and building placement and orientation, particularly with regard to environmentally sensitive areas.  Building Design. Guidelines emphasize harmony with surrounding neighborhood, including materials, texture, color, height, and architectural detail.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.1-4
 Landscaping. Planting materials, lighting, fencing, and signs are considered by the City in order to ensure a safe and visually pleasing project.

In addition to considerations related to the built environment, the scenic quality of City is also enhanced through the preservation of significant natural features, which include wetlands, sloughs, rivers, lakes, hillsides, and stands of vegetation. These resources are important not only for their visual contribution to the City, but also for their passive recreational and educational opportunities.

The following goals, policies, and implementation measures within the Urban Design and Scenic Resources Element are applicable to the aesthetics and visual character related to the proposed project within the City.
 Goal 5.1 Visual Resources: Preserve and enhance the built and natural visual resources within Watsonville.
 Goal 5.2 Community Appearance: Blend new development and recognized values of community appearance and scenic qualities, and ensure that new development enhances, rather than detracts from its surroundings.
 Goal 5.5 Viewscape: Preserve scenic rural qualities surrounding the urbanized portions of the planning area.
 Goal 5.8 Urban Beautification: Support public and private urban beautification activities and promote pride in community appearance.
 Goal 5.9 Scenic Corridors: Protect and enhance views to and from the scenic streets and highways and the planning area.
 Goal 5.10 Natural Scenic Resources: Conserve and enhance natural resources that contribute to the visual, recreational, and educational aesthetics of Watsonville. Such resources include wetlands, sloughs, rivers, lakes, hillsides, and stands of vegetation.  Policy 5.A Project Design Review: The preservation of visual resources shall be accomplished through the design review process.
− Implementation Measure 5.A.2, Design Information Requirements: Application requirements for projects to meet the design review criteria shall include a preliminary site plan, exterior elevations, vehicular and pedestrian circulation, grading, parking plans, colors, sign locations and elevations, fence height and design, and a landscape plan.
− Implementation Measure 5.A.4, Development Standards: In addition to the design review guidelines, the City shall use the adopted standards for multiple family residential developments to ensure that medium- and high-density development is designed so as to enhance rather than detract from the urban environment. − Implementation Measure 5.A.5, Scenic Resources: The City shall, through its design review process, consider the impact of the development on both the visual quality of the build environment and the scenic quality of natural features including sloughs, wetland, rivers, lakes, hillsides and stands of vegetation.  Policy 5.B Design Consistency: The City shall review new development proposals to encourage high standards or urban design and to ensure that elements of architectural design and site orientation do not degrade or conflict with the appearance of existing structures.

Exhibit B
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Environmental Impact Analysis
Aesthetics
Draft Environmental Impact Report 4.1-5
− Implementation Measure 5.B.2, Neighborhood Identity: New development in established neighborhoods shall be encouraged to utilize the surrounding architectural themes and/or materials to promote neighborhood harmony and identity. − Implementation Measure 5.B.3, Enhancement: The City shall utilize the development standards, zoning ordinance regulations for each district, and the design review guidelines to ensure that new development is an asset to the existing neighborhood and community with regard to parking, landscaping, open space, and project design.  Policy 5.F Design Factors: The design review process shall combine elements of aesthetics with considerations for project efficiency.
− Implementation Measure 5.F.1, Project Appearance Factors: Considerations for project appearance shall include, but are not limited to, the following:
a. Compatibility with adjacent architectural styles;
b. Respect for design features of the original architectural style for building renovation projects;
c. Avoids of monotonous expanses of blank walls, including fire walls; d. Orientation of the project with respect to natural topography, the retention of trees, and significant natural habitat;
e. Placement and screening of trash containers from view and adequacy of the type and number of trash containers provided on site;
f. Undergrounding of utility lines and meter boxes and screening of transformers; g. Visual interest of exterior finishes and colors;
h. Discrete placement of microwave dish and satellite antennas; and i. Placement and design of external lighting fixtures to blend with the architectural style, provide safe areas, and avoid offsite glare.
 Policy 5.J Scenic Natural Resources: The City shall conserve and enhance natural resources that contribute to visual, recreational, and educational aesthetics of Watsonville. Such resources include: wetlands, sloughs, rivers, lakes, hillsides, and stands of vegetation. − Implementation Measure 5.J.2, Compatibility: Whenever a new development is proposed next to a natural scenic resource, the design review process will be used to maintain or create visual harmony between new and old structures and their natural setting.

City of Watsonville Livable Community Residential Design Guidelines In 2001, the Watsonville City Council adopted the Watsonville Livable Community Residential Design Guidelines (Guidelines) with the objective to develop more housing in a way that conserves the desirable characteristics of established neighborhoods, while improving new and evolving neighborhoods. Based on seven neighborhood and architectural design principles, the Guidelines provide a framework of neighborhood and design criteria for shaping residential development in the City. The Guidelines indicate that new housing should 1) connect to the community, 2) use block patterns that are similar to Watsonville’s traditional neighborhoods, 3) avoid flood and wetland areas, and 4) fully integrate parks and community facilities where appropriate.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.1-6

4.1.3 Impact Analysis
a. Methodology and Significance Thresholds
The DWSP is a planning document to guide development; it does not propose specific development projects. Therefore, the following discussions provide program-level review of the potential aesthetic impacts that could result from implementation of the DWSP.

The assessment of aesthetic impacts involves qualitative analysis that is inherently subjective in nature. Different viewers react to viewsheds and aesthetic conditions differently. This discussion evaluates the existing visual environment against the anticipated level of development with implementation of the proposed project. The discussion below, therefore, emphasizes change in aesthetic character and views, rather than placing value on the aesthetic quality of a particular condition.

In accordance with Appendix G of the State CEQA Guidelines, the proposed project would result in potentially significant environmental effects on the aesthetic and visual character of the area if it would:
1) Have a substantial adverse effect on a scenic vista; 2) Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway; 3) Conflict with applicable zoning and other regulations governing scenic quality; 4) Create a new source of substantial light or glare that would adversely affect day or nighttime views in the area.

The Initial Study (Appendix A) found impacts related to substantial damage to scenic resources, within a state scenic highway as less than significant because there are no officially designated state scenic highways within or near the plan area. Therefore, Threshold 2 is not studied further in this section.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project have a substantial adverse effect on a scenic vista? Impact AES-1 IMPLEMENTATION OF THE DWSP WOULD HAVE NO SUBSTANTIAL ADVERSE EFFECTS ON SCENIC VISTAS. THIS IMPACT WOULD BE LESS THAN SIGNIFICANT.

The plan area consists of downtown Watsonville, which is characterized by urban development and is relatively flat. There are no scenic vistas, such a mountain overlooks or other point providing panoramic views and vistas. However, as described in Viewing Corridors and Scenic Roadways, four scenic routes are present within the plan area (Watsonville 2005). The DWSP envisions these roadways or the buildings and landscape visible from them, or both. For example, Main Street is classified as a scenic route by the City and the DWSP envisions numerous changes on and along Main Street would alter views. These modifications to the roadway would change views, generally making the view more appealing with wider pedestrian sidewalks and landscaping. Furthermore, Chapter 6 of the DWSP contains standards to ensure that new or redeveloped buildings on scenic roads in the plan area would be consistent with the views that currently are provided. Additionally, the development envisioned in the DWSP would be infill within the downtown area, where distant views are already obstructed by the many buildings present in the plan area. The additional building Exhibit B
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Environmental Impact Analysis
Aesthetics
Draft Environmental Impact Report 4.1-7
height envisioned in the DWSP would therefore not substantially obstruct views since the entire plan area is already developed with structures exceeding eye level of viewers.

Because the plan area consists of a large, urbanized area characterized by buildings and roadways, it could be visible from areas outside of Watsonville that some people might consider scenic vistas. An example could be the “Sand Point Overlook” in or near the Forest of Nisene Marks, approximately 12 miles northwest of the plan area. However, because the DWSP contains the design standards described above, changes would be subtle and negligible from these distant vistas. Accordingly, the impacts of the DWSP on scenic vistas would be less than significant.

Mitigation Measures
No mitigation measures are required
Significance after Mitigation
Impacts would be less than significant without mitigation.

Threshold 3: Would the project conflict with applicable zoning and other regulations governing scenic quality?
Impact AES-2 IMPLEMENTATION OF THE DWSP WOULD ESTABLISH NEW ZONING AND DESIGN STANDARDS THAT PRESERVE AND IMPROVE SCENIC QUALITY IN THE PLAN. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The plan area is an urbanized area because it consists of existing downtown Watsonville. As discussed in Section 2, Project Description, the DWSP would implement new zoning, overlays, and development standards for the plan area to meet the following key objectives:
 Preserve key elements that make Downtown unique
 Establish a varied choice of uses and experiences for our diverse community  Create housing opportunities for all
 Promote local economic prosperity
 Create a vibrant, safe, and active Downtown
 Foster a healthy, inclusive, and culturally connected community where all can thrive  Re-imagine and innovate mobility options and connections  Incorporate sustainable design elements to improve community health As stated in Section 2, Project Description, and described in the impact analysis for impact AES-1, Chapter 6 of the DWSP outlines proposed development standards and guidelines for Downtown Watsonville; unless otherwise specified in the DWSP. The DWSP would establish four zoning districts and three zoning overlays within the Downtown area (see Section 2, Project Description, for location of proposed zoning).

To preserve key elements that make Downtown unique and establish a varied choice of uses and experiences for the diverse community, plans for development with the plan area would be subject to review for consistency with the DWSP including new zoning, overlays, and development standards. Thus, compliance with the design guidelines in the DWSP would be in keeping with the aesthetic standards for future development in the plan area.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.1-8
The City would review and approve new development for compliance with development standards, sign regulations, and urban design guidelines in the DWSP, prior to the approval of individual building permits. Thus, with compliance to the DWSP proposed development standards and guidelines for plan area, development would not conflict with applicable zoning and other regulations governing scenic quality. Therefore, impacts of the DWSP would be less than significant.

Mitigation Measures
No mitigation measures are required
Significance after Mitigation
Impacts would be less than significant without mitigation.

Threshold 4: Would the project create a new source of substantial light or glare that would adversely affect daytime or nighttime views in the area? Impact AES-3 IMPLEMENTATION OF THE DWSP WOULD CREATE NEW SOURCES OF LIGHT AND GLARE, BUT NEW LIGHT AND GLARE WOULD NOT BE SUBSTANTIAL. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

Implementation of the DWSP would result in the addition of new nighttime light and daytime glare to the plan area including external housing lights, streetlights, parking lot lights, security lights, vehicular headlights, internal building lights that spill through windows and doors, and reflective building surfaces and windows that create glare.

Future development pursuant to the DWSP would be subject to the Watsonville Municipal Code requirements such as Chapter 14-16, District Regulation, which outlines permitted uses and other requirements including lighting requirements for the various zoning districts within Watsonville.

Additionally, compliance with lighting guidelines in the DWSP and the City’s development regulations regarding glare would prevent the creation of significant adverse light and glare impacts.

For example, Chapter 6 of the DWSP requires that site lighting be shielded by permanent attachments to light fixtures so that light sources are not visible from a public way and to prevent off-site glare. Chapter 6 of the DWSP also contains requirements that would restrict how bright or intense light fixtures could be depending on whether the fixture is used for residential structures or commercial/industrial structures. Chapter 6 provides standards for buildings, such as arcades, which are extensions of upper floors of a building, and these would shade bottom floors which typically contain larger panels of glass for windows. This would also reduce glare from reflective surfaces, for example. Therefore, the project would not create a new source of substantial glare that would adversely affect daytime or nighttime views in the area. Light and glare impacts of the DWSP would be less than significant.

Mitigation Measures
No mitigation measures are required.

Significance after Mitigation
Impacts would be less than significant without mitigation.

Exhibit B
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Environmental Impact Analysis
Aesthetics
Draft Environmental Impact Report 4.1-9
c. Cumulative Impacts Assessment
The cumulative impacts assessment area for aesthetics is the area within the limits of the City of Watsonville. The city limits are an appropriate boundary for the cumulative impacts assessment area because the cumulative projects in Table 3-1 and there is substantial open space between Watsonville and surrounding communities.

The reasonably foreseeable future projects in Table 3-1 would result in continued urbanization of Watsonville. For example, the foreseeable Hillcrest Subdivision project would add residential buildings and internal circulation roads on a property that is not currently developed with these uses. The reasonably foreseeable Freedom Campus Master Plan project would result in densification of property along Freedom Boulevard, proximate to the DWSP plan area. Reasonably foreseeable future projects would be required to comply with applicable zoning code, including zoning code pertaining to design styles and aesthetics. This would prevent significant cumulative impacts related to conflicts with applicable zoning and other regulations governing scenic quality. However, cumulative development may, over time, alter the visual character of the City with further urban development. This would be a potentially significant cumulative impact on aesthetic resources due to changing the visual quality of the City’s viewing corridors. However, with compliance to existing zoning and development standards and guidelines, cumulative development would not conflict with applicable zoning and other regulations governing scenic quality.

As discussed in the impact analysis above, the proposed DWSP would not have a significant negative impact on the aesthetics of the plan area or its surroundings. The plan area does not contain natural or rural areas because it consists of the urbanized downtown area of Watsonville. The DWSP focuses on infill development which would reduce demolition of existing architecture while adding cohesive facades, streetscapes, and public art, among other visual enhancements and standards.

Infill development could increase the potential for demolishing existing historic structures, however, future development would also be subject to review for consistency with new zoning, overlays, and development standards which would preserve key elements that make Downtown unique. It would also prevent substantial increases in new sources of light pollution or glare in Watsonville, as described in Impact AES-3, above. Thus, buildout of the DWSP would not result in a cumulatively considerable contribution to significant cumulative aesthetic impacts.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.1-10
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Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-1

4.2 Air Quality
This section assesses potential impacts of implementation of the DWSP to air quality, including short-term construction emissions, long-term operational emissions, and potential impacts on sensitive receptors in and near the plan area.

4.2.1 Setting
a. Climate and Topography
The DWSP plan area is located in the North Central Coast Air Basin (Basin). The Basin covers an area of 5,159 square miles, including the counties of Santa Cruz, San Benito, and Monterey. The semipermanent high pressure cell in the eastern Pacific is the basic controlling factor in the climate of the Basin. In the summer, the high pressure cell is dominant and causes persistent west and northwest winds over the entire California coast. Air descends in the Pacific High forming a stable temperature inversion of hot air over a cool coastal layer of air. The onshore air currents pass over cool ocean waters to bring fog and relatively cool air into the coastal valleys. The warmer air loft acts as a lid to inhibit vertical air movement (MBARD, 2008a).

The generally northwest-southeast orientation of mountainous ridges tends to restrict and channel the summer onshore air currents. Surface heating in the interior portion of the Salinas and San Benito valleys creates a weak low pressure which intensifies the onshore air flow during the afternoon and evening. In the fall, the surface winds become weak, and the marine layer grows shallow, dissipating altogether on some days. The air flow is occasionally reversed in a weak offshore movement, and the relatively stationary air mass is held in place by the Pacific Highpressure cell, which allows pollutants to build up over a period of a few days. It is most often during this season that the north or east winds develop to transport pollutants from either the San Francisco Bay area or the Central Valley into the Basin (MBARD, 2008a).

During the winter, the Pacific High migrates southward and has less influence on the air basin. Air frequently flows in a southeasterly direction out of the Salinas and San Benito valleys, especially during night and morning hours. Northwest winds are nevertheless still dominant in winter, but easterly flow is more frequent. The general absence of deep, persistent inversions and the occasional storm systems usually result in good air quality for the Basin as a whole in winter and early spring (MBARD, 2008a).

Climate, or the average weather condition, affects air quality in several ways. Wind patterns can remove or add air pollutants emitted by stationary or mobile sources. Inversion, a condition where warm air traps cooler air underneath it, can hold pollutants near the ground by limiting upward mixing (dilution). Topography also affects the local climate, as valleys often trap emissions by limiting lateral dispersal.

Winds originating in the San Francisco Bay Area Air Basin to the north often transport pollutants into the Basin, where surface winds move the pollutants to the eastern part of the Basin. For instance, the transport of ozone precursor emissions from San Francisco Bay Area Air Basin through the Santa Clara Valley/San Benito River Valley plays a dominant role in ozone concentrations measured in San Benito County (MBARD, 2013). The transport of pollutants can often cause exceedances of air quality standards in the Basin.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.2-2
The plan area is located in the northern portion of the Basin. Air pollutant emissions within the Basin are generated primarily by stationary and mobile sources. Stationary sources can be divided into two major subcategories: point and area sources. Point sources occur at a specific location and are often identified by an exhaust vent or stack. Examples include boilers or combustion equipment that produce electricity or generate heat. Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and some consumer products. Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on- or off-road.

On-road sources may be legally operated on roadways and highways. Off-road sources include aircraft, ships, trains, and self-propelled construction equipment. Air pollutants can also be generated by the natural environment such as when high winds suspend fine dust particles. b. Air Pollution
The federal and state Clean Air Acts regulate the emission of airborne pollutants from various mobile and stationary sources. The United States Environmental Protection Agency (USEPA) is the federal agency designated to administer air quality regulation, while the California Air Resources Board (CARB) is the state equivalent in the California Environmental Protection Agency (CalEPA).

These agencies have established ambient air quality standards for the protection of public health.

Local air quality management control and planning is provided through regional air pollution control districts established by CARB for the 14 statewide air basins. CARB is responsible for control of mobile emission sources, while the local air pollution control districts are responsible for control of stationary sources and enforcing regulations. Watsonville is located within the Basin, which is under the jurisdiction of the Monterey Bay Air Resources District (MBARD).

Federal and state standards have been established for six criteria pollutants, including ozone, carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), particulates less than 10 and 2.5 microns in diameter (PM10 and PM2.5), and lead (see Table 4.2-1). California has also set standards for sulfates, hydrogen sulfide, vinyl chloride, and visibility-reducing particles. The local air quality management agency is required to monitor air pollutant levels to assure that air quality standards are met and, in the event they are not, to develop strategies to meet these standards. Depending on whether the standards are met or exceeded, the local air basin is classified as being in “attainment” or “nonattainment.”
Table 4.2-1 Current Federal and State Ambient Air Quality Standards Pollutant Federal Standard California Standard
Ozone 0.07 ppm (8-hr average) 0.09 ppm (1-hr average)

0.07 ppm (8-hr average)
Carbon Monoxide (CO) 35 ppm (1-hr average)
9 ppm (8-hr average)
20 ppm (1-hr average)
9 ppm (8-hr average)
Nitrogen Dioxide (NOx) 0.10 ppm (1-hr average)

0.053 ppm (annual average)

0.18 ppm (1-hr average)

0.03 ppm (annual average)
Sulfur Dioxide (SO2) 0.075 ppm (1-hr average)

0.14 ppm (24-hr average)

0.25 ppm (1-hr average)

0.04 ppm (24-hr average)
Lead 1.5 µg/m3 (3-month average) 1.5 µg/m3 (30-day average) Particulate Matter (PM10) 150 µg/m3 (24-hr average) 50 µg/m3 (24-hr average) 20 µg/m3 (annual average)
Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-3
Pollutant Federal Standard California Standard
Particulate Matter (PM2.5) 35 µg/m3 (24-hr average)
12 µg/m3 (annual average)
12 µg/m3 (annual average)
ppm= parts per million
µg/m3 = micrograms per cubic meter
Source: CARB 2016.

The general characteristics of the six criteria pollutants regulated by the Federal Clean Air Act and California Clean Air Act are described below.

Ozone
Ozone (O3) is a highly oxidative unstable gas produced by a photochemical reaction (triggered by sunlight) between nitrogen oxides (NOX) and reactive organic gases (ROG)/volatile organic compounds (VOC).1 ROG is composed of non-methane hydrocarbons (with specific exclusions), and NOX is composed of different chemical combinations of nitrogen and oxygen, mainly nitric oxide and nitrogen dioxide (NO2). NOX is formed during the combustion of fuels, while ROG is formed during the combustion and evaporation of organic solvents. As a highly reactive molecule, O3 readily combines with many different atmosphere components. Consequently, high O3 levels tend to exist only while high ROG and NOX levels are present to sustain the O3 formation process. Once the precursors have been depleted, O3 levels rapidly decline. Because these reactions occur on a regional rather than local scale, O3 is considered a regional pollutant. In addition, because O3 requires sunlight to form, it mainly occurs in concentrations considered serious between April and October. Groups most sensitive to O3 include children, the elderly, people with respiratory disorders, and people who exercise strenuously outdoors (USEPA 2022a). Depending on the level of exposure, O3 can cause coughing and a sore or scratch throat; make it more difficult to breathe deeply and vigorously and cause pain when taking a deep breath; inflame and damage the airways; make the lungs more susceptible to infection; and aggravate lung diseases such as asthma, emphysema, and chronic bronchitis.

Carbon Monoxide
Carbon monoxide (CO) is a localized pollutant found in high concentrations only near its source. The primary source of CO, a colorless, odorless, poisonous gas, is automobile traffic's incomplete combustion of petroleum fuels. Therefore, elevated concentrations are usually only found near areas of high traffic volumes. Other sources of CO include the incomplete combustion of petroleum fuels at power plants and fuel combustion from wood stoves and fireplaces during the winter. When CO levels are elevated outdoors, they can be of particular concern for people with some types of heart disease. These people already have a reduced ability to get oxygenated blood to their hearts in situations where they need more oxygen than usual. As a result, they are especially vulnerable to the effects of CO when exercising or under increased stress. In these situations, short-term exposure to elevated CO may result in reduced oxygen to the heart accompanied by chest pain, also known as angina (USEPA 2022a).
1 CARB defines VOC and ROG similarly as, “any compound of carbon excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate,” with the exception that VOC are compounds that participate in atmospheric photochemical reactions. For the purposes of this analysis, ROG and VOC are considered comparable in terms of mass emissions, and the term ROG is used in this report.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.2-4
Nitrogen Dioxide
Nitrogen dioxide (NO2) is a by-product of fuel combustion. The primary sources are motor vehicles and industrial boilers, and furnaces. The principal form of NOx produced by combustion is nitric oxide (NO), but NO reacts rapidly to form NO2, creating the mixture of NO and NO2, commonly called NOx. NO2 is a reactive, oxidizing gas and an acute irritant capable of damaging cell linings in the respiratory tract. Breathing air with a high concentration of NO2 can irritate airways in the human respiratory system. Such exposures over short periods can aggravate respiratory diseases leading to respiratory symptoms (such as coughing, wheezing, or difficulty breathing), hospital admissions, and visits to emergency rooms. Longer exposures to elevated concentrations of NO2 may contribute to the development of asthma and potentially increase susceptibility to respiratory infections. People with asthma and children and the elderly are generally at greater risk for the health effects of NO2 (USEPA 2022a). NO2 absorbs blue light and causes a reddish-brown cast to the atmosphere and reduced visibility. It can also contribute to the formation of O3/smog and acid rain.

Sulfur Dioxide
Sulfur dioxide (SO2) is included in a group of highly reactive gases known as “oxides of sulfur.” The largest sources of SO2 emissions are from fossil fuel combustion at power plants (73 percent) and other industrial facilities (20 percent). Smaller sources of SO2 emissions include industrial processes such as extracting metal from ore and burning fuels with a high sulfur content by locomotives, large ships, and off-road equipment. Short-term exposures to SO2 can harm the human respiratory system and make breathing difficult. People with asthma, particularly children, are sensitive to these effects of SO2 (USEPA 2022a).

Asbestos
Asbestos is a highly friable material often found in older buildings (pre-1979), typically used as insulation in walls or ceilings. It was formerly popular as an insulating material; however, it can pose a health risk when very small particles become airborne. In conformance with the Clean Air Act, USEPA established the National Emissions Standards for Hazardous Air Pollutants to protect the public. The asbestos regulations under National Emissions Standards for Hazardous Air Pollutants control work practices during the demolition and renovation of institutional, commercial, or industrial structures. Following identification of friable asbestos, the federal Occupational Safety and Health Administration required that asbestos trained and certified abatement personnel perform asbestos abatement. The Occupational Safety and Health Administration also required that all asbestos containing material removed from onsite structures be hauled to a licensed receiving facility and disposed of under proper manifest by a transportation company certified to handle asbestos. Disposal of any asbestos containing material is also regulated by the County Fire Department, and specific requirements are determined during the permitting process.

Lead
Lead (Pb) is a metal found naturally in the environment, as well as in manufacturing products. The major sources of Pb emissions historically have been mobile and industrial. However, due to the USEPA’s regulatory efforts to remove lead from gasoline, atmospheric Pb concentrations have declined substantially over the past several decades. The most dramatic reductions in Pb emissions occurred with the permanent phase-out of leaded gasoline, controls on emissions on emissions of Pb compounds through EPA’s air toxics program, and other national and state regulations. The result was a decrease of airborne Pb concentrations by 98 percent between 1980 and 2005 (U.S.

Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-5
EPA 2022a). As a result of phasing out leaded gasoline, metal processing is currently the primary source of Pb emissions. The highest Pb level in the air is generally found near Pb smelters. Other stationary sources include waste incinerators, utilities, and Pb-acid battery manufacturers. Pb can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems, and cardiovascular system depending on exposure. Pb exposure also affects the oxygen-carrying capacity of the blood. The Pb effects most likely encountered in current populations are neurological in children. Infants and young children are susceptible to Pb exposures, contributing to behavioral problems, learning deficits, and lowered intelligence quotient (USEPA 2022a).

Suspended Particulate Matter
Particulates less than 10 microns in diameter (PM10) and less than 2.5 microns in diameter (PM2.5) are comprised of finely divided solids and liquids such as dust, soot, aerosols, fumes, and mists. Both PM10 and PM2. are emitted into the atmosphere as by-products of fuel combustion and wind erosion of soil and unpaved roads. The atmosphere, through chemical reactions, can form particulate matter. The characteristics, sources, and potential health effects of PM10 and PM2.5 can be very different. PM10 is generally associated with dust mobilized by wind and vehicles. In contrast, PM2.5 is generally associated with combustion processes and formation in the atmosphere as a secondary pollutant through chemical reactions. PM10 can cause increased respiratory disease, lung damage, cancer, premature death, reduced visibility, surface soiling. For PM2.5, short-term exposures (up to 24-hours duration) have been associated with premature mortality, increased hospital admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory symptoms, and restricted activity days. These adverse health effects have been reported primarily in infants, children, and older adults with preexisting heart or lung diseases (CARB 2023a). c. Current Ambient Air Quality
Local air districts and the CARB monitor ambient air quality to assure that air quality standards are met, and if they are not met, to also develop strategies to meet the standards. Air quality monitoring stations measure pollutant ground-level concentrations ten feet aboveground level, typically. Depending on whether the standards are met or exceeded, the local air basin is classified as in “attainment” or “non-attainment.” Some areas are unclassified, which means no monitoring data are available. Unclassified areas are considered to be in attainment. Table 4.2-2 summarizes the State and federal attainment status for criteria pollutants in the Basin.

Table 4.2-2 Attainment Status of the North Central Coast Air Basin Pollutant State Standard (CAAQS) Federal Standard (NAAQS) Ozone Non-attainment/Transitional Unclassified/Attainment Inhalable Particulates (PM10) Non-attainment Unclassified Fine Particulates (PM2.5) Attainment Unclassified/Attainment Carbon Monoxide (CO) Unclassified (Santa Cruz County) Unclassified/Attainment Nitrogen Dioxide (NO2) Attainment Unclassified/Attainment Sulfur Dioxide (SOX) Attainment Unclassified
Lead Attainment Unclassified/Attainment
Source: CARB 2022
CAAQS = California Ambient Air Quality Standard, NAAQS = National Ambient Air Quality Standard Note: Non-attainment pollutants are highlighted in Bold.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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As shown in Table 4.2-2, although the Basin is in attainment or unclassified for all NAAQS, it is designated as non-attainment with respect to the more stringent California Ambient Air Quality Standard (CAAQS) PM10 standard and eight-hour ozone standard.

Ambient air quality is monitored at seven monitoring stations throughout the Basin: Scotts Valley, Santa Cruz, Hollister, Salinas, Carmel Valley, Pinnacles National Monument, and King City.

Table 4.2-3 summarizes the representative annual air quality data for the Watsonville vicinity over the years 2019-2021, which is the most recent available data. The nearest monitoring station to the plan area is Santa Cruz-2544 Soquel Avenue. As indicated in Table 4.2-3, there were thirteen exceedances of PM2.5 in 2020 during this time period.

Table 4.2-3 Ambient Air Quality Data
Pollutant 2019 2020 2021
Ozone (ppm), Worst 1-Hour 0.068 0.070 0.072
Number of days of State exceedances (>0.09 ppm) 0 0 0
Ozone (ppm), 8-Hour Average 0.059 0.057 0.058
Number of days of State exceedances (>0.07 ppm) 0 0 0
Number of days of Federal exceedances (>0.075 ppm) 0 0 0 Carbon Monoxide (CO) (ppm), Highest 8-Hour Average * * * Number of days of above State or Federal standard (>9.0 ppm) * * * Particulate Matter <10 microns, µg/m3, Worst 24 Hours * * * Number of days above State standard (>50 µg/m3) * * *
Number of days above Federal standard (>150 µg/m3) * * * Particulate Matter <2.5 microns, µg/m3, Worst 24 Hours 21.3 90.4 17.5 Number of days above Federal standard (>65 µg/m3) 0 13 0 * There was insufficient (or no) data available to determine the value. ppm = parts per million; µg/m3 = micrograms per cubic meter Source: CARB 2023bi
d. Hazardous Air Pollutants/Toxic Air Contaminants
Both USEPA and CARB regulate Hazardous Air Pollutants (HAPs)/toxic air contaminants (TACs).

According to Section 39655 of the California Health and Safety Code, a TAC is “an air pollutant which may cause or contribute to an increase in mortality or an increase in serious illness, or which may pose a present or potential hazard to human health.” In addition, 189 substances that have been listed as federal HAPs pursuant to Section 7412 of Title 42 of the United States Code are TACs under the State’s air toxics program pursuant to section 39657(b) of the California Health and Safety Code.

In addition to the criteria pollutants discussed above, Toxic Air Contaminants (TAC) are airborne substances diverse group of air pollutants that may cause or contribute to an increase in deaths or serious illness, or that may pose a present or potential hazard to human health. TACs include both organic and inorganic chemical substances that may be emitted from a variety of common sources, including gasoline stations, motor vehicles, dry cleaners, industrial operations, painting operations, and research and teaching facilities. One of the main sources of TACs in California is diesel engine exhaust that contains solid material known as diesel particulate matter (DPM). More than 90 percent of DPM is less than one micron in diameter (about 1/70th the diameter of a human hair) and Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-7
thus is a subset of PM2.5. Because of their extremely small size, these particles can be inhaled and eventually trapped in the bronchial and alveolar regions of the lungs (CARB 2023c). TACs are different than criteria pollutants because ambient air quality standards have not been established for TACs. TACs occurring at extremely low levels may still cause health effects and it is typically difficult to identify levels of exposure that do not produce adverse health effects. TAC impacts are described by carcinogenic risk and by chronic (i.e., long duration) and acute (i.e., severe but of short duration) adverse effects on human health. People exposed to TACs at sufficient concentrations and durations may have an increased chance of getting cancer or experiencing other serious health effects. These health effects can include damage to the immune system, as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory, and other health problems (U.S.

EPA 2020).
e. Sensitive Receptors
Certain population groups are more sensitive to air pollution than the general population; in particular, sensitive receptors include children, the elderly, and acutely ill and chronically ill persons, especially those with cardio-respiratory diseases. Sensitive receptors that are in proximity to localized sources of particulate matter, toxics, and CO are of particular concern. As described in the MBARD’s 2008 CEQA Guidelines, a sensitive receptor is defined as: any residence including private homes, condominiums, apartments, and living quarters; education resources such as preschools and kindergarten through grade twelve (k-12) schools; daycare centers; and health care facilities such as hospitals or retirement and nursing homes.

MBARD recommends evaluating potential impacts to sensitive receptors located within 1,000 feet of a subject site. In addition to the residential developments (including retirement and nursing homes), sensitive receptors within the plan area include any daycare centers and preschools located within the boundaries including in-home facilities as well as several schools such as Radcliff Elementary School, La Manzana School, Watsonville Prep School, Linscott Charter School, Watsonville High School, Central Christian School, and Moreland Notre Dame High School. There are no hospitals within the plan area.

4.2.2 Regulatory Setting
a. Federal Regulations and State
As discussed in more detail below, the federal and State governments have been empowered by the federal and State Clean Air Acts to regulate the emission of airborne pollutants and have established ambient air quality standards for the protection of public health. USEPA is the federal agency designated to administer air quality regulation, while CARB is the State equivalent in California.

Local control in air quality management is provided by CARB through county-level or regional (multicounty) air pollution control districts. CARB establishes air quality standards and is responsible for control of mobile emission sources, while the local air pollution control districts are responsible for enforcing standards and regulating stationary sources. CARB has established 14 air basins statewide.

Federal Clean Air Act
The USEPA is charged with implementing national air quality programs. USEPA’s air quality mandates are drawn primarily from the Federal Clean Air Act. The Federal Clean Air Act was passed in 1963 by the U.S. Congress and has been amended several times. The 1970 Federal Clean Air Act amendments strengthened previous legislation and laid the foundation for the regulatory scheme of Exhibit B
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the 1970s and 1980s. In 1977, Congress again added several provisions, including non-attainment requirements for areas not meeting NAAQS and the Prevention of Significant Deterioration program. The 1990 Federal Clean Air Act amendments represent the latest in a series of federal efforts to regulate the protection of air quality in the United States. The Federal Clean Air Act allows states to adopt more stringent standards or to include other additional pollution species.

National Ambient Air Quality Standards
As discussed above, the Federal Clean Air Act requires USEPA to establish primary and secondary NAAQS for a number of criteria air pollutants. The air pollutants for which standards have been established are considered the most prevalent air pollutants that are known to be hazardous to human health. NAAQS have been established for the following pollutants: ozone, CO, SO2, PM10, PM2.5, and lead.

Title III of the Federal Clean Air Act
As discussed above, HAPs are the air contaminants identified by USEPA as known or suspected to cause cancer, other serious illnesses, birth defects, or death. The Federal Clean Air Act requires USEPA to set standards for these pollutants and reduce emissions of controlled chemicals.

Specifically, Title III of the Federal Clean Air Act requires USEPA to promulgate National Emissions Standards for Hazardous Air Pollutants for certain categories of sources that emit one or more pollutants that are identified as HAPs. The Federal Clean Air Act also requires USEPA to set standards to control emissions of HAPs through mobile source control programs. These include programs that reformulated gasoline, national low emissions vehicle standards, Tier 2 motor vehicle emission standards, gasoline sulfur control requirements, and heavy-duty engine standards.

HAPs tend to be localized and are found in relatively low concentrations in ambient air. However, they can result in adverse chronic health effects if exposure to low concentrations occurs for long periods. Many HAPs originate from human activities, such as fuel combustion and solvent use.

Emission standards may differ between “major sources” and “area sources” of the HAPs/TACs.

Under the Federal Clean Air Act, major sources are defined as stationary sources with the potential to emit more than 10 tons per year of one HAP or more than 25 tons per year of any combination of HAPs; all other sources are considered area sources. Mobile source air toxics are a subset of the 188 HAPs. Of the 21 HAPs identified by USEPA as mobile source air toxics, a priority list of six priority HAPs were identified that include: diesel exhaust, benzene, formaldehyde, acetaldehyde, acrolein, and 1,3-butadiene. While vehicle miles traveled in the United States are expected to increase by 64 percent over the period 2000 to 2020, emissions of mobile source air toxics are anticipated to decrease substantially as a result of efforts to control mobile source emissions (by 57 percent to 67 percent depending on the contaminant).

California Clean Air Act
The California Clean Air Act, signed into law in 1988, requires all areas of the State to achieve and maintain the CAAQS by the earliest practical date. CARB is the State air pollution control agency and is a part of CalEPA. CARB is the agency responsible for coordination and oversight of State and local air pollution control programs in California, and for implementing the requirements of the California Clean Air Act. CARB overseas local district compliance with California and federal laws, approves local air quality plans, submits the State Implementation Plans to the USEPA, monitors air quality, determines and updates area designations and maps, and sets emissions standards for new mobile sources, consumer products, small utility engines, off-road vehicles, and fuels.

Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-9
California Ambient Air Quality Standards
The California Clean Air Act requires CARB to establish CAAQS. Similar to the NAAQS, CAAQS have been established for the following pollutants: ozone, CO, NO2, SO2, PM10, PM2.5, lead, vinyl chloride, hydrogen sulfide, sulfates, and visibility-reducing particulates. In most cases, the CAAQS are more stringent than the NAAQS pollutants. The California Clean Air Act requires that all local air districts in the State endeavor to achieve and maintain the CAAQS by the earliest practical date. The California Clean Air Act specifies that local air districts should focus particular attention on reducing the emissions from transportation and area-wide emission sources, and provides districts with the authority to regulate indirect sources.

California Air Resources Board Air Quality and Land Use Handbook In April 2005, CARB released the final version of its Air Quality and Land Use Handbook: A Community Health Perspective. This guidance document is intended to encourage local land use agencies to consider the risks from air pollution before they approve the siting of sensitive land uses such as residences near sources of TACs such as freeway and high traffic roads, commercial distribution centers, rail yards, ports, refineries, dry cleaners, gasoline stations and industrial facilities. These advisory recommendations include general setbacks or buffers from air pollution sources. However, unlike industrial or stationary sources of air pollution, the siting of new sensitive land uses does not require air quality permits or approval by air districts and as noted above, the CARB handbook provides guidance rather than binding regulations. b. Regional Regulations
MBARD regulates air quality in the Basin. MBARD is responsible for attainment planning related to criteria air pollutants as well as district rule development and enforcement. To assist agencies with air quality analyses prepared for CEQA assessments, MBARD published the CEQA Air Quality Guidelines document (2008b). The purpose of the Guidelines is to assist in the review and evaluation of air quality impacts from projects that are subject to CEQA. The Guidelines are an advisory document intended to provide lead agencies, consultants, and project proponents with uniform procedures for assessing potential air quality impacts and preparing the air quality section of environmental documents. The Guidelines are also intended to help these entities anticipate areas of concern from the MBARD in its role as a lead and/or responsible agency for air quality.

Air Quality Management Plan
In accordance with the California Clean Air Act, the MBARD developed the 2008 Air Quality Management Plan (AQMP) for the Monterey Bay Region (MBARD, 2008a). The 2008 AQMP is a transitional plan shifting focus of the MBARD’s efforts from achieving the 1-hour ozone component of the CAAQS to achieving the 8-hour ozone requirement. The plan includes an updated air quality trends analysis, which reflects both the 1- and 8-hour standards, as well as an updated emission inventory, which includes the latest information on stationary, area, and mobile emission sources.

In April 2013, MBARD adopted the 2012 Triennial Plan Revision (2012 AQMP Revision), which assesses and updates elements of the 2008 AQMP, including the air quality trends analysis, emission inventory, and mobile source programs. The 2012 AQMP Revision only addresses attainment of the State ozone standard. In 2012, USEPA designated the Basin as attainment of the current national 8- hour ozone standard of 0.075 ppm and in 2015 the national standard was revised to 0.070 ppm.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.2-10
In March 2017, MBARD adopted the 2012-2015 AQMP, which documents the District’s progress toward attaining the State ozone standard. Similar to the 2012 AQMP Revision, the 2012-2015 AQMP only addresses attainment of the State ozone standard. As mentioned, USEPA designated the Basin as attainment of the current national 8-hour ozone standard in the 2012 AQMP Revision and the Basin continues to be in attainment with the stricter national standard.

The following MBARD rules would limit emissions of air pollutants from construction and operation of the proposed project:
 Rule 400 (Visible Emissions) – Discharge of visible air pollutant emissions into the atmosphere from any emission source for a period or periods aggregating more than three minutes in any one hour, as observed using an appropriate test method, is prohibited.  Rule 402 (Nuisances) – No person shall discharge from any source whatsoever such quantities of air contaminants or other materials which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public; or which endanger the comfort, repose, health, or safety of any such persons or the public; or which cause, or have a natural tendency to cause, injury or damage to business or property.
 Rule 425 (Use of Cutback Asphalt) – The use of cutback asphalt (asphalt cement that has been blended with petroleum solvents) is restricted.
 Rule 426 (Architectural Coatings) – This rule limits the emissions of ROGs from the use of architectural coatings.
c. Local Regulations
City of Watsonville 2005 General Plan
The Watsonville 2005 General Plan Environmental Resources and Transportation and Circulation Elements includes the following goals, policies, and implementation measures pertaining to air quality that are relevant to this analysis:

Environmental Resource Management Element
 Goal 9.4 Air Quality: Maintain or improve the present air quality level within the Pajaro Valley.  Goal 9.11 Hazardous Materials: Protect the air, water, soil, and biotic resources from damage by exposure to hazardous materials through aggressive management of hazardous materials.  Goal 9.12 Energy: Promote the conservation of energy and the use of alternative energy resources in transportation and residential, commercial, and industrial development.  Policy 9.C Air Quality: The City shall cooperate with MBARD to maintain and improve regional air quality.
− Implementation Measure 9.C.1, Referral to MBARD: The City shall refer projects with identifiable air quality impacts to the MBARD for recommendation or appropriate air quality mitigations.
− Implementation Measure 9.C.2, Alternate Travel Modes: In order to reduce automobile related pollution, the City shall plan for and encourage the use of transit, ridesharing, bicycles, and walking as alternatives to automobile travel, and the use lowemission and electric vehicles.

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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-11
− Implementation Measure 9.C.3, Housing Jobs Linkage: The City shall encourage new residential development to include housing suitable to employees of workplaces in the City and its immediate environs in order to minimize commuting and the motor vehicle emissions thus generated. The City shall strive to locate housing and job land uses to enhance the use of carpooling and transit.
− Implementation Measure 9.C.4, Design Review: The City shall require new development to include consideration for transit, Transportation Demand Management, and alternative travel modes in project designs including but not limited to transit stops, car, and vanpool preferred parking, and bicycle access and storage facilities. − Implementation Measure 9.C.8, Transportation Management Associations: The City shall promote the creation of transportation management associations in areas of high employment density.
− Implementation Measure 9.C.9, Environmental Review: The City shall use the environmental review process to determine both stationary source and transportation related potential air quality impacts for project proposals. − Implementation Measure 9.C.10, Construction-related Impacts: The City shall require construction contractors to implement a dust abatement program to reduce the effect of construction on local PM10 concentrations.
 Policy 9.J Energy: The City shall strive to reduce non-renewable energy resource consumption and promote the use of alternative energy resources. − Implementation Measure 9.J.1, Alternative Transportation: As outlined in the Transportation and Circulation chapter, the City shall promote the use and development of alternative transportation modes intended to reduce the consumption of fossil fuels and other non-renewable energy resources.
− Implementation Measure 9.J.2, Development: The City shall encourage energy efficient design and design which utilizes solar opportunities in residential, commercial, and industrial development.
− Implementation Measure 9.J.3, Land Use and Transportation: Development shall be encouraged to occur in locations and at intensities that facilitate the use of alternative transportation modes to the extent compatible with the community.

Transportation and Circulation Element
 Policy 10.K Bicycle Facilities Development: The City shall plan for, and implement a comprehensive network of bicycle facilities in order to promote the bicycle as an alternative to the private automobile.
− Implementation Measure 10.K.1, New Construction and Improvements: New construction and improvements to designated streets shall include facilities for safe bicycle travel consistent with the City’s Bicycle Plan. − Implementation Measure 10.K.2, Designation of Bicycle Lanes: The City shall designate specified arterials for the development of bicycle lanes, consistent with the Bicycle Plan.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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 Policy 10.N Pedestrian Travel: The City shall plan for, and implement a comprehensive network of safe pedestrian facilities in order to promote pedestrian travel. − Implementation Measure 10.N.1, Construction/Improvement: The City shall require facilities for safe pedestrian travel as part of new construction or improvements to existing streets.
− Policy 10.P Pedestrian Access: Access for pedestrian travel shall be maintained where it already exists and provided where it does not, in order to prevent or eliminate barriers to pedestrian travel.
− Implementation Measure 10.P.1, Access to Adjoining Land Uses: The City shall require pedestrian access between adjoining multiple family residential developments, and from such residential developments to adjacent recreational or commercial areas.

4.2.3 Impact Analysis
a. Significance Thresholds and Methodology
Significance Thresholds
The analysis of the project’s air quality impacts follows the guidance and methodologies recommended in the MBARD CEQA Air Quality Guidelines (2008) as well as Appendix G of the State CEQA Guidelines.

According to Appendix G of the State CEQA Guidelines, the proposed project would result in potentially significant environmental effects on air quality if it would:
1) Conflict with or obstruct implementation of the applicable air quality plan; 2) Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or State ambient air quality standard (including releasing emissions which exceed qualitative thresholds for ozone precursors);
3) Expose sensitive receptors to substantial pollutant concentrations; and/or 4) Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

The State CEQA Guidelines further state that the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the determinations above.

MBARD Thresholds of significance
MBARD has issued criteria for determining the level of significance for project-specific impacts within its jurisdiction in accordance with the above thresholds. Based on criteria applied in or adapted from the MBARD Guidelines, the impacts related to emission of criteria air pollutants would be significant if the DWSP would:
 Be inconsistent with the adopted AQMP.
 During construction, cause a violation of PM10 CAAQS at nearby or upwind of sensitive receptors, based on whether the project would:

Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-13
− Emit greater than 82 lb/day of PM10 if located nearby or upwind of sensitive receptors; or
− Use equipment that is not “typical construction equipment” as specified in Section 5.3 of the MBARD CEQA Guidelines.
 During operations:
− Generate direct (area source or stationary) plus indirect (operational or mobile) emissions of either ROG or NOX that exceed 137 pounds per day (lbs/day); − Generate onsite emissions of PM10 exceeding 82 lbs/day; − Generate direct emissions of CO exceeding 550 lbs/day; or − Generate direct emissions of SOX exceeding 150 lbs/day.  Cause or substantially contribute to a violation of a CO standard.  MBARD’s Guidelines indicate that any of the following traffic effects should be assumed to generate a significant CO impact, unless CO dispersion modeling demonstrates otherwise:
 Intersections or road segments that operate at Level of Service (LOS) D or better would operate at LOS E or F with the project's traffic.
 Intersections or road segments that operate at LOS E or F where the volume-to-capacity ratio would increase 0.05 or more with the project's traffic.  Intersections that operate at LOS E or F where delay would increase by 10 seconds or more with the project's traffic.
 Unsignalized intersections which operate at LOS E or F where the reserve capacity would decrease by 50 or more with the project's traffic.
 The project would generate substantial heavy duty truck traffic or generate substantial traffic along urban street canyons or near a major stationary source of CO.

In addition to MBARD’s guidance from 2008 (MBARD 2008b), the Bay Area Air Quality Management District (2017) and South Coast Air Quality Management District (2003) also use the number of vehicles that pass through an intersection to determine if additional analysis is required. This is due to the drastic increase in efficiencies in automobiles with respect to CO emissions as well as the fact that their Air Districts, as with MBARD’s Air District, are in attainment for the Federal and State CO Standards. The SCAQMD studied four intersections in the 2003 AQMP and noted that the most congested intersection was that of Wilshire Boulevard and Veteran Avenue with an average daily vehicle count of 100,000. The 2003 AQMP (Table 4-10 of Appendix V in the AQMP) shows that emissions at this intersection were 4.6 ppm (1-hour average) and 3.2 (8-hour average). These are both substantially less than the CAAQS of 20 ppm and 5 ppm respectively. Therefore, if intersections are below 100,000 vehicles per day would not have the potential to case a CO Hotspot.

BAAQMD’s 2017 CEQA Guidelines have a screening analysis that identifies traffic volumes at affected intersections of less than 44,000 vehicles per hour, or 24,000 vehicles per hours where vertical and/or horizontal mixing is limited (e.g. tunnels, bridge underpass, below-grade roadway).

For the purposes of this analysis, for any roadway that exceeds the MBARD’s LOS criteria, significance shall be determined using compliance with 100,000 vehicles per day or 24,000 vehicles per hour screening levels.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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The MBARD guidelines state that odor impacts would be significant if the project would result in the emission of substantial concentrations of pollutants that produce objectionable odors, causing injury, nuisance, or annoyance to a considerable number of persons, or endangering the comfort, health, or safety of the public. If construction or operation of a project would emit pollutants associated with odors in substantial amounts, the analysis should assess the impact on existing or reasonably foreseeable sensitive receptors.

Air Quality Management Plan Consistency
Projects which increase population also generate population-related emissions, including those from motor vehicles, heating, and cooling emissions. Therefore, a project would conflict with or obstruct implementation of the 2012 – 2015 AQMP for the Monterey Bay Region if it is inconsistent with the Plan’s population growth assumptions. Emissions have been forecast in the AQMP using population forecasts adopted by the Association of Monterey Bay Area Governments (AMBAG).

Thus, a proposed project is consistent with the AQMP if the countywide increase in population resulting from the project will not cause the estimated cumulative population to exceed forecasts.

Additionally, projects that do not exceed the construction or operational regional thresholds as discussed above would be considered to be consistent with the AQMP.

Cumulative Impacts
Given the nature of air quality impacts, the criteria for assessing cumulative impacts on localized air quality such as CO and PM10 are the same as those for assessing individual project impacts, as listed under Significance Thresholds above. Projects that do not exceed MBARD’s construction or operational thresholds and that are consistent with the AQMP would not have cumulatively considerable impacts on regional air quality (MBARD, 2008a).

Methodology
The analysis of air quality impacts conforms to the methodologies recommended in the MBARD’s CEQA Air Quality Guidelines (2008). The handbook includes thresholds for emissions associated with both construction and operation of proposed projects.

Construction Emissions
The regional construction emissions associated with development envisioned in the DWSP were calculated using CalEEMod version 2022.1. As discussed in Section 2.0, Project Description, the project would be constructed over 20 to 30 years. As a conservative estimate of growth, the analysis assumes that in any year up to one-twentieth of the project would be constructed. This assumes construction would be completed within 20 years. As regional thresholds are identified in pounds per day as discussed under Significance Thresholds above, one year of growth was assumed. In order to estimate emissions from multiple mixed-use projects occurring at the same time, seven project scenarios were considered. The analysis assumes that all seven of these development scenarios could be under construction at the same time. These scenarios include:
 Residential and Retail
 Office and Retail
 Research and Development and Restaurant
 Industrial Park and Restaurant
 General Light Industrial and Restaurant
Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-15
 Civic Center
 Government Office
Due to the nature of the DWSP, each construction scenario assumes the demolition of the one half of the growth. As specific sites are unknown, the analysis assumes that all soils will be balanced onsite. This is a reasonable assumption given that the plan area is relatively flat and would not require substantial grading or contouring to facilitate typical development. As a conservative estimate of emissions, it was assumed that construction could begin as early as September of 2023.

The analysis assumes that one third of the project identified industrial and civic uses would be asphalt paved. Construction schedules, equipment fleets, and on-road worker, vendor and haul trucks, and architectural coating applications were determined using CalEEMod defaults.

Operational Emissions
Operational emissions associated with project implementation were estimated using CalEEMod defaults for mobile source emissions, area sources, and energy sources. Emissions attributed to energy use include electricity and natural gas consumption for space and water heating and cooling.

Area source emissions are generated by landscape maintenance equipment, consumer products, and architectural coatings. Water and solid waste information were extracted from the Initial Study (see Appendix A).
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project conflict with or obstruct implementation of the applicable air quality plan?
Impact AQ-1 THE PROPOSED PROJECT WOULD INTRODUCE ADDITIONAL HOUSING TO THE AREA AND

CONTRIBUTE TO POPULATION GROWTH THAT CONFLICTS WITH THE GROWTH ASSUMPTIONS IN THE AIR QUALITY MANAGEMENT PLAN. IMPACTS WOULD BE SIGNIFICANT AND UNAVOIDABLE.

As noted above in Methodology and Significance Thresholds, a project would conflict with or obstruct implementation of the AQMP if it is inconsistent with the population growth assumptions included in the AQMP (MBARD, 2008b). As detailed in Section 4.7 Population and Housing, the current population of Watsonville is 50,669 and the average household size is approximately 3.52 persons per household. The proposed project would add an estimated 3,866 additional residential units, which would increase the City’s population by 13,679 to approximately 64,348. According to AMBAG’s population forecast, the City’s population would be 56,344 in 2045. Therefore, the estimated population of 64,348 with buildout of the DWSP would exceed AMBAG’s population forecasts for 2045 by approximately 8,004 people. Since the anticipated increase in population would be inconsistent with long-term growth projections for the county, implementation of the DWSP would conflict with an air quality plan.

As detailed in impact AQ-2, development under the DWSP would not exceed regional construction emissions for PM10. However, operational emissions would exceed regional threshold of ROG, CO and PM10. Therefore, development under the DWSP could conflict with the AQMP and impacts are potentially significant.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.2-16
Mitigation Measures
AQ-1 Conduct Project Specific Air Quality Analysis
The City shall require future projects that are subject to discretionary approval and that are not found to be exempt from CEQA review to evaluate potential air quality impacts as part of projectlevel CEQA analysis and implement respective mitigation measures to minimize impacts that exceed MBARD project level thresholds.

Significance After Mitigation
There are no feasible mitigation measures available to reduce population and employment and be consistent with the objectives of the DWSP. Reducing the growth envisioned in the DWSP would not necessarily reduce population growth because people could still move to the region or Basin, but would reside outside of the plan area. Additionally, as the AQMP is updated to reflect new growth assumptions, the anticipated growth from the DWSP would be accounted for in the next AQMP emissions calculations. However, as the growth forecasts are currently inconsistent with AQMP projections, impacts would remain significant and unavoidable until that time.

As detailed under Impact AQ-2, even with the incorporation of Mitigation Measure AQ-1, there is the potential for ROG and CO emissions to exceed operational regulatory thresholds. Therefore, with the incorporation of mitigation, impacts related to conflict with an air quality management plan would remain significant and unavoidable.

Threshold 2: Would the project result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard?
Impact AQ-2 CONSTRUCTION AND OPERATION OF DEVELOPMENT ENVISIONED BY THE DWSP WOULD

RESULT IN THE TEMPORARY AND LONG-TERM GENERATION OF AIR POLLUTANTS, WHICH WOULD AFFECT LOCAL AIR QUALITY AND EXCEED MBARD THRESHOLDS. THEREFORE, THIS IMPACT IS SIGNIFICANT AND UNAVOIDABLE.

Construction Emissions
Construction emissions are generally referred to as temporary impacts that occur during construction activities but end shortly after construction is completed. Fugitive dust emissions are among the pollutants of greatest concern with respect to construction activities. General site grading operations are the primary sources of fugitive dust emissions. However, these emissions can vary greatly, depending on the level of activity, the specific operations taking place, the number and types of equipment operated, vehicle speeds, local soil conditions, weather conditions, and the amount of earth disturbance from site grading. Emissions of ozone precursors NOX and ROG are primarily generated by the operation of off-road construction equipment and mobile sources such as delivery vehicles and construction worker vehicles. Generation of these emissions vary as a function of the types and number of heavy-duty, off-road equipment used and the intensity and frequency of their operation, as well as vehicle trips per day associated with delivery of construction materials, the export of soil, vendor trips, and worker commute trips.

Construction of the development envisioned in the DWSP would result in the temporary generation of vehicle and equipment exhaust and fugitive dust over the course of construction. Daily construction emissions related to one year of construction are presented in Table 4.2-4.

Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-17
Table 4.2-4 Estimated Construction Emissions
Year
Maximum Daily Emissions (lbs/day)
ROG NOx CO SOX PM10 PM2.5
Residential and Retail 15.1 25.0 143.2 0.2 15.3 7.0
Office and Retail 16.5 29.0 36.0 0.1 1.6 1.3
Research and Development and Restaurant 24.3 29.0 36.2 0.1 1.7 1.3 Industrial Park and Restaurant 59.9 29.2 37.1 0.1 1.7 1.3 General Light Industrial and Restaurant 100.7 68.5 73.7 0.1 9.0 5.4 Civic Center 12.5 28.9 36.0 0.1 1.6 1.3
Government Office 12.5 28.9 36.0 0.1 1.6 1.3
Maximum Daily Construction Emissions 242 238 398 1 32 19 MBARD Significance Threshold N/A N/A N/A N/A 82 N/A
Exceeds Threshold? N/A N/A N/A N/A No N/A
See Appendix B CalEEMod worksheets.

As shown in Table 4.2-4, construction of the development envisioned in the DWSP would result in a maximum of 32 lbs/day of PM10, which is below the MBARD threshold of 82 lbs/day of PM10.

Furthermore, compliance with MBARD Rule 400 (Visible Emissions) and Rule 425 (Use of Cutback Asphalt) would further reduce emissions of dust particulates during construction activity. Analysis quantifies implementation of one of MBARD’s BMP for controlling fugitive dust. The analysis assumes that active construction areas would be watered at least twice daily. Although the estimated annual emissions would be below thresholds of significance for PM10, MBARD recommends the use of the following additional BMPs for the control of short-term construction generated emissions in any event:
 Prohibit all grading activities during periods of high wind (over 15 mph).  Apply chemical soil stabilizers on inactive construction areas (disturbed lands within construction projects that are unused for at least four consecutive days).  Apply non-toxic binders (e.g., latex acrylic copolymer) to exposed areas after cut and fill operations and hydroseed areas.
 Haul trucks shall maintain at least two feet of freeboard.  Cover all trucks hauling soil, sand, and other loose materials.  Plant tree windbreaks on the windward perimeter of construction projects if adjacent to open land.
 Plant vegetative ground cover in disturbed areas as quickly as possible.  Cover inactive storage piles.
 Install wheel washers at the entrance to construction sites for all exiting trucks.  Pave all roads on construction sites.
 Sweep streets, if visible soil material is carried out from the construction site.  Post a publicly visible sign which specifies the telephone number and person to contact regarding dust complaints. This person shall respond to complaints and take corrective action within 48 hours. The phone number of the MBARD shall be visible to ensure compliance with Rule 402 (Nuisance).

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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 Limit the area under construction at any one time.

Implementation of the MBARD recommended BMPs or equivalent measure would be required for compliance with the City’s General Plan Implementation Measure 9.C.10, requiring a dust abatement program during construction. Even without implementation of the MBARD recommended BMPs, the DWSP’s would result in less than significant impacts related to construction air emissions.

Operational Emissions
Long-term operational emissions associated with the DWSP are those attributed to vehicle trips (mobile emissions), the use of natural gas and electricity (energy source emissions), and consumer products, architectural coatings, and landscape maintenance equipment (area source emissions) from development envisioned in the DWSP. CalEEMod was used to calculate emissions based on the proposed land uses for the plan area and the number of trips generated. Table 4.2-5 illustrates the long-term operational emissions from the project. The analysis does not take into account the Title 24 requirement of implementation of electric vehicle charging stations for development or projects that include vehicle parking, nor does it account for ambient emissions reductions from the potential removal of existing land uses. As this is a program level analysis, the exact nature and location of the individual development projects is unknown and therefore the amount of electric vehicle charging stations, or the amount of demolition required is unknown. Therefore, accounting for removal of these emissions would be speculative. As shown in Table 4.2-5, emissions from operational emissions would exceed MBARD’s significance thresholds for ROG, CO, and PM10.

Impacts from operational emissions would be potentially significant.

Table 4.2-5 Estimated Operational Emissions
Category
Maximum Daily Emissions (lbs/day)
ROG NOx CO SOX PM10 PM2.5
Area 129 0 253 0 0 0
Energy 2 33 18 0 3 3
Mobile 128 67 776 2 83 15
Total* 259 100 1,047 2 85 18
MBARD Significance Threshold 137 137 550 150 82 N/A
Exceeds Threshold? Yes No Yes No Yes N/A
*Numbers may not total due to rounding.

See Appendix B for CalEEMod worksheets.

Mitigation Measures
Implementation of Mitigation Measure AQ-1 is required.

Significance After Mitigation
The analysis does not take into account the Title 24 requirement of implementation of electric vehicle charging stations, nor does it account for net emissions from the potential removal of existing land uses. This would reduce overall DWSP operational emissions. Incorporation of these features and implementation of Mitigation Measure AQ-1 could reduce operational emissions to Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-19
below MBARD regulatory thresholds at the individual development level and below MBARD regulatory thresholds for PM10 at the plan level. However, it is unknown if these reductions would reduce cumulative DWSP operational emissions of ROG and CO to below regulatory thresholds.

Therefore, impacts would remain significant and unavoidable for operational emissions.

Threshold 3: Would the project expose sensitive receptors to substantial pollutant concentrations?
Impact AQ-3 THE DEVELOPMENT ENVISIONED IN THE DWSP WOULD NOT EXPOSE SENSITIVE RECEPTORS TO SUBSTANTIAL POLLUTANT CONCENTRATIONS. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH IMPLEMENTATION OF MITIGATION MEASURES.

Construction Dust
As described under Impact AQ-2, emissions from construction of development envisioned in the DWSP would not exceed MBARD daily thresholds. The nearest existing sensitive receptors to the area proposed for construction could include existing sensitive receptors adjacent to new development site.

MBARD recommends evaluating potential impacts to sensitive receptors within 1,000 feet of a project site; however, as shown in Impact AQ-2, the highest daily PM10 emissions associated with construction would not exceed the MBARD’s threshold of 82 pounds per day for seven development scenarios occurring at the same time and would be substantially less for a single development scenario within 1,000 feet of a receptor. This estimate for PM10 emissions included the assumption of watering two times per day as well as Rule 426 (Architectural Coatings) but does not include compliance with MBARD Rule 400 (Visible Emissions) or Rule 425 (Use of Cutback Asphalt), which would further reduce emissions of dust particulates. Therefore, the DWSP would have a less than significant impact on sensitive receptors as it relates to construction dust emissions.

Short-Term Construction Toxic Air Contaminants
The greatest potential for exposure to substantial pollutant concentrations and TAC emissions during construction of development envisioned in the DWSP would be diesel particulate emissions associated with heavy duty equipment operations and truck traffic. Diesel exhaust causes health effects from both short-term or acute exposures, and long-term chronic exposures. The type and severity of health effects depends upon several factors including the amount of chemical exposure and the duration of exposure. Acute exposure to diesel exhaust may cause irritation to eyes, nose, throat and lungs, and some neurological effects, such as lightheadedness. Acute exposure may also elicit a cough or nausea as well as exacerbated asthma. Chronic exposure to diesel exhaust in experimental animal inhalation studies has shown a range of dose-dependent lung inflammation and cellular changes in the lung and immunological effects. Based upon human and laboratory studies, there is considerable evidence that diesel exhaust is a carcinogen. Human epidemiological studies demonstrate an association between diesel exhaust exposure and increased lung cancer rates in occupational settings.

The specific locations within the plan area of future construction activity for the DWSP are not currently known. Because the exact nature of the construction activities on an individual development level, as well as the distance to sensitive receptors is unknown, the development under the DWSP could potentially result in substantial pollutant concentrations during construction activities. As a result, this impact would be potentially significant.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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Operational Toxic Air Contaminants
Diesel particulate matter would be emitted from diesel-fueled vehicles generated by the development envisioned in the DWSP during operation and by existing traffic adjacent to the project site. The particulate matter component of diesel exhaust has been classified as a TAC by CARB based on its potential to cause cancer and other adverse health effects. Urban roads with traffic volumes exceeding 100,000 vehicles per day or rural roads with volumes greater than 50,000 vehicles per day are potentially hazardous sources of TACs within 500 feet of a sensitive receptor.

There are no roadways within the DWSP area that have traffic volumes that exceed these thresholds (Kimley Horn, 2022). Highway 1, which does have traffic volumes exceeding 50,000 vehicles per day is located approximately 5,500 feet west of the DWSP plan area, well beyond the 500 feet threshold.

Additionally, land uses in the plan area could incorporate generators, other permitted sources, potentially unpermitted sources and potentially heavy-duty truck traffic in excess of 100 vehicles per day. Permitted sources such as generator use, would be required by MBARD to be below regulatory risk thresholds and would not represent a potential impact. However, given the exact nature of the development is unknown as is the potential inclusion of unpermitted sources and/or potential for heavy-duty trucks to exceed 100 vehicles per day at any site, coupled with the unknown distance between these sources and the potential receptors, operational health impacts would be potentially significant.

CO Hotspots
Areas with high vehicle density and poor air circulation, such as congested intersections and parking garages, have the potential to create high concentrations of CO, known as carbon monoxide “hot spots,” which can expose sensitive receptors to substantial pollutant concentrations. Specifically, hot spots can be created at intersections where traffic levels are sufficiently high such that the local CO concentration exceeds the NAAQS of 35.0 ppm or the CAAQS of 20.0 ppm. Where intersections may operate under conditions that could result in elevated CO concentrations, sensitive receptors could be exposed to the CO hotspot.

The Transportation Impact Analysis (TIA) (see Appendix E) studied nine intersections within the plan area for traffic congestion. Under existing and existing plus project conditions all nine intersections operate within acceptable City standards. Under future plus project all intersections would also operate acceptable with the exception of Riverside Drive and Main Street which would operate unacceptable with traffic congestion. This intersection would have a daily peak hourly traffic count of 4,707 and a daily traffic count of approximately 47,000 both of which are below the 24,000 hourly and 100,000 daily numeric screening levels. Additionally, the TIA indicates that this intersection is highly influenced by regional traffic originating outside of Watsonville. The TIA also indicates that there are future local and regional projects that would have a positive impact on traffic volumes and delay at this intersection. This, coupled with hourly and daily threshold being below numeric screening levels, results in CO hotspot impacts that are less than significant.

Mitigation Measures
Implementation of Mitigation Measures AQ-1, AQ-3(a) and AC-3(b) are required.

Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-21
AQ-3(a) Construction Equipment
The project applicant for individual developments or projects envisioned in the DWSP shall ensure the following requirements are incorporated into applicable bid documents, purchase orders, and contracts. Contractors shall confirm the ability to supply the compliant construction equipment prior to any ground-disturbing and construction activities:
 Mobile off-road construction equipment (wheeled or tracked) greater than 50 hp used during construction of the project shall meet the U.S. EPA Tier 4 final standards. In the event of specialized equipment use where Tier 4 equipment is not commercially available at the time of construction, the equipment shall, at a minimum, meet the Tier 3 standards. Zero-emissions construction equipment may be incorporated in lieu of Tier 4 final equipment. A copy of each equipment’s certified tier specification or model year specification shall be available to the City upon request at the time of mobilization of each piece of equipment.  Mobile off-road construction equipment less than 50 hp used during construction of the individual projects shall be electric or other alternative fuel type. A copy of each unit’s certified tier specification or model year specification shall be available to the City upon request at the time of mobilization of each applicable unit of equipment.  Electric hook-ups to the power gird shall be used instead of temporary diesel- or gasolinepowered generators, whenever feasible during construction of development or projects envisioned in the DWSP. If generators need to be used, the generators shall be non-diesel generators.

AQ-3(b) Operational Health Risk Assessment
The City shall require all applicants for development projects in the plan area that are within the buffer distances cited in the CARB’s Air quality and Land Use Handbook: A Community Health Perspective April 2005, and incorporate any of the following features, to conduct an operational health risk assessment. The health risk assessment shall follow MBARD and the Office of Environmental Health Hazards Assessment guidelines. The health risk analysis shall mitigate the risk in exceedance of regulatory thresholds to below the regulatory thresholds. The features that shall require an operational health risk analysis include:
 Incorporation of unpermitted sources (such as industrial processes that emit TACs);  Incorporation of diesel heavy duty-vehicles greater than 100 trips per day; or  Incorporation of more than 300 hours per week of diesel transportation refrigeration unit operations.

Significance After Mitigation
Incorporation of Mitigation Measure AQ-1 would require all individual development envisioned in the DWSP that are required to undergo CEQA analysis to complete a development specific air quality analysis. Mitigation Measure AQ-3(a) requires the use of Tier 4 equipment, alternative equipment, and electric hook-ups during construction of development in the DWSP. These measures would address and reduce TAC impacts from construction. Implementation of Mitigation Measure AQ-3(a) would reduce TAC impacts to below regulatory thresholds, and impacts from construction TACs would be reduced to less than significant levels.

Incorporation of Mitigation Measure AQ-3(b) would require an operational health risk assessment for development projects that meet the provided criteria and to mitigate any potential operational Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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health risks to below regulatory thresholds. Therefore, implementation of this mitigation measure would reduce TAC risks from operational activities to a less than significant level.

Overall, impacts from construction and operational TAC’s would be reduced to less than significant with the implementation of mitigation.

Threshold 4: Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Impact AQ-4 THE PROJECT WOULD HAS THE POTENTIAL TO CREATE OBJECTIONABLE ODORS THAT WOULD AFFECT NEIGHBORING PROPERTIES. IMPACTS RELATED TO ODORS WOULD BE LESS THAN SIGNIFICANT WITH MITIGATION.

Land uses typically producing objectionable odors include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, animal farms, fiberglass molding, and other industrial uses. While the majority of land uses identified under the DWSP would not be associated with objectionable odors, there is the potential for some of the industrial development envisioned in the DWSP to fall within food processing or other potential odor source categories in proximity to residential uses. Therefore, the DWSP would have the potential to result in significant impacts during operation of development envisioned in the DWSP.

During construction activities for development in the DWSP, short-term, temporary odors from vehicle exhaust and construction equipment engines would occur. The plan area is without substantially tall buildings, such as high-rise towers, to block air movement and hold odors, construction-related odors would disperse and dissipate fairly quickly and would not cause substantial odors at the closest sensitive receptors. In addition, construction-related odors would be relatively short-term and would cease upon completion of construction. Therefore, impacts related to objectionable odors during construction or operation of development envisioned in the DWSP would be less than significant.

Mitigation Measures
Implementation of Mitigation Measure AQ-1 is required.

Significance After Mitigation
Implementation of Mitigation Measure AQ-1 requires the analysis of air pollutant emissions of future individual projects in the plan area subject to CEQA. As part of the analysis, odor emissions would be analyzed for those projects that may fall into an odor source category. Where emissions of odors are found to be potentially significant, odor emissions would be mitigated to less than significant levels through measures developed specific to that individual project. The applicant or owner of that project would implement the specific measures. Therefore, with the implementation of Mitigation Measure AQ-1, overall DWSP odor emissions would be reduced to less than significant levels.

Exhibit B
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Environmental Impact Analysis
Air Quality
Draft Environmental Impact Report 4.2-23
c. Cumulative Impacts
IMPACT AQ-C1: THE DWSP WOULD HAVE A CUMULATIVELY CONSIDERABLE CONTRIBUTION TO A

SIGNIFICANT CUMULATIVE IMPACT RELATED TO EMISSIONS OF AIR POLLUTION AND CONFLICTS WITH AN APPLICABLE AIR QUALITY MANAGEMENT PLAN.

The geographic scope for considering cumulative impacts to air quality is the Basin. Air pollutants have impacts that are usually, though not always, cumulative by nature. Any new source of pollution may combine with other cumulative projects to result in violations of criteria pollutant standards if the existing background sources cause nonattainment conditions, as they do according to the State standards for ozone and particulate matter in MBARD. Air districts manage attainment of the criteria pollutant standards by adopting rules, regulations, and attainment plans, which comprise a multifaceted programmatic approach to such attainment. Because attainment is measured within an air basin, the use of the Basin for the cumulative impacts assessment area is reasonable.

The proposed project would generate ROG and NOX emissions, both precursors to ozone, throughout construction activities and through long-term operations. When high levels of ROG and NOX are present, ozone is able to be formed, however once the precursors decline, ozone levels also decline. As shown in Table 4.2-5, ROG emissions would exceed MBARD thresholds during operations. Emissions of PM10 would occur throughout construction and operations of the proposed project. These emissions, as shown in Table 4.2-4 and Table 4.2-5, would not exceed MBARD thresholds during construction but would exceed MBARD thresholds during operations.

MBARD’s approach to determining cumulative air quality impacts for criteria air pollutants is the same as for assessing individual project impacts. A project that does not exceed MBARD’s construction or operational thresholds and is consistent with the 2012 - 2015 AQMP would not have cumulatively considerable impacts on regional air quality (MBARD, 2008b). Since the proposed project emissions of ROG, PM10 and CO, would exceed MBARD thresholds during operations, exceedances of ROG and CO cannot be fully mitigated to below thresholds, and because the project would be inconsistent with the AQMP, cumulative impacts would significant and unavoidable.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.2-24
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Exhibit B
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Environmental Impact Analysis
Biological Resources
Draft Environmental Impact Report 4.3-1

4.3 Biological Resources
This section addresses impacts to biological resources, including special status species, sensitive natural communities, regulated waters and wetlands, sensitive habitat and mature native trees, and wildlife movement corridors.

4.3.1 Setting
Land Cover Types
The entire DWSP plan area consists of urban land cover. Most of the plan area is developed with small sections of non-native vegetation and bare ground. The General Plan land use designations include Central Commercial, General Commercial, Industrial, Public/Quasi-Public, Residential High Density, and Residential Low Density. No native vegetative communities exist within the plan area; however, scattered ornamental vegetation and native plants are present throughout the plan area.

Special Status Species
Special status species are those plants and animals listed, proposed for listing, or candidates for listing as threatened or endangered by the U.S. Fish and Wildlife Service (USFWS) or National Marine Fisheries Service (NMFS) under the Federal Endangered Species Act; those listed or candidates for listing as rare, threatened, or endangered by the California Department of Fish and Wildlife (CDFW) under the California Endangered Species Act; animals designated as “Species of Special Concern” by CDFW; and CDFW Special Plants, specifically those with a California Rare Plant Rank of 1A, 1B and 2 as assigned by the California Native Plant Society (CNPS) online Inventory of Rare and Endangered Plants of California (2022). A number of special status wildlife species are also considered to be of “local concern” by the County of Santa Cruz. Animals in this category are of concern because they have limited distributions, are experiencing local or regional population declines, are vulnerable to current or future threats to their preferred habitat, and/or are of unusual scientific, recreational, or educational value.

Data used to characterize the biological resources on and adjacent to the plan area included aerial photographs, topographic maps, and accepted scientific texts to identify species. Other data on biological resources were collected from numerous sources, including relevant literature, maps of natural resources, and queries of the Information for Planning and Consultation system (IPaC; USFWS 2022a), California Natural Diversity Database (CNDDB; CDFW 2022a), and online Inventory of Rare and Endangered Plants of California (Inventory; CNPS 2022). The query of these data sources was conducted in October 2022 for a 5-mile radius for IPaC, and for the USGS Watsonville West and 7 surrounding 7.5-minute series quadrangles for CNDDB and Inventory. 1 Standard queries of the
CNDDB and Inventory include eight surrounding quadrangles; however, one of the quadrangles surrounding Watsonville West quadrangle is entirely within the Pacific Ocean and was not included in this analysis. The Critical Habitat Mapper (USFWS 2022b), National Wetlands Inventory (USFWS 2022c), and eBird (The Cornell Lab of Ornithology 2022) were also queried.

A target list of special status plant and animal species that could potentially occur in the plan area was developed based on the outcome of the database queries and resultant lists of special status 1 Typically, a topographic quadrangle is surrounded by 8 adjacent topographic quadrangles. However, the extent of the Watsonville West quadrangle extends to the coastline of the Pacific Ocean/Monterey, and there is no adjacent quadrangle to the west for this reason.

Accordingly, the Watsonville West quadrangle has only seven surrounding USGS quadrangles.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.3-2
species that were reviewed by Rincon’s regional biological experts for accuracy and completeness.

The final list of special status species and sensitive natural communities was evaluated based on documented occurrences in the eight-quadrangle search area and biologists’ expert opinions on species known to occur in the region. The evaluation results and justification were compiled into a table (Appendix C).

Special Status Plant Species
Based on the database and literature review, 45 special status plant species occur in the eightquadrangle area including and surrounding the plan area. All but one of these species were determined to be absent from the within the plan area due to a combination of factors including absence of suitable habitat, lack of specific microhabitat or soil requirements, such as serpentine, alkaline, or sandy soils, and/or the elevation range of the species outside the range of the plan area.

One species, the Santa Cruz tarplant (Holocarpha micradenia), was determined to have a low potential to occur within the plan area. There are ten CNDDB occurrences of this species within five miles of the plan area; however, there is only marginally suitable habitat for this species within the plan area, so it was determined to have a low potential to occur. Santa Cruz tarplant is listed as threatened by USFWS and endangered by CDFW.

Special Status Wildlife Species
Based on the database and literature review, 40 special status wildlife species occur in the eightquadrangle area including and surrounding the plan area. Given the urbanized condition of the plan area, it does not contain adequate habitat to support the 40 special status wildlife species. A number of these species, primarily birds, have a low potential to occur within the plan area for brief periods of time as they disperse from more suitable habitat surrounding the plan area. For the purposes of CEQA analysis, non-listed special status species with low potential to occur on site will not be addressed further.

Wildlife Corridors
Wildlife movement corridors, or habitat linkages, are generally defined as connections between habitats that allow for physical and genetic exchange between otherwise isolated animal populations. Such linkages may serve a local purpose, such as providing a linkage between foraging and denning areas, or they may be regional in nature. Some habitat linkages may serve as migration corridors, wherein animals periodically move away from an area and then subsequently return.

Others may be important as dispersal corridors for young animals. A group of habitat linkages in an area can form a wildlife corridor network. The California Essential Habitat Connectivity project commissioned by the California Department of Transportation and CDFW identifies “Natural Landscape Blocks” which support native biodiversity and the “Essential Connectivity Areas” which link them (Spencer et al. 2010). Because the plan area is thoroughly urbanized and more suitable habitat is nearby but outside of the plan area, the plan area does not provide value as a wildlife corridor.

Exhibit B
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Environmental Impact Analysis
Biological Resources
Draft Environmental Impact Report 4.3-3

4.3.2 Regulatory Setting
a. Federal Regulations
Federal Endangered Species Act
The federal Endangered Species Act protects federally listed wildlife species from harm or take, which is broadly defined as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, collect, or attempt to engage in any such conduct.” Take can also include habitat modification or degradation that directly results in death or injury of a listed wildlife species. An activity can be defined as take even if it is unintentional or accidental. Listed plant species are provided less protection than listed wildlife species. Listed plant species are legally protected from take under the Federal Endangered Species Act only if they occur on federal lands.

The USFWS and the National Marine Fisheries Service have jurisdiction over federally listed, threatened, and endangered species under Federal Endangered Species Act. The USFWS also maintains lists of proposed and candidate species. Species on these lists are not legally protected under Federal Endangered Species Act, but may become listed in the near future and are often included in their review of a project.

The federal Migratory Bird Treaty Act, 16 U.S.C. Section 703, prohibits killing, possessing, or trading of migratory birds except in accordance with regulations prescribed by the Secretary of the Interior.

The Migratory Bird Treaty Act protects whole birds, parts of birds, and bird eggs and nests; and prohibits the possession of all nests of protected bird species whether they are active or inactive. An active nest is defined as having eggs or young, as described by the Department of the Interior in its April 16, 2003 Migratory Bird Permit Memorandum. Nest starts (nests that are under construction and do not yet contain eggs) are not protected from destruction.

Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act The Migratory Bird Treaty Act authorizes the Secretary of the Interior to regulate the taking of migratory birds. The act provides that it is unlawful, except as permitted by regulations, “to pursue, hunt, take, capture, kill, attempt to take, capture, or kill, possess, […] any migratory bird, or any part, nest, or egg of any such bird” (16 USC Section 703(a)). The Bald and Golden Eagle Protection Act is the primary law protecting eagles, including individuals and their nests and eggs. The USFWS implements the Migratory Bird Treaty Act (16 USC Section 703-711) and the Bald and Golden Eagle Protection Act (16 USC Section 668). Under the Bald and Golden Eagle Protection Act’s Eagle Permit Rule (50 CFR 22.26), USFWS may issue permits to authorize limited, non-purposeful take of bald eagles and golden eagles.

Clean Water Act
Areas meeting the regulatory definition of waters of the U.S. are subject to the jurisdiction of the U.S. Army Corps of Engineers (USACE) under provisions of Section 404 of the 1972 Clean Water Act.

Waters of the U.S. include other waters, such as intrastate lakes, rivers, streams, mudflats, sandflats, playa lakes, natural ponds, territorial seas, and wetlands (33 Code of Federal Regulations, Part 328). Wetlands are generally identified by examining the vegetation, soils, and hydrology of an area use the “Routine Determination Method, On-Site Inspection Necessary (Section D)” outlined in the Corps Manual (Environmental Laboratory 1987). In non-tidal waters, USACE jurisdiction extends to the ordinary high water mark, which is defined in Title 33, Code of Federal Regulations, Part Exhibit B
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328.3, as “the line on the shore established by the fluctuations of water and indicated by physical characteristics, such as a clear, natural line impressed on the bank, shelving, changes in the character of the soil, destruction of terrestrial vegetation or the presence of litter and debris.” This guidance is based on the identification of the ordinary high water mark through examination of physical evidence of surface flow in the stream channel; there is no hydrologic definition of the ordinary high water mark. Construction activities that directly impact waters of the U.S., such as grading and fill placement, require a Section 404 permit from the USACE. b. State Regulations
California Endangered Species Act
The California Endangered Species Act (California Fish and Game Code, Chapter 1.5, Sections 2050- 2116) prohibits the take of any plant or animal listed or proposed for listing as rare (plants only), threatened, or endangered. In accordance with the California Endangered Species Act, CDFW has jurisdiction over state-listed species (Fish and Game Code 2070). 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. CDFW, however, has interpreted take to include the “killing of a member of a species which is the proximate result of habitat modification.” California Fish and Game Code
Certain sections of the California Fish and Game Code describe regulations pertaining to protection of certain wildlife species. For example, Code Section 2000 prohibits take of any bird, mammal, fish, reptile, or amphibian except as provided by other sections of the code.

The California Fish and Game Code Sections 3503, 3513, and 3800 (and other sections) protect native birds, including their nests and eggs, from all forms of take. Disturbance that causes nest abandonment and/or loss of reproductive effort is considered take by CDFW. Raptors (i.e., eagles, hawks, and owls) and their nests are specifically protected in California under Code Section 3503.5.

Section 3503.5 states that it is “unlawful to take, possess, or destroy any birds in the order Falconiformes or Strigiformes (birds of 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.” Bats and other non-game mammals are protected by California Fish and Game Code Section 4150, which states that all non-game mammals or parts thereof may not be taken or possessed except as provided otherwise in the code or in accordance with regulations adopted by the commission.

Activities resulting in mortality of nongame mammals (e.g., destruction of an occupied nonbreeding bat roost, resulting in the death of bats), or disturbance that causes the loss of a maternity colony of bats (resulting in the death of young), may be considered take by CDFW. c. Local Regulations
City Of Watsonville 2005 General Plan
The Watsonville 2005 General Plan, adopted May 24, 1994, provides the following goals, policies and implementation measures pertaining to biological resources that are relevant to this analysis:

Exhibit B
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Environmental Impact Analysis
Biological Resources
Draft Environmental Impact Report 4.3-5
Environmental Resource Management Element
 Goal 9.3 Natural Resources: Identify and protect the natural resources of the Watsonville Planning Area.
 Goal 9.8 Wildlife Habitat: Preserve and protect the remaining areas of wildlife habitat for their scenic and scientific value.
 Goal 9.11 Hazardous Materials: Protect the air, water, soil, and biotic resources from damage by exposure to hazardous materials through aggressive management of hazardous materials. − Implementation Measure 9.A.2, Landscape Restoration: The City shall require landscape restoration with native plants from regional seed stocks on sites disturbed by urban development.
 Policy 9.D Water Quality: The City shall provide for the protection of water quality to meet all beneficial uses, including domestic, agricultural, industrial, recreational, and ecological uses.
− Implementation Measure 9.E.1, Vegetation: The City shall require that removal of vegetation from a site be limited to the area required for building, and that all exposed soils be provided with new vegetation prior to project completion. − Implementation Measure 9.E.3, Wetland Protection: The City shall require that new construction on slopes leading toward sloughs and wetlands, maintain an undisturbed protective buffer between all cut and fill slopes and the riparian zone. − Implementation Measure 9.F.1, Habitat Protection: Impacts to important wildlife habitat areas shall be identified as part of the City's development review and environmental review processes, and appropriate mitigations shall be considered.

Mitigation measures to be considered include: designation of sensitive areas as open space, restriction of new development on lands that provide important wildlife habitat, setback requirements, habitat conservation plans, and habitat mitigation banking. Lands within the urban limit line that provide important wildlife habitat include, but are not limited to the following:
a. Riparian Corridors
b. Fresh Water Marshes and Sloughs
c. Woodlands and Steep Slopes.
− Implementation Measure 9.F.4, Fish and Game Consultation: The City shall refer development proposals to the California Department of Fish and Game for its recommendations on conservation measures for native plant communities, riparian vegetation, wildlife habitat, and wetland preservation.

City of Watsonville Tree Protection Policies
The City has jurisdiction over all trees growing along public streets (WMC Chapter 7-11). Trimming and removing these “protected” trees requires authorization through a permit issued by the Director of Public Works. In addition, an individual tree or a cluster of trees with special character, historical, and/or aesthetic value may be designated as a “historical” via a resolution of either the City Council or Planning Commission.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.3-6

4.3.3 Impact Analysis
a. Methodology and Significance Thresholds
The DWSP is a planning document to guide development; it does not propose specific development projects. Therefore, the following discussions provide program-level review of the potential aesthetic impacts that could result from implementation of the DWSP. This analysis is based on biologists’ assessment of how development envisioned in the DWSP could or would impact existing biological resources, based on the results of data collected during the literature review and evaluation of database query results described in Section 4.3.1.

In accordance with Appendix G of the State CEQA Guidelines, the proposed project would result in potentially significant environmental effects on biological resources if it would:
1) Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S.

Fish and Wildlife Service;
2) Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service; 3) Have a substantial adverse effect on state or federally protected wetlands (including but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means;
4) 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;
5) Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance;
6) Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

The Initial Study (Appendix A) found that the DWSP would have no impacts related to conflicts with habitat conservations plans because there are no such adopted plans applicable to the plan area.

Therefore, Threshold 6 is not analyzed further in this section. b. Project Impacts and Mitigation Measures
Threshold 1: Would the project have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? Impact BIO-1 PROJECT ACTIVITIES COULD DISTURB KNOWN SPECIAL STATUS SPECIES OR THEIR ASSOCIATED HABITAT, INCLUDING MIGRATORY NESTING BIRDS. IMPACTS WOULD BE LESS THAN SIGNIFICANT WITH IMPLEMENTATION OF MITIGATION.

As discussed in Section 4.3.1, Santa Cruz tarplant is the only special status species with potential to occur within the plan area. Suitable habitat for the species, although poor in quality, may exist Exhibit B
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Biological Resources
Draft Environmental Impact Report 4.3-7
within the plan area, such as vacant areas or landscaped areas not routinely maintained.

Construction of the development envisioned in the DWSP would require grading, excavation, and other typical activities that disturb or cover the ground surface. Accordingly, these activities would have the potential to destroy or otherwise harm Santa Cruz tarplant, if present. Impacts would be potentially significant and require mitigation.

Development in the plan area may involve the removal of exiting trees and other vegetation that may be used by native resident or migratory birds as nesting habitat. Construction disturbance during the breeding season (February 1 through August 31, for most species) could result in the incidental loss of eggs or nestlings, either directly through the destruction or disturbance of active nests or indirectly by causing the abandonment of nests. Even if nests themselves are not removed, impacts such as noise and sustained human presence in proximity to active nests can disrupt nesting behavior and cause nest abandonment and failure. Disturbance or destruction of active bird nests from construction would be a potentially significant impact.

Mitigation Measures
The following mitigation measures are required to reduce potential construction impacts on Santa Cruz tarplant and nesting birds.

BIO-1 Pre-Disturbance Santa Cruz Tarplant Survey and Mitigation Planting Prior to commencement of construction activities on property with undeveloped areas or unmaintained landscaping within the plan area, a focused survey for Santa Cruz tarplant shall be conducted by a qualified biologist in areas where a qualified biologist identifies suitable habitat. The survey shall be conducted during the species’ blooming period (May-November), and findings of the survey shall be submitted to the City of Watsonville for review and approval.

If a population of Santa Cruz tarplant is found, mitigation for the loss of individuals shall be conducted. Mitigation shall be achieved by establishing a new population of Santa Cruz tarplant in an area approved by the USFWS and CDFW. This area shall not be developed and shall contain suitable habitat types for establishing a new population. Mitigation shall be a 1:1 ratio (impact mitigation) of plant establishment on an acreage basis.

Monitoring of the new mitigation population shall occur annually. Annual monitoring shall include quantitative sampling of the Santa Cruz tarplant population to determine the number of plants that have germinated and set seed. This monitoring shall continue annually or until success criteria have been met; once annual monitoring has documented that a self-sustaining population of this annual species has been successfully established on site, this mitigation measure shall be determined to have been met and the project applicant released from further responsibility.

Establishment of the plant population shall be subject to a Habitat Mitigation and Monitoring Plan.

To ensure the success of mitigation sites required for compensation of permanent impacts on Santa Cruz tarplant, the project applicant for specific development projects in the plan area for which this mitigation measure applies shall retain a qualified biologist to prepare a Habitat Mitigation and Monitoring Plan. The Habitat Mitigation and Monitoring Plan shall be submitted to the City of Watsonville for review and approval prior to the start of construction. The Habitat Mitigation and Monitoring Plan shall include, at a minimum, the following information:
 A summary of habitat and species impacts and the proposed mitigation for each element  A description of the location and boundaries of the mitigation site(s) and description of existing site conditions
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.3-8
 A description of any measures to be undertaken to enhance (e.g., through focused management) the mitigation site for special-status species  Identification of an adequate funding mechanism for long-term management  A description of management and maintenance measures intended to maintain and enhance habitat for the target species (e.g., weed control, fencing maintenance)  A description of habitat and species monitoring measures on the mitigation site, including specific, objective performance criteria, monitoring methods, data analysis, reporting requirements, monitoring schedule, etc. Monitoring will document compliance with each element requiring habitat compensation or management. At a minimum, performance criteria will include a minimum 1:1 mitigation ratio for the number of plants in the impacted population (at least one plant preserved for each plant impacted).  A contingency plan for mitigation elements that do not meet performance or final success criteria within described periods; the plan will include specific triggers for remediation if performance criteria are not met and a description of the process by which remediation of problems with the mitigation site (e.g., presence of noxious weeds) will occur  A requirement that the project proponent will be responsible for monitoring, as specified in the Habitat Mitigation and Monitoring Plan, for at least three (3) years post-construction; during this period, annual reporting will be provided to the City’s Supervising Environmental Planner.

At the request of CDFW or USFWS, the annual reporting shall also be provided to these agencies.

BIO-2 Nesting Bird Avoidance
To the extent feasible, construction activities shall be scheduled to avoid the nesting season. The nesting season for most birds in Santa Cruz County extends from February 1 through August 31. If it is not possible to schedule construction activities between September 1 and January 31, then preconstruction surveys for nesting birds shall be conducted by a qualified biologist to ensure that no nests will be disturbed during project implementation. These surveys shall be conducted no more than seven days prior to the initiation of construction activities and shall be conducted prior to tree removal, tree trimming, or other vegetation clearing. During the survey, the biologist shall inspect all trees and other potential nesting habitats, including trees, shrubs, ruderal grasslands, and buildings in and immediately adjacent to the impact areas for nests.

If an active nest is found sufficiently close to work areas to be disturbed by these activities, the biologist shall determine the extent of a construction-free buffer zone to be established around the nest (typically 300 feet for raptors and 100 feet for other species), to ensure that no nests of species protected by the Migratory Bird Treaty Act and CFGC shall be disturbed during project implementation.

Significance After Mitigation
With implementation of mitigation measures BIO-1 and BIO-2, potential impacts to special status plant species and nesting birds would be less than significant.

Exhibit B
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Environmental Impact Analysis
Biological Resources
Draft Environmental Impact Report 4.3-9
Threshold 2: Would the project have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service?
Impact BIO-3 THE PROJECT WOULD NOT HAVE A SUBSTANTIAL ADVERSE EFFECT ON ANY RIPARIAN

HABITAT OR OTHER SENSITIVE NATURAL COMMUNITY IDENTIFIED IN LOCAL OR REGIONAL PLANS, POLICIES, OR REGULATIONS, OR BY THE CALIFORNIA DEPARTMENT OF FISH AND WILDLIFE OR U.S. FISH AND WILDLIFE SERVICE. IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The plan area does not include riparian habitat, or other sensitive natural communities, nor is the plan area within 50 feet of riparian habitat or sensitive natural communities. The Pajaro River and its associated riparian zone south of the plan area boundary and beyond 50 feet away. While the DWSP does not include or envision development outside of the plan area boundary, development within the plan area could have indirect effects that extend beyond the boundary, especially where development occurs immediately adjacent to the plan area boundary. For example, exterior lighting on new development can extend beyond the perimeter of the development property, and lighting could impact riparian habitat where it occurs near the plan area boundary, such as along the Pajaro River. However, Chapter 6 of the DWSP requires that site lighting be shielded by permanent attachments to light fixtures. Chapter 6 of the DWSP also contains requirements that would restrict how bright or intense light fixtures could be depending on whether the fixture is used for residential structures or commercial/industrial structures. These DWSP requirements would prevent light pollution from impact riparian habitat outside of the plan area.

Based on the lack of riparian habitat or other sensitive natural communities within the plan area, as well as DWSP requirements limiting off-site light pollution, impacts to riparian habitat or other sensitive natural communities would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
Impacts would be less than significant without mitigation.

Threshold 3: Would the project have a substantial adverse effect on state or federally protected wetlands (including but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? Impact BIO-4 THE PROJECT WOULD NOT HAVE A SUBSTANTIAL ADVERSE EFFECT ON STATE OR FEDERALLY PROTECTED WETLANDS. THERE WOULD BE NO IMPACT.

There are no State or federally protected wetlands within or adjacent to the plan area. The DWSP would have no impact to these resources.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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Threshold 4: Would the project interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Impact BIO-5 THE PROJECT WOULD NOT SUBSTANTIALLY IMPEDE WILDLIFE MOVEMENT AREAS OR NATIVE WILDLIFE NURSERY SITES. THERE WOULD BE NO IMPACT.

The plan area does not include recognized Natural Landscape Blocks or Essential Connectivity Areas.

Existing development in the plan area likely deters wildlife movement through the plan area. Most of the plan area consists of city blocks surrounded by roadways on all sides. Future development envisioned in the DWSP would occur within and among existing development in the downtown area where no wildlife corridors or wildlife nursery sites exist. Therefore, no impacts to wildlife movement areas or wildlife nursery sites would occur from implementation of the DWSP.

Mitigation Measures
No mitigation measures would be required.

Significance After Mitigation
There would be no impact.

Threshold 5: Would the project conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance? Impact BIO-6 TREE REMOVAL ASSOCIATED WITH POTENTIAL PROJECT ACTIVITIES COULD RESULT IN DAMAGE OR DESTRUCTION OF PROTECTED TREES. HOWEVER, COMPLIANCE WITH THE WATSONVILLE MUNICIPAL CODE WOULD ENSURE THAT IMPACTS WOULD BE LESS THAN SIGNIFICANT.

The plan area contains trees protected by Watsonville Municipal Code Chapters 7-11 and 13-7. The DWSP envisions development that would require the removal of some of these trees. For example, the modifications to Main Street envisioned in the DWSP would involve changing the number of travel lanes and widening pedestrian sidewalks. These activities would likely require the removal of street trees, which are protected by the Watsonville Municipal Code. Another example of how the DWSP might impact protected trees is from construction damage during development of commercial or residential uses. Building construction would require excavation, which could sever root systems of nearby trees, resulting in the partial or complete death. However, project activities would require compliance with the City’s regulations, including obtaining tree removal permits that require replacement of removed native and landscaped trees. For example, Section 13-7.32 requires the preservation of trees measuring at least 6 inches in diameter during construction activities in Watsonville to the extent feasible. Trees that must be removed must be replaced at a ratio determined appropriate by the City’s Community Development Director. The DWSP also includes requirements for landscaping, including tree planting. For example, Section 3.2 of the DWSP calls for a carefully selected palette of street trees to be planted in the plan area. Therefore, impacts would be less than significant.

Mitigation Measures
No mitigation measures would be required.

Exhibit B
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Environmental Impact Analysis
Biological Resources
Draft Environmental Impact Report 4.3-11
Significance After Mitigation
Impacts would be less than significant without mitigation. c. Cumulative Impacts
The cumulative impact assessment area for biological resources in the area within the city limits of Watsonville. This is an appropriate geographical area for this cumulative impact assessment because the DWSP would occur entirely in the downtown area of Watsonville and not affect regional wildlife or plant populations beyond the city limits.

The cumulative impacts assessment area is mostly developed with urban to suburban uses, as well as commercial, industrial, and civic uses. This existing urban development has resulted in the reduction of native plant and wildlife species and habitats. However, some reasonably foreseeable future development would result in impacts to biological resources. For example, the reasonably foreseeable Hillcrest Subdivision Project would result in impacts to wetlands along the Watsonville Slough, which provides habitat for wildlife and occurs in a more suburban area of the City outside of the plan area. Other reasonably foreseeable future projects in the cumulative impacts assessment area, such as the Freedom Campus Master Plan, would require the removal of street trees and other native trees in landscaped settings. Although these landscape settings do not provide habitat for special-status species, they could be used as nesting sites by migratory nesting birds. Therefore, the reasonably foreseeable future projects in the cumulative impact assessment area would have significant cumulative impacts on biological resources, including special-status species, wetlands and riparian zones, trees, and nesting birds.

Santa Cruz tarplant is the only special-status species with potential to occur within the plan area, and therefore the only special-status species that could be potentially impacted from implementation of the DWSP. Additionally, development envisioned in the DWSP could impact nesting migratory birds or their nests, which would combine with the cumulative impacts to nesting birds. With implementation of the mitigation measures described in Section 4.3.3, the DWSP would not result in a cumulatively considerable contribution to impacts on these special-status species or nesting birds. New development within the plan area would not result in the degradation of sensitive habitats including riparian and wetland areas because they do not occur within the plan area; therefore, the proposed DWSP would not result in a cumulatively considerable contribution to impacts on these resources or contribute to cumulative impacts on these resources. The plan area does not support wildlife movement or nurseries within its boundary; therefore, the proposed project would not result in a cumulatively considerable contribution to this resource or contribute to significant cumulative impacts. Relevant policies and regulations would apply to development within the plan area and provide protection for these resources under existing conditions; therefore, the proposed DWSP would not result in a cumulatively considerable contribution to these resources. Development within the plan area would occur within the existing urban buffer and would not result in a cumulatively considerable contribution on biological resources in the region.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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Exhibit B
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Environmental Impact Analysis
Cultural Resources
Draft Environmental Impact Report 4.4-1

4.4 Cultural Resources
This section describes the cultural resources settings and regulations applicable to the plan area and assesses the potential impacts on cultural resources that may result with implementation of the proposed DWSP. The impacts analysis in this section supported by the Watsonville Downtown Specific Plan Area Historic Resources Survey Report (Survey Report; Appendix D). This section focuses primarily on historic-era cultural resources. Prehistoric-era cultural resources are discussed in more detail in the Initial Study (Appendix A).

4.4.1 Setting
Please see the Survey Report (Appendix D) for a full historic context of the City of Watsonville. An abbreviated context of the DWSP plan area is provided below to support the analysis that follows.

The plan area comprises Watsonville’s commercial core, some of the community’s oldest residential neighborhoods, and the northeastern fringe of its main warehouse and industrial district. Sanborn Fire Insurance maps show that the current patterns of commercial and residential development were established more or less by the 1880s (Figure 4.4-1). The 1886 edition of the Sanborn map shows that the Main Street corridor was already predominantly commercial, with a notable concentration of businesses located near the plaza, on Main, Peck and Beach streets and Maple Avenue. Industrial development was limited, but included packing, milling, and warehouse operations and the Watsonville Brewery, clustered around Main Street. By the time the 1888 edition was surveyed, there were significant neighborhoods of single-family homes around the intersection of Beach and Rodriguez Streets and north of Union and Brennan Streets. Chinatown was located at the southeast corner of Union Street and Maple Avenue. Through the late nineteenth century, institutional properties, including the Watsonville Opera House and at least two public schools, were located centrally in the commercial core or in bordering residential areas.

Development northwest of Ford Street was limited by “un-reclaimed swamp land.” By 1892, Walker Street was constructed along the Southern Pacific Railroad tracks. Walker Street had yet to assume its current industrial character, however, and was sparsely lined with residences. Martinelli’s Ciderworks (on Beach Street near the intersection with Marchant) supported a growing neighborhood of single-family dwellings.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.4-2
Figure 4.4-1 1892 Sanborn Map of City Plaza and Immediate Surroundings Watsonville’s rapid population growth in the 1890s fueled development throughout the City, including the new sections of the DWSP plan area. By 1902, the Main Street corridor expanded north to Freedom Boulevard (formerly known as Santa Cruz Road). Development in this area included St. Patrick’s Catholic Church (just outside the DWSP plan area), Stoesser’s cement plant near the intersection of Main and Ford streets, and several residences along both sides of Main Street. A large area between Main and Rodriguez streets east of Sixth Street experienced increasingly dense residential development, while a growing number of homes and cottages were built in the area bounded by Rodriguez, Walter, Second, and Fourth streets. These were likely constructed in conjunction with the early development of the industrial district that emerged to the south, along Walker Street. A box factory, feed mill, vinegar distillery, and several warehouses appeared on, or just off, Walker Street by the early twentieth century. By the time the survey was conducted for the 1920 Sanborn map warehousing dominated the northside of Walker Street. The densification of existing residential and commercial areas and the construction of a few scattered institutional properties made up much of the remainder of development carried out between 1902 and 1920. By the late 1930s, historic aerial photos show, the DWSP plan area was nearly completely developed (Figure 4.4-2).

Exhibit B
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Cultural Resources
Draft Environmental Impact Report 4.4-3
Figure 4.4-2 1935 Aerial Photograph of Downtown Watsonville Available sources offer little evidence of new development until after World War II. The DWSP plan area was essentially entirely developed by this time, and most new construction involved the redevelopment of properties and the realignment of some streets on the City’s irregular grid.

Sanborn maps and historic aerial photographs show that a number of properties on the southeast side of the City were razed to accommodate the construction of Riverside Drive, which created a thoroughfare for Highway 129. Between 1968 and 1982, Brennan and Rodriguez Streets were both realigned between Beach Street and Lake Avenue. The realignment work involved the demolition of several buildings, mostly commercial and residential buildings (Netronline 1968; 1981; 1982). The destructive Loma Prieta Earthquake of 1989 led to the loss of multiple buildings in downtown Watsonville, including the National Register-listed Stoesser Block and Annex at 331-341 Main Street.

Much of the redevelopment that took place after World War II centered on Main Street, especially between Maple Avenue and the Pajaro River. Unfolding over several decades, this redevelopment included the construction of large institutional buildings—such as City Hall, the Civic Plaza building and a new post office—and several new commercial and residential properties located west of the Pajaro River. Additionally, over the last decade, several historic-period commercial buildings formally located on Main Street, in particular between Riverside Drive and 2nd Street, were demolished and redeveloped with commercial buildings that house establishments such as McDonalds and a gas station.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.4-4
The analysis summarized in the Survey Report identified three potential historical resource types within the DWSP plan area: designated historical resources, potentially eligible individual historical resources, and groupings of properties which may constitute historic districts or overlay/ conservation zones pending further study. The designated historical resources, of which 13 were identified in the Survey Report, are designated or eligible for listing in a federal, state and/or local historic register and are therefore considered historical resources pursuant to CEQA (see Table 4.4-1). The potentially eligible individual historical resources identified by the Survey Report (77) and groupings of properties identified by the Survey Report (4), are those which have potential architectural and/or historical significance and therefore have an increased potential to qualify as historical resources pursuant to CEQA pending further study. In addition, the DWSP plan area contains additional buildings and structures that are 45 or more years of age and therefore have the potential to qualify as a historical resource as defined by CEQA.

Exhibit B
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Environmental Impact Analysis
Cultural Resources
Draft Environmental Impact Report 4.4-5
Table 4.4-1 Known Designated Resources Within the DWSP Plan Area Map
Number Resource Name/Location Architectural Style/ Associated Architect Date of
Construction Designation Photograph
1 Watsonville Woman’s Club
12 Brennan Street
Tudor Revival
Frank Wyckoff,
Architect
1917 Listed in the Watsonville HR
2 “Judge” Julius Lee
House/Lewis Home
128 East Beach Street
Queen Anne
Victorian
William Weeks,
Architect
1884 Listed in the NRHP, CRHR
and the Watsonville HR
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.4-6
Map
Number Resource Name/Location Architectural Style/ Associated Architect Date of
Construction Designation Photograph
3 Tyler/Ash House
225 East Lake Avenue
Queen Anne
Victorian
William Weeks,
Architect
1890s Listed in the Watsonville HR
4 Porter Building
280 Main Street
Classical Revival
William Weeks,
Architect
1903 Listed in the Watsonville HR
(located on City Hall
property)
Exhibit B
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Environmental Impact Analysis
Cultural Resources
Draft Environmental Impact Report 4.4-7
Map
Number Resource Name/Location Architectural Style/ Associated Architect Date of
Construction Designation Photograph
5 Wells Fargo Building
326 Main Street
Art Deco
H.H. Winner,
Architect
1940 Determined eligible for
listing in the NRHP (2S2)
6 Lettunich Building
406 Main Street
Renaissance
Revival/Chicago
Style
William Weeks,
Architect
1911 Listed in the NRHP, CRHR
and the Watsonville HR
7 Mansion House Hotel
418-428 Main Street
Second Empire
Thomas Beck,
Architect
1871 Listed in the NRHP, CRHR
and the Watsonville HR
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.4-8
Map
Number Resource Name/Location Architectural Style/ Associated Architect Date of
Construction Designation Photograph
8 Kalich Building
426-434 Main Street
Renaissance Revival
William Weeks,
Architect
1914 Listed in the Watsonville HR
9 Watsonville City Plaza
Bounded by Main, Peck,
Union, and East Beach
Streets
William Weeks,
Architect
(bandstand)
1906
(bandstand)
Listed in the NRHP, CRHR
and the Watsonville HR
10 318 Union Street Spanish Colonial
Revival
Lorimer Rich,
Architect
1937 Determined eligible for
listing in the NRHP (2S2)
Exhibit B
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Environmental Impact Analysis
Cultural Resources
Draft Environmental Impact Report 4.4-9
Map
Number Resource Name/Location Architectural Style/ Associated Architect Date of
Construction Designation Photograph
11 Resetar Hotel
15 West Lake Avenue
Spanish Colonial
William Weeks,
Architect
1927 Determined eligible for
listing in the NRHP (2S2)
12 26 West Beach Street Neoclassical Revival
William Weeks,
Architect
1911 Listed in Watsonville HR
13 Jefsen Hotel
6 East Lake Avenue
Italianate 1920-1907 Listed in Watsonville HR
Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.4-10

4.4.2 Regulatory Setting
a. Federal Regulations
National Register of Historic Places
Properties which are listed in or have been formally determined eligible for listing in the NRHP are automatically listed in the CRHR and are therefore considered historical resources per CEQA. The NRHP was authorized by Section 101 of the National Historic Preservation Act and is the nation’s official list of cultural resources worthy of preservation. The NRHP recognizes the quality of significance in American, state, and local history, architecture, archaeology, engineering, and culture is present in districts, sites, buildings, structures, and objects. Per 36 CFR Part 60.4, a property is eligible for listing in the NRHP if it meets one or more of the following criteria:

Criterion A: Are associated with events that have made a significant contribution to the broad patterns of our history
Criterion B: Are associated with the lives of persons significant in our past Criterion C: Embody the distinctive characteristics of a type, period, or method of installation, or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction
Criterion D: Have yielded, or may be likely to yield, information important in prehistory or history
In addition to meeting at least one of the above designation criteria, resources must also retain integrity. The National Park Service recognizes seven aspects or qualities that, considered together, define historic integrity. To retain integrity, a property must possess several, if not all, of these seven qualities, defined as follows:

Location: The place where the historic property was constructed or the place where the historic event occurred
Design: The combination of elements that create the form, plan, space, structure, and style of a property
Setting: The physical environment of a historic property Materials: The physical elements that were combined or deposited during a particular period of time and in a particular pattern or configuration to form a historic property Workmanship: The physical evidence of the crafts of a particular culture or people during any given period in history or prehistory
Feeling: A property’s expression of the aesthetic or historic sense of a particular period of time
Association: The direct link between an important historic event or person and a historic property
Certain properties are generally considered ineligible for listing in the NRHP, including cemeteries, birthplaces, graves of historical figures, properties owned by religious institutions, relocated structures, or commemorative properties. Additionally, a property must be at least 50 years of age to be eligible for listing in the NRHP. The National Park Service states that 50 years is the general Exhibit B
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Cultural Resources
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estimate of the time needed to develop the necessary historical perspective to evaluated significance (National Park Service 1997:41). Properties which are less than 50 years must be determined to have “exceptional importance” to be considered eligible for NRHP listing.

Archaeological Resources Protection Act of 1979
This regulation was enacted to protect archaeological resources and sites that are on public lands and tribal lands, to foster increased cooperation and exchange of information between government representatives, the professional archaeological community, and private individuals. Section 4 of the statute and Sections 16.5-16.12 of the uniform regulations describe the requirements that must be met before federal authorities can issue a permit to excavate or remove any archaeological resource on federal or tribal lands. The curation requirements of artifacts, other materials excavated or removed, and the records related to the artifacts and materials are described in Section 5 of the Archaeological Resources Protection Act of 1979. This section also authorizes the Secretary of the Interior to issue regulations describing in more detail the requirements regarding these collections.

American Indian Religious Freedom Act
The American Indian Religious Freedom Act established federal policy to protect and preserve the inherent rights of freedom for Native groups to believe, express, and exercise their traditional religions. These rights include but are not limited to access to sites, use and possession of sacred objects, and freedom to worship through ceremonial and traditional rites.

Native American Graves Protection and Repatriation Act
The Native American Graves Protection and Repatriation Act of 1990 sets provisions for the intentional removal and inadvertent discovery of human remains and other cultural items from federal and tribal lands. It clarifies the ownership of human remains and sets forth a process for repatriation of human remains and associated funerary objects and sacred religious objects to the Native American groups claiming to be lineal descendants or culturally affiliated with the remains or objects. It requires any federally funded institution housing Native American remains or artifacts to compile an inventory of all cultural items within the museum or with its agency and to provide a summary to any Native American tribe claiming affiliation. b. State Regulations
California Environmental Quality Act
California Public Resources Code (PRC) Section 21804.1 requires lead agencies determine if a project could have a significant impact on historical or unique archaeological resources. As defined in PRC Section 21084.1, a historical resource is a resource listed in, or determined eligible for listing in, the California Register of Historical Resources (CRHR); a resource included in a local register of historical resources or identified in a historical resources survey pursuant to PRC Section 5024.1(g); or any object, building, structure, site, area, place, record, or manuscript that a lead agency determines to be historically significant. PRC Section 21084.1 also states resources meeting the above criteria are presumed to be historically or cultural significant unless the preponderance of evidence demonstrates otherwise. Resources listed in the National Register of Historic Places (NRHP) are automatically listed in the CRHR and are, therefore, historical resources under CEQA. Historical resources may include eligible built environment resources and archaeological resources of the precontact or historic periods.

Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

4.4-12
CEQA Guidelines Section 15064.5(c) provides further guidance on the consideration of archaeological resources. If an archaeological resource does not qualify as a historical resource, it may meet the definition of a “unique archaeological resource” as identified in PRC Section 21083.2.

PRC Section 21083.2(g) defines a unique archaeological resource as an artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria: 1) it contains information needed to answer important scientific research questions and that there is a demonstrable public interest in that information; 2) has a special and particular quality such as being the oldest of its type or the best available example of its type; or 3) is directly associated with a scientifically recognized important prehistoric or historic event or person.

If an archaeological resource does not qualify as a historical or unique archaeological resource, the impacts of a project on those resources would be less than significant and need not be considered further (CEQA Guidelines Section 15064.5[c][4]). CEQA Guidelines Section 15064.5 also provides guidance for addressing the potential presence of human remains, including those discovered during the implementation of a project.

According to CEQA, an impact that results in a substantial adverse change in the significance of a historical resource is considered a significant impact on the environment. A substantial adverse change could result from physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of the historical resource would be materially impaired (CEQA Guidelines §15064.5 [b][1]). Material impairment is defined as demolition or alteration in an adverse manner [of] those characteristics of a historical resource that convey its historical significance and that justify its inclusion in, or eligibility for inclusion in, the CRHR or a local register (CEQA Guidelines §15064.5[b][2][A]).

If it can be demonstrated that a project would cause damage to a unique archaeological resource, the lead agency may require reasonable efforts be made to permit any or all of these resources to be preserved in place or left in an undisturbed state. To the extent that resources cannot be left undisturbed, mitigation measures are required (PRC §21083.2[a], [b]).

Section 15126.4 of the CEQA Guidelines stipulates an EIR shall describe feasible measures to minimize significant adverse impacts. In addition to being fully enforceable, mitigation measures must be completed within a defined time period and be roughly proportional to the impacts of the project. Generally, a project which is found to comply with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings (the Standards) is considered to be mitigated below a level of significance (CEQA Guidelines Section 15126.4 [b][1]). For historical resources of an archaeological nature, lead agencies should also seek to avoid damaging effects where feasible. Preservation in place is the preferred manner to mitigate impacts to archaeological sites; however, data recovery through excavation may be the only option in certain instances (CEQA Guidelines Section 15126.4[b][3]).

California Register of Historical Resources
The CRHR was established in 1992 and codified by PRC §§5024.1 and 4852. The CRHR is an authoritative listing and guide to be used by State and local agencies, private groups, and citizens in identifying the existing historical resources of the State and to indicate which resources deserve to be protected, to the extent prudent and feasible, from substantial adverse change (Public Resources Code, 5024.1(a)). The criteria for eligibility for the CRHR are consistent with the NRHP criteria but have been modified for state use in order to include a range of historical resources that better Exhibit B
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Environmental Impact Analysis
Cultural Resources
Draft Environmental Impact Report 4.4-13
reflect the history of California (Public Resources Code, 5024.1(b)). Unlike the NRHP however, the CRHR does not have a defined age threshold for eligibility; rather, a resource may be eligible for the CRHR if it can be demonstrated sufficient time has passed to understand its historical or architectural significance (California Office of Historic Preservation 2006). Further, resources may still be eligible for listing in the CRHR even if they do not retain sufficient integrity for NRHP eligibility (California Office of Historic Preservation 2006). Generally, the California Office of Historic Preservation recommends resources over 45 years of age be recorded and evaluated for historical resources eligibility (California Office of Historic Preservation 1995:2).

Properties are eligible for listing in the CRHR if they meet one of more of the following criteria:

Criterion 1: Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage
Criterion 2: Is associated with the lives of persons important to our past Criterion 3: Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values
Criterion 4: Has yielded, or may be likely to yield, information important in prehistory or history c. Local Regulations
City of Watsonville Historic Preservation Ordinance
Chapter 8-13 of the City of Watsonville’s municipal code authorizes the City Council, by ordinance, to designate structures, features, or integrated groups of structures and features on a single lot or site as “historic structures” if they have special character, or historical, architectural, or aesthetic interest (Municipal Code Chapter 8-13, Section 8-13.02[a]). “Historic structures” are further defined in Chapter 9-2, Section 9-2.200 as:

Listed individually in the NRHP (a listing maintained by the Department of the Interior) or preliminarily determined by the Secretary of the Interior as meeting the requirements for individual listing on the NRHP
Certified or preliminarily determined by the Secretary of the Interior as contributing to the historical significance of a registered historic district or a district preliminarily determined by the Secretary of Interior to qualify as a registered historic district Individually listed on a state inventory of historic places in states with historic preservation programs which have been approved by the Secretary of Interior or Individually listed on a local inventory of historic places Alterations to historic structures as defined above is subject to review by the Planning Commission and Section 8-13.12 of Chapter 8-13 of the municipal code, which states:

The Planning Commission shall be guided by the standards set forth in this section in its review of permit applications for work or change of conditions on a historical structure. In appraising the effects and relationships established herein, the Planning Commission in all cases shall consider the factors of architectural style, design, arrangement, texture, materials and color, and any other pertinent factors.

Exhibit B
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The proposed work shall be appropriate for and consistent with the effectuation of the purposes of this chapter and shall preserve or enhance the characteristics and particular features specified in the designating ordinance.

The proposed work shall not adversely affect the exterior architectural features of the structure and, where specified in the designating ordinance for a publicly owned structure, its major interior architectural features; nor shall the proposed work adversely affect the special character or special historical, architectural, or aesthetic interest or value of the structure and its site, as viewed both in themselves and in their setting.

City of Watsonville 2005 General Plan
The Watsonville 2005 General Plan Environmental Resources Element includes the following goals, policies, and implementation measures pertaining to cultural resources that are relevant to this analysis:

Environmental Resource Management Element
 Policy 9.H Archaeological Resources: The City shall foster and provide for the preservation of cultural resources and artifacts of historic and prehistoric human occupation within the Pajaro Valley.
− Implementation Measure 9.H.1, Inventory: The City shall maintain an inventory of historic and prehistoric sites, structures, and landmarks of historic and cultural significance in order to determine the potential impacts on these resources from proposed projects.
− Implementation Measure 9.H.2, Protection Measures: The City shall notify the Regional Office, California Archaeological Site Survey, and the Ohlone Indian Cultural Association of projects within identified archaeological sensitive areas. An archaeological site survey by a professional archaeologist may also be required. − Implementation Measure 9.H.3, Project Conditions: The City shall require appropriate land use controls on projects that may endanger or destroy historic and prehistoric artifacts. Such controls include additional of fill to prevent disruption of site by grading, and site planning to avoid disturbance on sensitive portions of the site. − Implementation Measure 9.H.4, Private Participation: The City shall foster and encourage private efforts to preserve historic sites and cultural artifacts. − Implementation Measure 9.H.5, Ordinance: The City shall enforce the historic preservation ordinance.

4.4.3 Impact Analysis
a. Methodology and Significance Thresholds
The State Legislature, in enacting the CRHR, amended CEQA to clarify which properties are significant, as well as which project impacts are considered significantly adverse. A project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that may have significant effect on the environment (CEQA Guidelines Section 150645[b]). A substantial adverse change in the significance of a historical resource means demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired (CEQA Guidelines Section 150645[b][1]).

Exhibit B
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Cultural Resources
Draft Environmental Impact Report 4.4-15
The CEQA Guidelines further state that “[t]he significance of an historical resource is materially impaired when a project… [d]demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in the California Register … local register of historic resources… or its identification in an historic resources survey.” As such, the test for determining whether or not the project will have a significant impact on identified historic resources is whether it will materially impair physical integrity of the historic resource such that it could no longer be listed in the CRHR or a local landmark program.

In accordance with Appendix G of the State CEQA Guidelines, the proposed project would result in potentially significant environmental effects on cultural resources if it would:
1) Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5;
2) Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5;
3) Disturb any human remains, including those interred outside of formal cemeteries.

Potential impacts of the DWSP to archaeological resource pursuant to CEQA §15064.5 were analyzed in the Initial Study (Appendix A), which indicated that the DWSP plan area has high sensitivity for archaeological resources and that future development facilitated by the DWSP would have the potential to result in archaeological adverse change in the significance of archaeological resources. As presented in the Initial Study, Mitigation Measures CUL-1, CUL-2, and CUL-3 would apply to future construction facilitated by the project, thereby reducing impacts to archaeological resources to a less than significant level. Accordingly, threshold 2 is not studied further in this section of the EIR. Likewise, the Initial Study concluded impacts related to disturbance of human remains would be less than significant. Accordingly, Threshold 3 is not studied further in this section of the EIR.
b. Project Impacts and Mitigation Measures
Threshold 1: Would the project cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5?
Impact CUL-1 DEVELOPMENT ENVISIONED IN THE DWSP COULD ADVERSELY AFFECT KNOWN AND PREVIOUSLY UNIDENTIFIED HISTORICAL RESOURCES. IMPACTS TO HISTORICAL RESOURCES WOULD BE SIGNIFICANT AND UNAVOIDABLE.

Development under the proposed project could impact historical resources through construction activities associated with buildout. The DWSP has a future land use scenario that emphasizes infill development in existing urbanized areas of downtown. Because future infill development could be located near or adjacent to existing historic structures, the integrity of such structures could be indirectly or directly impacted as a result. For example, future infill development could consist of modern-style architecture, which if located near a historic building, could adversely change the historic context or setting in which the historic building occurs. Moreover, if future infill development would involve redevelopment/demolition of existing structures, it is possible that such structures could have historical significance (as determined by site specific evaluation) given the presence of structures that are over 50 years old within the plan area. Redevelopment or demolition could result in the permanent loss of or permanent adverse changes to historic structures. For Exhibit B
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City of Watsonville
Downtown Watsonville Specific Plan

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example, redevelopment could replace the architectural elements of a building that contribute toward its historic designation. Impacts would be potentially significant, and mitigation is required.

Mitigation Measures
CUL-1(a) Historical Resources Evaluation
During the planning phase for projects and development envisioned in the DWSP, and prior to permit approval for said projects and development, the City shall confirm the presence of historical resources with the potential to be impacted by the particular project or development. If the property on which the project or development is proposed is not currently designated but contains built environment features over 45 years of age, a historical resources evaluation shall be prepared by an architectural historian or historian who meets the Secretary of the Interior’s (SOI) Professional Qualification Standards (PQS) in architectural history or history (36 Code of Federal Regulations Part 61). The qualified architectural historian or historian shall conduct an intensive-level survey and perform the historical evaluation in accordance with the guidelines and best practices promulgated by the California Office of Historic Preservation (OHP). Properties shall be evaluated within their historic context and documented in a report meeting the California OHP guidelines. All evaluated properties shall be documented on California Department of Parks and Recreation Series 523 Forms.

The report with attached DPR forms shall be submitted to the City for review and concurrence.

CUL-1(b) Compliance with the Secretary of the Interior’s Standards for the Treatment of Historic Properties
If it is determined that a proposed project site located in the DWSP plan area contains a historical resource, efforts shall be made to avoid impacts as feasible. Any relocation, rehabilitation, or alteration of a resource shall be implemented consistent with the Secretary of the Interior’s Standards for the Treatments of Historic Properties (the Standards). Application of the Standards shall be overseen by a qualified architectural historian or historical architect meeting the SOI PQS in architectural history or history (36 Code of Federal Regulations Part 61). In conjunction with any development application that may impact a historical resource, a report identifying and specifying proposed construction activities and the treatment of character-defining features shall be provided to the city for review and concurrence, in addition to the historical resources evaluation required by CUL-4.

CUL-1(c) Historical Resource Documentation
If historical resources are identified on a proposed project site located in the DWSP plan area and compliance with Mitigation Measure CUL-1(b) and/or avoidance is not feasible, the project applicant or developer shall provide a report explaining why compliance with the Standards and/or avoidance is not feasible for the City’s review and approval. Site-specific mitigation measures shall be established and undertaken, including, but not limited to, documentation of the historical resource in a Historic American Buildings Survey (HABS) or HABS-like report. If a HABS or HABS-like report is proposed, it shall be commissioned by the project applicant or their consultant to comply with the Secretary of the Interior’s Standards for Architectural and Engineering Documentation (Federal Register Vol. 48, No. 190, pp. 44730-34) and shall generally follow the Historic American Buildings Survey Level III requirements, including digital photographic recordation, detailed historic narrative report, and compilation of historical research. The documentation shall be completed by a qualified architectural historian or historian who meets the SOI PQS in architectural history or Exhibit B
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history (36 Code of Federal Regulations Part 61) and submitted to the City prior to issuance of permits for the demolition or alteration of the historical resource.

Significance After Mitigation
Implementation of Mitigation Measures CUL-1(a), CUL-1(b), and CUL-1(c) would reduce impact to historical resources to the extent feasible. However, impacts would remain significant and unavoidable because development within the plan area could still adversely affect historic properties. For example, development envisioned in the DWSP could result in entire demolition of a historic building.
c. Cumulative Impacts
IMPACT CUL-C1: THE DWSP WOULD HAVE A CUMULATIVELY CONSIDERABLE CONTRIBUTION TO A SIGNIFICANT CUMULATIVE IMPACT ON HISTORIC-ERA CULTURAL RESOURCES.

The cumulative impact analysis area for cultural resources consists of the plan area and the city of Watsonville, based on the historic, ethnographic, and prehistoric period use patterns of the region.

This is appropriate because cultural resources identified in this larger region will be similar in type and style to those that are or may be present in the plan area.

The reasonably foreseeable future projects in the cumulative impact assessment area (see Table 3-1 in Section 3, Environmental Setting) would involve construction activities that require ground disturbance. For example, these projects could require trenching for utility connections or grading to prepare the site for pouring foundations. These types of construction activities would therefore have potential to impact both known or previously unknown prehistoric cultural resources. The cumulative impact would be potentially significant.

The DWSP also envisions development that would require ground disturbance. The plan area is mostly developed. Because of this, the potential to encounter the same prehistoric resources as the other reasonably foreseeable future projects would be minimized. Additionally, the physical distance separating the plan area from reasonably foreseeable future projects would also reduce the potential for the DWSP to impact the same archaeological resources as these foreseeable projects. Implementation of the DWSP would also require implementation of the mitigation measures identified in the Initial Study, including CUL-1, CUL-2, and CUL-3. With implementation of these mitigation measures, the DWSP would not have a cumulatively considerable contribution toward a significant impact on prehistoric-era cultural resources.

Historic-era cultural resources are typically site specific. For example, a designated historic building typically occurs on a single property. While most cultural resources are site specific, with impacts that are project specific, others may have regional significance; for example, a historic structure that represents the last known example of its kind would constitute a regional impact. Additionally, development near a historic resource could change the context of the landscape, which would also adversely impact the historic resource. The reasonably foreseeable future projects in the cumulative impact assessment area would have potential to result in these changes to historic resources.

Cumulative impacts on historic-era cultural resources would be significant.

Mitigation Measures CR-1(a), CR-1(b), and CR-1(c) would reduce impacts associated with DWSP projects through impact minimization for historical resources. However, the plan area contains historic-era resources that could be substantially and adversely changed by the development envisioned in the DWSP, even with implementation of CR-1(a) through CR-1(c). Therefore, the Exhibit B
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DWSP would have a cumulatively considerable contribution to a significant cumulative impact on historic resources.

Exhibit B
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Environmental Impact Analysis
Hazards and Hazardous Materials
Draft Environmental Impact Report 4.5-1

4.5 Hazards and Hazardous Materials
This section describes the existing setting and regulatory framework pertaining to hazards and hazardous materials. This section also evaluates potential impacts from hazards and hazardous materials from the proposed DWSP.

4.5.1 Setting
a. Terminology
Hazardous Waste
The United States Environmental Protection Agency (USEPA) defines a “hazardous waste” as a substance that: (1) may cause or significantly contribute to an increase in mortality or an increase in serious, irreversible, or incapacitating reversible illness, and (2) poses a substantial present or potential future hazard to human health or the environment when it is improperly treated, stored, transported, disposed of, or otherwise managed (40 Federal Code of Regulations (CFR) 261.10).

Hazardous waste is also defined as ignitable, corrosive, explosive, or reactive and is identified by the USEPA by its form: solids, semi-solids, liquids, and gases. Producers of such wastes include private businesses and federal, State, and local government agencies. A material may also be classified as hazardous if it contains defined amounts of toxic chemicals. USEPA regulates the production and distribution of commercial and industrial chemicals to protect human health and the environment.

USEPA also prepares and distributes information to inform the public about these chemicals and their effects, and provides guidance to manufacturers in pollution prevention measures, such as more efficient manufacturing processes and recycling used materials.

Hazard versus Risk
Public health is potentially at risk whenever hazardous materials have been used or where there could be exposure to such materials. Ecological communities, such as avian and terrestrial habitats and the aquatic environment, may be at risk, depending on the type of populations and locations relative to potential exposure sources. Important to the setting and analyses presented in this section are the concepts of the “hazard” of these materials and the “risk” they pose to human health and the environment.

Exposure to some chemical substances may harm internal organs or systems in the human body, ranging from temporary effects to permanent disability or death. Aquatic, terrestrial, or avian species may be similarly adversely affected. Hazardous materials that result in adverse effects are generally considered toxic. However, chemical materials may be corrosive or react with other substances to form other hazardous materials, but they are not considered toxic because organs or systems are not affected. Because toxic materials can result in adverse health effects, they are considered hazardous materials, but not all hazardous materials are necessarily toxic. For example, some hazardous materials are flammable but not necessarily toxic to human health. For purposes of the information and analyses presented in this section, the terms hazardous substances and hazardous materials are used interchangeably and include materials that are considered toxic.

The risk to human health and the ecological environment is determined by the probability of exposure to a hazardous material and the severity of harm such exposure would pose. The likelihood and means of exposure, along with the inherent toxicity of a material, are used to Exhibit B
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