Agenda packet — Woodland City Council, September 5, 2023 (part 4 of 13)

Table 6-1
Woodland Research and Technology Park Financing PlanRTIF Program Fee Summary (2023$)Land Use Category Streets Parks Storm
Drainage Water Sewer Subtotal Admin. Total
Percentage 4.00%Residential by Land Use
Low Density (LDR) - - $6,952 $2,907 $1,176 $11,036 $441 $11,477 Medium Density (MDR) - - $4,742 $2,475 $910 $8,127 $325 $8,452High Density (HDR) - - $3,085 $1,759 $819 $5,663 $227 $5,890 Residential by Square Foot Range
Single Family (LDR and MDR)
< 1,000 sq. ft. $12,800 $8,199 - - - $20,999 $840 $21,839 1,000 to 1,999 sq. ft. $20,696 $14,450 - - - $35,146 $1,406 $36,552 2,000 to 2,999 sq. ft $29,904 $22,380 - - - $52,284 $2,091 $54,375 > 2,999 sq. ft. $36,547 $27,555 - - - $64,102 $2,564 $66,666 Multifamily (HDR)
< 1,000 sq. ft. $12,256 $14,450 - - - $26,705 $1,068 $27,773 ≥1000 sq. ft. $13,606 $16,533 - - - $30,139 $1,206 $31,345 Residential for Average Unit Size
Low Density (2,300 sq. ft.) $29,904 $22,380 $6,952 $2,907 $1,176 $63,321 $2,533 $65,854 Medium Density (1,850 sq. ft.) $20,696 $14,450 $4,742 $2,475 $910 $43,273 $1,731 $45,004 High Density (990 sq. ft.) $12,256 $14,450 $3,085 $1,759 $819 $32,368 $1,295 $33,663 Commercial [1]
Village Center/Community Commercial $189,072 N/A $22,213 $2,580 $2,596 $216,461 $8,658 $225,119 Business Park $86,378 N/A $22,213 $2,346 $1,731 $112,667 $4,507 $117,174 Commercial [1]
Village Center/Community Commercial $9.99 N/A $1.17 $0.14 $0.14 $11.43 $0.46 $11.89 Business Park $4.96 N/A $1.27 $0.13 $0.10 $6.47 $0.26 $6.73 Source: City of Woodland; EPS
[1] Commercial fees will be charged per acre. The amount per bldg. sq. ft. is shown for comparitive purposes. per unitper unit
per acre
per bldg. sq. ft.
per unit
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Woodland Research and Technology Park Public Facilities Financing Plan July 2023
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RTIF Program Implementation and
Administration
Implementation
The proposed RTIF Program is anticipated to be approved by the City through an ordinance establishing and authorizing collection of the fee and a resolution setting the amount of the fees. The RTIF Program will be independent and separate from all other City, County, other agency, or regional development impact fees that will be applicable to WRTP development.

Note that as part of the tentative map process, the developers will be required to submit proposed development plans. If there has been a change to the proposed land uses or number of dwelling units that results in less RTIF revenue generation than anticipated under the original land uses, then the developer will be required to make a shortfall payment to cover the difference at the time that a final map is filed.

Administration
The City will administer the RTIF Program. The RTIF Program includes a fourpercent planning and administration component to fund RTIF Program administration. Administration of the RTIF Program includes, but is not limited to, the following major tasks:
 Tracking all RTIF Program payments and assignment of fee credits and reimbursements for improvements constructed privately by developers.  Tracking the progress of construction contracts for RTIF Program improvements.
 Performing annual fee adjustments to account for the inflation of infrastructure and public facilities costs.
 Conducting periodic reviews of development projections, facilities requirements, improvement costs, funding sources, and cost allocation methodologies and making necessary adjustments to the RTIF Program.  Preparing the required annual and five-year reports on the status of the RTIF Program.

The RTIF Program implementation and administration are further detailed in the Nexus Study.

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Feasibility of the Financing Plan
This chapter quantifies and evaluates the total estimated infrastructure cost burden and total effective annual tax rate anticipated for new WRTP development and makes observations regarding the financial feasibility of the Financing Plan.

The financial feasibility is addressed by reviewing a total infrastructure burden analysis, as well as bond issuance guidelines, to ensure the Finance Plan will meet the required financial tests.

Description of Static Feasibility
Analyses
This analysis includes the following static methods for evaluating the financial feasibility of the WRTP:
 Total Backbone Infrastructure and Public Facilities Cost Burden.  Total Taxes and Assessments as a Percentage of Sales Price.

Each of these methods is based on a static financial feasibility evaluation. To be considered financially feasible, the Project should meet each of the static feasibility tests.

It is important to note that these feasibility metrics, described in detail below, should be considered initial diagnostics, offering a general indicator of whether or not a project is likely to meet financial feasibility criteria or whether measures should be taken to improve viability, either through a reduction in cost burdens, identification of other funding sources, or other approaches. None of the indicators, by themselves, should be considered absolute determinations regarding Project feasibility.

Total Backbone Infrastructure and
Public Facilities C ost Burden
It is common for developers of major development projects to advance-fund and carry infrastructure costs for some timeframe. The impact of the land developer’s cost burden depends on several factors, including the timeframe for the reimbursements and the extent to which full reimbursement is received, either through public funding programs or through adjustments in land sales prices.

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The purpose of the total backbone infrastructure and public facilities cost burden feasibility test is to assess the financial feasibility of the WRTP, given all current and proposed fees and the additional burden of WRTP-specific infrastructure costs. This feasibility test assesses the total fee burden on residential dwelling units associated with the proposed backbone infrastructure and public facilities.

The total backbone infrastructure and public facilities cost burden feasibility test provides a performance indicator of a project’s feasibility. For each residential land use, the total cost burden per dwelling unit and nonresidential building square foot is expressed as a percent of the finished sales price. Project feasibility is evaluated based on the following general guidelines or benchmarks:
 Burdens below 15 percent generally are considered financially feasible.  Burdens between 15 and 20 percent may be feasible depending on the specific circumstances of the project.
 Burdens above 20 percent suggest a project may not be financially feasible unless other components of the project pro forma are particularly advantageous to the developer, thus allowing the project to bear unusually high backbone infrastructure and public facilities costs.1 These static feasibility benchmarks are based on EPS’s experience conducting financial feasibility analyses for numerous projects throughout the Sacramento Region and Central Valley over the last 3 decades. This feasibility diagnostic is merely a tool that can be used—along with other tools—as a general measure of financial feasibility. This measure should not automatically be interpreted to mean that if one land use type exceeds the threshold, the project definitely is infeasible.

In certain circumstances, there are ways in which a development project can mitigate against a high cost burden. In addition, the backbone infrastructure and public facilities costs will be fine-tuned and possibly reduced as engineering studies are completed closer to actual construction.
1 Such other components may include extraordinarily low land basis (e.g., land has been in the family for a long time, land acquired during severe real estate market downturn, etc.), development phasing (e.g., fast early absorption ahead of a major infrastructure cost such as a new water treatment plant), or low or no environmental mitigation requirements (e.g., through avoidance or on-site preservation).

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As summarized in Table 7-1 (and further detailed in Appendix B), the total backbone infrastructure and public facilities cost burden accounts for between approximately 19.2 percent and 19.8 percent of the estimated sales price of residential units in the WRTP. Cost burdens of this magnitude are at the upper end of the diagnostic range indicating that the Project may be financially feasible if home sales values do not taper or if infrastructure costs don’t continue to escalate rapidly. Other factors such as the magnitude of advance funding requirements within each development phase, anticipated reimbursement timeframes, and development absorption would also factor into the feasibility of individual development phases. Although fee burdens for new development in Woodland plan areas typically are close to 20 percent, the City generally experiences strong building permit activity except under the most difficult economic circumstances.

The infrastructure cost burden could change for several reasons, including a re-allocation of costs among land uses and cost reductions resulting from fine-tuning the estimates as engineering studies are completed and the WRTP development becomes closer to implementation. The cost burden estimates will continue to be examined and may be refined as the WRTP development is implemented.

Total Taxes and Assessments as a
Percentage of Sales Price
The Total Taxes and Assessments as a Percentage of Sales Price feasibility test often is referred to as a “two-percent test.” This test provides another measure of the financial feasibility of a project that is used by land developers, builders, and municipal governments to evaluate development projects. The Total Taxes and Assessments as a Percentage of Sales Price test provides a general rule for the feasibility of proposed annual special taxes and assessments. In general, if the sum of property taxes, other ad valorem taxes, and all annual special taxes and assessments is less than 2 percent of the average finished home sales price, then the burden of annual taxes and assessments is considered financially feasible. In the Sacramento Region, jurisdictions and developers typically target total taxes and assessments at levels no greater than approximately 1.6 percent to 1.8 percent of the finished home sales price.

Table 7-2 shows the estimated taxes and assessments as a percentage of home sales prices for three different proposed Project land uses. The total annual amount includes the following taxes and assessments:
 Property taxes
 Other general ad valorem taxes (e.g., school/other General Obligation bonds)  Services CFD taxes
 Infrastructure CFD taxes (proposed in this Finance Plan)

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Table 7-1
Woodland Research and Technology Park Financing PlanSummary of Infrastructure Burden per Unit or Building Square Foot (2023$)Item Low
Density
Medium
Density
High
Density
Village Center/
Com. Commercial
Business
Park
Sales Price per Dwelling Unit/Sq. Ft. $675,000 $550,000 $375,000 $350 $350 City Building Permit Processing Fees $3,861 $3,608 $1,274 $1.44 $1.83 City Development Impact Fees
General City $1,005 $1,005 $755 $0.67 $0.79
Fire $3,406 $3,406 $2,042 $1.99 $2.15Library $628 $628 $471 $0.00 $0.00Police $823 $823 $616 $0.55 $0.65 Wastewater $7,524 $7,524 $5,642 $3.07 $1.74Parks & Recreation $9,279 $9,279 $6,959 $0.00 $0.00Roads $9,915 $9,915 $4,063 $12.31 $6.23Water $6,174 $6,174 $977 $0.42 $0.46Administration $291 $291 $154 $0.14 $0.09 Affordable Housing - Proposed $6,900 $4,625 $1,980 $0.00 $0.00Agricultural Mitigation $2,500 $1,250 $625 $0.79 $0.86Public Transit Fee (due at final map) $311 $311 $218 $0.00 $0.00Total Citywide Development Impact Fees $48,756 $45,231 $24,502 $19.94 $12.97 Other Agency Fees
County Facilities and Services Authorization (FSA) $3,118 $3,118 $2,312 $0.50 $0.67 School District Fees $9,384 $7,548 $4,039 $0.66 $0.66
Yolo County HCP Fee $2,700 $1,350 $675 $0.86 $0.93Total Other Agency Fees $15,202 $12,016 $7,026 $2.02 $2.26 RTIF - Proposed $65,854 $45,004 $33,663 $11.89 $6.73
Total Fees $133,673 $105,859 $66,465 $35.30 $23.78Percentage of Sales Price 19.8% 19.2% 17.7% 10.1% 6.8%Source: City of Woodland; Yolo County; WJUSD; EPS Fee per Unit Fee per Building Square Foot
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Table 7-2
Woodland Research and Technology Park Financing PlanTest of 2% Sales Price - Residential Market-Rate Units (2023$)Item Pct. LDR MDR HDR Village Center/
Com. Commercial
Business
Park
Assumptions
Sales Price $675,000 $550,000 $375,000 $350 $350FAR 0.43 0.40Maintenance CFD Category (assumes SLSP rates) Avg of R-5 and R-8
R-15 R-25 Non-Res. Non-Res.

Property Taxes
General Property Tax [2] 1.0000% $6,750 $5,500 $3,750 $3.50 $3.50 WJUSD 0.0190% $128 $105 $71 $0.07 $0.07
Yuba CCD 2006 0.0240% $162 $132 $90 $0.08 $0.08
Yuba CCD 2016 0.0081% $55 $45 $31 $0.03 $0.03
Total Ad Valorem Taxes Range 1.0512% $7,095 $5,781 $3,942 $3.68 $3.68Estimated Special Annual Taxes/Assessments Maintenance CFD [1] $1,122 $669 $599 $0.20 $0.20
Sports Park Maintenance CFD [2] $218 $180 $180 $0.03 $0.04Total Estimated Special Annual Taxes/Assessments $1,340 $850 $779 $0.23 $0.24 Estimated WRTP Infrastructure CFD [3] $3,700 $3,200 $2,000 $0.53 $0.57 Total Annual Taxes and Assessments $12,135 $9,831 $6,721 $4.44 $4.49Taxes & Assessments as % of Sales Price 1.80% 1.79% 1.79% 1.27% 1.28% Source: City of Woodland; EPS.[1] Maintenance CFD residential rates set equal to SLSP rates; nonresidential rates estimated by EPS. Per the City, the following SLSP rates are assumed for the WRTP land use categories:

LDR: average of SLSP R-5 and R-8 ratesMDR: SLSP R-15 rateHDR: SLSP R-25 rate [2] Sports Park maintenance CFD rates set equal to SLSP rates. Assumed Spring Lake categories are the same as those shown above in footnote [1]. [3] Residential rates set so that taxes and assessments=1.80% of sales price. Nonresidential rates set at $10,000 per acre. per unit per bldg. sq. ft.

Residential
price per unit price per bldg. sq. ft.

Commercial
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It is proposed that development in the WRTP participate in two services CFDs to pay for required services and ongoing maintenance of public improvements. One of the two districts would be a general maintenance CFD to provide funding for services, operations, and maintenance specifically required for WRTP development. In addition, the WRTP will be required to participate in the Citywide Sports Park maintenance CFD. When combined with the potential implementation of infrastructure special taxes that range from $2,000 to $3,700 per unit, the WRTP total special taxes and assessments would equal approximately 1.80% of the home sales prices.

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Financing Plan Implementation
This Financing Plan establishes a detailed and specific financing strategy for the WRTP. This chapter identifies the key administration and implementation actions and policies that will be required to carry out the financing strategy.

Implementation of the Financing Plan, along with EIR mitigation measures, DA provisions, and Master Reimbursement Agreement provisions will ensure that the public improvements needed to serve the WRTP are constructed consistent with the Specific Plan requirements. The City will implement the Financing Plan, which will include the following near-term and ongoing actions related specifically to the WRTP:
 Approval of the Specific Plan.
 Approval of the DAs and the Master Reimbursement Agreement between the developers and the City.
 Adoption of the Nexus Study and establishment of the RTIF Program.  Coordinating closely with all appropriate City departments and other service providers to implement the Financing Plan.
 Working with State and Federal agencies to secure State and Federal funding, where available and applicable.
 Coordinating the infrastructure construction program and funding sources with the developers.
 Periodically reviewing and updating the CIP.
 Monitoring identified revenue sources.
 Estimating fee program cash flows.
 Forming CFD(s) or other financing districts and administering subsequent bond sales and tax collection.
 Accounting for RTIF payments, credits, and reimbursements.  Updating and adjusting the RTIF Program as new infrastructure cost, land use, and revenue information become available.

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Updates
It is anticipated that as the Financing Plan is implemented, there may be changes to anticipated development, public facilities costs, and funding sources. Changes should be evaluated in the context of the overall financing strategy framework, ensuring that required funding is available when needed. The costs and funding sources for the Project may need to be adjusted periodically to reflect changes in the Specific Plan.

Such changes over time may be updated or reflected in the documents and City actions taken to implement various financing mechanisms identified in this document rather than revisiting or updating the Financing Plan itself. The City has the discretion to determine whether the Financing Plan itself should be updated or whether applicable updates should be made to the implementing documents themselves.

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APPENDICES:

Appendix A: Summary of WRTP Capital
Improvement Program
Appendix B: Development Impact Fee
Analysis
Appendix C: Infrastructure Cost
Burden Comparison

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APPENDIX A:

Summary of WRTP
Capital Improvement Program
Table A-1 Backbone Infrastructure Cost Estimates (2 pages) ........ A-1

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Table A-1Woodland Research and Technology Park Financing PlanBackbone Infrastructure Cost Estimates (2023$)Item Assumption Streets [1] Storm
Drainage Water Sewer
Parks and
Open Space
Planning
and Admin. Total Streets [1]
Storm
Drainage Water Sewer
Parks and
Open Space
Planning
and Admin. Total
County Road 25A (Hwy 113 to Harry Lorenzo and Parkland to Miekle) Construction $4,173,000 $249,000 $374,000 $0 $0 $0 $4,796,000 $4,173,000 $249,000 $374,000 $0 $0 $0 $4,796,000 Contingency 10% $418,000 $25,000 $37,000 $0 $0 $0 $480,000 $418,000 $25,000 $37,000 $0 $0 $0 $480,000Soft Cost 15% $626,000 $37,000 $56,000 $0 $0 $0 $719,000 $626,000 $37,000 $56,000 $0 $0 $0 $719,000Subtotal County Road 25A $5,217,000 $311,000 $467,000 $0 $0 $0 $5,995,000 $5,217,000 $311,000 $467,000 $0 $0 $0 $5,995,000 Parkland Avenue
Construction $5,451,000 $652,000 $369,000 $0 $0 $0 $6,472,000 $5,451,000 $652,000 $369,000 $0 $0 $0 $6,472,000Contingency 10% $545,000 $65,000 $37,000 $0 $0 $0 $647,000 $545,000 $65,000 $37,000 $0 $0 $0 $647,000 Soft Cost 15% $818,000 $98,000 $55,000 $0 $0 $0 $971,000 $818,000 $98,000 $55,000 $0 $0 $0 $971,000 Subtotal Parkland Avenue $6,814,000 $815,000 $461,000 $0 $0 $0 $8,090,000 $6,814,000 $815,000 $461,000 $0 $0 $0 $8,090,000 Main Internal Roadways
Construction $12,008,000 $3,723,000 $1,914,000 $1,579,000 $0 $0 $19,224,000 $5,246,000 $2,113,000 $1,614,000 $1,041,000 $0 $0 $10,014,000 Contingency 10% $1,201,000 $372,000 $191,000 $158,000 $0 $0 $1,922,000 $525,000 $211,000 $161,000 $104,000 $0 $0 $1,001,000 Soft Cost 15% $1,801,000 $558,000 $287,000 $237,000 $0 $0 $2,883,000 $787,000 $317,000 $242,000 $156,000 $0 $0 $1,502,000 Subtotal Main Internal Roadways $15,010,000 $4,653,000 $2,392,000 $1,974,000 $0 $0 $24,029,000 $6,558,000 $2,641,000 $2,017,000 $1,301,000 $0 $0 $12,517,000 Road B
Mobility Hub (includes 25% contingency) $862,000 $0 $0 $0 $0 $0 $862,000 $862,000 $0 $0 $0 $0 $0 $862,000 Other Construction $10,048,000 $839,000 $1,118,000 $467,000 $0 $0 $12,472,000 $10,048,000 $839,000 $1,118,000 $101,000 $0 $0 $12,106,000 Contingency (on Other Construction) 10% $1,005,000 $84,000 $112,000 $47,000 $0 $0 $1,248,000 $1,005,000 $84,000 $112,000 $10,000 $0 $0 $1,211,000Soft Cost 15% $1,637,000 $126,000 $168,000 $70,000 $0 $0 $2,001,000 $1,637,000 $126,000 $168,000 $15,000 $0 $0 $1,946,000Subtotal Road B $13,552,000 $1,049,000 $1,398,000 $584,000 $0 $0 $16,583,000 $13,552,000 $1,049,000 $1,398,000 $126,000 $0 $0 $16,125,000 Harry Lorenzo - Half Section North [2] $387,000 $0 $0 $0 $0 $0 $387,000 $0 $0 $0 $0 $0 $0 $0 Hwy 113/CR 25A Interchange
Right of Way and Utilities (no soft costs/cont.) $250,000 $0 $0 $0 $0 $0 $250,000 $132,000 $0 $0 $0 $0 $0 $132,000 Construction (incl. 20% contingency) $10,307,000 $0 $0 $0 $0 $0 $10,307,000 $5,463,000 $0 $0 $0 $0 $0 $5,463,000 Construction Management 15% $1,546,000 $0 $0 $0 $0 $0 $1,546,000 $819,000 $0 $0 $0 $0 $0 $819,000 Soft Cost 15.56% $1,604,000 $0 $0 $0 $0 $0 $1,604,000 $850,000 $0 $0 $0 $0 $0 $850,000Subtotal SR 113/CR 25A Interchange $13,707,000 $0 $0 $0 $0 $0 $13,707,000 $7,264,000 $0 $0 $0 $0 $0 $7,264,000 Parkland Avenue Overcrossing
Construction $7,863,000 $0 $0 $0 $0 $0 $7,863,000 $3,590,000 $0 $0 $0 $0 $0 $3,590,000 Construction Management 25% $1,966,000 $0 $0 $0 $0 $0 $1,966,000 $898,000 $0 $0 $0 $0 $0 $898,000 Soft Cost 15% $1,180,000 $0 $0 $0 $0 $0 $1,180,000 $539,000 $0 $0 $0 $0 $0 $539,000 Subtotal Parkland Avenue Overcrossing $11,009,000 $0 $0 $0 $0 $0 $11,009,000 $5,027,000 $0 $0 $0 $0 $0 $5,027,000 Sewer Lift Station Upgrades
Construction $0 $0 $0 $734,000 $0 $0 $734,000 $0 $0 $0 $335,000 $0 $0 $335,000 Offsite Contingency 20% $0 $0 $0 $147,000 $0 $0 $147,000 $0 $0 $0 $67,000 $0 $0 $67,000 Soft Cost 15% $0 $0 $0 $110,000 $0 $0 $110,000 $0 $0 $0 $50,000 $0 $0 $50,000 Subtotal Sewer Lift Station Upgrades $0 $0 $0 $991,000 $0 $0 $991,000 $0 $0 $0 $452,000 $0 $0 $452,000 Greenbelts, Parks, and Ponds
Construction $0 $3,632,000 $408,000 $0 $22,249,000 $0 $26,289,000 $0 $3,632,000 $0 $0 $21,310,000 $0 $24,942,000Contingency 10% $0 $363,000 $41,000 $0 $2,225,000 $0 $2,629,000 $0 $363,000 $0 $0 $2,131,000 $0 $2,494,000 Soft Cost 15% $0 $545,000 $61,000 $0 $3,337,000 $0 $3,943,000 $0 $545,000 $0 $0 $3,197,000 $0 $3,742,000Subtotal Greenbelts, Parks, and Ponds $0 $4,540,000 $510,000 $0 $27,811,000 $0 $32,861,000 $0 $4,540,000 $0 $0 $26,638,000 $0 $31,178,000 Off-Site Storm Drainage $0 $8,650,000 $0 $0 $0 $8,650,000 $0 $1,159,000 $0 $0 $0 $1,159,000Land Allocations $2,908,000 $648,000 $0 $0 $2,035,000 $0 $5,591,000 $1,828,000 $648,000 $0 $0 $2,035,000 $0 $4,511,000 Ag Mitigation and HCP Cost $992,000 $175,000 $0 $0 $273,000 $0 $1,440,000 $992,000 $175,000 $0 $0 $273,000 $0 $1,440,000 Subtotal Costs $69,596,000 $20,841,000 $5,228,000 $3,549,000 $30,119,000 $0 $129,333,000 $47,252,000 $11,338,000 $4,343,000 $1,879,000 $28,946,000 $0 $93,758,000Planning and Administration [3] 0% $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 Total Costs $69,596,000 $20,841,000 $5,228,000 $3,549,000 $30,119,000 $0 $129,333,000 $47,252,000 $11,338,000 $4,343,000 $1,879,000 $28,946,000 $0 $93,758,000 Source: Cunningham Engineering[1] Includes Grading & Erosion Control, Street Work & Concrete, Dry Utilities, Streetlights, Mobility Hub, and ROW acquisition. [2] Improvements completed.[3] Planning and Administration costs from CIP are excluded because they are accounted for in the RTIF Program Administration fee component.

Total Estimated Costs RTIF
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Table A-1Woodland Research and Technology Park Financing PlanBackbone Infrastructure Cost Estimates (2023$)Item AssumptionCounty Road 25A (Hwy 113 to Harry Lorenzo and Parkland to Miekle) ConstructionContingency 10%Soft Cost 15%Subtotal County Road 25A Parkland Avenue
ConstructionContingency 10%Soft Cost 15%Subtotal Parkland Avenue Main Internal Roadways
ConstructionContingency 10%Soft Cost 15%Subtotal Main Internal Roadways Road B
Mobility Hub (includes 25% contingency)
Other ConstructionContingency (on Other Construction) 10%Soft Cost 15%Subtotal Road B Harry Lorenzo - Half Section North [2]Hwy 113/CR 25A Interchange Right of Way and Utilities (no soft costs/cont.)Construction (incl. 20% contingency)Construction Management 15%Soft Cost 15.56%Subtotal SR 113/CR 25A Interchange Parkland Avenue Overcrossing
ConstructionConstruction Management 25%Soft Cost 15%Subtotal Parkland Avenue Overcrossing Sewer Lift Station Upgrades
ConstructionOffsite Contingency 20%Soft Cost 15%Subtotal Sewer Lift Station Upgrades Greenbelts, Parks, and Ponds
ConstructionContingency 10%Soft Cost 15%Subtotal Greenbelts, Parks, and Ponds Off-Site Storm DrainageLand AllocationsAg Mitigation and HCP CostSubtotal CostsPlanning and Administration [3] 0% Total CostsSource: Cunningham Engineering
[1] Includes Grading & Erosion Control, Street Work & Concrete, Dry Utilities, Streetlights, Mobility Hub, and ROW acquisition. [2] Improvements completed.[3] Planning and Administration costs from CIP are excluded because they are accounted for in the RTIF Program Administration fee component.

SP-1B/1C Other
Streets [1]
Storm
Drainage Water Sewer Total Streets [1] Water Sewer Total Streets [1] Streets [1] Parks and
Open Space Total
Storm
Drainage
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$6,762,000 $1,610,000 $300,000 $538,000 $9,210,000 $0 $0 $0 $0 $0 $0 $0 $0 $676,000 $161,000 $30,000 $54,000 $921,000 $0 $0 $0 $0 $0 $0 $0 $0 $1,014,000 $241,000 $45,000 $81,000 $1,381,000 $0 $0 $0 $0 $0 $0 $0 $0 $8,452,000 $2,012,000 $375,000 $673,000 $11,512,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0$0 $0 $0 $366,000 $366,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $37,000 $37,000 $0 $0 $0 $0 $0 $0 $0 $0$0 $0 $0 $55,000 $55,000 $0 $0 $0 $0 $0 $0 $0 $0$0 $0 $0 $458,000 $458,000 $0 $0 $0 $0 $0 $0 $0 $0 $387,000 $0 $0 $0 $387,000 $0 $0 $0 $0 $0 $0 $0 $0
$0 $0 $0 $0 $0 $63,000 $0 $0 $63,000 $0 $55,000 $55,000 $0 $0 $0 $0 $0 $0 $2,577,000 $0 $0 $2,577,000 $0 $2,267,000 $2,267,000 $0$0 $0 $0 $0 $0 $387,000 $0 $0 $387,000 $0 $340,000 $340,000 $0 $0 $0 $0 $0 $0 $401,000 $0 $0 $401,000 $0 $353,000 $353,000 $0 $0 $0 $0 $0 $0 $3,428,000 $0 $0 $3,428,000 $0 $3,015,000 $3,015,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $4,273,000 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $1,068,000 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $0 $0 $641,000 $0 $0 $0$0 $0 $0 $0 $0 $0 $0 $0 $0 $5,982,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $399,000 $399,000 $0 $0 $0 $0$0 $0 $0 $0 $0 $0 $0 $60,000 $60,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $80,000 $80,000 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $0 $539,000 $539,000 $0 $0 $0 $0
$0 $0 $0 $0 $0 $0 $408,000 $0 $408,000 $0 $0 $939,000 $939,000 $0 $0 $0 $0 $0 $0 $0 $41,000 $0 $41,000 $0 $0 $94,000 $94,000 $0$0 $0 $0 $0 $0 $0 $61,000 $0 $61,000 $0 $0 $140,000 $140,000 $0 $0 $0 $0 $0 $0 $0 $510,000 $0 $510,000 $0 $0 $1,173,000 $1,173,000 $0$0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $7,491,000 $538,000 $0 $0 $0 $538,000 $0 $0 $0 $0 $542,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$9,377,000 $2,012,000 $375,000 $1,131,000 $12,895,000 $3,428,000 $510,000 $539,000 $4,477,000 $6,524,000 $3,015,000 $1,173,000 $4,188,000 $7,491,000 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0 $0
$9,377,000 $2,012,000 $375,000 $1,131,000 $12,895,000 $3,428,000 $510,000 $539,000 $4,477,000 $6,524,000 $3,015,000 $1,173,000 $4,188,000 $7,491,000 Developer City SLSP
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APPENDIX B:

Development Impact Fee Analysis
Table B-1 Single-Family Development Fees ................................ B-1 Table B-2 Multifamily Development Fees .................................... B-2 Table B-3 Nonresidential Development Fees (2 pages) ................. B-3 Table B-4 Estimated WRTP Fee Revenue for Backbone
Infrastructure and Public Facilities ............................... B-5

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Table B-1
Woodland Research and Technology Park Financing Plan
Single Family Development Fees (2023$)
Development Impact Fees Description/Formula
Low
Density
Medium
Density
Assumptions
Building Valuation Group R-3 R-3
Construction Type VB VB
Valuation per sq. ft. (VB construction type Feb. 2023) $167.37 $167.37 Garage Valuation per sq. ft. (VB construction type Feb. 2023) $66.48 $66.48 Square Feet 2,300 1,850
Garage Square Feet 450 400
Units per Acre 6 12
Building Valuation per Unit $384,951 $309,635
Garage Valuation per Unit $29,916 $26,592
Total Unit Valuation $414,867 $336,227
City Building Permit Processing Fees (effective July 1, 2022) Building Inspection and Plan Review Fee [1] $1,641 $1,402 Green Building Plan Review $276 $276
Permit Processing Charge/Application $8 $8
Seismic/Strong Motion $0.00013 of total valuation $54 $44 California Building Standards Commission Fee $1.00 per $25,000 value $17 $14 Electrical Permit Processing $58 $58
Electrical Inspection 10% of building fee; $200 min. $200 $200 Plumbing Permit Processing $58 $58
Pluming Inspection 20% of building fee; $400 min. $400 $400 Mechanical Permit Processing $58 $58
Mechanical Inspection 10% of building fee; $200 min. $200 $200 Solar Plan Review and Inspection $280 $280
Energy Compliance Inspections $55 $55
Fire Sprinklers Plan Check and Review $556 $556
Total Processing Fees $3,861 $3,608
City Development Impact Fees (effective Jan. 1, 2023)
General City $1,005 $1,005
Fire $3,406 $3,406
Library $628 $628
Police $823 $823
Wastewater $7,524 $7,524
Parks & Recreation $9,279 $9,279
Roads $9,915 $9,915
Water $6,174 $6,174
Administration $291 $291
Affordable Housing - Proposed Fee per sq. ft.: LDR: $3; MDR: $2.50 $6,900 $4,625 Agricultural Mitigation [2] $15,000 per acre $2,500 $1,250 Public Transit Fee (due at final map) $311 $311
Total City Development Impact Fees $48,756 $45,231
Other Agency Fees
County Facilities and Services Authorization (effective 9/13/16) $3,118 $3,118 School District Fees [3] $4.08 per sq. ft. $9,384 $7,548 Yolo County HCP Fee (effective 3/27/23) $16,202 per acre $2,700 $1,350 Total Other Agency Fees $15,202 $12,016
RTIF - Proposed $65,854 $45,004
Total Fees per Unit $133,673 $105,859
Source: City of Woodland; Yolo County; WJUSD; EPS
[1] First 1,000 sq. ft.; $946
1,000-2,000 sq. ft.: $53.60 for each 100 sq. ft. or fraction thereof 2,000-3,000 sq. ft.: $53.10 for each 100 sq. ft. or fraction thereof [2] Estimated amount. Different requirements for different development and mitigation land. [3] Fee for all areas of Woodland except Spring Lake. Spring Lake rate is $6.13 per sq. ft.

Fee per Unit
Fee per Unit
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Table B-2
Woodland Research and Technology Park Financing Plan
Multifamily Development Fees (2023$)
Development Impact Fees Description/Formula Per Permit Per Unit Assumptions
Building Valuation Group R-2
Valuation per sq. ft. (VA construction type) $117.40
Square Feet per Unit 990
Units per Acre 24
Acres per Permit 1
Building Valuation per Unit $116,226
Total Building Valuation per Permit $2,789,424
City Building Permit Processing Fees
Building Inspection/Building Permit Fee [1] $15,491 $645 Plan Review 65% of bldg. insp. fee $10,069 $420
Permit Processing Charge/Application $58 per permit $58 $2 Energy Plan Review 5% of plan review $503 $21
Disability Plan Review 5% of plan review $503 $21
Seismic/Strong Motion $0.00028 of valuation $781 $33
California Building Standards Commission Fee $1.00 per $25,000 value $112 $5 Electrical Permit Processing $58 per permit $58 $2
Electrical Inspection $0.012 per sq. ft. $285 $12
Plumbing Permit Processing $58 per permit $58 $2
Pluming Inspection $0.02 per sq. ft. $475 $20
Mechanical Permit Processing $58 per permit $58 $2
Mechanical Inspection $0.012 per sq. ft. $285 $12
Solar Plan Review and Inspection $600 per permit $600 $25 Energy Compliance Inspections $9 per unit $216 $9
Fire Sprinklers Plan Check and Review [2] $1,017 per permit $1,017 $42 Total Processing Fees $30,570 $1,274
City Development Impact Fees (effective Jan. 1, 2023)
General City $755
Fire $2,042
Library $471
Police $616
Wastewater $5,642
Parks & Recreation $6,959
Roads $4,063
Administration $154
Water (including 0.75% administration) $977
Affordable Housing - Proposed $2.00 per sq. ft. $1,980
Agricultural Mitigation [3] $15,000 per acre $625
Public Transit Fee (due at final map) [4] $218
Total Citywide Development Impact Fees $24,502
Other Agency Fees
County Facilities and Services Authorization (effective 9/13/16) $2,312 School District Fees [5] $4.08 per sq. ft. $4,039
Yolo County HCP Fee (effective 3/27/23) $16,202 per acre $675 Total Other Agency Fees $7,026
RTIF - Proposed $33,663
Total Fees $66,465
Source: City of Woodland; Yolo County; WJUSD; EPS
[1] First $1 million of valuation: $6,730.50. Remaining valuation: $4.38 for each $1,000 or fraction thereof. [2] $242 + $0.05 per bldg. sq. ft. for first 10,000 square feet + $0.02 per bldg. sq. ft. for remaining square feet. [3] Estimated amount. Different requirements for different development and mitigation land. [4] 70% of single family fee.
[5] Fee for all areas of Woodland except Spring Lake. Spring Lake rate is $6.13 per sq. ft.

Multifamily
(High Density)
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Woodland Research and Technology Park Financing Plan
Nonresidential Development Fees (2023$)
Item Description/Formula
Village Center/
Com. Commercial
Business
Park
Assumptions
Building Valuation Group MB
Construction Type IIIA IIIA
Valuation per sq. ft. (ICC February 2023) $164.83 $213.00 Acres 5.00 5.00
FAR 0.43 0.40
Square Feet 94,651 87,120
Total Project Valuation $15,601,351 $18,556,554
Water Meters 22
Water Meter Size 2" 2"
City Building Permit Processing Fees (effective July 1, 2022) Building Inspection/Building Permit Fee [1] $72,431 $85,571 Plan Review 65% of bldg. insp. fee $47,080 $55,621
Permit Processing Charge/Application $58 per permit $58 $58 Energy Plan Review 5% of plan review $2,354 $2,781
Disability Plan Review 5% of plan review $2,354 $2,781
Seismic/Strong Motion $0.00028 of valuation $4,368 $5,196 California Building Standards Commission $1.00 per $25,000 value $625 $743 Electrical Permit Processing $58 per permit $58 $58
Electrical Inspection $0.012 per sq. ft. $1,136 $1,045
Plumbing Permit Processing $58 per permit $59 $58
Pluming Inspection $0.02 per sq. ft. $1,893 $1,742
Mechanical Permit Processing $58 per permit $59 $58
Mechanical Inspection $0.012 per sq. ft. $1,136 $1,045
Solar Plan Review and Inspection $600 per permit $600 $600 Energy Compliance Inspections $108 per permit $108 $108 Fire Sprinklers Plan Check and Review [2] per sq. ft. $2,435 $2,284 Total Processing Fees $136,753 $159,750
City Development Impact Fees (effective Jan. 1, 2023)
Land Use
General City per 1,000 sq. ft.

Fire per 1,000 sq. ft.

Library per 1,000 sq. ft.

Police per 1,000 sq. ft.

Wastewater per 1,000 sq. ft.

Parks & Recreation per 1,000 sq. ft.

Roads per 1,000 sq. ft.

Administration per 1,000 sq. ft.

Water (including 0.75% administration) $19,757 per 2" meter $39,810 $39,810 Agricultural Mitigation [3] $15,000 per acre
Total Citywide Development Impact Fees
Other Agency Fees
County Facilities and Services Authorization (eff. 9/13/16) per 1,000 sq. ft.

School District Fees $0.66 per sq. ft.

Yolo County HCP Fee (effective 3/27/23) $16,202 per acre Total Other Agency Fees
RTIF - Proposed
Total Fees
Source: City of Woodland; Yolo County; WJUSD; EPS
[1] First $1 million of valuation: $6,730.50.

Remaining valuation: $4.38 for each $1,000 or fraction thereof. [2] $242 plus $0.05 for the first 10,000 sq. ft. plus $0.02 for each additional sq. ft. thereafter. [3] Estimated amount. Different requirements for different development and mitigation land.

Fee per Permit
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Woodland Research and Technology Park Financing Plan
Nonresidential Development Fees (2023$)
Item Description/Formula
Assumptions
Building Valuation Group
Construction Type
Valuation per sq. ft. (ICC February 2023)
Acres
FAR
Square Feet
Total Project Valuation
Water Meters
Water Meter Size
City Building Permit Processing Fees (effective July 1, 2022) Building Inspection/Building Permit Fee [1]
Plan Review 65% of bldg. insp. fee
Permit Processing Charge/Application $58 per permit
Energy Plan Review 5% of plan review
Disability Plan Review 5% of plan review
Seismic/Strong Motion $0.00028 of valuation
California Building Standards Commission $1.00 per $25,000 value Electrical Permit Processing $58 per permit
Electrical Inspection $0.012 per sq. ft.

Plumbing Permit Processing $58 per permit
Pluming Inspection $0.02 per sq. ft.

Mechanical Permit Processing $58 per permit
Mechanical Inspection $0.012 per sq. ft.

Solar Plan Review and Inspection $600 per permit
Energy Compliance Inspections $108 per permit
Fire Sprinklers Plan Check and Review [2] per sq. ft.

Total Processing Fees
City Development Impact Fees (effective Jan. 1, 2023)
Land Use
General City per 1,000 sq. ft.

Fire per 1,000 sq. ft.

Library per 1,000 sq. ft.

Police per 1,000 sq. ft.

Wastewater per 1,000 sq. ft.

Parks & Recreation per 1,000 sq. ft.

Roads per 1,000 sq. ft.

Administration per 1,000 sq. ft.

Water (including 0.75% administration) $19,757 per 2" meter Agricultural Mitigation [3] $15,000 per acre
Total Citywide Development Impact Fees
Other Agency Fees
County Facilities and Services Authorization (eff. 9/13/16) per 1,000 sq. ft.

School District Fees $0.66 per sq. ft.

Village Center/
Com. Commercial
Business
Park
MB

IIIA IIIA
$164.83 $213.00

5.00 5.00

0.43 0.40
94,651 87,120
$15,601,351 $18,556,554
22 2" 2"
$0.77 $0.98
$0.50 $0.64
$0.00 $0.00
$0.02 $0.03
$0.02 $0.03
$0.05 $0.06
$0.01 $0.01
$0.00 $0.00
$0.01 $0.01
$0.00 $0.00
$0.02 $0.02
$0.00 $0.00
$0.01 $0.01
$0.01 $0.01
$0.00 $0.00
$0.03 $0.03
$1.44 $1.83
Retail Office
$0.67 $0.79
$1.99 $2.15
$0.00 $0.00
$0.55 $0.65
$3.07 $1.74
$0.00 $0.00
$12.31 $6.23
$0.14 $0.09
$0.42 $0.46
$0.79 $0.86
$19.94 $12.97
$0.50 $0.67
$0.66 $0.66
$0.86 $0.93
$2.02 $2.26
$11.89 $6.73
$35.30 $23.78
Fee per Bldg. Sq. Ft.

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Table B-4
Woodland Research and Technology Park Financing PlanEstimated WRTP Fee Revenue for Backbone Infrastructure and Public Facilities (2023$) Item
Low
Density
Medium
Density
High
Density
Village Center/
Com. Commercial
Business
Park Total
Dwelling Units/Building Square Feet 628 524 518 310,948 1,980,115Building Permit Processing Fees $2,424,854 $1,890,754 $659,800 $449,262 $3,630,892 $9,055,563City Development Impact Fees General City $631,140 $526,620 $391,090 $208,646 $1,572,211 $3,329,707Fire $2,138,968 $1,784,744 $1,057,756 $617,543 $4,257,247 $9,856,258Library $394,384 $329,072 $243,978 $0 $0 $967,434 Police $516,844 $431,252 $319,088 $170,400 $1,283,115 $2,720,698Wastewater $4,725,072 $3,942,576 $2,922,556 $954,921 $3,453,321 $15,998,446Parks & Recreation $5,827,212 $4,862,196 $3,604,762 $0 $0 $14,294,170 Roads $6,226,620 $5,195,460 $2,104,634 $3,828,392 $12,326,216 $29,681,322Water $3,877,272 $3,235,176 $506,086 $130,785 $904,834 $8,654,153Administration $182,748 $152,484 $79,772 $43,222 $172,270 $630,496 Affordable Housing - Proposed $4,333,200 $2,423,500 $1,025,640 $0 $0 $7,782,340Agricultural Mitigation $1,570,000 $655,000 $323,750 $246,390 $1,704,645 $4,499,785Public Transit $195,308 $162,964 $112,924 $0 $0 $471,196 Total Citywide Development Impact Fees $30,618,768 $23,701,044 $12,692,036 $6,200,298 $25,673,858 $98,886,004 Other Agency Fees
County Facilities and Services Authorization $1,958,104 $1,633,832 $1,197,616 $155,474 $1,318,757 $6,263,783 School District Fees $5,893,152 $3,955,152 $2,092,306 $205,226 $1,306,876 $13,452,711 Yolo County HCP Fee $1,695,809 $707,487 $349,693 $266,134 $1,841,244 $4,860,368Total Other Agency Fees $9,547,065 $6,296,471 $3,639,615 $626,834 $4,466,876 $24,576,862 RTIF - Proposed
Streets $17,619,713 $11,811,748 $6,348,539 $3,105,698 $9,816,301 $48,702,000 Storm Drainage $4,366,048 $2,484,704 $1,598,075 $364,864 $2,524,309 $11,338,000 Water $1,825,876 $1,296,889 $911,283 $42,385 $266,566 $4,343,000Sewer $738,832 $476,823 $424,029 $42,641 $196,674 $1,879,000 Parks and Open Space $13,055,403 $8,404,261 $7,484,867 $0 $0 $28,944,531Total RTIF $37,605,873 $24,474,425 $16,766,793 $3,555,589 $12,803,851 $95,206,531 Total Fee Revenue $80,196,561 $56,362,695 $33,758,244 $10,831,983 $46,575,477 $227,724,959 Source: City of Woodland; Yolo County; WJUSD; EPS
Residential Commercial
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APPENDIX C:

Infrastructure Cost Burden Comparison
Table C-1 Fee Comparison—Low-Density
Single-Family Development........................................ C-1 Table C-2 Fee Comparison—Medium-Density
Single-Family Development........................................ C-2 Table C-3 Fee Comparison—High Density Dwelling Unit ................ C-3 Table C-4 Fee Comparison—Commercial Development ................. C-4 Table C-5 Spring Lake Single Family Development Fees ............... C-5 Table C-6 Spring Lake Multifamily Development Fees ................... C-6 Table C-7 Spring Lake Commercial Fees ..................................... C-7 Table C-8 Panhandle Residential Development
Impact Fees (2 pages) .............................................. C-8 Table C-9 Northlake Residential Development
Impact Fees .......................................................... C-10 Table C-10 Northlake Commercial Fees ...................................... C-11

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Table C-1
Woodland Research and Technology Park Financing Plan
Fee Comparison - Low-Density Single-Family Development (2023$) Item WRTP SLSP
Panhandle
(Traditional Unit) Northlake [1]
Source Table 7-1 Table C-5 Table C-8 Table C-9
Building Permit Processing Fees $3,861 $3,861 $8,185 $8,308 City Fees $48,756 $54,396 $23,939 $23,939
Other Agency Fees $15,202 $19,917 $32,183 $39,433
Plan Area Fees $65,854 $56,510 $23,605 $5,333
Total Fees $133,673 $134,685 $87,911 $77,012
Source: City of Woodland; City of Sacramento; other public agencies; EPS [1] The Northlake plan area fees include only certain public facility obligations not covered through existing City fees. Because the project was developed by a single master developer, costs for project-related backbone infrastructure were not included.

Woodland Sacramento
Fee per Low-Density Single-Family Dwelling Unit
$0
$20,000
$40,000
$60,000
$80,000
$100,000
$120,000
$140,000
$160,000
WRTP SLSP Panhandle Northlake
Fee per Low-Density Single-Family Dwelling Unit
Building Permit Processing City Other Agency Plan Area
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Table C-2
Woodland Research and Technology Park Financing Plan
Fee Comparison - Medium Density Single Family Development (2023$) Item WRTP SLSP
Panhandle
(Village Unit) Northlake
Source Table 7-1 Table C-5 Table C-8 Table C-9
Building Permit Processing Fees $3,608 $3,608 $6,864 $6,864 City Fees $45,231 $44,539 $22,337 $22,337
Other Agency Fees $12,016 $15,809 $27,331 $34,432
Plan Area Fees $45,004 $37,637 $23,446 $3,742
Total Fees $105,859 $101,593 $79,978 $67,375
Source: City of Woodland; City of Sacramento; other public agencies; EPS [1] The Northlake plan area fees include only certain public facility obligations not covered through existing City fees. Because the project was developed by a single master developer, costs for project-related backbone infrastructure were not included.

Fee per Medium-Density Single-Family Dwelling Unit
Woodland Sacramento
$0
$20,000
$40,000
$60,000
$80,000
$100,000
$120,000
WRTP SLSP Panhandle Northlake
Fee per Medium-Density Single-Family Dwelling Unit
Building Permit Processing City Other Agency Plan Area
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Table C-3
Woodland Research and Technology Park Financing Plan
Fee Comparison - High Density Dwelling Unit (2023$)
Item WRTP SLSP
Source Table 7-1 Table C-6
Building Permit Processing Fees $1,274 $1,274
City Fees $24,502 $23,473
Other Agency Fees $7,026 $7,026
Plan Area Fees $33,663 $37,637
Total Fees $66,465 $69,410
Source: City of Woodland; City of Sacramento; other public agencies; EPS Woodland
Fee per High-Density Dwelling Unit
$0
$10,000
$20,000
$30,000
$40,000
$50,000
$60,000
$70,000
$80,000

WRTP SLSP
Fee per High-Density Dwelling Unit
Building Permit Processing City Other Agency Plan Area
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Table C-4
Woodland Research and Technology Park Financing Plan
Fee Comparison - Commercial Development (2023$)
Sacramento
Item WRTP
Spring Lake
Specific Plan Northlake
Source Table 7-1 Table C-7 Table C-10
Building Permit Processing Fees $1.44 $1.44 $3.79
City Fees $19.94 $19.94 $4.47
Other Agency Fees $2.02 $2.02 $8.66
Plan Area Fees $11.89 $43.45 $4.58
Total Fees $35.30 $66.85 $21.50
Source: City of Woodland; City of Sacramento; other public agencies; EPS [1] The Northlake plan area fees include only certain public facility obligations not covered through existing City fees. Because the project was developed by a single master developer, costs for project-related backbone infrastructure were not included.

Woodland
Fee per Commercial Bldg. Sq. Ft.
$0.00
$10.00
$20.00
$30.00
$40.00
$50.00
$60.00
$70.00
$80.00
WRTP SLSP Northlake
Fee per Commercial Building Square Foot
Building Permit Processing City Other Agency Plan Area
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Table C-5
Woodland Research and Technology Park Financing Plan
Spring Lake Single Family Development Fees (2023$)
Item
Low
Density
Medium
Density
Assumptions
Building Valuation Group R-3 R-3
Construction Type VB VB
Valuation per sq. ft. (VB construction type Feb. 2023) $167.37 $167.37 Garage Valuation per sq. ft. (VB construction type Feb. 2023) $66.48 $66.48 Square Feet 2,300 1,850
Garage Square Feet 450 400
Units per Acre 6 12
Building Valuation per Unit $384,951 $309,635
Garage Valuation per Unit $29,916 $26,592
Total Unit Valuation $414,867 $336,227
City Building Permit Processing Fees (effective July 1, 2022) Building Inspection and Plan Review Fee [1] $1,641 $1,402 Green Building Plan Review $276 $276
Permit Processing Charge/Application $8 $8
Seismic/Strong Motion $54 $44 $0.00013 of total valuation California Building Standards Commission Fee $17 $14 $1.00 per $25,000 value Electrical Permit Processing $58 $58
Electrical Inspection $200 $200 10% of building fee; $200 min.

Plumbing Permit Processing $58 $58
Pluming Inspection $400 $400 20% of building fee; $400 min.

Mechanical Permit Processing $58 $58
Mechanical Inspection $200 $200 10% of building fee; $200 min.

Solar Plan Review and Inspection $280 $280
Energy Compliance Inspections $55 $55
Fire Sprinklers Plan Check and Review $556 $556
Total Processing Fees $3,861 $3,608
City Development Impact Fees (effective Jan. 1, 2023)
General City $1,005 $1,005
Fire $3,406 $3,406
Library $628 $628
Police $823 $823
Wastewater $7,524 $7,524
Parks & Recreation $5,105 $5,105
Roads $9,915 $9,915
Water $6,174 $6,174
Administration $259 $259
Affordable Housing [2] [3] $8,629 $3,200
Agricultural Mitigation [4] $2,500 $1,250 $15,000 per acre Fiscal Deficit Fee $1,500 $1,050
Fire Operations & Maintenance Fund $771 $540
General Purpose Fee [2] [3] $5,790 $3,402
Habitat Education (due at final map) $56 $40
Public Transit Fee (due at final map) $311 $218
Total City Development Impact Fees $54,396 $44,539
Other Agency Fees
County Facilities and Services Authorization (effective 9/13/16) $3,118 $3,118 School District Fees [5] $14,099 $11,341 $6.13 per sq. ft.

Yolo County HCP Fee (effective 3/27/23) $2,700 $1,350 $16,202 per acre Total Other Agency Fees $19,917 $15,809
SLIF
Roadway $24,503 $16,173 multifamily rate for medium density Water $2,777 $1,794 multifamily rate for medium density Sewer $3,579 $2,739 multifamily rate for medium density Drainage $12,702 $8,383 multifamily rate for medium density Fire Station $1,021 $674 multifamily rate for medium density Parks $10,084 $6,656 multifamily rate for medium density On-going Admin Costs $1,844 $1,218 multifamily rate for medium density Subtotal SLIF $56,510 $37,637
Total Fees per Unit $134,685 $101,593
Source: City of Woodland; Yolo County; WJUSD; EPS
[1] First 1,000 sq. ft.; $946
1,000-2,000 sq. ft.: $53.60 for each 100 sq. ft. or fraction thereof 2,000-3,000 sq. ft.: $53.10 for each 100 sq. ft. or fraction thereof [2] LDR fees are based on Pioneer Village development project. [3] MDR fees are based on Beeghly multifamily development project. Affordable housing assuming a 10 percent requirement. [4] Estimated amount. Different requirements for different development and mitigation land. [5] School fee set equal to Spring Lake rate. Rate for all other areas of Woodland is $4.08 per sq. ft.

Fee per Unit
Fee per Unit
Description/Formula
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Table C-6
Woodland Research and Technology Park Financing Plan
Spring Lake Multifamily Development Fees (2023$)
Item Per Permit Per Unit
Assumptions
Building Valuation Group R-2
Valuation per sq. ft. (VA construction type) $117.40
Square Feet per Unit 990
Units per Acre 24
Acres per Permit 1
Building Valuation per Unit $116,226
Total Building Valuation per Permit $2,789,424
City Building Permit Processing Fees
Building Inspection/Building Permit Fee [1] $15,491 $645 Plan Review $10,069 $420 65% of bldg. insp. fee
Permit Processing Charge/Application $58 $2 $58 per permit Energy Plan Review $503 $21 5% of plan review
Disability Plan Review $503 $21 5% of plan review
Seismic/Strong Motion $781 $33 $0.00028 of valuation
California Building Standards Commission Fee $112 $5 $1.00 per $25,000 value Electrical Permit Processing $58 $2 $58 per permit
Electrical Inspection $285 $12 $0.012 per sq. ft.

Plumbing Permit Processing $58 $2 $58 per permit
Pluming Inspection $475 $20 $0.02 per sq. ft.

Mechanical Permit Processing $58 $2 $58 per permit
Mechanical Inspection $285 $12 $0.012 per sq. ft.

Solar Plan Review and Inspection $600 $25 $600 per permit Energy Compliance Inspections $216 $9 $9 per unit
Fire Sprinklers Plan Check and Review [2] $1,017 $42 $1,017 per permit Total Processing Fees $30,570 $1,274
City Development Impact Fees (effective Jan. 1, 2023)
General City $755
Fire $2,042
Library $471
Police $616
Wastewater $5,642
Parks & Recreation $3,828
Roads $4,063
Administration $131
Water (including 0.75% administration) [3] $977
Affordable Housing $2,475
Agricultural Mitigation [4] $625 $15,000 per acre
Fiscal Defecit Fee $1,050
Fire Operations & Maintenance Fund $540
Habitat Education $40
Public Transit Fee (due at final map) [5] $218
Total Citywide Development Impact Fees $23,473
Other Agency Fees
County Facilities and Services Authorization (effective 9/13/16) $2,312 School District Fees $4,039 $4.08 per sq. ft.

Yolo County HCP Fee (effective 3/27/23) $675 $16,202 per acre Total Other Agency Fees $7,026
SLIF
Roadway $16,173
Water $1,794
Sewer $2,739
Drainage $8,383
Fire Station $674
Parks $6,656
On-going Admin Costs $1,218
Subtotal SLIF $37,637
Total Fees per Unit $69,410
Source: City of Woodland; Yolo County; WJUSD; EPS
[1] First $1 million of valuation: $6,730.50. Remaining valuation: $4.38 for each $1,000 or fraction thereof. [2] $242 + $0.05 per bldg. sq. ft. for first 10,000 square feet + $0.02 per bldg. sq. ft. for remaining square feet. [3] City water Is based on Vista Del Robles with 2 4" and 2-2" water mains for 168 units. [4] Estimated amount. Different requirements for different development and mitigation land. [5] 70% of single family fee.

Multifamily
Description/Formula
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Table C-7
Woodland Research and Technology Park Financing Plan
Spring Lake Commercial Fees (2023$)
Item
Fee per
Permit
Fee per Bldg.

Sq. Ft.

Assumptions
Building Valuation Group M
Construction Type IIIA
Valuation per sq. ft. (ICC February 2023) $164.83
Acres 5.00
FAR 0.43
Square Feet 94,651
Total Project Valuation $15,601,351
Water Meters 2
Water Meter Size 2"
City Building Permit Processing Fees (effective July 1, 2022) Building Inspection/Building Permit Fee [1] $72,431 $0.77 Plan Review $47,080 $0.50 65% of bldg. insp. fee
Permit Processing Charge/Application $58 $0.00 $58 per permit Energy Plan Review $2,354 $0.02 5% of plan review
Disability Plan Review $2,354 $0.02 5% of plan review
Seismic/Strong Motion $4,368 $0.05 $0.00028 of valuation California Building Standards Commission $625 $0.01 $1.00 per $25,000 value Electrical Permit Processing $58 $0.00 $58 per permit
Electrical Inspection $1,136 $0.01 $0.012 per sq. ft.

Plumbing Permit Processing $60 $0.00 $58 per permit
Pluming Inspection $1,893 $0.02 $0.02 per sq. ft.

Mechanical Permit Processing $60 $0.00 $58 per permit
Mechanical Inspection $1,136 $0.01 $0.012 per sq. ft.

Solar Plan Review and Inspection $600 $0.01 $600 per permit Energy Compliance Inspections $108 $0.00 $108 per permit Fire Sprinklers Plan Check and Review [2] $2,435 $0.03 per sq. ft.

Total Processing Fees $136,755 $1.44
City Development Impact Fees (effective Jan. 1, 2023)
Land Use Retail
General City $0.67 $671 per 1,000 sq. ft.

Fire $1.99 $1,986 per 1,000 sq. ft.

Library $0.00 $0 per 1,000 sq. ft.

Police $0.55 $548 per 1,000 sq. ft.

Wastewater $3.07 $3,071 per 1,000 sq. ft.

Parks & Recreation $0.00 $0 per 1,000 sq. ft.

Roads $12.31 $12,312 per 1,000 sq. ft.

Administration $0.14 $139 per 1,000 sq. ft.

Water (including 0.75% administration) $39,810 $0.42 $19,757 per 2" meter Agricultural Mitigation [3] $0.79 $15,000 per acre
Total Citywide Development Impact Fees $19.94
Other Agency Fees
County Facilities and Services Authorization (eff. 9/13/16) $0.50 $500 per 1,000 sq. ft.

School District Fees $0.66 $0.66 per sq. ft.

Yolo County HCP Fee (effective 3/27/23) $0.86 $16,202 per acre Total Other Agency Fees $2.02
SLIF
Roadway $18.86
Water $2.10
Sewer $2.70
Drainage $9.79
Fire Station $0.78
Park $7.77
On-going Admin Costs $1.45
Subtotal SLIF $43.45
Total $66.85
Source: City of Woodland; Yolo County; WJUSD; EPS
[1] First $1 million of valuation: $6,730.50.

Commercial
Description/Formula
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Table C-8 Page 1 of 2
Woodland Research and Technology Park Financing PlanPanhandle Residential Development Impact Fees (2023$)Item Estates Traditional Village NotesAssumptions Net Acres 75.7 147.7 60.5Number of Units 340 869 453Unit Size/Bldg. Sq. Ft. 2,500 2,300 1,850Garage Square Feet 500 500 450Units per Acre 4.5 5.9 7.5Valuation per Bldg. Sq. Ft.- Living Area (VB) $167.37 $167.37 $167.37Valuation per Bldg. Sq. Ft. - Garage (U) $66.48 $66.48 $66.48Building Valuation - Living Area and Garage $451,665 $418,191 $339,5512002 Building plus Equipment Valuations Valuation per Bldg. Sq. Ft.- Living Area $92.40 $92.40 $92.40Valuation per Bldg. Sq. Ft. - Garage $24.30 $24.30 $24.30Air Conditioning - Living Area $3.50 $3.50 $3.50Sprinklers - Living Area and Garage $2.60 $2.60 $2.60Building and Equipment Valuation $259,700 $224,670 $181,875 Used for calculation of Construction Excise Tax Current as of Apr-23 Apr-23 Apr-23
Processing Fees per unit per unit per unit
Administrative Processing Fee $164 $164 $164 $164 per hour, assumes 1 hour reviewBuilding Permit $3,465 $3,238 $2,704 $1,078 + $0.006787 for each dollar over $100,000 of bldg. valuation Technology Surcharge $277 $259 $216 8% of Building Permit Plan Review Fee $728 $680 $568 42% of Building Permit Fee; 50% of amount for Master Plan projects.

Technology Surcharge $58 $54 $45 8% of Plan Review Fee
Planning Review Fee $109 $102 $85 15% of Plan Review FeePlanning Inspection Fee $336 $336 $336 Flat rate; charged when Planning Division performs inspections.Seismic/Strong Motion $59 $54 $44 $0.00013 per $1 of bldg. valuationGeneral Plan Recovery Fee $1,174 $1,087 $883 $2.60 per $1,000 of bldg. valuationGreen Building/CBSC Fee $19 $17 $14 $1 per $25,000 of bldg. valuation or fraction, thereofConstruction Excise Tax $2,078 $1,797 $1,455 0.008 * valuation of 2002 bldg. + equipment valuationFire Inspection Fee $279 $260 $214 $0.093 x gross square feetFire Review Fee $136 $136 $136 $136 per hour, assumes 1 hour reviewSubtotal Processing Fees $8,882 $8,185 $6,864 City Development Impact Fees
Adjusted Transportation Development Impact Fee (TDIF) $2,188 $2,188 $2,188 Net of alternative modes creditsWater Development Fee $3,609 $3,609 $3,609 Assumes 1" domestic meter Water Easement Tap Installation Fee $1,822 $1,822 $1,822 Assumes 1" domestic meterWater Meter Installation $672 $672 $672 Assumes 1" domestic meterResidential Construction Water Use Fee $201 $201 $201 Flat rate per residential lotCity Business Operations Tax $181 $167 $136 $0.0004 per $1 of bldg. valuation; Max. $5,000/year/contractor Erosion and Sediment Control (ESC) $70 $70 $70 Flat rate per residential lot Residential
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Table C-8 Page 2 of 2
Woodland Research and Technology Park Financing PlanPanhandle Residential Development Impact Fees (2023$)Item Estates Traditional Village Notes Residential
Neighborhood and Community Parks $4,504 $4,504 $4,504 $4,504 per unit for units 2,000 sq. ft. or largerCitywide Parks/Facilities $2,293 $2,293 $2,293 $2,293 per unit for units 2,000 sq. ft. or largerMixed Income Housing Ordinance/Housing Trust Fund $8,725 $8,027 $6,457 $3.49 per unit sq. ft.Residential Construction Tax $385 $385 $385 Flat rate for dwelling units with 3 or more bedroomsSubtotal City Development Impact Fees $24,650 $23,939 $22,337 Other Agency Fees
Twin Rivers and Robla Elementary School District Fees $11,150 $10,258 $8,251 $4.46 per living area sq. ft. (effective 3/29/2023) Natomas Basin Habitat Conservation Plan Fee $6,638 $5,068 $3,982 $29,815 per acre; assumes land dedication in-lieu ($15,750/acre), so excludes land acquisition portion of total fee ($45,565 per acre).

Sacramento Area Flood Control Agency Dev. Impact Fee $5,250 $4,830 $3,885 $2.10 per habitable area sq. ft.(effective 1/4/2020).Sacramento Countywide Transportation Mitigation Fee $1,458 $1,458 $1,458 $1,429 mitigation fee + 2% admin fee (7/192022)Air Quality Mitigation Fee $290 $290 $290 Estimated $220.18 per unit, plus 15% admin fee ($37.86)Sacramento Area Sewer District (Expansion) $4,978 $3,800 $2,986 $22,360 per net acre for Expansion AreaRegional SAN (New) $6,479 $6,479 $6,479 $6,479 per ESD for New Growth AreaSubtotal Other Agency Fees $36,243 $32,183 $27,331 Panhandle Plan Area Fees
Panhandle DA Fee Component
Regional Park Land Acquisition $2,388 $2,388 $2,388Transit $587 $587 $587Fire Facilities $596 $596 $596Community Center $368 $368 $368Library $936 $936 $936Subtotal Panhandle DA Fee Component $4,875 $4,875 $4,875 Panhandle Impact Fee Component
Roadways $8,736 $8,736 $8,736Sanitary Sewer $234 $178 $175Storm Drainage (Including Land Acquisition) $11,131 $8,497 $8,346Trails $631 $631 $631Subtotal Panhandle Impact Fee Component $20,732 $18,042 $17,888 Panhandle Administration Fee (3%) $768 $688 $683Subtotal Panhandle Plan Area Fees $26,375 $23,605 $23,446 Total Fees $96,150 $87,911 $79,978Source: City of Sacramento; various public agencies; EPS.[1] From the FEIR and escalated by percentage change in SF CPI from April 2018 through April 2022 (14.63%) See Table A-1.

Fee in the FEIR was $220.18 per unit plus 15% administration.

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Table C-9
Woodland Research and Technology Park Financing Plan
Northlake Residential Development Impact Fees (2023$)
Item Low Density Medium Density Notes
Assumptions
Net Acres 147.7 60.5
Number of Units 869 453
Unit Size/Bldg. Sq. Ft. 2,300 1,850
Garage Square Feet 500 450
Units per Acre 5.9 7.5
Valuation per Bldg. Sq. Ft.- Living Area (VB) $167.37 $167.37 Valuation per Bldg. Sq. Ft. - Garage (U) $66.48 $66.48
Building Valuation - Living Area and Garage $418,191 $339,551 2002 Building plus Equipment Valuations
Valuation per Bldg. Sq. Ft.- Living Area $92.40 $92.40
Valuation per Bldg. Sq. Ft. - Garage $24.30 $24.30
Air Conditioning - Living Area $3.50 $3.50
Sprinklers - Living Area and Garage $2.60 $2.60
Building and Equipment Valuation $240,000 $181,875 Used for calculation of Construction Excise Tax Processing Fees per unit per unit
Administrative Processing Fee $164 $164 $164 per hour, assumes 1 hour review Building Permit $3,238 $2,704 $1,078 + $0.006787 for each dollar over $100,000 of bldg. valuation Technology Surcharge $259 $216 8% of Building Permit
Plan Review Fee $680 $568 42% of Building Permit Fee; 50% of amount for Master Plan projects.

Technology Surcharge $54 $45 8% of Plan Review Fee
Planning Review Fee $102 $85 15% of Plan Review Fee
Planning Inspection Fee $336 $336 Flat rate; charged when Planning Division performs inspections.

Seismic/Strong Motion $54 $44 $0.00013 per $1 of bldg. valuation General Plan Recovery Fee $1,087 $883 $2.60 per $1,000 of bldg. valuation Green Building/CBSC Fee $17 $14 $1 per $25,000 of bldg. valuation or fraction, thereof Construction Excise Tax $1,920 $1,455 0.008 * valuation of 2002 bldg. + equipment valuation Fire Inspection Fee $260 $214 $0.093 x gross square feet Fire Review Fee $136 $136 $136 per hour, assumes 1 hour review Subtotal Processing Fees $8,308 $6,864
City Development Impact Fees
Adjusted Transportation Development Impact Fee (TDIF) $2,188 $2,188 Net of alternative modes credits Water Development Fee $3,609 $3,609 Assumes 1" domestic meter Water Easement Tap Installation Fee $1,822 $1,822 Assumes 1" domestic meter Water Meter Installation $672 $672 Assumes 1" domestic meter Residential Construction Water Use Fee $201 $201 Flat rate per residential lot City Business Operations Tax $167 $136 $0.0004 per $1 of bldg. valuation; Max. $5,000/year/contractor Erosion and Sediment Control (ESC) $70 $70 Flat rate per residential lot Neighborhood and Community Parks $4,504 $4,504 $4,504 per unit for units 2,000 sq. ft. or larger Citywide Parks/Facilities $2,293 $2,293 $2,293 per unit for units 2,000 sq. ft. or larger Mixed Income Housing Ordinance/Housing Trust Fund $8,027 $6,457 $3.49 per unit sq. ft.

Residential Construction Tax $385 $385 Flat rate for dwelling units with 3 or more bedrooms Subtotal City Development Impact Fees $23,939 $22,337
Other Agency Fees
Twin Rivers USD $11,017 $8,862 $4.79 per living area sq. ft. (effective 3/29/2023) Rio Linda Supplemental School Fee [1] $6,781 $6,781 $5,180 escalated to 2023$ Natomas Basin Habitat Conservation Plan Fee $5,068 $3,982 $29,815 per acre; assumes land dedication in-lieu ($15,750/acre), so excludes land acquisition portion of total fee ($45,565 per acre).

Sacramento Area Flood Control Agency Dev. Impact Fee $4,830 $3,885 $2.10 per habitable area sq. ft.(effective 1/4/2020).

Sacramento Countywide Transportation Mitigation Fee $1,458 $1,458 $1,429 mitigation fee + 2% admin fee Sacramento Area Sewer District (Expansion) $3,800 $2,986 $22,360 per net acre for Expansion Area Regional SAN $6,479 $6,479 $6,479 per ESD for New Growth Area Subtotal Other Agency Fees $39,433 $34,432
North Lake (Greenbriar) Impact Fee [2]
Transit Fee $985 $820
Regional Park Fee $2,766 $1,760
Fire Facilities Fee $691 $496
Community Center Fee $891 $666
Subtotal Greenbriar Impact Fee $5,333 $3,742
Total Fees $77,012 $67,375
Source: City of Sacramento; various public agencies; EPS. [1] EPS obtained the project-specific supplemental school fee from the Greenbriar Specific Plan Draft Proposed Public Facilities Financing Plan (PFFP) prepared April 26, 2017 and escalated these fees using the average of the 20-City and San Francisco Construction Cost Indices from March 2016 to March 2023 as published by Engineering-News Record.
[2] The Northlake plan area fees include only certain public facility obligations not covered through existing City fees. Because the project was developed by a single master developer, costs for project-related backbone infrastructure were not included.

Residential
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Table C-10
Woodland Research and Technology Park Financing Plan
Northlake Commercial Fees (2023$)
Item Fee per Permit
Fee per Bldg.

Sq. Ft Notes
Assumptions
Building Valuation Group M
Construction Type IIIA
Valuation per sq. ft. (ICC February 2023) $164.83
Acres 5.00
FAR 0.43
Square Feet 94,651
Total Project Valuation $15,601,351
Water Meters 2
Water Meter Size 2"
Current as of Apr-23 Apr-23
Processing Fees
Administrative Processing Fee $164.00 $0.00 $164 per hour, assumes 1 hour review Building Permit $85,448 $0.90 $20,761 + $0.0051333 for each dollar over $3,000,000 of bldg. valuation Technology Surcharge $6,835.80 $0.07 8% of Building Permit Plan Review Fee $69,896 $0.74 $16,970 + $0.0042 for each dollar over $3,000,000 Technology Surcharge $5,591.65 $0.06 8% of Plan Review Fee Planning Review Fee $10,484.35 $0.11 15% of Plan Review Fee Planning Inspection Fee $1,344 $0.01 Flat rate; charged when Planning Division performs inspections.

Seismic/Strong Motion $4,368 $0.05 $0.00028 per $1 of bldg. valuation General Plan Recovery Fee $40,564 $0.43 $2.60 per $1,000 of bldg. valuation Green Building/CBSC Fee $624 $0.01 $1 per $25,000 of bldg. valuation Construction Excise Tax $124,811 $1.32 0.008 * valuation of 2002 bldg.

Fire Inspection Fee $8,803 $0.09 $0.093 x gross square feet Fire Review Fee $136 $0.00 $136 per hour, assumes 1 hour review Subtotal Processing Fees $3.79
City Development Impact Fees
Adjusted Transportation Development Impact Fee (TDIF) $0.85 Water Development Fee $28,942 $0.31 Assumes 2 2" domestic meters Water Easement Tap Installation Fee $5,146 $0.05 Assumes 2 2" domestic meter Water Meter Installation $2,056 $0.02 Assumes 2 2" domestic meter City Business Operations Tax $5,000 $0.05 $0.0004 per $1 of bldg. valuation; Max. $5,000/year/contractor Erosion and Sediment Control (ESC) $1,000 $0.01 $1,000 per permit for building sq. ft. of 50,000 or more Neighborhood and Community Parks $0.39 $0.39 per sq. ft.

Citywide Parks/Facilities $0.16 $0.16 per sq. ft
Mixed Income Housing Ordinance/Housing Trust Fund $2.62 $2.62 per unit sq. ft.

Subtotal City Development Impact Fees $4.47
Other Agency Fees
Twin Rivers USD $0.78 $0.78 per sq. ft. (effective 3/29/2023) Natomas Basin Habitat Conservation Plan Fee $1.57 $29,815 per acre; assumes land dedication in-lieu ($15,750/acre), so excludes land acquisition portion of total fee ($45,565 per acre).

Sacramento Area Flood Control Agency Dev. Impact Fee $1.60 $1.60 per habitable area sq. ft.(effective 1/4/2020).

Sacramento Countywide Transportation Mitigation Fee $3.17 $2,146 per 1000 sq. ft + 2% admin fee Sacramento Area Sewer District (Expansion) $1.18 $22,360 per net acre for Expansion Area Regional SAN $0.36 $3,602 per ESD for New Growth Area
Subtotal Other Agency Fees $8.66
North Lake (Greenbriar) Impact Fee [1] per acre
Transit Fee $52,327 $2.76
Regional Park Fee $18,641 $0.98
Fire Facilities Fee $5,254 $0.28
Community Center Fee $10,488 $0.55
Subtotal Greenbriar Impact Fee $86,710 $4.58
Total Fees $574,632 $21.50
Source: City of Sacramento; various public agencies; EPS. [1] Shopping Center fees. The Northlake plan area fees include only certain public facility obligations not covered through existing City fees. Because the project was developed by a single master developer, costs for project-related backbone infrastructure were not included.

Commercial
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PLACEHOLDER FOR APPENDIX A-2

MITIGATION MONITORING AND

REPORTING PROGRAM

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Final
Environmental Impact Report
Woodland Research &
Technology Park Specific Plan
State Clearinghouse #2017062042
August 2023

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Final
Environmental Impact Report
Woodland
Research &
Technology Park
Specific Plan
August 2023
Prepared for:

City of Woodland
Community Development
Department300 First Street
Woodland, CA 95695
Contact:

Erika Bumgardner,
Principal Planner / Business Development Liaison
Prepared by:

AECOM
2020 L Street, Suite 300
Sacramento, CA 95811
Matthew Gerken,
Project Manager

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Woodland Research & Technology Park Specific Plan FEIR AECOM City of Woodland i Table of Contents

TABLE OF CONTENTS
Section Page
1 INTRODUCTION................................................................................................................................... 1-1

1.1 Input on the Draft EIR............................................................................................................. 1-1

1.2 Organization of Final EIR........................................................................................................ 1-1

1.3 Use of the Final EIR................................................................................................................ 1-2 2 COMMENTS AND RESPONSES TO COMMENTS ON THE WRTP SPECIFIC PLAN DRAFT EIR...................................................................................................................................................... 2-1

2.1 COMMENTS ON THE WRTP SPECIFIC PLAN DRAFT EIR............................................... 2-1

2.2 COMMENTS AND RESPONSES TO COMMENTS .............................................................. 2-1

2.2.1 Comment Letter #1: California Department of Transportation (Caltrans)..................... 2-2 Response to Comment Letter 1......................................................................... 2-5

2.2.2 Comment Letter #2: Yolo Local Agency Formation Commission (Yolo LAFCo) ...... 2-12 Response to Comment Letter 2....................................................................... 2-13

2.2.3 Comment Letter #3: Laborers International Union of North America (LIUNA), Local Union No. 185................................................................................................. 2-14 Response to Comment Letter 3..................................................................... 2-221

2.2.4 Comment Letter #4: Nathan Benedicto.................................................................... 2-252 Response to Comment Letter 4..................................................................... 2-253

2.2.5 Comment Letter #5: John Chen ............................................................................... 2-254 Response to Comment Letter 5..................................................................... 2-255

2.2.6 Comment Letter #6: Brian Coward.......................................................................... 2-256 Response to Comment Letter 6..................................................................... 2-278

2.2.7 Comment Letter #7: Eric Garber ............................................................................. 2-283 Response to Comment Letter 7..................................................................... 2-284

2.2.8 Comment Letter #8a: Bruce Jacks (June 3, 2021) .................................................... 2-285 Response to Comment Letter 8a ................................................................... 2-297 Comment Letter #8b Bruce Jacks (June 18, 2021).................................................. 2-314 Response to Comment Letter 8b................................................................... 2-317 Comment Letter #8c Bruce Jacks (July 2, 2021)..................................................... 2-322 Response to Comment Letter 8c ................................................................... 2-333

2.2.9 Comment Letter #9: Paul Kramer............................................................................ 2-343 Response to Comment Letter #9................................................................... 2-346

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AECOM Woodland Research & Technology Park Specific Plan FEIR Table of Contents ii City of Woodland

2.2.10 Comment Letter #10: Sheryl Patterson .................................................................... 2-348 Response to Comment Letter #10................................................................. 2-350

2.2.11 Comment Letter #11: Dorothy Rosenberg ............................................................... 2-351 Response to Comment Letter 11................................................................... 2-353

2.2.12 Comment Letter #12: Jim Smith.............................................................................. 2-354 Response to Comment Letter 12................................................................... 2-355

2.2.13 Comment Letter #13: A. Takieu .............................................................................. 2-356 Response to Comment Letter 13................................................................... 2-357

2.2.14 Comment Letter #14: Randi Thornton ..................................................................... 2-359 Response to Comment Letter 14................................................................... 2-360

2.2.15 Comment Letter #15: Brenda Trotman .................................................................... 2-361 Response to Comment Letter 15................................................................... 2-362

2.2.16 Communications Received After the Close of trhe Comment Period........................ 2-363 Correspondence from Bruce Jacks, Received 7/4/2021:.......................................... 2-364 Response to Bruce Jacks Correspondence of 7/4/2021.................................. 2-366 Correspondence from Bruce Jacks, Received 7/22/2021:........................................ 2-367 Response to Bruce Jacks Correspondence of 7/22/2021. ............................... 2-373 3 ERRATA ............................................................................................................................................ 3-1

3.1 Executive Summary................................................................................................................. 3-1

3.2 Project Description .................................................................................................................. 3-5

3.3 Environmental Setting, Impacts, and Mitigation Measures....................................................... 3-6

3.3.1 Draft EIR Section 3.3, Air Quality............................................................................... 3-6

3.3.2 Draft EIR Section 3.4, Biological Resources................................................................ 3-7

3.3.3 Draft EIR Section 3.9, Hydrology, Flooding, and Water Quality.................................. 3-8

3.3.4 Draft EIR Section 3.11, Noise and Vibration ............................................................... 3-8

3.3.5 Draft EIR Section 3.12, Public Services and Recreation............................................... 3-9 4 REFERENCES....................................................................................................................................... 4-1 Appendix
Appendix A: Mitigation Monitoring and Reporting Program Tables
Table 2-1 Comments Received on the Draft EIR....................................................................................... 2-1

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Woodland Research & Technology Park Specific Plan FEIR AECOM City of Woodland iii Table of Contents

ACRONYMS AND ABBREVIATIONS
2006 SDFMP 2006 Storm Drainage Facilities Master Plan
2D two-dimensional
BMPs best management practices
CalEEMod California Emissions Estimator Model
CalGreen California Green Building Standards
Caltrans California Department of Transportation
CAP Climate Action Plan
CDFW California Department of Fish and Wildlife
CEQA California Environmental Quality Act
cfs cubic feet per second
City City of Woodland
CNDDB California Natural Diversity Database
County Yolo County
County Road Yolo County Road
CUPs Conditional Use Permits
DWR California Department of Water Resources
EIR environmental impact report
GHG greenhouse gas
HCP Habitat Conservation Plan
I- Interstate
ICM Integrated Catchment Modeling
IPaC Information for Planning and Conservation
LID low impact development
LiDAR light detection and ranging or laser imaging, detection and ranging LOS level of service
mi. Miles
MMRP mitigation monitoring and reporting program
MOU Memorandum of Understanding
MS4 Municipal Separate Storm Sewer System
MW megawatt
NAVD88 North American Vertical Datum of 1988
NOP notice of preparation
NOX nitrogen oxide
n-value Manning’s n-value
PG&E Pacific Gas & Electric Company
PM10 particulate matter with aerodynamic diameter less than 10 microns proposed project Woodland Research & Technology Park Specific Plan PV photovoltaic
ROG reactive organic gas
RR railroad
SACOG Sacramento Area Council of Government
SB1C1, SB1C1 and SB1D1 shed
SLSP Spring Lake Specific Plan
SWAPE Soil / Water / Air Protection Enterprise

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AECOM Woodland Research & Technology Park Specific Plan FEIR Table of Contents iv City of Woodland
SP-1B and SP-1C Specific Plan area
SRP South Regional Pond
SUGA South Urban Growth Area
TAC toxic air contaminant
TK/K transitional kindergarten and kindergarten
TRUs transportation refrigeration units
USFWS U.S. Fish and Wildlife Service
VMT vehicle miles travelled
WJUSD Woodland Joint Unified School District
WRP West Regional Pond
WRR1, WWR2A, and WRR2B watersheds with baseline conditions WRTP Woodland Research & Technology Park
WRTP Woodland Research and Technology Park
WRTP Specific Plan Woodland Research & Technology Park Specific Plan WS water surface
Yolo HCP/NCCP Yolo Habitat Conservation Plan/Natural Community Conservation Plan Yolo LAFCo Yolo Local Agency Formation Commission
YSAQMD Yolo-Solano Air Quality Management District

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Woodland Research & Technology Park Specific Plan FEIR AECOM City of Woodland 1-1 Introduction
1 INTRODUCTION
The City of Woodland (City) prepared an environmental impact report (EIR) to evaluate the potential environmental effects of the proposed Woodland Research & Technology Park (WRTP) Specific Plan (referred to henceforth as the WRTP Specific Plan or the proposed project) in compliance with the California Environmental Quality Act (CEQA) (Public Resources Code Section 21000 et seq.) and the CEQA Guidelines (California Code of Regulations Section 15000 et seq.).

1.1 INPUT ON THE DRAFT EIR
To assist the City in determining the focus and scope of analysis for this EIR, pursuant to the provision of Section 15082 of the CEQA Guidelines, the City circulated a Notice of Preparation (NOP) dated June 16, 2017, to government agencies, special service districts, organizations, and individuals with an interest in or jurisdiction over the proposed project. The NOP is a brief notice sent by the lead agency to inform the public, interested parties, responsible agencies, trustee agencies, and potentially affected federal, state, and local agencies that the lead agency plans to prepare an EIR. The NOP also seeks comments regarding the scope and content of the EIR. The City held a public scoping meeting for the project on June 26, 2017 to solicit additional input.

The NOP and responses to the NOP are contained in Appendix A of the Draft EIR.

1.2 PUBLIC REVIEW OF THE DRAFT EIR
The Draft EIR (State Clearinghouse Number 2017062042) was received by the State Clearinghouse and circulated for a 45-day public review period from May 14 through July 2, 2021. The City circulated the document to public agencies, other public and private organizations, property owners, developers, and other interested individuals.

Detailed information related to the WRTP Specific Plan and this EIR are available at the City of Woodland City Hall and online at the project webpage: https://www.cityofwoodland.org/585/Documents. The City’s 2035 General Plan, Climate Action Plan and related EIR – documents that served as an important foundation for the Specific Plan and this EIR – are also available online at the General Plan Update Website:
https://www.cityofwoodland.org/1000/Documents.

City staff provided a presentation on the Draft EIR at a public meeting of the Woodland Planning Commission on June 17, 2021, at 6:30 p.m. to solicit additional input on the Draft EIR.1 In accordance with Section 15088 of the CEQA Guidelines, the City, as the lead agency, has reviewed the comments received on the Draft EIR for the WRTP Specific Plan and has prepared written responses to the comments received. 1 Consistent with Executive Order N-29-20 issued on March 17, 2020, and Executive Order N-35-20 issued on March 21, 2020, by the Governor of the State of California, this meeting was held online only via Zoom. The meeting agendas and virtual login information was made available online through the City’s website here: https://www.cityofwoodland.org/654/Meetings-Agendas.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Introduction 1-2 City of Woodland

1.3 ORGANIZATION OF FINAL EIR
The City prepared this Final EIR, which includes:
► A full list of agencies, organizations, and individuals that provided comments on the Draft EIR in Chapter 2 of this Final EIR;
► A summary of comments and responses to comments on the Draft EIR in Chapter 2 of this Final EIR; and ► Minor revisions to the Draft EIR detailed in Chapter 3, “Errata,” of this Final EIR.2 ► References used in this Final EIR are provided in Chapter 4, “References,” of this Final EIR.

Chapter 2, “Comments and Responses to Comments” of this Final EIR includes the written comments received on the Draft EIR and responses to these comments (as required by the CEQA Guidelines Section 15132). To assist the reader, each response includes a summary of the comment. The range of responses include providing clarification on the Draft EIR, making factual corrections, explaining why certain comments may not warrant further response, or simply acknowledging the comment for consideration by decision makers when the comment does not relate to the adequacy of the EIR for addressing potential adverse physical environmental effects of the proposed project.

In some instances, responses to comments may warrant modification of the text of the Draft EIR. In those cases, the text of the Draft EIR is revised and the changes compiled in Chapter 3, “Errata” of this Final EIR. The text deletions are shown in strikeout (strikeout) and additions are shown in underline (underline). The revisions summarized in Chapter 3 of this Final EIR do not change any of the impact conclusions presented in the Draft EIR.

This document and the Draft EIR together constitute the Final EIR that the Planning Commission and City Council will consider. Appendix A to this Final EIR is the Mitigation Monitoring and Reporting Program.

1.4 USE OF THE FINAL EIR
The Final EIR allows the public and the City decision makers an opportunity to review revisions to the Draft EIR and the Responses to Comments. The Final EIR serves as the environmental document to inform the City Council’s consideration of the proposed project, or one of the alternatives to the project discussed in the Draft EIR.

As required by Section 15090(a)(1)-(3) of the CEQA Guidelines, a lead agency, in certifying a Final EIR, must make the following three determinations:

1. The Final EIR has been completed in compliance with CEQA.

2. The Final EIR was presented to the decision-making body of the lead agency, and the decision-making body reviewed and considered the information in the Final EIR prior to approving the project.

3. The Final EIR reflects the lead agency’s independent judgment and analysis. 2 Chapter 3, “Errata,” includes only pages of the Draft EIR where revisions have been made, not the entire Draft EIR.

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Woodland Research & Technology Park Specific Plan FEIR AECOM City of Woodland 1-3 Introduction
As required by Section 15091 of the CEQA Guidelines, no public agency shall approve or carry out a project for which an EIR has been certified that identifies one or more significant environmental effects of the project unless the public agency makes one or more written findings (Findings of Fact) for each of those significant effects, accompanied by a brief explanation of the rationale for each finding supported by substantial evidence in the record.

The possible findings are:

1. Changes or alterations have been required in, or incorporated into the project which avoid or substantially lessen the significant environmental effect as identified in the Final EIR.

2. Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency.

3. Specific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the Final EIR.

The Final EIR, once certified with an adopted Mitigation Monitoring and Reporting Program will serve as the environmental document for future projects consistent with and proposed under the Specific Plan. The Final EIR was designed to streamline review of future private development projects and public infrastructure improvements required to serve development proposed as a part of the Specific Plan. Future projects will be required to incorporate development standards and other guidance included in the Specific Plan and to implement appropriate mitigation measures included as a part of the Mitigation Monitoring and Reporting Program. As projects are proposed, the City would make findings relative to the applicability of this Final EIR, which may include findings that:
► future projects are within the scope of the Specific Plan EIR analysis pursuant to CEQA Guidelines Section 15168;
► the Specific Plan and/or 2035 General Plan and Climate Action Plan EIR considered the impacts of the project and no additional review or only focused review is required pursuant to Public Resources Code Section 21083.3 and CEQA Guidelines Section 15183;
► future projects qualify for streamlining using the Specific Plan EIR using the provisions of CEQA Guidelines Section 15182 for Projects Pursuant to a Specific Plan; or ► future projects qualify for applicable streamlining, tiering, or exemptions that exist today or that may be enacted in the future.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-1 Responses to Comments on the Draft EIR 2 COMMENTS AND RESPONSES TO COMMENTS ON THE

WRTP SPECIFIC PLAN DRAFT EIR
This section of the Final EIR contains comment letters received during the public review period for the Woodland Research and Technology Park (WRTP) Specific Plan Draft EIR. In conformance with CEQA Guidelines Section 15088(a), the City has prepared written responses to comments on environmental issues received from reviewers of the WRTP Specific Plan Draft EIR.

2.1 COMMENTS ON THE WRTP SPECIFIC PLAN DRAFT EIR
Table 2-1 identifies a number for each comment letter received, the author of the comment letter, and the date of the comment letter.1
Table 2-1. Comments Received on the WRTP Specific Plan Draft EIR Letter # Commenter Date
1 California Department of Transportation (Caltrans) July 2, 2021 2 Yolo Local Agency Formation Commission (Yolo LAFCo) June 29, 2021 3 Laborers International Union of North America, Local Union No. 185 July 2, 2021 3A Exhibit A, Shawn Smallwood, PhD July 1, 2021
3B Exhibit B, SWAPE (Soil / Water / Air Protection Enterprise) July 2, 2021 4 Nathan Benedicto July 2, 2021
5 John Chen July 1, 2021
6 Brian Coward July 2, 2021
7 Eric Garberville July 2, 2021
8a Bruce Jacks June 3, 2021
8b Bruce Jacks June 23, 2021
8c Bruce Jacks July 2, 2021
9 Paul Kramer July 1, 2021
10 Sheryl Patterson June 11, 2021
11 Dorothy Rosenberg July 1, 2021
12 Jim Smith May 22, 2021
13 A.Takieu July 2, 2021
14 Thorton, Randi June 30, 2021
15 Trotman, Brenda July 1, 2021

2.2 COMMENTS AND RESPONSES TO COMMENTS
This section of the Final EIR contains summaries of the comment letters received during the public review period for the WRTP Specific Plan Draft EIR and the City’s responses to these comments. 1 The City also received communications after the public review period which do not affect any of the EIR analysis. See Section 3.3 for responses to late communications.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-2 City of Woodland

2.2.1 Comment Letter #1:

CALIFORNIA DEPARTMENT OF TRANSPORTATION (CALTRANS)

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland2-3 Responses to Comments on the Draft EIR

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR2-4 City of Woodland

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-5 Responses to Comments on the Draft EIR RESPONSE TO COMMENT LETTER 1
Comment 1-1 Summary of Comment: The comment states that the California Department of Transportation (Caltrans) has reviewed the Draft EIR for the proposed project and notes that Caltrans has analyzed the impacts of the project to the State Highway System and its consistency with the State’s mobility goals.

Response: Thank you for your review. This comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

Comment 1-2 Summary of Comment: The commenter has provided a summary of the proposed project.

Response: This comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the City appreciates the review of the Draft EIR.

Comment 1-3 Summary of Comment: The commenter requests that the site plans show the State right-of-way delineated.

Response: Any future improvement plans for construction of state facilities will identify exiting state rights of way in addition to any additional right of way needs to construct said facilities. State highway improvement plans will be provided to Caltrans per Caltrans Plans Preparation Manual and/or appropriate Caltrans manuals that establish uniform standards and procedures to be used when preparing right of way maps, preliminary exhibits, and the development of project plans.

Comment 1-4 Summary of Comment: The commenter requests that all work proposed and performed within the State’s highway right of way must be consistent with Caltrans’ standards and that a Caltrans Encroachment Permit be obtained before construction.

Response: The Draft EIR does not identify any transportation improvement mitigations within the State highway right of way. As such, this comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

Any future locally funded transportation improvements related to the WRTP Specific Plan that are constructed within the State highway right of way, would obtain a Caltrans Encroachment Permit before construction.

Comment 1-5 Summary of Comment: The commenter recommends identifying any monument preservation plans (if applicable) to identify any vulnerable survey monuments that will need to be perpetuated.

Response: Any future improvement plans for construction of State facilities will identify exiting state highway survey monuments and any other survey monuments that may be disturbed and reset and/or are needed to construct said facilities. State highway improvement plans will be provided to Caltrans per Caltrans Plans Preparation Manual and/or other appropriate Caltrans manuals that establishes uniform standards and procedures to be used when preparing right of way maps, preliminary exhibits, and the development of project plans.

Comment 1-6 Summary of Comment: The comment requests queue analysis at five intersections including two intersections on Yolo County Road (County Road) 25A (at State Route 113 southbound ramp and State Route 113

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-6 City of Woodland northbound ramp intersections) and three intersections on East Main Street (between State Route 113 northbound off-ramp and Interstate (I)- 5 northbound off-ramp).

Response: Traffic analysis queues for the intersections were derived from Level of Service analysis that was conducted separate from the Draft EIR and included in Appendix E to the Draft EIR for informational and planning purposes, as Level of Service is no longer an allowable CEQA threshold per Senate Bill 743 (as of July 1, 2020).

Separate from the Draft EIR, a General Plan Level of Service consistency analysis was prepared for the WRTP Specific Plan Area. Level of Service analysis for the two intersections on County Road 25A (at State Route 113 southbound ramp and State Route 113 northbound ramp intersections) provides off-ramp queue results. Forecasts prepared for the cumulative scenario include full build-out of the WRTP Specific Plan Area and build-out of remaining vacant parcels in the adjacent Spring Lake Specific Plan Area as well as anticipated growth under the 2035 General Plan on other parcels through 2035. The Level of Service analysis for this scenario, which is based on application of SimTraffic micro-simulation software for the existing side street stop-controlled interchange configuration, indicate that queues will exceed storage capacity. The implementation of roundabouts and related improvements at the interchange were subsequently evaluated and it was determined these improvements provided Level of Service D or better conditions during both 2035 AM and PM peak hour conditions. The resulting 95th percentile queues for cumulative conditions, identified using SIDRA, are as follows. The results of the queuing analysis show that the implementation of roundabouts will result in reduced vehicle queues and improved safety when compared to the existing side street stop-controlled intersection configuration.
 State Route 113/County Road 25A Southbound Ramp Queues (future storage with roundabout of approximately 1,550 feet)
 AM Peak Hour – 75 feet (approximately 5 percent of available storage)  PM Peak Hour – 75 feet (approximately 5 percent of available storage)  State Route 113/County Road 25A Northbound Ramp Queues (future storage with roundabout of approximately 1,565 feet)
 AM Peak Hour – 25 feet (approximately 2 percent of available storage)  PM Peak Hour – 200 feet (approximately 15 percent of available storage) Forecasts prepared to address General Plan Level of Service consistency indicate that a small number of vehicle trips generated by uses in the WRTP Specific Plan Area would use the three intersections on East Main Street (i.e., less than 2 percent of cumulative p.m. peak hour trips on East Main Street between State Route 113 northbound ramps and Pioneer Avenue), which are over 2 miles north of the core of the WRTP Specific Plan Area. Vehicle trips from the WRTP Specific Plan Area destined for the State highway north of the project would use routes that do not include the East Main Street intersections #3, #4, or #5. Trips destined to and from the north on I-5 would gain access to the State Highway System at the State Route 113/County Road 25A interchange and make a direct connection to I-5, while most project-related trips destined to and

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-7 Responses to Comments on the Draft EIR from the south on I-5 would gain access to the State Highway System at the I-5/County Road 102 interchange. As such, queues at the three intersections on East Main Street would not be measurably affected by the added vehicle trips from implementation of the WRTP Specific Plan.

As noted, this comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR, and no change has been made, nor would any change be appropriate, to the Draft EIR.

Comment 1-7 Summary of Comment: The commenter requests a safety evaluation to determine the need for ramp metering at four freeway on-ramps including the I-5 southbound on-ramp at County Road 102, the State Route 113 southbound on-ramp at County Road 25A, the State Route 113 southbound on-ramp at East Main Street, and the I-5 southbound on-ramp at East Main Street.

Response: The I-5 southbound on-ramp at County Road 102 currently has ramp metering that was constructed when locally funded improvements to the interchange were constructed by the City of Woodland in 2010. The Project Report/Environmental Document prepared for the I-5/County Road 102 interchange in 2006 documented the improvements completed in 2010 as well as a series of ultimate design improvements that include further widening of the off-ramps to be constructed at a later date when triggered.

For the State Route 113/County Road 25A interchange, the City of Woodland is initiating consultation with Caltrans on the preparation of project development studies to address design details for the proposed roundabout improvements at the off-ramp intersections. This process will include identification of required ramp metering infrastructure based on the Caltrans criteria in place.

For the other two on-ramps that access southbound State Route 113 and southbound I-5 from East Main Street, forecasts prepared to address General Plan Level of Service consistency indicate that a small number of vehicle trips generated by uses in the WRTP Specific Plan Area would use these on-ramps on East Main Street, which are over 2 miles north of the core of the Specific Plan Area. As such, the need for ramp metering at these on-ramps accessed via East Main Street would not be measurably affected by the added vehicle trips from the WRTP Specific Plan Area (i.e., less than 2 percent of cumulative p.m. peak hour trips on I-5 southbound on-ramp from East Main Street).

Comment 1-8 Summary of Comment: The comment requests a weaving analysis of the northbound and southbound segments of I-5 between the East Main Street and County Road 102 interchanges.

Response: A freeway weaving analysis is conducted applying a Level of Service analysis that is not an allowable CEQA threshold. As such, this comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-8 City of Woodland Forecasts prepared to address General Plan Level of Service consistency indicate that a small number of vehicle trips generated by uses in the WRTP Specific Plan Area would use these segments of I-5 (i.e., less than 2 percent of cumulative p.m. peak hour trips on I-5 between East Main Street and County Road 102 interchanges), which are over 2 miles north of the core of the Specific Plan Area. As such, a freeway weaving analysis for this segment would not be measurably affected by the added vehicle trips from the WRTP Specific Plan Area. It should be noted that the I-5/State Route 113 Connector Phase 2 project, which is programmed in Sacramento Area Council of Government’s (SACOG’s) 2020 Metropolitan Transportation Plan / Sustainable Communities Strategy for completion by 2035, would construct a new northbound I-5 to southbound State Route 113 freeway to freeway connection designed to address the level of existing and forecast traffic that exits northbound I-5 to use East Main Street as a connector to southbound State Route 113.

It should be noted that a freeway segment Level of Service analysis was conducted separate from the Draft EIR and included in Appendix E to the Draft EIR for informational and planning purposes. This analysis was prepared for segments of State Route 113 adjacent to the County Road 25A interchange that is the primary freeway access for the WRTP Specific Plan Area. The freeway operations analysis, conducted for cumulative conditions, concluded that the freeway segments and ramps analyzed would operate at Level of Service D or better under cumulative a.m. and p.m. peak hour conditions.

Comment 1-9 Summary of Comment: The commenter requests an evaluation/analysis for the interim timing modifications for intersections on East Main Street between the State Route 113 and I-5 ramp junctions.

Response: An evaluation/analysis of signal timing modifications is conducted applying a Level of Service analysis that is not an allowable CEQA threshold. As such, this comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR.

Forecasts prepared to address General Plan Level of Service consistency indicate that a small number of vehicle trips generated by uses in the WRTP Specific Plan area would use the four intersections on East Main Street (i.e., less than 2 percent of cumulative p.m. peak hour trips on East Main Street between State Route 113 northbound ramps and Pioneer Avenue), which are over 2 miles north of the core of the Specific Plan Area. Vehicle trips from the WRTP Specific Plan Area destined for the State highway north of the project would use routes that do not include the East Main Street intersections. Trips destined to and from the north on I-5 would gain access to the State highway system at the State Route 113/County Road 25A interchange and make a direct connection to I-5, while virtually all project-related trips destined to and from the south on I-5 would gain access to the State highway system at the I-5/ County Road 102 interchange.

As such, the interim timing modifications at the four intersections on East Main Street would not be measurably affected by the small number of added trips from implementation of the WRTP Specific Plan.

Comment 1-10 Summary of Comment: The commenter requests all roundabout analyses be completed with Sidra, as Synchro is not an approved software for roundabout analysis by Caltrans.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-9 Responses to Comments on the Draft EIR Response: The requested roundabout analysis is conducted applying a Level of Service analysis that is not an allowable CEQA threshold. As such, this comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR.

Separate from the Draft EIR, a General Plan Level of Service consistency analysis was prepared for the WRTP Specific Plan Area and included as Appendix E to the Draft EIR for informational and planning purposes. For the State Route 113/County Road 25A interchange, the ramp intersections were evaluated using SimTraffic micro-simulation for both the existing side-street stop-controlled configuration as well as an evaluation of improvement options that included an alternative with roundabouts and an alternative with traffic signals. For the roundabout alternative at the State Route 113/County Road 25A interchange, the intersections were evaluated using both SimTraffic and SIDRA, with the analysis concluding that the intersections at the State Route 113/County Road 25A interchange would operate at level of service (LOS) D conditions or better with the planned roundabout improvements under cumulative a.m. and p.m. peak hour conditions.

Comment 1-11 Summary of Comment: The comment requests that Level of Service analysis be conducted for cumulative conditions at local ramp intersections on the I-5 side.

Response: The requested LOS analysis would focus on traffic congestion. The social inconvenience of traffic congestion is not an environmental impact under CEQA that would be relevant for study in an EIR. As such, this comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

Separate from the Draft EIR, a General Plan Level of Service consistency analysis was prepared for the WRTP Specific Plan Area; this analysis was included in Appendix E to the Draft EIR for informational and planning purposes. The cumulative analysis was conducted for 21 intersections and concluded that 18 (86 percent) of those intersections would meet General Plan Level of Service D goals. The intersections evaluated for cumulative conditions are those located in closest proximity to the WRTP Specific Plan Area and thus the locations where the highest level of added vehicle trips would occur. The cumulative analysis was not conducted for the intersections along East Main Street between State Route 113 and I-5 for several reasons.

Forecasts prepared to address General Plan Level of Service consistency indicate that a small number of vehicle trips generated by uses in the WRTP Specific Plan Area would use the four intersections on East Main Street, which are over 2 miles north of the core of the Specific Plan Area. Additionally, the I-5/State Route 113 Connector Phase 2 project, which is programmed in SACOG’s 2020 Metropolitan Transportation Plan / Sustainable Communities Strategy for completion by 2035, would construct a new northbound I-5 to southbound State Route 113 freeway to freeway connection design to address the high level of existing traffic that exits northbound I-5 to use East Main Street as a connector to southbound State Route 113.

As noted in response to comment 1-7, the Project Report/Environmental Document prepared by the City of Woodland for the I-5/County Road 102 interchange in 2006 documented the locally funded improvements completed in 2010 as well as a series of ultimate design improvements that include further widening of the off-ramps to be constructed at a later date when triggered.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-10 City of Woodland The additional ultimate interchange improvements are included in the City of Woodland traffic impact fee program.

Comment 1-12 Summary of Comment: The commenter recommends having a fair-share fee program to handle future projects that are needed to mitigate potential impacts due to anticipated growth and cumulative impacts from the project.

Response: This comment does not relate to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

The requested information is in Section 6.4 of the WRTP Specific Plan, which explains the financing and maintenance of public facility improvements to serve the WRTP Specific Plan Area. As noted, a separate Financing Plan has been prepared for the WRTP that details the costs for construction and operation of backbone infrastructure, public facilities, and operational costs necessary for development under the WRTP Specific Plan. A fair-share fee program is one of a variety of funding mechanisms that may be used to fund the necessary improvements. As development progresses under the Specific Plan, the timing and mix of cost and funding sources may change, but the Financing Plan will serve as a framework to guide and support the City’s objectives for the WRTP Specific Plan.

Comment 1-13 Summary of Comment: The commenter notes the importance of an ongoing monitoring program for implementation of individual improvement measures. The commenter recommends the project applicant to conduct focused traffic studies for each phase of project development, in addition to mitigation measures if General Plan standards are not met.

Response: Please refer to Appendix E, Transportation Impact Study, which was conducted in support of the Draft EIR. Furthermore, as described in Section 6.3.1 of the Specific Plan, analysis prepared by the City’s traffic consultant identifies capacity limits of the WRTP Specific Plan Area, beyond which future improvements would be triggered. For development beyond this limit, as stated in Section 6.3.1 of the Final WRTP Specific Plan, “[s]ubsequent development projects within the [WRTP Specific] Plan Area shall be required to prepare a project specific traffic analysis to determine the exact timing for construction of the interchange to the satisfaction of the Community Development Director of City Engineer, in consultation with the State of California Transportation Department.”
Comment 1-14 Summary of Comment: The commenter has the following questions:

How many phases does the project have? What is the timeline for each phase completion/opening year? What is the full build out year?
Response: Specific Plan implementation and development sequencing is further explained in Section 6 of the WRTP Specific Plan. This comment does not question to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

Comment 1-15 Summary of Comment: The commenter requests drainage calculations to confirm that no additional flow (Q) of water will be entering Caltrans’ existing drainage system for the 100-year storm event.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-11 Responses to Comments on the Draft EIR Response: This is addressed in the Draft EIR on page 3.9-15. The Woodland Research and Technology Park Stormwater Management Technical Memorandum includes existing and proposed drainage patterns and drainage sheds exhibits in addition to peak flow calculation sheets for major drainage pipes. This Technical Memorandum, as updated in 2023, is available on the City’s website with the WRTP Specific Plan and other supporting technical reports.

Design plans for construction of highway facilities within the State highway right of way and design plans for facilities that may impact State highway facilities will be provided to Caltrans per appropriate Caltrans manuals that establishes uniform standards and procedures to be used when preparing right of way maps, preliminary exhibits, and the development of project plans.

Comment 1-16 Summary of Comment: The commenter requests spread and depth calculations for the curb and gutter to be constructed with respect to the 10-year design storm.

Response: The design of curb and gutter within the State right of way will follow the requirements for design of curb and gutter and other drainage facilities needed for construction of state facilities per State highway improvement plans that will be provided to Caltrans per Caltrans Plans Preparation Manual and/or other appropriate Caltrans manuals that establishes uniform standards and procedures to be used when preparing right of way maps, preliminary exhibits, and the development of project plans.

Comment 1-17 Summary of Comment: The commenter requests the use of the 2018 version of the Caltrans Standard Plans for Curbs & Driveways.

Response: The design of curbs and driveways within the state right of way will follow the requirements for design of curbs and driveways within state right of way per Caltrans Plans Preparation Manual and/or other appropriate Caltrans manuals that establishes uniform standards and procedures to be used when preparing right of way maps, preliminary exhibits, and the development of project plans.

Comment 1-18 Summary of Comment: The commenter requests copies of any further actions regarding the project.

Response: The City will provide notification of availability of the Final EIR. This comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-12 City of Woodland

2.2.2 Comment Letter #2:

YOLO LOCAL AGENCY FORMATION COMMISSION (YOLO LAFCO)

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-13 Responses to Comments on the Draft EIR RESPONSE TO COMMENT LETTER 2
Comment 2-1 Summary of Comment: The commenter confirmed that the City fulfilled its legal requirement to consult with Yolo LAFCo as a responsible agency for the WRTP Specific Plan EIR.

Response: The City appreciates this review. The comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted.

Comment 2-2 Summary of Comment: The commenter confirmed that the proposed project is consistent with the City’s General Plan and that the Specific Plan ensures adequate provision of municipal services. The commenter also provided a summary of the loss of agricultural resources identified in the Draft EIR and notes that the City’s requirements to conserve agricultural land is consistent with Yolo LAFCo’s agricultural mitigation policies.

Response: The consistency of proposed mitigation with Yolo LAFCo policies is noted.

Comment 2-3 Summary of Comment: The commenter closes the comment letter and gives thanks to the City for consulting with Yolo LAFCo.

Response: The City is appreciative of Yolo LAFCo’s review.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-14 City of Woodland

2.2.3 COMMENT LETTER #3:

LABORERS INTERNATIONAL UNION OF NORTH AMERICA (LIUNA), LOCAL UNION NO. 185

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-221 Responses to Comments on the Draft EIR RESPONSE TO COMMENT LETTER 3
Comment 3-1 Summary of Comment: The commenter introduces the letter and provides a summary of the WRTP Specific Plan and the Draft EIR. The commenter states that the Draft EIR suggests streamlining future development projects and would not reevaluate public comments or reconsider whether additional mitigation strategies are necessary for future projects. The commenter states that LIUNA believes this is in violation of CEQA and limits the City and residents to ensure that signification impacts are assessed for future projects, and if feasible, can become less than significant through mitigation.

Response: The parts of this comment that introduce the comment letter and summarize the Draft Specific Plan do not raise any topics related to the veracity of the Draft EIR. Regarding future environmental review of projects developed under the Specific Plan, as noted on page 1-2 of the Draft EIR, the City will evaluate future projects within the Specific Plan Area for consistency with the Specific Plan and the EIR, will evaluate whether additional CEQA analysis is necessary, complying with CEQA in all respects.

Comment 3-2 Summary of Comment: The commenter states that the City “must” include the requirement that future projects be required to obtain a discretionary conditional use permit, to allowing the City’s discretion to adopt specific mitigation measures for future development. The commenter states that this is a feasible mitigation measure required by CEQA to address the significant and unavoidable impacts of the WRTP Specific Plan. The commenter also asserts that the City will be required to “revisit” its finding of significant and unavoidable impacts when it conducts CEQA review of future development projects under Communities for a Better Environment v. Cal.

Resources Agency (2002) 103 Cal.App.4th 98 122-125.

Response: Chapters 3, Environmental Impact Analysis, and 5, Other CEQA Considerations [including Cumulative Impacts Analysis], of the Draft EIR provides analysis of potential impacts and identification of relevant mitigation to address future projects within the WRTP Specific Plan takes into consideration the allowed and anticipated land uses, and the zoning and development standards contained in the WRTP Specific Plan and as detailed in Chapter 2, Project Description, of the Draft EIR. As explained in Chapter 1, Introduction, of this Final EIR, identified in the Final EIR, the Final EIR, once certified with an adopted Mitigation Monitoring and Reporting Program will serve as the environmental document for future projects consistent with, and proposed under the Specific Plan. Future projects will be required to incorporate development standards and other guidance included in the Specific Plan and to implement appropriate mitigation measures included as a part of the Mitigation Monitoring and Reporting Program.

Mitigation measures recommended in the Draft EIR for adoption by the City, should it approve the WRTP Specific Plan, will be imposed as conditions of approval for any development under the Specific Plan and thus will apply to future projects, in accordance with the Mitigation and Monitoring Plan provided as Appendix A to this Final EIR. No provision of Communities for a Better Environment v. Cal. Resources Agency (2002) 103 Cal.App.4th 98 concerns the City requiring future development projects to receive conditional use permit, nor is a requirement for a discretionary permit a form of mitigation, as a discretionary permit does not, per se, constitute mitigation. (Public Resources Code §§21002.1(a), 21100(b)(3); CEQA Guidelines §15126.4(a)(1).) There is no need to revise the Specific Plan or the Draft EIR in response to any part of this comment.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-222 City of Woodland Comment 3-3 Summary of Comment: The commenter states the City has an obligation to include one or more alternatives that would require Conditional Use Permits (CUPs) and not permit certain uses by right in the WRTP Specific Plan. The commenter states that this will reduce the significant impacts of the WRTP Specific Plan since additional feasible mitigation measures for future developments would be considered and ensure public review of these projects.

Response: In compliance with CEQA the EIR identifies and evaluates a range of alternatives consistent with criteria in CEQA Guidelines Section 15126.6, including (1) the ability of the alternative to attain most of the basic project objectives, (2) the potential feasibility of an alternative, and (3) ability of the alternative to avoid or substantially reduce one or more significant environmental effects of the proposed project. The alternatives were developed to consider permutations under which the City could reduce the significant impacts of the WRTP Specific Plan through their different range and distribution of land uses, as well as, in some cases, via implementation of siting restrictions to avoid sensitive land uses or minimize impacts to sensitive receptors. The alternatives analysis presented in Chapter 4 of the Draft EIR does assess and contrast the potential impacts of the alternatives and the proposed WRTP Specific Plan to identify in what way an alternative may be able to avoid or reduce the potentially significant impacts of the proposed WRTP Specific Plan, consistent with guidance in the CEQA statutes and Guidelines.

Please see also the response to comment 3-2 related to the WRTP Specific Plan’s direction for future projects under current CEQA Guidelines, which was accounted for in the identification of feasible alternatives. Please see also response to comment 3-1.

Changes related to the future administrative process for future developments within the Specific Plan Area would not change the impact analysis or mitigation presented in the Draft EIR since the analysis makes specific assumptions regarding land uses anticipated under the Specific Plan regardless of the nature of the future approval process. As explained in Chapter 1, Introduction, of this Final EIR, mitigation imposed by the Draft EIR become conditions of approval for the Specific Plan as a whole and will apply to future projects regardless of whether future projects are approved by right or through an administrative zoning approval or through a conditional use permit process. The Mitigation and Monitoring Plan, which is provided as Attachment A to this Draft EIR, identifies the timing and responsibility of mitigation to ensure enforcement. To the extent that any uses that were not anticipated by the Specific Plan and EIR are proposed in the future, the City will comply with CEQA in evaluating such proposals. As such, commenter’s proposed alternative is not considered as considerably different than those analyzed. No changes to the Draft EIR are needed.

Comment 3-4 Summary of Comment: The commenter states that wildlife biologist Shawn Smallwood, Ph.D., and environmental consulting firm Soil/Water/Air Protection Enterprise (“SWAPE”) provided review of the Draft EIR and contributed to the comments contained in this comment letter from LIUNA and that comments from and curriculum vitae of these parties are attached to the letter and incorporated into the letter by reference.

Response: The fact that Dr. Smallwood and SWAPE have contributed to the comments is noted. Specific responses to comments provided by LIUNA, including those incorporating comments from the above noted parties are provided in the responses to comments 3-5 through 3-28.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-223 Responses to Comments on the Draft EIR Comment 3-5 Summary of Comment: The commenter provides a summary of legal concepts related to CEQA.

Response: The information provided by the commenter is noted. The Draft and Final EIR incorporate all relevant statutory, regulatory, and case law guidance. No revision to the Draft EIR in response to this general recitation of legal concepts is needed, nor would it be appropriate.

Comment 3-6 Summary of Comment: The commenter states that the Draft EIR fails to discuss all potentially feasible mitigation measures available to address the project’s significant air quality impacts resulting from its operation. The commenter states that all mitigation measures concerning air pollution impacts, besides one, only address impacts during construction. The commenter provides a list of additional feasible mitigation measures identified as example measures to mitigate air quality and greenhouse gas impacts from operations of warehouse projects in the California Attorney General’s Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, and asserts that the Draft EIR must be recirculated in order to evaluate, consider, and, where feasible, adopt these measures. The comment goes on to assert that all 19 example measures are feasible for future development within the Research and Technology Park of the Specific Plan Area and therefore should be adopted and made enforceable in order for the City to make a finding of overriding considerations.

Response: As noted by the California Attorney General’s Bureau of Environmental Justice in its Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, the document “is meant to help lead agencies pursue CEQA compliance and promote environmentally-just development as they confront warehouse project proposals.” The document acknowledges that CEQA analysis is “necessarily project-specific” but that the document “provides information on feasible best management practices and mitigation measures, the overwhelming majority of which have been adapted from actual warehouse projects in California.” This guidance from the Attorney General is not presented as mandatory mitigation, nor does it assert that the example mitigation measures are feasible for all projects.

The estimating of mass emissions was done at a detailed level for the purposes of analysis and to the extent feasible to represent anticipated future development and related operational uses within the WRTP Specific Plan Area. However, the emissions estimates presented in Tables

3.3-3 and 3.3-5 of the Draft EIR are not presumed to demonstrate all possible future operational uses and are instead intended to present a worst-case scenario, including conservative estimates with regard to mobile source emissions, as explained on pages 3.3-23 and 3.3-30 of the Draft EIR. It is true that the Specific Plan may be developed with a range of uses that have emissions and impacts that are lower than outlined in the Draft EIR.

The WRTP Specific Plan allows for a range of land uses within the Research and Technology Park designation, one of which in the Draft WRTP Specific Plan was warehouse, storage, and distribution/logistics. The intent of the Draft WRTP Specific Plan to include “Warehouse, Storage and Distribution / Logistics” as a permitted use was to provide for this use only as an ancillary use to support other related uses. Notes 10 and 11 of Table 3.1 of the Draft WRTP Specific Plan provided specific constraints to the warehouse, storage, and distribution/logistics permitted and ancillary uses. Note 10 indicated that “commercial and/or private ‘miniPage 823 AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-224 City of Woodland storage’/’self-storage’ is prohibited,” and Note 11 indicated that this use was “only permitted as incidental/ancillary to primary business/company operations; not more than 50 percent of primary building square footage.” The WRTP Specific Plan has since been updated to eliminate “Warehouse, Storage and Distribution / Logistics” use type from Table 3.1 of the WRTP Specific Plan; it is not provided as a permitted use under the Final Specific Plan. In addition, the WRTP Specific Plan includes development standards to address sustainability requirements and implementation of future development, including measures to achieve the Specific Plan’s goal to strive for zero net energy consumption, as outlined in the City’s 2035 Climate Action Plan.

These measures include energy efficient building design and mobility features, consistent with measures recommended in the Attorney General’s guidance for warehouse projects. As noted in Section 3.3.1 of the Specific Plan, all uses in the WRTP Specific Plan Area are required to adhere to Performance Standards in Section 3.3.2 of the WRTP Specific Plan and are also required to demonstrate consistency with the City’s 2035 Climate Action Plan, which includes reduction strategies that would further reduce indirect emissions related to energy efficient lighting, building energy efficiency, temperature controls, renewable energy generation, transit service, bicycling and pedestrian access, electric vehicle charging stations, and tree planting. A “Truck Trips” Performance Standard has been added to Section 3.3.2 of the WRTP Specific Plan in order to limit daily truck trips to no more than 50 one-way diesel-powered truck trips per day. This proposed limit is one-fourth of the truck trip rate that California Air Resources Board includes in its reference to the siting of a “distribution center” with respect to sensitive receptors in the California Air Resources Board Air Quality and Land Use Handbook (ARB 2005), which is also considered conservative because this guidance was published in 2005 based on emissions standards that have since been substantially.

Furthermore, as described on page 3.3-24 of the Draft EIR, consistent with General Plan Policy

2.L.2, the WRTP Specific Plan is intended to be implemented in a manner that encourages “sustainable development through the use of renewable energy sources and water conservation tools with the goal of striving to achieve zero net energy at the building and neighborhood level to the extent feasible.” Section 2.2.3 of the WRTP Specific Plan outlines the WRTP Specific Plan’s sustainability principles and consistency with related policies of the 2035 General Plan and Climate Action Plan that implement this goal. In particular, these policies require new development be consistent with the City’s Climate Action Plan, including the goal of achieving zero net energy at the building and neighborhood level, using trees for cooling and related energy conservation, providing for alternative fueling and electric vehicle charging throughout residential and non-residential garages and parking lots, incorporation of Transportation Demand Management tools and programs to reduce total vehicle miles travelled (VMT) generated by operations within the WRTP Specific Plan Area. Applying these policies to implementation of the WRTP Specific Plan would result in a reduction of long-term emissions of criteria air pollutants, particularly from energy and mobile sources. These policies and approach to development within the WRTP Specific Plan Area is relevant for all future development projects and operations, not only potential warehouse land uses, but is also consistent with the intent of the Attorney General’s guidance that is specific to warehousing operations.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-225 Responses to Comments on the Draft EIR The mitigation imposed through the Draft EIR is designed to apply to a range of future uses that are allowed under the Specific Plan and anticipated for development under the Specific Plan, with appropriate performance standards. For example, Mitigation Measure 3.3-3c requires future projects to achieve less than 10.0 in a million excess cancer cases for the Maximally Exposed Individual and less than a 1.0 Hazard Index (chronic or acute) non-cancer risk (Draft EIR, page 3.3-41). Mitigation measures imposed by the EIR will be required regardless of whether future projects are approved by right, through a zoning administrator approval, through the conditional use permit process, or by other means.

Site plan and design review for non-residential uses that require a zoning administrator approval or conditional use permit will be considered in conjunction with the review of required permits, which would generally be considered discretionary for the purposes of CEQA. Development allowed by right is only allowed as permitted by law and future environmental approvals. If uses that were not anticipated by the Specific Plan and EIR are proposed in the future, or if uses that propose development beyond the amounts allowed under the Specific Plan are proposed, or if the circumstances or conditions changed as provided in CEQA Guidelines Section 15162, the City will follow relevant guidance related to supplemental or subsequent environmental review, including consideration of feasible mitigation.

As explained in the introduction of California Attorney General’s Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, the mitigation measures contained therein, and referenced by the commenter, were developed building upon the Attorney General’s Bureau of Environmental Justice’s comment letters on and collecting knowledge gained from the Bureau of Environmental Justice’s review of hundreds of warehouse projects across the state in order to “help lead agencies pursue CEQA compliance and promote environmentally-just development as they confront warehouse project proposals.” As stated above, the Final WRTP Specific Plan has been revised to make clear that warehousing is not a permitted use and that any land use within the WRTP Specific Plan area would be held to truck trip limits and gross square footage to ensure that diesel emissions would not compare to the levels generated by the truck traffic intensity for which the Attorney General’s recommendations were developed. Furthermore, Mitigation Measure 3.3-3b requires those guidelines of the CARB Air Quality and Land Use Handbook: A Community Health Perspective (2005), and subsequent Technical Advisory (2017) be implemented for new development within the WRTP Specific Plan area. These guidelines include avoiding the siting of new commercial trucking facilities that accommodate more than 100 trucks per day, or 40 trucks equipped with transportation refrigeration units (TRUs), within 1,000 feet of sensitive receptors (e.g., residences); the Final WRTP Specific Plan Performance Standard E (Section

3.3.2 of the Final WRTP Specific Plan) is consistent with this guidance.

Therefore, the City’s existing General Plan policies, Climate Action Plan implementation measures, and Final WRTP Specific Plan Design Standards and Specifications, along with proposed mitigation in the EIR and the City’s discretionary review and approval of future projects within the WRTP Specific Plan Area ensure that future projects will reduce long-term operational emissions to the extent feasible.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-226 City of Woodland While the City has imposed all feasible mitigation, it is acknowledged that a significant and unavoidable impact would remain. This is consistent with the City’s obligations under CEQA.

No change to the Draft EIR is needed, nor would any change be appropriate. No revision to the EIR mitigation measures have been made or are necessary.

Comment 3-7 Summary of Comment: The commenter states that the Draft EIR fails to discuss all potentially feasible mitigation measures available to address the project’s significant air quality impacts resulting from its construction. The commenter provides a list of additional feasible measures identified by the Attorney General and claims that the City must adopt and make enforceable these measures in order for the City to make a finding of overriding considerations.

Response: Please see the response to comment 3-6 with regard to the purpose and enforceability of recommendations of the California Attorney General’s Bureau of Environmental Justice Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act. As detailed in Mitigation Measure 3.3-2a, the identified mitigation measures are recommended by the lead agency for the County responsible for overseeing air quality, Yolo-Solano Air Quality Management District. However, the mitigation measure does not limit the required mitigation measures to that list, rather it extends to “those [measures] determined by the City to be as effective.”
Furthermore, as the mitigation measures from the California Attorney General’s Bureau of Environmental Justice Warehouse Projects white paper, and referenced by the commenter, could be applicable to construction projects in general and not only warehousing projects, these additional mitigation measures have been reviewed and considered for applicability, feasibility, and enforceability, and incorporated into the EIR as a revision to Mitigation Measure 3.3-2a.

1. Requiring off-road construction equipment to be zero-emission, where available, and all diesel-fueled off-road construction equipment, to be equipped with CARB Tier 4 Final engines, and including this requirement in applicable bid documents, purchase orders, and contracts, with successful contractors demonstrating the ability to supply the compliant construction equipment for use prior to any ground-disturbing and construction activities.

2. Prohibiting off-road diesel-powered equipment from being in the “on” position for more than 10 hours per day.

3. Requiring on-road heavy-duty haul trucks to be model year 2010 or newer if diesel-fueled.

4. Providing electrical hook ups to the power grid, rather than use of diesel-fueled generators, for electric construction tools, such as saws, drills and compressors, and using electric tools whenever feasible.

5. Limiting the amount of daily grading disturbance area. Prohibiting grading on days with an Air Quality Index forecast of greater than 100 for particulates or ozone for the project area.

6. Forbidding trucks from idling for more than two minutes and requiring operators to turn off engines when not in use.

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7. Keeping onsite and furnishing to the lead agency or other regulators upon request, all equipment maintenance records and data sheets, including design specifications and emission control tier classifications.

8. Conducting an on-site inspection to verify compliance with construction mitigation and to identify other opportunities to further reduce construction impacts.

9. Providing meal options onsite or shuttles between the facility and nearby meal destinations for construction employees.

Comment 3-8 Summary of Comment: The commenter claims that the Draft EIR fails to discuss all potentially feasible mitigation measures available to address the project’s significant noise impacts resulting from construction and operational activities of the implementation of the WRTP Specific Plan. The commenter acknowledges that the Draft EIR identifies several noise mitigation measures but, even with implementation of mitigation, finds potential noise impacts to be significant and unavoidable. states that all mitigation measures concerning air pollution impacts, besides one, only address impacts during construction.

Response: Mitigation Measure 3.11-1 has been reviewed. The construction hour limitations included with this mitigation measure are consistent with City policy and ordinance guidance and have not been revised. Additional mitigation has been incorporated into Mitigation Measure 3.11-1, as suggested by the commenter, including the following (see also Chapter 3, Errata, of this Final EIR, as well as the Mitigation Monitoring and Reporting Plan provided as Appendix A to this Final EIR):
 Further limiting idling time of noise-generating vehicles and equipment to 2 minutes, rather than 5 minutes.
 Where construction work is within 445 feet of properties with existing, occupied noisesensitive uses, construction shall be prohibited on weekends and holidays and construction should start no earlier than 8 a.m.
 Where non-residential construction work is within 445-feet of an existing off-site residence, installation of continuous noise curtains shall be required between the construction site and those residences.

Comment 3-9 Summary of Comment: The commenter states that the Draft EIR fails to disclose the potentially feasible mitigation measure that large commercial development projects within the WRTP be conditioned on obtaining a CUP and ensure the City and the public have an opportunity to review additional feasible mitigation measures to address unavoidable significant impacts identified in the Draft EIR. The commenter asserts that requiring a CUP for future proposed developments within the Specific Plan Area would mitigate unavoidable air quality and noise impacts for the Project.

Response: Please see the responses to comments 3-1 and 3-2.

Comment 3-10 Summary of Comment: The commenter states that the Draft EIR fails to consider an Alternative to the WRTP Specific Plan that requires large commercial development projects within the WRTP be conditioned on obtaining a CUP. The commenter also states that providing Alternative versions of the Specific Plan that require

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-228 City of Woodland the use of CUPs for non-residential uses must be included in the Draft EIR to evaluate a reasonable range of alternatives and allow for informed decision making.

Response: Please see the responses to comments 3-1 through 3-3.

Comment 3-11 Summary of Comment: The commenter states that the Draft EIR does not address adequately the project’s impacts on wildlife, and that Dr. Smallwood believes that the efforts to identify a meaningful baseline of wildlife values in and adjacent to the Specific Plan were inadequate. The commenter provides a summary of the three visits by Dr. Smallwood to the Project site and the findings and conclusions.

Response: The biological resources impacts of the WRTP Specific Plan and future projects within the Specific Plan Area and off-site improvement areas are evaluated in detail in Draft EIR Section

3.4, “Biological Resources.” As described in Draft EIR Section 3.4.4 “Thresholds of Significance,” the CEQA Guidelines Appendix G (14 California Code of Regulations 15000 et seq.) has identified significance criteria to be considered for determining whether a project could have significant impacts on biological resources, and those criteria were used for this project.

Baseline wildlife use of the site was determined through desktop database review and also through field reconnaissance surveys in order to assess land cover types and special-status species habitat within the Specific Plan Area and off-site improvement areas. Results of these reconnaissance surveys are provided in Section 3.4.1 of the Draft EIR, which provides information about land cover types and special status species habitat in the WRTP Specific Plan Area and off-site improvement areas in order to define baseline site conditions to identify potential species that may be impacted by the project, to inform the need for future focused preconstruction species-specific surveys for avoidance and minimization of potential impacts on such species, and to quantify the direct loss of wildlife habitat as a result of buildout of the WRTP Specific Plan. The results of database review and biological surveys are presented in Section 3.4.2 “Environmental Setting” of the Draft EIR and include complete descriptions and mapping of all habitats in the Specific Plan Area and off-site improvement areas, including lists of existing vegetation and use of the site by common and special-status species. Section 3.4.2 accurately and completely describes the project site as having been altered by agricultural development and undergoing regular disturbance related to agricultural activities, and states that numerous common and special-status species may use the site for forage, cover, and/or nesting purposes.

A point-in-time list of wildlife species observed during a single survey effort, such as what was done by Dr. Smallwood on June 28-30, 2021, is not as informative to the baseline evaluation of the WRTP Specific Plan Area as the methods used in the Draft EIR given that the site is regularly disturbed by agricultural operations and wildlife use of the site is likely to change depending on time of year, type of crop in rotation, and level of disturbance at the time of the survey. Instead, the Draft EIR uses a habitat-based approach that conservatively identifies and evaluates impacts on species known to occur onsite (based on the desktop database review) and also species that may occur (based on the presence of suitable habitat), rather than only the species detected during a survey at a point in time. The Draft EIR describes that agricultural lands provide important habitat for common and special-status species, and provide greater habitat values than urban areas and developed land. The impact analysis presented in the Draft EIR assumes use of

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-229 Responses to Comments on the Draft EIR the site by Swainson’s hawk, white-tailed kite, northern harrier, and other special status birds, and that the site also provides nesting opportunities for raptors and other birds.

More specifically, the Draft EIR’s impact analysis is based on reconnaissance-level site visits conducted by qualified biologists in 2017 and 2019 to identify the presence of land cover and habitat that could support special-status species within or adjacent to the WRTP Specific Plan Area and the off-site improvement areas, and a desktop database review of the California Natural Diversity Database (CNDDB) and U.S. Fish and Wildlife Service (USFWS) Information for Planning and Conservation (IPaC) search results in 2019 to identify species known to occur within or adjacent to the project site. The Draft EIR’s use of a potential-for-occurrence based approach conservatively evaluates impacts on species for which suitable habitat is present, as opposed to conducting protocol level surveys to determine which species are present and may be affected by the project. This potential-for-occurrence type of approach typically results in a more inclusive, conservative analysis of species potentially affected. As such, all 7 special-status species detected during surveys by Dr. Smallwood are evaluated for impacts from the project in the Draft EIR and mitigation proposed (See Impacts 3.4-1 and 3.4-2). In addition to the Mitigation Measures adopted in the 2035 General Plan EIR, the WRTP Specific Plan Draft EIR also contains eight additional mitigation measures designed to provide additional protection to special-status biological resources that are known to occur or may occur in the off-site improvement areas. See Response to Comment 3-14 below and Draft EIR Section 3.4.4 “Environmental Impacts and Mitigation Measures” for more detail. The commenter notes that loggerhead shrike could be present in the project area based on his personal experience observing them near the project site. The commenter also notes that Northern harrier could potentially nest in the project area. The potential for occurrence Table 3.4-4 from Section 3.4, “Biological Resources,” of the EIR has been updated and this change provided in Chapter 3, “Errata” of this Final EIR to include these species. Impacts to these species are already addressed in in Impact 3.4-2 and Mitigation Measures 3.4-2a and 3.4-2b would avoid direct loss of protected bird nests and compensate for habitat loss. The commenter also points out that the tricolored blackbird has been listed under the California Endangered Species Act as threatened since 2018. At the time of the Notice of Preparation in 2017, the tricolored blackbird was listed as a candidate species under the California Endangered Species Act and is identified as such in the Draft EIR (Table 3.4-4). The listing status of the tricolored blackbird has been updated, as provided in Chapter 3, Errata, of this Final EIR, to reflect its current listing status. These revisions do not change the findings, conclusions, or recommendations of the Draft EIR.

Comment 3-12 Summary of Comment: The commenter states that the wildlife baseline described in the Draft EIR is inadequate and omits numerous special status species observed by Dr. Smallwood on and adjacent to the Project site. The commenter also claims that this makes the Draft EIR insufficient as an information document pursuant to CEQA.

Response: Section 3.4.2 “Environmental Setting” of the Draft EIR establishes the baseline that agricultural lands provide important habitat for common and special-status species, and states that they generally provide greater habitat values than urban areas and developed land. The impact analysis presented in the Draft EIR assumes use of the site by special status raptors listed in Table 3.4-4, and acknowledges that the site also provides nesting opportunities for raptors and

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-230 City of Woodland other birds, which are inclusive of the species observed by Dr. Smallwood. No protocol-level species-specific surveys were conducted for the WRTP Specific Plan Area and off-site improvement areas because the suitable habitat potential-for occurrence based approach used in the Draft EIR provided a more conservative (i.e., inclusive) assessment of potential impacts, and because each future project proposed under the WTRP Specific Plan will be required to carry out species-specific preconstruction surveys in accordance with the mitigation measures identified in Section 3.4.4 of the Draft EIR. Because site occupancy by a particular species may vary over time, especially given the noted disturbances to agricultural lands within the project site and potential for crop rotations including fallow fields at times, it is more appropriate to require preconstruction protocol-level surveys for raptors and other nesting birds at the time of each future project’s implementation (such as the mitigation measures currently require) to ensure a more accurate identification of baseline nesting activity and appropriate avoidance and mitigation at the time of impact. Impacts to federal trust species, common raptors, and migratory birds mentioned specifically in the commenter’s letter are addressed under Impact 3.4-2 (Special-Status and Migratory Nesting Birds and Raptors) in Draft EIR Section 3.4.4 “Environmental Impacts and Mitigation Measures,” because specifically-mentioned species are either special-status or migratory nesting birds or raptors. Implementation of Mitigation Measures 3.4-1a – 3.4-1c requires focused preconstruction surveys for Swainson’s hawk, whitetailed kite and burrowing owl, and will ensure that foraging habitat would be preserved at the appropriate ratio of habitat value lost. Implementation of Mitigation Measures 3.4-2a and 3.4- 2b will ensure that all nesting birds and raptors, including the common and special-status species noted in the commenter’s letter, will be protected in accordance with the Migratory Bird Treaty Act and the California Fish and Game Code.

The City appreciates the additional bird observation and nest location information provided in the commenter’s attachments. Dr. Smallwood reported observation of the following seven special-status species as a result of visual surveys of the WRTP Plan Area: three raptor species that are protected by Fish and Game Code Section 3503.5 (red-tailed hawk, American kestrel, and barn owl); one California Department of Fish and Wildlife (CDFW) fully-protected species (white-tailed kite); and two species listed as threatened under the California Endangered Species Act (Swainson’s hawk and tricolored blackbird). Dr. Smallwood also reported another 32 common wildlife species, including ground squirrel, black-tailed jackrabbit, coyote, and numerous migratory birds. These observations are consistent with Section 3.4.2 “Environmental Setting”, which states that several species of raptors, common birds, and mammals are associated with habitats within the study area, and that agricultural lands in the site provide important habitat for common and special status raptors, including Swainson’s hawk, whitetailed kite, northern harrier, and burrowing owl. The commenter points out that the tricolored blackbird has been listed under the California Endangered Species Act as threatened since 2018.

At the time of the Notice of Preparation in 2017, the tricolored blackbird was listed as a candidate species under the California Endangered Species Act and is identified as such in the Draft EIR (Table 3.4-4). The listing status of the tricolored blackbird has been updated, as provided in Chapter 3, Errata, of this Final EIR, to reflect its current listing status. This revision does not change the findings, conclusions, or recommendations of the Draft EIR.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-231 Responses to Comments on the Draft EIR Comment 3-13 Summary of Comment: The commenter states the Draft EIR fails to address impacts of habitat loss to bird species.

Response: Impact analysis was based on the conservative assumption that all existing vegetation could be removed and that all existing habitat functions would be lost. Habitat loss to bird species is addressed in Section 3.4.4 under Impact 3.4-2 “Special-status and Migratory Nesting Birds and Raptors.” Compensatory mitigation for modifications to habitats that are suitable for special status species, including nesting birds, are addressed under mitigation measures proposed for the loss of nesting and foraging habitat for Swainson’s hawk (Mitigation Measure 3.4-1b) in Section 3.4.4 of the Draft EIR, which proposes compensatory mitigation for the loss of nesting and foraging habitat for Swainson’s hawk; this mitigation would also cover the loss of suitable nesting and foraging habitat for other special-status and migratory birds. Furthermore, as discussed in Chapter 3.2 “Agriculture and Forestry Resources”, project applicants for future projects proposed within the WRTP Specific Plan Area are required to replace Prime Farmland at a 1:1 ratio for lands within the City and 3:1 for lands within the County commensurate with the quantity and quality of the converted farmlands, within the same agricultural regions as the impacts occur, that could also provide suitable nesting and foraging habitat for special-status raptors and other birds. Given that the impact assessment within the Draft EIR is conservative and may even overstate actual impacts, no change to the Draft EIR is needed.

Comment 3-14 Summary of Comment: The commenter claims the Draft EIR’s sole reliance on the Yolo County Habitat Conservation Plan (HCP) to mitigate wildlife impacts is not supported by substantial evidence and is insufficient as a matter of law. The commenter asserts that relying solely on the Yolo County HCP creates shortfalls to the cumulative impact analysis, and that there is an absence of information explaining the effect of HCP in achieving habitat goals.

Response: The WRTP Specific Plan Draft EIR was developed to be consistent with the Yolo HCP/NCCP, as required by Item 6 of the environmental checklist in Appendix G of the CEQA Guidelines, as amended, which states that a proposed project “would result in a significant impact related to biological resources if it would conflict with the provisions of an adopted HCP, natural community conservation plan, or other approved local, regional, or state HCP.” Because the WRTP Specific Plan Area is within the Yolo HCP/NCCP coverage area, each project within the WRTP Specific Plan Area and Off-site Improvement Areas must apply for HCP/NCCP coverage prior to grading permit issuance and the avoidance, minimization, and mitigation measures included in the Draft EIR must be, and are, consistent with the Yolo HCP/NCCP.

However, these mitigation measures do not rely solely on the Yolo HCP/NCCP to mitigate wildlife impacts. In addition to the provisions of the Yolo HCP/NCCP, all project-related work would be subject to the City of Woodland’s uniformly applied development standards (CEQA Guidelines Section 15183[f][7]). Uniformly applied development standards include the 2035 General Plan, the Climate Action Plan, existing City regulations and standards, design review requirements, and impact fee programs. Furthermore, a suite of eight different mitigation measures specifically designed to protect wildlife and associated habitat related to buildout of the WRTP Specific Plan Area and off-site improvement areas would be implemented as part of future development projects. These mitigation measures would also protect wildlife species not covered in the HCP (i.e. yellow-billed magpie) and include the following:

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-232 City of Woodland • Mitigation Measure 3.4-1a: Minimize Take and Adverse Effects on Habitat of Swainson’ Hawk and White-Tailed Kite.
• Mitigation Measure 3.4-1b: Comply with Yolo HCP/NCCP Requirements for Compensation for Loss of Swainson’s Hawk Foraging Habitat. • Mitigation Measure 3.4-1c: Minimize Take and Adverse Effects on Western Burrowing Owl.

As noted on pages 3.4-29 and 3.4-30 of the Draft EIR, implementing Mitigation Measures 3.4- 1a through 3.4-1c would reduce significant impacts on Swainson’s hawk, white-tailed kite, and burrowing owl to a less-than-significant level because it would ensure that these species are not disturbed during nesting so that project construction would not result in nest abandonment and loss of eggs or young or result in decreased reproductive success of Swainson’s hawks, whitetailed kites, or burrowing owls. These measures would also ensure that Swainson’s hawk foraging habitat would be preserved at the appropriate ratio of habitat value lost, consistent with the strategy of the Yolo HCP/NCCP, which would also benefit other sensitive and common bird species that utilize this habitat for foraging.
• Mitigation Measure 3.4-2a: Avoid Loss of Protected Bird Nests. • Mitigation Measure 3.4-2b: Implement Mitigation Measures 3.4-1b As noted on pages 3.4-31 and 3.4-32 of the Draft EIR, implementing Mitigation Measure 3.4-2 would avoid disturbing birds during nesting so that project construction would not result in nest abandonment and loss of eggs or young and would ensure compliance with the MBTA and CDFG Code. Mitigation 3.4-2b would require developers for each individual project within the WRTP Specific Plan Area to apply for the HCP/NCCP coverage and payment of developmentbased fees to fund mitigation that will offset losses of land cover types, covered species habitat, and other biological values. Implementation of Mitigation Measure 3.4-2b would reduce significant impacts on foraging habitat for tricolored blackbird (as well as yellow-billed magpie and other sensitive bird species) and wintering habitat for mountain plover to a less-thansignificant level because it would ensure that foraging habitat (i.e., 310 acres of cultivated lands) would be preserved at the appropriate ratio of habitat value lost, consistent with the conservation strategy of the Yolo HCP/NCCP (Yolo Habitat Conservancy 2018). Therefore, there would not be a negative cumulative impact.
• Mitigation Measure 3.4-3: Minimize Take and Adverse Effects on Habitat of Valley Elderberry Beatle.

As noted on page 3.4-34 of the Draft EIR, implementing Mitigation Measure 3.4-3 would reduce potentially significant impacts on VELB to a less-than-significant level because all elderberry shrubs would be mapped and impacts would be avoided and if impacts cannot be avoided, compensatory mitigation will be required. The WRTP Specific Plan will be implemented in accordance with the Yolo HCP/NCCP avoidance and minimization measures. Therefore, with incorporation of HCP/NCCP equivalent mitigation and adherence to other HCP/NCCP

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-233 Responses to Comments on the Draft EIR avoidance and minimization measures, WRTP Specific Plan’s individual impacts and its contribution to cumulative impacts to covered species would be less than significant. • Mitigation Measure 3.4-4: Avoid Direct Loss of Bat Roosts and Special-status Bats.

As noted on page 3.4-35 of the Draft EIR, implementing Mitigation Measure 3.4-4 would reduce potentially significant impacts on bat roosts and special-status bat species, including pallid bat and western red bat, to a less-than-significant level because appropriate avoidance minimization measures will be implemented, such as preconstruction surveys, delaying removal of roost habitat until end of maternity season (August 31) or until the young are capable of flights in consultation with CDFW, and having a qualified biological monitor present during removal of habitat trees or structures.
• Mitigation Measure 3.4-5: Avoid Loss of and Degradation of Federally Protected Waters.

As noted on page 3.4-36 of the Draft EIR, implementing Mitigation Measure 3.4-5 would reduce potentially significant impacts on potentially jurisdictional water features, to a less-thansignificant level because implementation of the BMPs, permit conditions, and mitigation requirements will avoid, minimize, and mitigate for impacts on jurisdictional waters. (see Draft EIR Section 3.4.4 “Environmental Impacts and Mitigation Measures” for more detail).

The commenter notes that populations of burrowing owl breeding pairs and white-tailed kite breeding pairs in the County have declined over the past 25-27 years, and that there is no substantial evidence supporting the assumption that implementation of the HCP will mitigate the Project’s cumulative impacts on these species. The Draft EIR does not rely solely on the HCP/NCCP and includes mitigation measures as described above (Mitigation Measures 3.4-1a – 3.4-1c) to avoid, mitigate, and compensate for impacts to these species.

As for the commenter questioning the status of implementation and performance trends of the HCP, the HCP/NCCP is a newly approved (2018) 50-year program and implementation is just getting underway. It is supported by CDFW and USFWS and this approach benefits natural resources at the landscape level. There is no substantial evidence at this point, and it would be considered speculative, that the HCP/NCCP and the mitigation measures included in this Draft EIR are insufficient to address cumulative impacts on burrowing owl, white-tailed kite, or Swainson’s hawk.

No change to the Draft EIR is needed.

Comment 3-15 Summary of Comment: The commenter states that the Draft EIR fails to adequately analyze the project’s impacts on wildlife movement. The commenter identifies that the Draft EIR must account for wildlife movement that includes stopover habitat and staging habitat for wildlife.

Response: Potential stop-over and foraging habitat for birds along the Pacific Flyway as addressed in Draft EIR Impact 3.4-6. As discussed in Impact 3.4-6, the WRTP Plan Area consists of open

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-234 City of Woodland agricultural land used for row crops, and abundant agricultural habitat of equal or better value (for migrating birds on the Pacific Flyway) is available surrounding the WRTP Specific Plan Area. Migratory routes associated with the Cache Creek, Willow Slough, and Yolo Bypass riparian corridors will not be affected by the proposed project. Furthermore, the WRTP Specific Plan Area and off-site improvement areas are not located within any of the ecological corridors identified in the Yolo HCP/NCCP as important to maintaining connectivity between communities, habitat patches, species populations, or the Yolo HCP/NCCP proposed reserve system. No change to the Draft EIR is needed.

Comment 3-16 Summary of Comment: The commenter states that the Draft EIR fails to address the impacts on wildlife from additional traffic generated by the project, specifically, the potentially significant impact on wildlife that could occur due to possible increased vehicle collisions with special-status species.

Response: The loss of species as a result of buildout of the WRTP Specific Plan is already addressed through evaluation of project-related impacts in Section 3.4.4 of the Draft EIR, which assumes total loss of existing habitats. The WRTP Specific Plan Area is surrounded by roadways, including State Route 113 immediately to the west, that pose existing unquantified traffic threats to wildlife that may use the site or surrounding areas. Speculating on additional cumulative impacts on any remaining wildlife and/or wildlife that may be attracted to the site after buildout of the Specific Plan Area, and speculating on the potential future use of the site by wildlife and possible new traffic-related threats after buildout of future projects, is not consistent with the purpose or requirements of CEQA. The commenter is referring to an animal crossing the road and getting hit by a vehicle or a flying bird getting hit by a vehicle, which would not be significant. Analysis of vehicle traffic on wildlife in an urban setting is focused on those situations in which special-status species may regularly move from between suitable habitat, such as for breeding, and be hindered as a result of roadway crossings. In the case of the WRTP Specific Plan Area, the only special-status species in the area are birds that can fly out of harm’s way and there are no unusual obstacles or traffic conditions proposed by the Specific Plan that would preclude such. It would be speculative to try and determine if and how many mortalities of special-status birds there might be due to an incremental increase in regional traffic created by the project. No change to the Draft EIR is needed.

Comment 3-17 Summary of Comment: The commenter states that the project may have significant environmental impacts by causing fatal bird strikes on its structure and windows, and to be legally sufficient, the Draft EIR must include an analysis of the likely magnitude of bird collisions with the project, as well as the particular species that would be most likely to collide, and be evaluated for direct and cumulative impacts of bird fatalities.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-235 Responses to Comments on the Draft EIR Comment 3-18 Summary of Comment: The commenter states that the Draft EIR fails to analyze the impacts of house cats on wildlife, specifically, the project will likely introduce house cats to the project site that will prey upon birds and small mammals, and could contribute to the downstream loading of Toxoplasma gondii, a parasite in which definitive hosts are cats.

Response: The loss of species as a result of buildout of the WRTP Specific Plan is adequately and comprehensively addressed through evaluation of project-related impacts, as described in Section 3.4.4 of the Draft EIR, which assumes total loss of existing habitats. The WRTP Specific Plan Area is bordered to the east and north by the existing Spring Lake development that already poses an existing unquantified threat to wildlife via the presence of outdoor cats, all of whom may already move through the site. Speculating on additional cumulative impacts on any remaining wildlife and/or wildlife that may be attracted to the site after buildout of the Specific Plan Area, and speculating on the potential future use of the site by wildlife and possible addition of cats after buildout of future projects, is not consistent with the purpose or requirements of CEQA. No change to the Draft EIR is needed.

Comment 3-19 Summary of Comment: The commenter states that the Draft EIR’s estimate of air pollutant emissions is inconsistent with information presented in the Draft EIR and underestimates emissions that would result from the Specific Plan. The commenter includes claims of inconsistency and lack of substantial evidence for emissions estimating methodology, as identified in further comments below.

Response: The emissions estimates included in the Draft EIR use the best available information and industry accepted modeling methodology to analyze air pollutant emissions and related impacts, supported by substantial evidence. Specific responses to comments related to air pollutant emissions estimates are provided below in responses to comments 3-20 through 3-28.

Comment 3-20 Summary of Comment: The commenter states that the Draft EIR’s air quality models use unsubstantiated reductions to land use sizes. Specifically, that in the project’s California Emissions Estimator Model (CalEEMod) output files, found that the air model made reductions to land use sizes than what was proposed in the Draft EIR, without providing justification to the change.

Response: The estimate of total non-residential square footage provided on page 2-7 of the Draft EIR, as referenced by SWAPE in the comment letter, is an estimate based on developable land within the WRTP Specific Plan Area and allowable land uses and development standards included in the WRTP Specific Plan. The acreage and square footage estimates used to inform the land use inputs to CalEEMod were based upon more detailed land use planning exercises to reflect permitted land uses, as well as a more detailed understanding of circulation, utility, open space, and buffer areas that will be integrated in the WRTP Specific Plan Area, along with off-site improvement areas. As explained on page 0-7 of the Draft EIR, while the total development square footage and other land use details are all reasonable assumptions based on the land use designations and other planning details of the WRTP Specific Plan, these inputs are assumptions used for the purposes of analysis of environmental impacts of the WRTP Specific Plan. A difference of 27,831 square footage from the 2.2 million square feet as generally referenced in the Draft EIR project description, is approximately 1.2 percent. As detailed on page 3.3-23 of the Draft EIR, the emissions estimated using CalEEMod assume full-build out of the project by

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-236 City of Woodland the year 2035, but it is unlikely that the entire WRTP Specific Plan will be build out in 2035. In addition, as further described on this same page, emissions from building operations and mobile sources would likely be reduced in future years due to increasingly stringent regulatory requirements and technological advances to reduce emissions from both construction and operations and as a result of the WRTP Specific Plan Performance Standards, including that which requires that all uses within the WRTP Specific Plan are subject to the Performance Standards listed in Section 3.3.2 and shall demonstrate consistency with the 2035 Climate Action Plan as outlined in Section 3.3.3 of the WRTP Specific Plan, and the WRTP Specific Plan’s Transportation Demand Management/Vehicle Miles Traveled Reduction Program that would reduce overall vehicle miles traveled and related emissions from future operations within the WRTP Specific Plan Area, all of which were not accounted for in the emissions modeling for the WRTP Specific Plan Area. As such, the emissions presented in the Draft EIR are considered conservative and the slight difference between the square footage estimate presented in the Draft EIR Project Description and the more detailed land use estimates used in the CalEEMod model do not present an overall underestimation of future emissions to potential impacts associated with such emissions. Furthermore, the potential construction and operational emissions associated with buildout of the WRTP Specific Plan were updated to eliminate the discrepancy noted by the commenter. The emissions were estimated using the most current version of CalEEMod (Version 2023.1.1.14), applying the same methodology as detailed in the Draft EIR Section 3.3.4 and as detailed in Appendix B to the Draft EIR, but with updated land use detailed to match those of the Final WRTP Specific Plan Land Use Table 2.1 and to account to parking and landscaping as appropriate. Based on the updated modeling, the total construction and total operational emissions are less than those presented in the Draft EIR. Although the land use square footage was increased by approximately 1.2 percent, anticipated construction and operational emissions reflect the most current emission factor and energy use data, as appropriate for the land uses to be developed under the WRTP Specific Plan, with development starting at the earliest in 2024. This further supports the significance conclusions related to air quality impacts, as presented in Section 3.3 of the Draft EIR. Therefore, no change to the Draft EIR is needed or has been made.

Comment 3-21 Summary of Comment: The commenter states that the Draft EIR’s air quality model made unsubstantiated reductions related to parking, specifically, that neither the Draft EIR nor the CalEEMod output files provided an estimate of the extent of future parking, so the project’s air quality impacts can’t be relied upon.

Response: The specific parking areas and types associated with each proposed land use designation have not yet been identified; however, as explained in response to comment 3-20, emissions estimates have been updated to include estimated parking and landscaping areas associated with each of the proposed land uses based on the land use type and similar ratios of horizontal building development to parking and landscaping uses. The emissions were estimated using the most current version of CalEEMod (Version 2023.1.1.14) applying the same methodology as detailed in the Draft EIR Section 3.3.4 and as detailed in Appendix B to the Draft EIR, but with updated land use detailed to match those of the Final WRTP Specific Plan Land Use Table 2.1 and to account to parking and landscaping, as appropriate. Based on the updated modeling, construction-related emissions are less than those presented in the Draft EIR. Although parking and landscaping land uses were added as appropriate, anticipated construction emissions reflect

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-237 Responses to Comments on the Draft EIR the most current emission factor and energy use data, as appropriate for the land uses to be developed under the WRTP Specific Plan, with construction starting at the earliest in 2024. This further supports the significance conclusions related to air quality impacts, as presented in Section 3.3 of the Draft EIR. Therefore, no change to the Draft EIR is needed or has been made.

Comment 3-22 Summary of Comment: The commenter states that the modeling data does not include an adequate basis for changing the default percent paved values, and that it assumes that future hauling, vendor, and worker trips will only travel on paved surfaces, despite the project sitting on farmland. The commenter states that this is an important distinction to make for estimating the project’s fugitive dust emissions.

Response: Notes provided within the CalEEMod output files contained in Appendix B to the Draft EIR specifically state that the Specific Plan Area’s proximity to major roadways surrounding the Specific Plan Area is the relevant factor in changing the percent paved values. Trips to and from the WRTP Specific Plan Area for future development projects would use the surrounding highways and major roadways. In addition, as detailed in Chapter 6 of the WRTP Specific Plan, infrastructure requirements for each phase of development of the WRTP Specific Plan include on-site backbone infrastructure and off-site facilities necessary for each development, which includes roadway and other facilities and improvements. As such, there would be minimal onroad vehicle activity on unpaved roadways since the roadway improvements would occur to support the larger development area. In addition, as development occurs, agricultural operations within the development footprint that include fugitive-dust generating vehicle and equipment activity on previously unpaved roadways and agricultural land would no longer occur once development occurs. The default percent unpaved road characteristics in CalEEMod are based up a county average for unpaved roadways, and do not reflect project-specific considerations of construction traffic routes and project planning that would occur to appropriately phase any necessary roadway improvements with proposed development projects. The revision of the default to 99 percent paved roadways for construction is appropriate and reflects that between one-tenth to one-half mile of the various construction-related trips may occur on unpaved roadways, which is a reasonable assumption for a portion of initial construction-related trips as internal roadways infrastructure is being developed, and perhaps conservative for later phases of construction when roadway improvements to support initial development phases would have already been completed, thereby providing paved roadways for 100 percent of the constructionrelated on-road travel. Similarly, revising the default parameter for operational vehicle trips occurring on paved roadways to 100 percent accurately reflects that the WRTP Specific Plan provides for supporting infrastructure improvements, including new and improved roadways; in general, and as explained in Section 6.3, “Infrastructure Sequencing,” of the WRTP Specific Plan, development sequencing strategy is structured to advance the backbone infrastructure improvements needed to support associated development, in compliance with City policies and standards, and that the development area can support the costs of the required improvements.

Therefore, no change to the Draft EIR or supporting emissions estimates is needed.

Comment 3-23 Summary of Comment: The commenter states that the air quality model improperly assumes reductions to default values for energy usage.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-238 City of Woodland Response: As acknowledged in Exhibit B page 5 of this comment letter, the Draft EIR explains on page

3.3-17 that the energy intensity factors for energy uses subject to Title 24 standards were adjusted to reflect 2019 Title 24 standards from CalEEMod defaults, which are based on the 2016 Title 24 standards. Contrary to the claim in the comment letter that there is no “guarantee that these reductions would be implemented locally on the Project site,” Title 24 California Building Energy Efficiency Standards are adopted into the California Code of Regulations (Title 24) and are required of new development in California and would be implemented by future projects within the WRTP Specific Plan Area. The energy reductions between new development that would be constructed to the 2016 Title 24 standards and the same new development but construction to 2019 Title 24 standards are based upon data provided by the California Energy Commission and are a best available estimate for such information. In addition, these reductions are considered conservative, as they reflect only the most current standards, while the Title 24 standards are updated every three years and increase energy efficiency and conservation requirements with each subsequent iteration. As such, consistent with the balance of analysis in the Draft EIR, the reductions applied to the CalEEMod modeling for the WRTP Specific Plan Area are conservative (likely to overestimate future building energy consumption). No change to the Draft EIR is needed, nor would any change be appropriate.

Comment 3-24 Summary of Comment: The commenter states that the Draft EIR’s air quality model improperly assumed that off-road construction equipment would meet Tier 4 Final standards.

Response: Mitigation Measure 3.3-2b has been refined to clearly distinguish the requirement for the use of equipment greater than 50 horsepower to be powered with engines that meet Tier 4 Final emissions standards. Item ‘c.’ of Mitigation Measure 3.3-2b has been revised as such:

Mitigation Measure 3.3.-2b …
c. “ Comply with the State On-Road Regulation by using on-road For all off-road heavy-duty equipment greater than 50 horsepower, utilize equipment that meet or exceed CARB’s Tier 4 Final standards for on off-road heavy-duty diesel engines.” This aligns with the intent of the mitigation measure to reduce construction-related emissions of nitrogen oxides (NOX) and particulate matter with aerodynamic diameter less than 10 microns (PM10) and is reflected in the CalEEMod emissions modeling for the mitigation scenario, as included in Appendix B of the Draft EIR. This change does not change the significance determination as presented in the Draft EIR.

Comment 3-25 Summary of Comment: The commenter states that the Draft EIR failed to disclose a significant air quality impact from construction-related NOx emissions.

Response: The commenter is incorrect. The CalEEMod model inputs were specifically adjusted to projectspecific data and reasonable assumptions based on the proposed land use mix and regional context, as detailed in the responses to comments 3-19 through 3-24. The data are appropriate for use in the calculations presented in the Draft EIR. The use of the data inputs and assumption for the CalEEMod model is appropriate for the Draft EIR, and the emissions estimates based on this modeling provide substantial evidence for the impact analyses and findings of significance.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-239 Responses to Comments on the Draft EIR As explained in response to comments 3-20 and 3-21, the potential construction and operational emissions associated with buildout of the WRTP Specific Plan were updated to eliminate the discrepancy in buildout square footage noted by the commenter, and to include parking and landscaping areas. The emissions were estimated using the most current version of CalEEMod (Version 2023.1.1.14), applying the same methodology as detailed in the Draft EIR Section

3.3.4 and as detailed in Appendix B to the Draft EIR, but with updated land use detailed to match those of the Final WRTP Specific Plan Land Use Table 2.1 and to account to parking and landscaping as appropriate. Based on the updated modeling, unmitigated construction-related emissions of NOX would be 26 percent less than the NOx emissions presented in the Draft EIR, but would still exceed the Yolo-Solano Air Quality Management District (YSAQMD) threshold of significance for NOx prior to mitigation being applied. Impacts associated with NOx emissions are still concluded to be Less Than Significant with mitigation. This updated modeling therefore does not change the significance findings or the need for mitigation, as provided in the Draft EIR. The revised modeling by SWAPE is acknowledged, but does not reflect the appropriate modeling inputs or assumptions, as discussed above in the response to comments 3-19 through 3-24. Also note, the comment is incorrect in characterizing the Draft EIR as indicating a “no significant effect,” as the Draft EIR concludes that unmitigated NOX (as well as reactive organic gas [ROG] and PM10) emissions would exceed thresholds of significance and that NOX emissions are only reduce to below thresholds with implementation of Mitigation Measures 3.3-2a through 3.3-2c to reduce construction-related emissions. No change to the Draft EIR is needed, nor would any change be appropriate.

Comment 3-26 Summary of Comment: The commenter states that the Draft EIR fails to adequately evaluate health risks from diesel particulate matter emissions. The commenter requests that objective criteria be identified in the Draft EIR for any future projects requiring a health risk assessment, based on location relative to any existing or potential future residence and potential of toxic air contaminant (TAC) emissions during construction or operation.

Response: Mitigation Measure 3.3-3b requires implementation of guidelines from the California Air Resources Board’s Air Quality and Land Use Handbook: A Community Health Perspective and the subsequent Technical Advisory, which detail land use compatibilities and buffer zone recommendations between various land uses, as well as measures to reduce exposure of sensitive receptors to substantial TAC concentrations. Mitigation Measure 3.3-3c provides objective criteria in the form of specific performance standards for excess cancer cases and non-cancer acute and chronic indices for future projects, along with mitigation requirements for future projects developed under the Specific Plan (Draft EIR, page 3.3-41).

In addition, the WRTP Specific Plan includes design standards to ensure compatibility of proximate land uses and minimize adverse impacts. The Specific Plan’s land use diagram, as shown in Exhibit 2-3 of the Draft EIR, is designed to ensure separation of incompatible land uses such that proximity of sensitive receptors to substantial TAC emission sources. Chapter 3 of the WRTP Specific Plan includes guidelines regarding land use classifications and regulations pertaining to land uses within the WRTP Specific Plan Area. All uses are subject to the Performance Standards listed in Section 3.3.2 of the WRTP Specific Plan, including Performance Standard D that prohibits dust and particulate matter emissions “detectable beyond

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-240 City of Woodland property lines by a reasonable person without instruments” and requires that “[e]xhaust air ducts shall be located or directed away from abutting residentially-zoned properties.” Table 3.1 of the WRTP Specific Plan identifies the permitted uses in each of the zoning designations, including notes detailing specific requirements pertaining to each land use. No change to the Draft EIR is needed, nor would any change be appropriate.

Comment 3-27 Summary of Comment: The commenter claims that the Draft EIR’s reliance on the City’s Climate Action Plan to find that the Project’s greenhouse gas (GHG) emissions will be less than significant is in error because the Project does not comply with a number of measures set forth in the Climate Action Plan. The commenter references inconsistencies or omissions between the WRTP Specific Plan and the City’s Climate Action Plan that are identified in Exhibit B, pages 12 through 19, appended to the comment letter, and requests the City review the comments and ensure that the GHG reduction measure are binding and enforceable on future projects prior to approving the WRTP Specific Plan.

Response: In preparation of the Draft EIR, the City closely reviewed the proposed WRTP Specific Plan and whether it would meet the standards of consistency with the City’s Climate Action Plan and the 2035 General Plan and Climate Action Plan EIR, in accordance with CEQA Guidelines 15183.5(b).

Exhibit B of the comment letter asserts several reasons that the WRTP Specific Plan is inconsistent with the City’s Climate Action Plan or where mitigation is required to ensure enforceability.

With regard to Climate Action Plan measures E-2, E-5, T/LU-6, UF-3, W/W-1, and W/W-2, the commenter notes that these measures are not included in Table 3.5-2 of the Draft EIR and therefore the commenter is unable to verify the WRTP Specific Plan’s consistency with the City’s Climate Action Plan. However, these measures are not at the discretion of future development under the WRTP Specific Plan. Rather, these measure are actions under the City’s purview to promote and coordinate with local agencies for implementation. For example, and as noted by the commenter in the table provided in Exhibit B, page 12, Measure E-2 action are to: “Support/promote group purchasing programs for discounted energy-efficient appliance and equipment replacements; Promote residential programs such as Pacific Gas & Electric Company’s (PG&E‘s) Energy Savings Assistance Program to help low-income homeowners and renters manage energy use and energy costs through free or low-cost upgrades to more energy-efficient appliances, lighting, and building features; Conduct education and outreach to promote rebates, incentives, and other programs as they become available, and use available information on rebates used by consumers to determine where to focus education and outreach; Provide information on equipment upgrade benefits, rebates, and energy-efficiency assistance from Yolo Energy Watch and other programs as part of the business license renewal process.” These actions are not for individual projects to demonstrate consistency with and, therefore, were not included in Table 3.5-2 of the Draft EIR, which specifically was introduced as a table providing an outline of “the City’s Climate Action Plan policies as relevant to the WRTP Specific Plan,” and not a comprehensive list.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-241 Responses to Comments on the Draft EIR With regard to Climate Action Plan measures E-1, E-3, E-4, E-6, T/LU-5, T/LU-7, UF-2, the commenter points out that the City’s Climate Action Plan requires that “a project must demonstrate that it is included in the growth projections upon which the Climate Action Plan modeling is based and that it incorporates applicable strategies and measures from the Climate Action Plan as binding and enforceable components of the project.” As explained throughout the Draft EIR and specifically on page 3.5-15 of the Draft EIR impact analysis pertaining to greenhouse gas emissions and climate change, the scale and intensity of development proposed under the WRTP Specific Plan was assumed as part of the development analyzed under the 2035 General Plan and Climate Action Plan (CAP) EIR and considered in the growth projections upon which the CAP modeling is based.

The commenter goes on to claim that the identified policies, standards, and design guidelines of the WRTP Specific Plan that are referenced in the consistency checklist of Table 3.5-2 of the Draft EIR are not binding and enforceable components of the Project because they are not included as mitigation measures, referencing AEP CEQA Portal Topic Paper on mitigation measure that recommends inclusion of project design feature(s) that address environmental impacts in the mitigation monitoring and reporting program (MMRP) to ensure that these measure accompany building and construction plans through the permit process and are not eliminated during future design reviews without the understanding of the resulting environmental impact(s). In the case of the WRTP Specific Plan, these are not individual development design features, but policies, design standards, and design guidelines of the WRTP Specific Plan itself, which will serve as the governing document, along with other City regulations in effect at the time of development, against which subsequent development and/or proposed land use, including tentative map applications, within the WRTP Specific Plan Area will be reviewed for consistency and compliance. In acting to approve a project or permit, the City may impose conditions as are reasonably necessary to ensure that the project is in substantial compliance with the Specific Plan and all applicable plans and regulations.

Furthermore, while Table 3.5-2 in included as one piece of the analysis in the Draft EIR regarding consistency between the WRTP Specific Plan and the City’s Climate Action Plan, the analysis also included discussion and consideration of the implementation and administrative processes required of the WRTP Specific Plan and how those processes further ensure consistency of the WRTP Specific Plan with the City’s Climate Action Plan. This analysis is provided on page 3.5-21 of the WRTP Specific Plan and includes review of Section 3.3.3, “Climate Action Plan Consistency,” of the WRTP Specific Plan, which outlines the following requirements of all future development under the WRTP Specific Plan to demonstrate consistency with the City’s Climate Action Plan:
(A) All new development projects and major expansion projects shall provide a summary of incorporated conservation measures, consistent with the City’s 2035 Climate Action Plan, adopted with the General Plan in 2017 . For each Climate Action Plan strategy and related “action” relevant to new development projects, the City will determine: (a) the project is consistent; (b) the project with conditions or when modified would be consistent; (c) the strategy is relevant for new development, but not the subject project; or (d) the project includes one or more replacement strategies that would be equally or more effective in reducing GHG emissions and such replacement strategy or strategies are not include in

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-242 City of Woodland the Climate Action Plan or required by any other regulations, standards, design criteria, or other existing requirement.
(B) All projects shall complete and submit the City’s Climate Action Plan Consistency Checklist for review and approval by the City prior to project approval. The Climate Action Plan Consistency Checklist allows proposed development projects to demonstrate consistency with the Climate Action Plan.
(C) Consistent with General Plan Policy 2.L.2, all projects shall strive to meet net zero energy consumption through the incorporation of conservation measures above Title 24 standards and shall, at minimum, demonstrate consistency with CalGreen Tier 1 Standards. (D) Additional GHG reductions strategies and sustainability measures shall be considered in major expansion projects and in the ongoing operations and use of all commercial and residential projects within the [WRTP Specific] Plan Area including, but not limited to, Energy Conservation, Water Conservation/Quality and Low Water Landscape measures as outlined in [the WRTP Specific Plan] Sustainability Guidelines Sections 3.5.3.B for commercial uses and Section 3.5.12.B for residential.

As detailed in Chapters 3 through 5 of the City’s 2035 Climate Action Plan, the Climate Action Plan addresses each of the recommended plan elements spelled out in CEQA Guidelines Section 15183.5(b)(1), and, therefore, will be used to streamline review of projects that are consistent with the Climate Action Plan. The City’s Climate Action Plan Checklist serves to apply the relevant 2035 General Plan and Climate Action Plan policies and reduction measures through a streamlined review process for proposed new development projects that are subject to discretionary review and that trigger environmental review under CEQA. Projects that are consistent with the General Plan and demonstrate consistency with the Climate Action Plan may use this consistency determination in lieu of a project-specific GHG emissions analysis to address potential GHG emissions impacts. Therefore, construction and operational GHG emissions generated from implementation of the WRTP Specific Plan are evaluated based upon compliance with the City’s Climate Action Plan.

As noted on page 1-2 of the Draft EIR, the City will evaluate future projects within the Specific Plan Area for consistency with the Specific Plan and the EIR, and will evaluate whether additional CEQA analysis is necessary. Per Specific Plan Policy 2.2.3.1, and as outlined in Section 3.3.3. of the WRTP Specific Plan, development under the WRTP Specific Plan will be required to demonstrate consistency with the City’s Climate Action Plan as it is updated in the future to ensure the City stays on target to achieve future State GHG emissions targets, thereby providing for the consideration of additional reductions required and achievable in future years.

The Final WRTP Specific Plan Section 6, “Implementation,” also identifies an Enhanced Climate Action Plan Checklist to achieve WRTP energy efficiency and sustainable design goals and to achieve consistency with citywide and 2035 General Plan GHG reduction targets, as a subsequent plan that must be prepared either prior to approval of the first development application or residential tentative map or as otherwise required by conditions of approval and/or Environmental Impact Report and associated Mitigation Monitoring Program, or by the

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-243 Responses to Comments on the Draft EIR Community Development Director, as appropriate, to ensure feasibility and enforceability of this review requirement.

The analysis provided in Section 3.5 of the Draft EIR comprehensively assesses the proposed project. In addition to the anticipated land use plan, the policies, design standards, and design guidelines are the basis of review of the WRTP Specific Plan for the EIR, and are binding with the adoption of the WRTP Specific Plan. As with review of future development applications under the WRTP Specific Plan, proposed changes to the WRTP Specific Plan itself would undergo additional environmental review to determine whether additional review is required under CEQA Section 15183 and 15182, thereby ensuring that policies and standards of the WRTP Specific Plan, such as those describe above requiring review of future projects for consistency with the City’s Climate Action Plan do not get removed from the WRTP Specific Plan without recognizing the environmental impacts of such a change.

Table 3.5-2 of the Draft EIR, which is the subject of the commenter’s review for inconsistencies or omissions between the WRTP Specific Plan and the City’s Climate Action Plan, is one component of the environmental review and analysis provided to address this potential impact, along with future project-specific review for consistency with the City’s Climate Action Plan.

Per the commenter’s request, the City has reviewed the comments and ensures that the GHG reduction measures are binding and enforceable on future projects.

Section 3.5, “Climate Change, Greenhouse Gas Emissions, and Energy,” of the Draft EIR (page

3.5-15) comprehensively evaluates the WRTP Specific Plan’s fair share contribution to the emissions reduction required by the State’s emissions reduction targets. As explained in this analysis and reiterated above, consistent with CEQA Guidelines Section 15183.5(b), the WRTP Specific Plan was determined to be consistent with the City’s 2035 Climate Action Plan.

Therefore, as provided by CEQA Guidelines section 15183.5(b), the WRTP Specific Plan would not result in an incremental contribution to a cumulative effect. No change has been made to the analysis and no additional mitigation is required.

Comment 3-28 Summary of Comment: The commenter closes the letter and requests that the City amend and supplement the Draft EIR and recirculate it for additional public comment before approval of the Project.

Response: For the reasons stated above in responses to Comments 3-1 through 3-27, revisions to the Draft EIR have been made as appropriate. The revisions made and specified in response to Comments 3-1 through 3-27 do not change the validity or findings of significance of the of the analysis in the Draft EIR, and recirculation is not required.

Exhibit A
Comment 3A-1 Summary of Comment: The commenter introduces the letter and provides a summary of the Draft EIR. The commenter states that the analysis of baseline conditions included in the Draft EIR is incomplete and flawed, and the impact analysis fails to thoroughly address potential impacts to wildlife that are both substantial and significant.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-244 City of Woodland Response: The parts of this comment that introduce the comment letter and summarize the WRTP Specific Plan do not raise any topics related to the veracity of the Draft EIR. For the topics raised about the analysis of baseline conditions and the potential impacts to wildlife included in the Draft EIR, please see the response to comment 3-11.

Comment 3A-2 Summary of Comment: The commenter presents their qualifications and describes their contribution to the scientific foundation for the earliest version of the Yolo County Habitat Conservation Plan (HCP) and the certification process of the Spring Lake Specific Plan.

Response: This comment does not raise any topics related to the veracity of the Draft EIR. The disclosed information is noted.

Comment 3A-3 Summary of Comment: The commenter describes the site visits they completed within the project area on June 28, 29, and 30, 2021. The commenter provides a summary table of the thirty-nine species of vertebrate wildlife they identified during these site visits, and of which seven are listed as special-status species.

The commenter includes photographs taken during these site visits that show the observed wildlife in and around the project area, as well as a nonlinear regression model to predict the number of species that could have been detected with a longer survey effort using the same visual scan method (Figure 1 of Exhibit A to the Comment Letter 3). In addition, the commenter provided another figure; one graph demonstrating the relationship between the number of species detected during a survey being a function of survey effort, and the second graph depicting the probability of detection of listed species as a function of an increasing number of vertebrate wildlife species detected (Figure 2 of Exhibit A to the Comment Letter 3). Both graphs in Figure 2 used data from the outcomes of the 152 previous surveys completed at proposed project sites by the commenter. The commenter states that they are confident from their past experiences with site surveys, personal driving trips along Highway 113 in which they have seen Swainson’s Hawks on the project site, and other stories they have heard from the public concerning witnessing special-status species on or near the project site, that multiple additional special-status species would be detected with a greater survey effort. The commenter states that a larger survey effort is required to inform the public and decision makers about the potential project impacts to wildlife and special-status species and how to mitigate them.

Response: Please see the responses to comments 3-11 and 3-12.

Comment 3A-4 Summary of Comment: The commenter states that the two field reconnaissance surveys mentioned in the Draft EIR fail to include basic information a biologist would expect to see reported about these surveys, and that the Draft EIR provides no list of wildlife species that were detected.

Response: Please see the response to comment 3-11.

Comment 3A-5 Summary of Comment: The commenter states that there is a major shortfall in the analysis of project impacts to biological resources in the Draft EIR since no detection surveys were performed for specialstatus species. The commenter states that the catch-all surveys that were performed at the project site are inappropriate for determining the absence of special-status species and that detection surveys for the burrowing owl are warranted since ground squirrels occupy the project site, which increases the potential presence of burrowing owls. The commenter claims that the Draft EIR argues that the Yolo County Habitat Conservation Plan (HCP) exempts the City of Woodland from having to perform detection surveys.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-245 Responses to Comments on the Draft EIR Response: Please see the responses to comments 3-11 and 3-12.

Comment 3A-6 Summary of Comment: The commenter states that the Draft EIR accurately describes alfalfa production as part of the crop rotation typical of the project site, but it does not inform the reader of the importance of alfalfa to wildlife in Yolo County, and particularly to multiple special-status species in the area. The commenter describes their experience of studying wildlife alfalfa in Yolo County, and acknowledges that the Draft EIR did not include or make use of what was learned about wildlife use of alfalfa and of other Yolo County crops from their studies, or of other special-status species studies that have been conducted in the project area. The commenter states that the Draft EIR has severely underestimated the importance of the site to special-status species of wildlife, and that the Draft EIR should be revised to more carefully and thoroughly analyze potential project impacts to wildlife. The commenter gave specific mention of the Draft EIR ruling out the occurrence likelihood or of the project site offering no suitable habitat for loggerhead shrike, yellow warbler, northern harrier, tricolored blackbird nesting, and Modesto song sparrow, and that the Draft EIR should more realistically assess these occurrence likelihoods. The commenter provides a table of the occurrence likelihoods of special-status species at the project site based on records of sightings in eBird and iNaturalist (data bases) and the commenter’s project site visits.

Response: Please see the responses to comments 3-11 and 3-13 and 3-15.

Comment 3A-7 Summary of Comment: The commenter states that the project would contribute to an ongoing trend of declining birds in North America through habitat loss and the permanent loss of productive capacity. The commenter asserts that the project would result in a loss of 1.1 million birds over the first century following construction and that the Draft EIR does not include this as a significant and substantial impact or provide any mitigation measures. The commenter states that the Draft EIR should be revised to appropriately analyze the project’s impacts from habitat loss.

Response: Please see the response to comment 3-13.

Comment 3A-8 Summary of Comment: The commenter suggests that the water consumed by future operations of land uses of the WRTP Specific Plan could conceptually come from, and thereby reduce the amount of water available to, the agricultural sector in California. The commenter goes on to suggest that this water consumption would make water unavailable to and therefore take 319 acres of arable farmland out of production.

The commenter states that the Draft EIR should be revised in order to evaluate and analyze the project’s impacts to habitat loss from the project’s water demand, and the loss of breeding sites and annual production that would occur as a result.

Response: The commenter incorrectly suggests that the proposed project’s water demand would be served by sources that would then no longer be available to farmland and related wildlife habitat. As explained in Section 3.14, “Utilities,” of the WRTP Specific Plan Draft EIR, the City Public Works Department completed a Water Supply Assessment for the proposed land use plan contained within the WRTP Specific Plan and, as documented in the Water Supply Assessment and Certification Form, the City has sufficient water supplies for the proposed project during normal, single dry, and multiple dry years over a 20-year period. The WRTP Specific Plan would increase the demand for municipal water supplies, but there is no evidence that such

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-246 City of Woodland demand would result in any indirect loss of habitat, breeding sites, or annual production of wildlife species.

Comment 3A-9 Summary of Comment: The commenter states that the Draft EIR fails to adequately analyze the project’s impacts on wildlife movement, and that this constitutes a revision of the Draft EIR.

Response: Please see response to comment 3-15.

Comment 3A-10 Summary of Comment: The commenter states that the Draft EIR fails to analyze the project’s traffic impacts to wildlife caused by vehicles traveling to and from the project site. The commenter asserts that operations over fifty years would accumulate 2,333,264 wildlife fatalities, and that the Draft EIR must be revised to account for this impact and to implement mitigation measures to improve wildlife safety along the roads.

Response: Please see response to comment 3-16 and 3-17.

Comment 3A-11 Summary of Comment: The commenter states that the project would result in potentially significant adverse biological impacts because of the predicted level of bird-window collision mortality, and the lack of any proposed mitigation in the Draft EIR. The commenter asserts that the project would result in 8,206 bird deaths per year, and that the vast majority of these deaths would be of birds protected under the Migratory Bird Treaty Act and under the recently revised California Fish and Game code section 3513, thus causing unmitigated significant impacts. The commenter includes a list of bird-window collision factors, window collision solutions, and claims that post-construction fatality monitoring should be an essential feature of any new building project.

Response: Please see response to comment 3-17.

Comment 3A-12 Summary of Comment: The commenter states that the Draft EIR fails to analyze the impacts of house cats on wildlife, specifically, the project will likely introduce house cats to the project site that will prey upon birds and small mammals, and could contribute to the downstream loading of Toxoplasma gondii, a parasite in which definitive hosts are cats.

Response: Please see response to comment 3-18.

Comment 3A-13 Summary of Comment: The commenter states that impacts to wildlife would occur caused indirectly by the project’s demand for 3.15 megawatt (MW) of electricity. The commenter claims that wildlife mortality is caused by collisions of volant wildlife with wind turbines and utility-scale solar photovoltaic (PV) panels and associated infrastructure (fences, distribution lines, transmission lines). The commenter asserts that effects of habitat loss from renewable energy generation would result in an annual death toll of wildlife that would be exacerbated by on-site habitat loss, window collisions, traffic impacts, and house cats, and that these potential impacts warrant a revision of the Draft EIR.

Response: The proposed Project does not include proposed wind turbines or utility-scale PV panels. No revisions to the no revisions are required of or have been made to the WRTP Specific Plan EIR.

Comment 3A-14 Summary of Comment: The commenter states the Draft EIR’s sole reliance on the Yolo County HCP (Habitat Conservation Plan) to mitigate wildlife impacts is not supported by substantial evidence and is insufficient as a matter of law. The commenter states that relying solely on the Yolo County HCP creates shortfalls to the cumulative impact analysis, and that there is an absence of information explaining the effect of HCP in

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-247 Responses to Comments on the Draft EIR achieving habitat goals. The commenter asserts that that HCP can’t prevent significant cumulative impacts to its covered species, let along the special-status species that the HCP does not cover, and that an emergency cumulative impacts assessment is needed for burrowing owl and white-tailed kite.

Response: Please see response to comment 3-14.

Comment 3A-15 Summary of Comment: The commenter references Mitigation Measure 3.4-1a: Minimize Take and Adverse Effects on Habitat of Swainson’s Hawk and White-Tailed Kite, and states that prior to the certification of the Draft EIR, species detection surveys must be completed to support negative findings of species when appropriate, inform preconstruction surveys to improve their efficacy, estimate project impacts, and inform compensatory mitigation and other forms of mitigation.

Response: Please see the responses to comments 3-11 through 3-13.

Comment 3A-16 Summary of Comment: The commenter references Mitigation Measure 3.4-1b: Comply with Yolo HCP/NCCP Requirements for Compensation for Loss of Swainson’s Hawk Foraging Habitat, and states that prior to the certification of the Draft EIR, the project proponent should clearly identify lands where the Swainson’s Hawk mitigation fee would be applied. The commenter also states that the Draft EIR should be revised to demonstrate the efficacy of the HCP mitigation fee.

Response: Please see response to comment 3-14.

Comment 3A-17 Summary of Comment: The commenter references Mitigation Measure 3.4-1c: Minimize Take and Adverse Effects on Western Burrowing Owl, and states that preconstruction surveys aren’t substitutes for detection surveys, and that the proposed mitigation measure would be inconsistent with the standards of the burrowing owl survey and mitigation guidelines (CDFW 2012).

Response: Please see response to comment 3-12.

Comment 3A-18 Summary of Comment: The commenter references Mitigation Measure 3.4-2a: Avoid Direct Loss of Protected Bird Nests, and states that compensatory mitigation is required for bird nests and roosting bats that will be missed by preconstruction surveys, and that compensatory mitigation is also needed for the impacts to wildlife from mortality caused by collisions with windows and automobiles, predation by house cats, and by habitat loss.

Response: Please see response to comment 3-13, 3-17, and 3-18. In addition, loss of bat roosts and specialstatus bats is further addressed in Impact 3.4-4, and applicable mitigation provided through Mitigation Measure 3.4-4 to avoid direct loss.

Comment 3A-19 Summary of Comment: The commenter references Mitigation Measure 3.4-4: Avoid Direct Loss of Bat Roosts and Special-status Bats, and recommends that acoustic surveys with Sonobat be performed to identify which species of bats occur on the site, and that the Draft EIR should be revised to inform the public about bat use on the project site.

Response: As detailed in Mitigation Measure 3.4-4 of the Draft EIR, acoustic surveys are included in the applicable survey methods to provide the best opportunity to determine if roosting bats are

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-248 City of Woodland present. No revisions to the no revisions are required of or have been made to the WRTP Specific Plan EIR.

Comment 3A-20 Summary of Comment: The commenter describes their recommended mitigation measures concerning habitat protection; including, that habitat should be permanently protected in the form of fee title or conservation easement, or a combination thereof, and that fifteen years of monitoring be performed for targeted special-status species on and around the protected lands, and that native trees and shrubs be planted with incorporation of the project elements such as in residential yards, street-scaping, etc.

Response: The loss of species as a result of buildout of the WRTP Specific Plan is adequately and comprehensively addressed through project-related impacts, as described in Section 3.4.4 of the Draft EIR, which assumes total loss of existing habitats. Compensatory mitigation for modifications to habitats that are suitable for special status species, including nesting birds, are addressed under mitigation measures proposed for the loss of nesting and foraging habitat for Swainson’s hawk (Mitigation Measure 3.4-1b) in Section 3.4.4 of the Draft EIR, which proposes compensatory mitigation for the loss of nesting and foraging habitat for Swainson’s hawk; this mitigation would also cover the loss of suitable nesting and foraging habitat for other specialstatus and migratory birds and would be developed in consultation with CDFW. Furthermore, as discussed in Chapter 3.2 “Agriculture and Forestry Resources,” project applicants for future projects proposed within the WRTP Specific Plan Area are required to replace Prime Farmland at a 1:1 ratio for lands within the City and 3:1 for lands within the County commensurate with the quantity and quality of the converted farmlands, within the same agricultural regions as the impacts occur, that could also provide suitable nesting and foraging habitat for special-status raptors and other birds. Furthermore, City of Woodland General Plan Policies 7.B.8 require developers to use native and compatible non-native species, especially drought-resistant species, to the extent possible in order to preserve the visual integrity of the landscape, provide benefits for native wildlife, and ensure that a variety of plants suited to the region are maintained. The WRTP Specific Plan would also be required to comply with the City’s Tree Ordinance, including a tree plan and the replacement of any trees proposed to be removed. While the impact assessment within the Draft EIR may be conservative, and may tend to somewhat overstate actual impacts, no change to the Draft EIR is needed.

Comment 3A-21 Summary of Comment: The commenter recommends funding wildlife crossings at locations along roads used by the project in areas where special-status species likely travel, and road mortality would be anticipated. The commenter also recommends funding research into wildlife mortality caused by car and truck traffic.

Response: Please see response to comment 3-16.

Comment 3A-22 Summary of Comment: The commenter states that the project should adhere to available BirdSafe Guidelines, such as those prepared by American Bird Conservancy and New York and San Francisco. The commenter also recommends that fatality monitoring and compensatory mitigation be incorporated into any new building project.

Response: Please see response to comment 3-17.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-249 Responses to Comments on the Draft EIR Comment 3A-23 Summary of Comment: The commenter states that a fund should be established for long-term management of house cats in the project.

Response: Please see response to comment 3-18.

Comment 3A-24 Summary of Comment: The commenter states that the impacts of renewable energy generation should be mitigated by promotion of energy conservation and of distributed generation, and that all of the project’s homes and non-residential buildings should include solar panels. The commenter also recommends that fatality monitoring be implemented to establish whether the rooftop solar panels cause collision mortality.

Response: The proposed Project does not include proposed wind turbines or utility-scale PV panels. Please also see response to comment 3-17.

Comment 3A-25 Summary of Comment: The commenter states that compensatory mitigation should include funding contributions to wildlife rehabilitation facilities to cover the costs of injured animals caused by the project, including collisions with windows and automobiles, and by attacks by house cats.

Response: Please see response to comment 3-13, and 3-16 through 3-18.

Exhibit B
Comment 3B-1 Summary of Comment: The commenter introduces the letter and provides a summary of the WRTP Specific Plan. The commenter states that the Draft EIR fails to adequately evaluate the project’s air quality, health risk, and greenhouse gas impacts, resulting in the emissions and health risk impacts associated with construction and operation of the proposed project to be underestimated. The commenter recommends that the Draft EIR be updated to address these concerns.

Response: Specific responses to the topics addressed in this summary are provided through response to comments 3B-2 through 3B-12.

Comment 3B-2 Summary of Comment: The commenter states that the Draft EIR’s estimate of air pollutant emissions is inconsistent with information presented in the Draft EIR and underestimates emissions that would result from the Specific Plan. The commenter includes claims of inconsistency and lack of substantial evidence for emissions estimating methodology, as identified in further comments below.

Response: Please see response to comment 3-19.

Comment 3B-3 Summary of Comment: The commenter states that the Draft EIR’s air quality models use unsubstantiated reductions to land use sizes. Specifically, that in the project’s CalEEMod output files, found that the air model made reductions to land use sizes than what was proposed in the Draft EIR, without providing justification to the change.

Response: Please see response to comment 3-20.

Comment 3B-4 Summary of Comment: The commenter states that the Draft EIR’s air quality model made unsubstantiated reductions related to parking, specifically, that neither the Draft EIR nor the CalEEMod output files provided an estimate of the extent of future parking, so the project’s air quality impacts can’t be relied upon.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-250 City of Woodland Response: Please see response to comment 3-21.

Comment 3B-5 Summary of Comment: The commenter states that the modeling data does not include an adequate basis for changing the default percent paved values, and that it assumes that future hauling, vendor, and worker trips will only travel on paved surfaces, despite the project sitting on farmland. The commenter states that this is an important distinction to make for estimating the project’s fugitive dust emissions.

Response: Please see response to comment 3-22.

Comment 3B-6 Summary of Comment: The commenter states that the air quality model improperly assumes reductions to default values for energy usage.

Response: Please see response to comment 3-23.

Comment 3B-7 Summary of Comment: The commenter states that the Draft EIR’s air quality model improperly assumed that off-road construction equipment would meet Tier 4 Final standards.

Response: Please see response to comment 3-24.

Comment 3B-8 Summary of Comment: The commenter states that the Draft EIR fails to discuss all potentially feasible mitigation measures available to address the project’s significant air quality impacts resulting from its operation. The commenter references a section of the letter, “Feasible Mitigation Measures Available to Reduce Emissions,” and states that the Draft EIR should be revised including updated and accurate air modeling, as well as incorporating all feasible mitigation to reduce emissions to less-than-significant levels.

Response: Please see response to comments 3-6 through 3-8.

Comment 3B-9 Summary of Comment: The commenter states that the Draft EIR failed to disclose a significant air quality impact from construction-related NOx emissions.

Response: Please see response to comment 3-25.

Comment 3B-10 Summary of Comment: The commenter states that the Draft EIR fails to adequately evaluate health risks from diesel particulate matter emissions. The commenter requests that objective criteria be identified in the Draft EIR for any future projects requiring a health risk assessment, based on location relative to any existing or potential future residence and potential of toxic air contaminant emissions during construction or operation.

Response: Please see response to comment 3-26.

Comment 3B-11 Summary of Comment: The commenter claims that the Draft EIR’s reliance on the City’s Climate Action Plan to find that the Project’s GHG emissions will be less than significant is in error because the Project does not comply with a number of measures set forth in the Climate Action Plan. The commenter references inconsistencies or omissions between the WRTP Specific Plan and the City’s Climate Action Plan that are identified in Exhibit B, pages 12 through 19, appended to the comment letter, and requests that the Draft EIR be updated demonstrating the project’s consistency with the City’s CAP.

Response: Please see response to comment 3-27.

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-251 Responses to Comments on the Draft EIR Comment 3B-12 Summary of Comment: The commenter states that the Draft EIR fails to discuss all potentially feasible mitigation measures available to address the project’s significant air quality impacts resulting from its operation. The commenter provides a list of additional feasible mitigation measures identified as example measures to mitigate air quality and greenhouse gas impacts from operations of warehouse projects in the California Attorney General’s Warehouse Projects: Best Practices and Mitigation Measures to Comply with the California Environmental Quality Act, and asserts that the Draft EIR must be recirculated in order to evaluate, consider, and, where feasible, adopt these measures. The comment goes on to assert that all 19 example measures are feasible for future development within the Research and Technology Park of the Specific Plan Area and therefore should be adopted and made enforceable in order for the City to make a finding of overriding considerations.

Response: Please see response to comments 3-6 through 3-8.

Comment 3B-13 Summary of Comment: The commenter closes the letter and provides a disclaimer that they retain the right to revise or amend their report and review of the WRTP Specific Plan if additional information about the project becomes available.

Response: This comment does not raise any topics related to the veracity of the Draft EIR. The City is appreciative of SWAPE’s review.

Comment 3B-14 Summary of Comment: The commenter provides the detailed modeling outputs using CalEEMod Version 2016.3.2 that they prepared using their own inputs regarding percent paved roadways and mitigated equipment Tier emissions standards.

Response: Please see response to comments 3-20 through 3-22, 3-24, and 3-25.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-252 City of Woodland

2.2.4 COMMENT LETTER #4:

NATHAN BENEDICTO

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-253 Responses to Comments on the Draft EIR RESPONSE TO COMMENT LETTER 4
Comment 4-1 Summary of Comment: The commenter expresses their concern regarding the current and future capacity of schools within the Woodland Unified School District. The commenter claims that another elementary and middle school are needed to meet the community’s growing needs.

Response: With regard to the proposed WRTP Specific Plan and impacts related to school services, this concern is addressed in Section 3.12, Public Services and Recreation, of the Draft EIR. Table

3.1 of the WRTP Specific Plan identifies TK/K through 12 Public/Private School as a permitted use within the Medium Density Residential land use designation of the WRTP Specific Plan Area. The WRTP Specific Plan reserves up to a 12-acre portion of the medium density residential zone south of Parkland Avenue and east of Road B for a potential new elementary school site, should a school be needed, as determined by the Woodland Joint Unified School District (WJUSD) and the California Department of Education. See also, responses to comments 6-2 and 6-3. Also, in addition to the existing schools within WJUSD and the planning for a school site within the Specific Plan Area, WJUSD owns 20 acres in the Spring Lake Specific Plan Area and adjacent to Pioneer High School, which is currently identified as a potential site for a future middle school. Spring Lake Elementary School was also recently opened, recognizing the need for additional school services to support the current and planned development southeast of the area. Direct effects associated with the construction and operation of a new elementary school within the WRTP Specific Plan Area are addressed in specific resource area analyses, as appropriate, throughout the Draft EIR, including the indirect effects associated with transporting students. Chapter 2, Project Description, of the Draft EIR describes the inclusion of an option site for a school within the WRTP Specific Plan, and specific resource area section of Chapter 3, Environmental Impact Analysis, account for the potential for this school to be a part of the future land uses within the WRTP Specific Plan Area, as appropriate. For example, the transportation study used to inform the analysis in Section 3.13, Transportation and Circulation, applied modeling based on SACOG’s regional travel demand forecasting model and the anticipated land uses within the WRTP Specific Plan Land Use Plan, including those residential units that would generate regional and local trips including those to work, schools, and retail and commercial services, among others. This modeling was then also used to inform the air quality, greenhouse gas, and noise analysis of the Draft EIR. Should a school be constructed within the WRTP Specific Plan EIR, trip rates and distances associated with travel to this localserving school would be reduced compared to those required to travel to existing schools, further reducing potential impacts. In addition, Section 3.12, Public Services and Recreation, of the Draft EIR also evaluated the existing and projected future capacity and demand for schools within the Woodland Joint Unified School District jurisdiction, and Section 3.8, Hazards and Hazardous Materials, of the Draft EIR evaluated the potential for hazardous emissions and the handling of hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school, including the potential school within the WRTP Specific Plan Area. No additional CEQA review is required.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-254 City of Woodland

2.2.5 COMMENT LETTER #5:

JOHN CHEN

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-255 Responses to Comments on the Draft EIR RESPONSE TO COMMENT LETTER 5
Comment 5-1 Summary of Comment: The commenter requests and recommends for a physical buffer zone to be reserved between the WRTP Specific Plan Area and the community located to the east side in order to protect sensitive land uses such as residential and prevent incompatible land uses.

Response: The WRTP Specific Plan includes an extensive greenbelt system to provide both for a multimodal circulation system and open space. As shown in Exhibit 2-3 of the Draft EIR, and further detailed in the WRTP Specific Plan, the WRTP Specific Plan provides for a greenbelt along the western perimeter of Harry Lorenzo Avenue (County Road 101). In addition, to provide for separation between sensitive land uses, the City of Woodland General Plan 2035 identifies the following policies that are applicable to the WRTP Specific Plan: Policy 7.F.3.

Protect Sensitive Receptors, includes implementing applicable buffer distances recommended by the California Air Resources Board between sensitive land uses and sources of substantial pollutant concentrations. Also, Policy 7.F.4. Landscaping to Improve Air Quality includes promoting an increase of community-wide tree canopy and the use of plants and trees that are efficient pollutant absorbers. Also, the Land Use Plan Layout for the WRTP Specific Plan generally separates incompatible land uses and applies conditions to those that could have external effects, providing for residential land use designations in the eastern portion of the WRTP Specific Plan Area and non-residential land uses in the western and southern portions of the WRTP Specific Plan Area, away from existing residential land uses. No change to the WRTP Specific Plan is needed. No revision to the Draft EIR has been made or is necessary.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-256 City of Woodland

2.2.6 COMMENT LETTER #6:

BRIAN COWARD

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-278 City of Woodland RESPONSE TO COMMENT LETTER 6
Comment 6-1 Summary of Comment: The commenter introduces the letter and states that their main concern is the inclusion of schools in the land use and zoning maps of the WRTP Specific Plan.

Response: With regard to the proposed WRTP Specific Plan and impacts related to school services, this concern is addressed in Section 3.12, Public Services and Recreation, of the Draft EIR. Table

Comment 6-2 (and Attachment 6a to the Comment Letter) Summary of Comment: The commenter provides a summary of a petition they created in addition to comments and justifications to support why WJUSD needs more elementary schools. The petition, included in this Final EIR as Comment Letter 6a (above) includes signatures of community members in support of inclusion of a school in the land use and zoning maps for the WRTP, asks that the School Board and City formulate a financial plan for land and construction of a school to serve the WRTP Specific Plan Area and nearby Spring Land Specific Plan Area, provides comments from community members requesting a school, provides a “Planned School Sites” map for the WRTP and Spring Lake area, and provides independent calculations of student projections for the WRTP and Spring Lake areas at potential build out. The commenter explains the importance in which schools have in contributing to a healthy and vibrant community, and states that new schools are necessary to benefit the entire City.

Response: The petition has been reviewed in detail, including the planned school site map and student generation estimates for the Spring Lake Specific Plan and WRTP Specific Plan. As noted in the City’s General Plan, while the City does not control the location or design of schools, the City coordinates with WJUSD on school planning (General Plan, page PF 5-22). The City and WJUSD are coordinating on current and projected school service needs and are committed to ensuring adequate services are provided for all students in the community. Section 3.12.4 of the Draft EIR analyzes the proposed WRTP Specific Plan’s potential impacts to related school services. Table 3.12-2 has been updated (See Chapter 3, Errata, of this Final EIR) to reflect updated data from the WJUSD Annual Enrollment Projection Report supporting documentation regarding enrollment and capacity (DecisionInsight 2021). As explained in this section, student generation from anticipated development in the WRTP Specific Plan Area would be approximately 376 new elementary school students (grades K–6), 104 middle school students (grades 7–8), and 222 high school students (grades 9–12), each of which is below the remaining capacity at the schools surrounding the WRTP Specific Plan Area. In addition, based on growth

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-279 Responses to Comments on the Draft EIR projections developed for the WJUSD Annual Enrollment Projection Report, with an additional 2,800 residential units becoming occupied and generating growth in the number of students districtwide, Tafoya Elementary School, Douglass Middle School, and Pioneer High School all maintain capacity through 2030 (DecisionInsight 2021).

As acknowledged in Section 3.12.4 of the Draft EIR and accounted for by the City’s General Plan and Climate Action Plan EIR Impact 4.12-3 (pages 4.12-35 through 4.12-39) (City of Woodland 2016), future development consistent with the General Plan, based on the State’s classroom loading factors, would require new schools. The 2035 General Plan and Climate Action Plan EIR found this impact to be potentially significant. Funding for new school construction is provided through State and local revenue sources. Senate Bill 50 (Chapter 407, Statutes of 1998) governs the amount of fees that can be levied against new development.

Payment of fees authorized by the statute is deemed “full and complete mitigation.” The 2035 General Plan and Climate Action Plan EIR concluded that pursuant to State law the impact is considered less than significant after mitigation. As noted, in the event that additional students resulting from new residential development within the WRTP Specific Plan Area would exceed the elementary school capacity or an additional school is otherwise determined by the WJUSD and the California Department of Education to be necessary, the WRTP Specific Plan provides for a new school site within the Planning Area. The proposed development in the WRTP Specific Plan is consistent with that assumed for analysis in the 2035 General Plan and Climate Action Plan EIR, including increased students within the school district due to residential development, and planning for additional schools. Funding for new school construction, as provided through fees authorized by Senate Bill 50 and identified as mitigation under the 2035 General Plan and Climate Action Plan EIR would be applicable to development within the WRTP Specific Plan Area. Therefore, this impact was comprehensively considered and analyzed in the Draft EIR, and no changes are needed.

Comment 6-3 Summary of Comment: The commenter states that Exhibit 2-1 of the WRTP Specific Plan does not show zone designations for either a school or public/quasi-public land use. The commenter expresses their opinion that the 10-acre portion of medium-density residential land that is reserved under the WRTP Specific Plan for possible school use would be a conflicting use and not be consistent with the City’s General Plan 2035 housing mix requirements if this land is used for a school rather than residential use.

Response: Table 3.1 of the WRTP Specific Plan identifies transitional kindergarten and kindergarten (TK/K) through 12 Public/Private school uses as a permitted land use within the Medium Density Residential land use designation of the WRTP Specific Plan Area. As noted in the City’s General Plan, while the City does not control the location or design of schools, the City coordinates with WJUSD on school planning (General Plan, page PF 5-22). However, based on coordination with WJUSD, the WRTP Specific Plan reserves a location for a new school site, should a school be needed, as determined by WJUSD. See also, responses to comments 6-2 and 6-3.

Comment 6-4 Summary of Comment: The commenter expresses their opinion that the WJUSD and the School Board have displayed reticence towards potential development of new schools, but that the residents of Woodland want and need these additional resources.

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AECOM Woodland Research & Technology Park Specific Plan FEIR Responses to Comments on the Draft EIR 2-280 City of Woodland Response: This comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR, but please see the response to comment 6-2 with regard to the City’s planning efforts to support a school within the WRTP Specific Plan Area, should an additional school be determined by the WJUSD and the California Department of Education to be necessary.

Comment 6-5 Summary of Comment: The commenter states that the student-yield generation rates for the Woodland Joint Unified School District (Table 3.12-5) in the Draft EIR (page 3.12-16) do not account for students who reside in the Spring Lake community. The commenter also expresses his concern for the City’s capacity to provide local school availability so that students do not need to commute/travel outside their community for this purpose.

Response: Please see response to comments 6-1 through 6-3 and 6-6. In addition, it is noted on page 0-27 of the Draft EIR that the infrastructure provided for the WRTP Specific Plan is consistent with the anticipated growth under the 2035 General Plan. The commenter is correct that Table 3.12- 5 in the Draft EIR (page 3.12-16) only includes data pertaining to the anticipated student generation rate associated with the proposed WRTP Specific Plan. However, districtwide enrollment projections are evaluated by Woodland Joint Unified School District for planning purposes. The 2021 Annual Enrollment Projection Report for Woodland Joint Unified School District analyzed enrollment through 2030 with the addition of 2,800 residential units becoming occupied and generating growth in the number of students districtwide; this growth would account for growth within the WRTP Specific Plan Area, Spring Lake Specific Plan Area, and elsewhere throughout the City. Based on this report, even with this growth, of the schools closest to the WRTP Specific Plan Area, Tafoya Elementary School, Douglass Middle School, and Pioneer High School all maintain capacity through 2030 (DecisionInsight 2021). As discussed in response to comments 6-1 through 6-3, the WRTP Specific Plan also identifies TK/K through 12 Public/Private school uses as a permitted land use within the Medium Density Residential land use designation of the WRTP Specific Plan Area. Therefore, this impact was comprehensively considered and analyzed in the Draft EIR, and no changes are needed.

Comment 6-6 Summary of Comment: The commenter references the City’s affordable housing ordinance. The commenter also asserts that low-income families and residents not having sufficient access to local schools could cause an extra burden to low-income families.

Response: This comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR; the comment is noted. Please also see the response to comment 6-2 with regard to the planning efforts to provide for a new school within the WRTP Specific Plan Area, should it be determined by the WJUSD and California Department of Education to be needed. The identification of required school services is based on loading factors and actual and projected student generation. In addition, the City coordinates closely with WJUSD to implement City’s General Plan Policies 5.E.2, 6.B.2, 6.B.6, and 6.B.7, as listed below.  Policy 5.E.2: School Location and Site Design. Coordinate with the Woodland Joint Unified School District, private schools, and higher education institutions on site location and design to ensure that adequate educational facilities are available to meet the community’s needs,

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Woodland Research and Technology Park Specific Plan EIR AECOM City of Woodland 2-281 Responses to Comments on the Draft EIR are consistent with the General Plan and other City development regulations, and are integrated with neighborhoods.”
 Policy 6.B.2: Promote Active Transportation. Remove barriers and improve multimodal mobility throughout the city for all community members by supporting transit, pedestrian, and bicycle connections between residential neighborhoods and major destinations, including parks, civic facilities, school campuses, other educational institutions, employment centers, shopping destinations, parks and recreation areas.”
 Policy 6.B.6: Active Transportation to Schools. Improve the street and neighborhood conditions in the areas surrounding schools to support children and youth walking and bicycling to school. Continue to work with the Woodland Joint Unified School District and other agencies to implement a Safe Routes to School program and prioritize identified Safe Routes to School infrastructure improvements in transportation improvement plans.  Policy 6.B.7: Siting of New Schools. Work with Woodland Join Unified School District and private and charter schools to locate and design new school sites so they are easily and safely accessible to pedestrians and bicyclists and located and accessed away from major street intersections and major streets.

Comment 6-7 Summary of Comment: The commenter states that by developing more centralized schools within the neighborhoods of the City of Woodland, traffic congestion would be reduced, and road conditions would be preserved due to an increased accessibility for students to walk and ride their bikes to school. The commenter also asserts that without a new elementary school there would be about 900 elementary-age students from the buildout of the Spring Lake and WRTP Specific Plan Areas that would require a car/bus in order to get to school across town or in Davis.

Response: As noted on page 3.12-16 of the Draft EIR, depending on the timing of future development within the WRTP Specific Plan Area, future students could potentially be bused or driven to schools within the WJUSD boundaries, resulting in indirect impacts related to transportation, such as air pollutant emissions, greenhouse gas emissions, and transportation noise. While the City actively coordinates with the WJUSD regarding consideration of the need for new school facilities, as noted in Response to Comment 6-6, these potential impacts were considered in the 2035 General Plan and Climate Action Plan EIR analysis for the relevant resource areas, and are addressed as part of the impact analyses in each of the environmental topic-specific sections of the WRTP Specific Plan Draft EIR No revision to the Draft EIR has been made or is necessary.

Comment 6-8 Summary of Comment: The commenter expresses their excitement for the future development of greenbelts within their community and the beneficial impacts they will have on the quality of life for residents, such as promoting active lifestyles and providing a safe means for children to get to school.

Response: This comment does not pertain to the adequacy or completeness of the environmental analysis contained in the Draft EIR. The support for the Specific Plan’s proposed greenbelts is noted.

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Woodland City CouncilSeptember 5, 2023

Woodland City Council
September 5, 2023