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HomeMy WebLinkAboutStaff Report 5.C 08/03/2015DATE: August 3, 2015 Agenda Item #5.0 TO: Honorable Mayor and Members of the City Council through City Manager FROM: Olivia Ervin, Environmental Planner Heather Hines, Planning Manager SUBJECT: Resolutions Certifying the Final Environmental Impact Report, Approving the Mitigation Monitoring and Reporting Program, and Adopting Statements of Overriding Considerations from Cumulative Impacts for the Rainier Crosstown Connector Project. RECOMMENDATION It is recommended that the City Council conduct the required public hearing on the Final Environmental Impact Report (FEIR) for the Rainier Cross -Town Connector and adopt the attached resolutions: • Resolution certifying the FEIR and approving the Mitigation Monitoring and Reporting Program (MMRP) for the Rainier Cross -Town Connector Project; and • Resolution adopting the statements of overriding considerations for cumulative impacts. BACKGROUND The environmental review process initiated with the release of the Notice of Preparation (NOP) on August 11, 2011. In July 2014, the DEIR was released for public review and was considered before the Planning Commission and City Council during public hearings in August and September 2014, respectively. On May 28, 2015, the FEIR was released for public review and was considered by the Planning Commission at a noticed public hearing on June 23, 2015. DISCUSSION The following narrative summarizes the Planning Commission's review and discussion of the FEIR on June 23, 2015. A detailed analysis of the consistency of the proposed project with applicable planning documents, an overview of the FEIR, and responses to comments raised during the DEIR review period is provided in the Staff Report prepared for the June 23, 2015 Planning Commission (Attachment 3). Planning Commission Hearing on the FEIR (June 23, 2015) Per the City's California Environmental Quality Act (CEQA) Guidelines, the Planning Commission requested that the FEIR return to the Commission for consideration. On June 23, 2015, the FEIR was brought before the Commission for review and input. The Commission's discussion focused on responses to comments set forth in the FEIR, per CEQA Guidelines Section 15089(b). The Planning Commission heard a staff presentation, accepted public comment, requested clarification on several items (further described below) and provided comments. Three individuals offered public comment at the Planning Commission meeting (Dave Libchitz, Janis Cader- Thompson, and David Keller), all expressing opposition to the Project for the following reasons: • The FEIR fails to address comments raised during the public review process • Responses to comments were incomplete or inadequate • Funding is not available, only way to fund Rainier is to build out in the floodplain • Impacts were not properly identified • Proof of traffic relief is not apparent • Lack of a replanting plan for Oak trees • The project does not implement the River Enhancement Plan • The Project fails to provide access to the River • The Project fails to protect the River • The Project fails to provide access to multi -modal network • The attachment to David Keller's comment letter was omitted A motion to recommend that the Council certify the EIR and approve the Mitigation Monitoring and Reporting Program failed with a tie vote, (3 -3, Barrett absent). Due to the tie vote and resulting lack of action by the Planning Commission, staff has presented both sides of the Commission vote for the Council to consider as part of their deliberation. The three commissioners supporting the motion noted the following reasons: The responses in the FEIR were adequate The FEIR was understandable and disclosed potential impacts The Project achieved identified objectives Those Commissioners in support of the motion found that responses to comments provided in the FEIR and the record were satisfactory. They concluded that the Project's objective to improve the overall circulation network is fulfilled as congestion relief is realized. This conclusion was in part based on the data in the EIR showing that more intersections are improved (increase in LOS or decrease in delay) relative to intersections that degrade. Commissioners that supported the motion noted that data and information was set forth in a manner that was understandable and achieved the identified project objectives. Additionally, those in support found that the EIR met the intent of CEQA by fully disclosing potential impacts, considering a range of possible alternatives and requiring mitigation measures that avoid, reduce or offset impacts. The lack of funding for the project at this time was not thought to be a reason to reject the EIR. The three commissioners that voted against the motion noted the following reasons: • The responses in the FEIR were inadequate • The EIR does not identify all impacts • The EIR does not demonstrate sufficient traffic relief • The EIR does not address induced traffic from a new roadway • The Project fails to provide sufficient multi -modal connectivity • The Project does not achieve objectives • The FEIR fails to address induced growth in an area prone to flooding Those opposed to the motion argued that the Project failed to achieve the identified objectives, foremost by not providing traffic congestion relief. Commissioners opposed to the motion stated that based on the data presented in the EIR, the project does not demonstrate that traffic congestion is alleviated; rather it shows that the location of traffic congestion shifts. It was also noted that the increased traffic from induced demand generated by additional roadway capacity was not evident in the EIR. These commissioners stated that the objective to relieve congestion is not accomplished in the EIR analysis. Specifically, the LOS and delay improvements as a result of the Project do not constitute a relief program. For example, the delay time along Washington Street improves by one minute, which is not adequate relief. Commissioners opposed to the motion noted that separating the interchange element resulted in reduced traffic congestion relief. Another comment from the Commissioners opposed to the motion noted that the objective to "Not preclude future connection from adjacent parcels along the roadway" is by default growth inducing and the EIR does not analyze those impacts. Additionally, those parcels that would be accessible via a new future connection to Rainier are all located within the floodplain, which exacerbates the risks and losses associated with a functioning river system. Commissioners acknowledged that the City's General Plan designates those parcels for residential and commercial development, and suggested that development in that location is in conflict with other objectives of the General Plan. A further concern expressed was the apparent lack of connectivity to alternative modes of transportation. It was acknowledged that Rainier could potentially provide an important piece of the multi -modal network, but that connections to existing and future paths would be needed. The Citywide issue of congestion requires a holistic approach including improving safe routes to schools, providing pedestrian access and developing the multi -modal paths identified in the City's Bike and Pedestrian Plan. It was stated that Rainier could be an important opportunity to realize these multi -modal connections, but currently falls short. There was concern expressed that this was the only time that the Commission would be reviewing the roadway project. Additionally, the Commission formally requested that draft statements of overriding consideration be presented to the Commission for comment prior to going to the Council on future projects. 3 The lack of consensus on the adequacy of the EIR resulted in a failed motion (3 -3). No action was taken by the Planning Commission. As such there is no recommendation from the Planning Commission to the City Council to proceed with certification and adoption of the EIR and MMRP for the Rainier Cross -Town Connector stands. Staff Response The attached Staff Report prepared for the June 23, 2015 Planning Commission hearing provides a summary of the responses provided to many of the overlapping comments received on the EIR (Attachment X). Additionally, the Final EIR provides both Master Responses and individual responses to each comment raised. At the public hearing both city staff and the EIR consulting traffic engineer responded orally to questions and comments raised. The following provides a summary of the additional concerns that were raised at the June 23, 2015 Planning Commission hearing with staff response in italics: Induce Growth: It was stated that the Rainier Cross -Town Connector would induce growth in currently undeveloped portions of the City that are currently inaccessible. As described in response to comment 3 -22 of the FEIR (page 2.41), the project is considered growth accommodating since the new roadway would provide future opportunities for connection and access to parcels that are currently landlocked. The General Plan already considers the buildout potential of these parcels and Rainier would not induce growth beyond what has previously been identified and considered. Traffic Relief: It was stated that the Project does not provide sufficient traffic relief. As described in Master Responses 3, S and 6, the Project would increase the roadway capacity of the City by providing an additional east /west connector. Linder the opening year condition (2020) the project would correct 3 LOS deficient intersections (Table B in the FEIR, page 2 -10) and tinder the cumulative condition, six intersections would improve from deficient LOS to acceptable LOS (Table C in the FEIR, page 2 -13). As traffic patterns would shift, the project would result in degraded LOS at one new intersection under opening year and cumulative conditions. Multi - Modal: It was stated that the Project misses an opportunity to provide interconnectivity and enhance the City's multi -modal network. The Project as currently designed is consistent with the City's General Plan and the City's Pedestrian and Bicycle Plan in that it would introduce both sidewalks and striped bicycle lanes on Rainier, which would provide for an important East -West connection for these alternative modes of travel. Response 6 -29 of the FEIR (page 2 -73) further describes that the design of the bridge allows for the future development of a trail along the river as well as a Gateway planting scheme as depicted in the River Enhancement Plan. Omitted Attachment: It was stated that the attachment to the comment letter submitted by David Keller was omitted from the record. 4 Mr. Keller submitted a comment letter along with 3 attachments at the City Council hearing on the DEIR on September 8, 2014. The letter is included as comment letter 6 in the FEIR (beginning on Page 2 -56). The attachments provided as part of the letter are considered reference documents, are included as part of the record, but were not included in the FEIR. The attachments consist of the following: • A Letter from the Fish and Wildlife Service to the City of Petaluma Planning Division regarding comments on the Draft Environmental Impact Report on Rainier Avenue Extension and Freeway Interchange (dated September 14, 1993); • A Letter from the Fish and Wildlife Service to the Army Corps of Engineers regarding the Petaluma Factory Outlet Village Project (dated August 25, 1993); and • An article from the Argus Courier, "Rainier Spurs Land Boom: Developers buy up acreage around crosstown connector" (dated May 31, 1994) The comments provided by Mr. Keller, along with any references to the attached documents, were considered and responded to as part of the FEIR (see page 2 -69 through 2 -76). The attachments from the Fish and Wildlife Service are in response to two past projects that occurred over a decade ago. Translating comments from 1993 letters on different projects to the current EIR is neither appropriate nor intended by the agency. It is important to note that the Fish and Wildlife Service was notified as part of the public review process for the current EIR and to date no comment letter has been received. Also relevant is that consultation with the Fish and Wildlife Service may be required to occur (depending on the final design) as part of the permitting process for Rainier (page 3 -21 of the DEIR). The concerns raised in Mr. Keller's comment letter relate to the extensive biological resources that are located within the Petaluma River corridor. The EIR for the subject Rainier Cross -Tovvn Connector includes an assessment of resources, full disclosure of potential impacts, and sets forth a number of mitigation measures in an effort to avoid, reduce or offset those impacts. The comment letter provided by Mr. Keller is included in the FEIR which references the documents that were attached and a good faith effort has been made in responding to all comments raised in accordance with CEQA. FINANCIAL IMPACTS Although state funding for construction of the project is incomplete at this time, completion of the EIR allows Caltrans to conduct the necessary undercarriage improvements (raising the profile at the Highway 101 undercrossing); thereby permitting the project to move forward at the time that funding is secured. 5 ATTACHMENTS Resolution certifying of the Final Environmental Impact Report 2: Resolution making Finding of Fact and adopting the Mitigation Monitoring and Reporting Program and Statement of Overriding Considerations 3: Staff Report prepared for the June 23, 2015 Planning Commission Meeting 4: Comments on the FEIR ® Items listed below are large in volume and are not attached to this report, but may be viewed in the City Clerk's office. FEIR: Previously provided, hand delivered on May 28, 2015 DEIR: Previously provided on July 24, 2014 ATTACHMENT 1 RESOLUTION NO. RESOLUTION OF THE CITY OF PETALUMA CITY COUNCIL CERTIFYING AN ENVIRONMENTAL IMPACT REPORT FOR THE RAINIER CROSS -TOWN CONNECTOR PROJECT, PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT WHEREAS, the City of Petaluma Public Works and Utilities Department ( "Applicant') proposes a 0.65 mile, four lane arterial roadway featuring bridge, median, pedestrian, bicycle facilities and new signalized intersection. The Rainier Cross -Town Connector will connect North McDowell Boulevard on the eastern side of Highway 101 to Petaluma Boulevard North on the western side of the City ( "Project'); and WHEREAS, the Project boundaries constitute roadway and appurtenant improvements that would extend at grade from the signalized North McDowell Boulevard intersection, cross beneath Highway 101 under an elevated portion of the Freeway that will be constructed as part of the Marin- Sonoma Narrows HOV Project, would cross over the Sonoma Marin Area Rail Transit (SMART) Corridor and Petaluma River via a bridge, and return to grade proximate to Petaluma Boulevard North where it will terminate at a signalized T- intersection; and WHEREAS, the Notice of Preparation of the Draft Environmental Impact Report for the Project was mailed to all responsible and affected agencies on August 11, 2011, pursuant to Public Resources Code Section 21080.4 and California Environmental Quality Act ( "CEQA ") Guidelines Section 15082; and WHEREAS, a Draft Environmental Impact Report ( "Draft EIR ") was prepared for the Plan in accordance with Public Resources Code Section 21000 et seq. and CEQA Guidelines Section 15000 et seq., and circulated for public review between July 24, 2014 and September 8, 2014, with a notice inviting comments on the Draft EIR given in compliance with CEQA Guidelines Section 15087; and WHEREAS, Draft EIR relies on the EIR for the City of Petaluma General Plan 2025, certified by City Council Resolution No. 2008 -058 N.C.S on April 7, 2008, for information relating to certain cumulative impacts, as identified in the Draft EIR; and WHEREAS, the City has committed to implementing the mitigation measures contained in the Implementation Plan and Mitigation Monitoring and Reporting Program adopted by the City as Exhibit B to Resolution No. 2008 -084 N.C.S., Resolution of the City Council of the City of Petaluma Making Findings of Fact, Adopting a Statement of Overriding Considerations, and Adopting an Implementation and Mitigation Monitoring and Reporting Program in support of the General Plan 2025, pursuant to CEQA; and WHEREAS, the City distributed copies of the Draft EIR in conformance with CEQA to the public agencies which have jurisdiction by law with respect to the project and to other interested persons and agencies and sought the comments of such persons and agencies; and, WHEREAS, the Planning Commission held a public meeting and hearing on August 12, 2014 to consider the Draft EIR; and WHEREAS, the City Council held a public meeting and hearing on September 8, 2014 to consider the Draft EIR; and 1 -1 WHEREAS, written and oral comments to the Draft EIR have been received and responses to those comments have been prepared in the form of a Final Environmental Impact Report for the Project ( "Final EIR "); and WHEREAS, on June 23, 2015, the Planning Commission considered the Final EIR and accepted public testimony; and WHEREAS, the motion to recommend that the City Council certify the EIR and approve the Mitigation Monitoring and Reporting Program failed with a tie vote of Commissioners present at the June 23, 2015 meeting (3 -3); and WHEREAS, the City Council held a noticed public meeting on August 3, 2015, at which time it considered the Final EIR and accepted public testimony; and WHEREAS, the Project does not have the potential to have a significant adverse impact on wildlife resources as defined in the State Fish and Game Code, either individually or cumulatively, though it is not exempt from Fish and Game filing fees; and WHEREAS, the Project is not located on a site listed on any Hazardous Waste Site List compiled by the State pursuant to Section 65962.5 of the California Government Code; and WHEREAS, the EIR identified several potentially significant impacts that will be reduced to a less than significant level with specified mitigation measures, and pursuant to CEQA Guidelines Section 15091(d), a Mitigation Monitoring and Reporting Program has been prepared and set forth with the Final EIR to ensure that all mitigation measures which serve to reduce environmental impacts of the Project are fully implemented; and WHEREAS, it is recognized that the project will contribute to significant and unavoidable cumulative impacts identified in the City's General Plan EIR including a) City -wide traffic -noise impact; b) greenhouse gas emissions; and c) deficient level of service (LOS) at the Rainier Avenue/North McDowell Boulevard intersection; and NOW THEREFORE, BE IT RESOLVED that the City Council hereby certifies the Final Environmental Impact Report and finds as follows: 1. The Final Environmental Impact Report for the Project has been completed in compliance with CEQA, the CEQA Guidelines, and the City of Petaluma Environmental Review Guidelines; 2. The Final Environmental Impact Report was presented to the City Council which reviewed and considered it prior to making a decision on the Project; and 3. The Final Environmental Impact Report reflects the City's independent judgment and analysis of the potential for environment impacts of the Project. 1 -2 ATTACHMENT 2 RESOLUTION NO. RESOLUTION OF THE CITY OF PETALUMA CITY COUNCIL MAKING FINDINGS OF FACT AND ADOPTING A MITIGATION MONITORING AND REPORTING PROGRAM AND STATEMENT OF OVERRIDING CONSIDERATIONS FOR THE RAINIER CROSS -TOWN CONNECTOR PROJECT, PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT WHEREAS, The City of Petaluma Public Works and Utilities Department ( "Applicant ") proposes a 0.65 mile, four lane arterial roadway featuring bridge, median, pedestrian, bicycle facilities and new signalized intersection. The Rainier Cross -Town Connector will connect North McDowell Boulevard on the eastern side of Highway 101 to Petaluma Boulevard North on the western side of the City ( "Project "); and WHEREAS, the Project boundaries constitute roadway and appurtenant improvements that would extend at grade from the signalized North McDowell Boulevard intersection, cross beneath Highway 101 under an elevated portion of the Freeway that will be constructed as part of the Marin- Sonoma Narrows HOV Project, would cross over the Sonoma Marin Area Rail Transit (SMART) Corridor and Petaluma River via a bridge, and return to grade proximate to Petaluma Boulevard North where it terminates at a signalized T- intersection; and WHEREAS, the Notice of Preparation of the Draft Environmental Impact Report for the Project was mailed to all responsible and affected agencies on August 11, 2011, pursuant to Public Resources Code Section 21080.4 and California Environmental Quality Act ( "CEQA ") Guidelines Section 15082; and WHEREAS, a Draft Environmental Impact Report ( "Draft EIR ") was prepared for the Plan in accordance with Public Resources Code Section 21000 et seq. and CEQA Guidelines Section 15000 et seq., and circulated for public review between July 24, 2014 and Sept. 8, 2014, with a notice inviting comments on the Draft EIR given in compliance with CEQA Guidelines Section 15087; and WHEREAS, Draft EIR relies on the EIR for the City of Petaluma General Plan 2025, certified by City Council Resolution No. 2008 -058 N.C.S on April 7, 2008, for information relating to certain cumulative impacts, as identified in the Draft EIR; and WHEREAS, the City has committed to implementing the mitigation measures contained in the Implementation Plan and Mitigation Monitoring and Reporting Program adopted by the City as Exhibit B to Resolution No. 2008 -084 N.C.S., Resolution of the City Council of the City of Petaluma Making Findings of Fact, Adopting a Statement of Overriding Considerations, and Adopting an Implementation and Mitigation Monitoring and Reporting Program in support of the General Plan 2025, pursuant to CEQA; and WHEREAS, the City distributed copies of the Draft EIR in conformance with CEQA to the public agencies which have jurisdiction by law with respect to the project and to other interested persons and agencies and sought the comments of such persons and agencies; and, WHEREAS, the Planning Commission held a public meeting and hearing on August 12, 2014 to consider the Draft EIR; and 2 -1 WHEREAS, the City Council held a public meeting and hearing on September 8, 2014 to consider the Draft EIR; and WHEREAS, written and oral comments to the Draft EIR have been received and responses to those comments have been prepared in the form of a Final Environmental Impact Report for the Project ( "Final EIR "); and WHEREAS, on June 23, 2015, the Planning Commission considered the Final EIR and accepted public testimony; and WHEREAS, a motion to recommend that the City Council certify the EIR and approve the Mitigation Monitoring and Reporting Program failed with a tie vote of Commissioners (3 -3) present at the June 23, 2015 meeting; and WHEREAS, the Project does not have the potential to have a significant adverse impact on wildlife resources as defined in the State Fish and Game Code, either individually or cumulatively, though it is not exempt from Fish and Game filing fees; and WHEREAS, the Project is not located on a site listed on any Hazardous Waste Site List compiled by the State pursuant to Section 65962.5 of the California Government Code; and WHEREAS, the EIR identified several potentially significant impacts that will be reduced to a less than significant level with specified mitigation measures, and pursuant to CEQA Guidelines Section 15091(d), a Mitigation Monitoring and Reporting Program has been prepared and set forth with the Final EIR to ensure that all mitigation measures which serve to reduce environmental impacts of the Project are fully implemented; and WHEREAS, it is recognized that the project will contribute to significant and unavoidable cumulative impacts identified in the City's General Plan EIR including a) City -wide traffic -noise impact; b) greenhouse gas emissions; and c) deficient level of service (LOS) at the Rainier Avenue/North McDowell Boulevard intersection; and WHEREAS, Public Resources Code Section 21081(b) requires that the City Council find that specific economic, legal, social, technological or other consideration outweigh any significant environmental effects of the Project which cannot be fully mitigated; and WHEREAS, a Statement of Overriding Considerations consisting of the City's finding and determination regarding the Project's significant and unavoidable effects is contained in Exhibit C, which is incorporated herein by reference; and WHEREAS, pursuant to CEQA, a mitigation monitoring and Reporting Program has been prepared, as set forth in the FEIR, which is incorporated herein by reference, to ensure that all mitigation measures relied on in the findings are fully implemented; and WHEREAS, some mitigation measures identified in Exhibit A may require action by, or cooperation from, other agencies. NOW, THEREFORE, BE IT RESOLVED: 1. The above recitals are true and correct, incorporated herein by reference and adopted as findings of the City Council. 2 -2 2. The City Council certifies the Environmental Impact Report as an adequate description of the impacts of the Project in compliance with CEQA, the State CEQA Guidelines, and the City of Petaluma Environmental Guidelines. 3. Based on substantial evidence in the record, the City Council adopts the findings regarding potential significant impacts of the Project and mitigations, as set forth in Exhibit A, attached hereto and incorporated by reference. 4. The City Council adopts the Mitigation Monitoring Program set forth within the Final EIR. 5. Based on substantial evidence in the record, the City Council adopts the findings regarding alternatives to the Project, as set forth in Exhibit B, attached hereto and incorporated by reference. 6. Based on substantial evidence in the record, the City Council adopts the findings set forth in the Statement of Overriding Considerations regarding significant unavoidable impacts in considering the cumulative impact of the Project, attached hereto as Exhibit C, and incorporated by reference. 7. The custodian of the documents and other materials which constitute the record of proceedings to date for the Project is the City of Petaluma, Planning Division, Petaluma City Hall, 11 English Street, Petaluma, CA 94952. 8. This resolution shall take effect immediately upon its adoption. 2 -3 EXHIBIT A FINDINGS CONCERNING SIGNIFICANT IMPACTS AND MITIGATION MEASURES Pursuant to Public Resources Code section 21081 and CEQA Guidelines section 15091, the City Council hereby makes the following findings with respect to the potential for significant environmental impacts of the Rainier Crosstown Connector Project ( "Project ") and methods for mitigating those impacts. For the purpose of these findings, the term EIR means the Draft and Final EIR documents collectively, unless specified otherwise. These findings do not attempt to describe the full analysis of each environment impact contained in the EIR. Instead the findings provide a summary description of each impact and identify the applicable mitigation measures set forth in the EIR and adopted by the City, and state findings on the significance of each impact after imposition of the adopted mitigation measures. A full explanation of these environmental findings and conclusions is in the EIR, and these findings hereby incorporate by reference the discussion and analysis in those documents supporting the EIR's determinations regarding mitigation measures and the Project's impacts and mitigation measures designed to address those impacts. The facts supporting these findings are found in the record as a whole for the project. In making these findings, the City ratifies, adopts, and incorporates into these findings the analysis and explanation in the EIR, and ratifies, adopts, and incorporates into these findings the determination and conclusions of the EIR relating to environmental impacts and mitigation measures, except to the extent that any such determinations and conclusions are specifically and expressly modified by these findings. Many of the impacts and mitigation measures in the following findings are summarized rather then set forth in full. The text of the EIR should be consulted for a complete description of the impacts and mitigations. AIR QUALITY Impact AQ -8 Project construction would expose sensitive receptors to substantial pollutant concentrations resulting in cancer and noncancer risks. This is considered a potentially significant impact. AQ /GHG -8: Reduce emissions produced by all diesel fueled off -road construction equipment by at least 8 percent relative to Tier 2 engines. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: With mitigation, the impact on the residents can be reduced to 9.8 in one million, which is less than the BAAQMD's significance threshold of 10 in one million. Therefore, the impact on sensitive receptors would be less than significant after mitigation. 2 -4 BIOLOGICAL RESOURCES Impact 11I0-3: The project would have substantial adverse affect on riparian habitat or other sensitive natural community identified in local or regional plans, policies, regulations, or by the California Department of Fish and Wildlife (CDFW) or the U.S. Fish and Wildlife Service (U.S. FWS). 13I0-1: Reduce construction related impacts by minimizing the area of disturbance, limiting construction activities to the dry season when proximate to the river, locating equipment in designated staging areas, protecting topsoil, covering stockpiled materials, restoring disturbed areas, revegetating to achieve pre- construction coverage, and removing all construction equipment from the site. 13I0-2: Minimize potential discharge of sediment by use of silt fences, erosion control blankets, sediment - control devices, diverting runoff, covering materials stored onsite, preventing discharge of construction materials, implementing BMPs, providing pallets for containment areas, and training onsite personnel in spill prevention and spill containments. BIO -3: Mitigate impacts to riparian habitat at a 1:1 ratio or as deemed appropriate by regulatory agencies. BI0-7: Prepare an arborist report prior to construction activities and adhere to the recommendations therein and in accordance with the Petaluma Tree Preservation Ordinance. 11I0-8: The City of Petaluma shall develop a replanting plan such that at the end of a five -year monitoring period the plan shall be considered successful if 75 percent of the tree plantings survive. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Mitigation measures will limit areas of disturbance and timing of disturbance to avoid or reduce potential impacts that could adversely affect a sensitive natural community. In the event that minor and temporary disturbance occurs, any disturbed areas will be restored to preconstruction conditions. Where on -site mitigation is deemed infeasible, impacts to riparian habitat will be remediated by offsite measures proximate to the project site as practicable. The mitigation to be imposed also outlines best practices for handling and containing materials to prevent accidental environmental degradation. With the introduction of mitigation measures listed above, sensitive habitat will be left undisturbed or restored as necessary such that the long term health and vitality of on -site and surrounding sensitive habitat will be substantially retained. Impact 13I0-4: The project would adversely affect federally protected wetlands through direct removal, filling, hydrological interruption or other means. 11I0-1 (see above) 13I0-2 (see above) 2 -5 BIO -3 (see above) Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Implementation of mitigation measures will protect wetland habitat or offset any losses to wetland habitat through onsite creation of wetland and /or the procurement of mitigation bank credits that benefit the Petaluma River watershed. Therefore, after applying these measures, the impact would be less than significant. Impact BIO -5: The project would have a direct or indirect adverse effect on species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations by the CDFW or the U.S. FWS. Amphibians BIO -1 (see above) BIO -2 (see above) BIO -3 (see above) BIO -4: A qualified U.S. FWS - approved biologist shall conduct preconstruction surveys of all ground disturbance areas within suitable habitat to determine the presence of California Red Legged Frogs and Western Pond Turtle. Construction activities adjacent to the Petaluma River shall be conducted during the dry season and shall be supervised by an approved biologist as appropriate. Prior to initiating work, all construction personnel shall undergo training (conducted by a qualified biologist) for Endangered Species Act provisions, best practices, and species /habitat recognition. During construction, the area of activity shall be delineated and limited to the area within a temporary high visibility orange fence, flagging, or other barriers. All trash shall be kept in closed containers and removed at the close of each day and any holes or trenches deeper than one foot shall be covered to prevent entrapment. Fish BIO -1 (see above) BIO -2 (see above) BIO -5: To avoid and minimize impact and potential disturbance to Central California Coast Steelhead, Green Sturgeon, and Sacramento Splittail, all construction activities shall be conducted during the dry season. Prior to construction activities, a qualified biologist shall train construction personnel in salmonid and habitat identification, best practices, and review of project site boundaries. Should construction of cofferdams or dewatering occur during construction activities, a fish rescue effort shall be conducted, as necessary. 2 -6 Birds 13I0-6: If construction is scheduled during the nesting season of migratory birds then pre - construction survey shall be conducted by a qualified biologist to identify the presence of any nesting birds. In the event that an active nest is identified, a qualified biologist, in consultation with the CDFW, shall determine a buffer zone and clearly delineate the buffer area. If an active nest is found after the pre- construction survey and once construction has begun, all construction activities will cease until the nest has been evaluated by the qualified biologist and appropriately protected. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Mitigation measures would limit areas and times of disturbance, require pre- construction surveys and nesting bird surveys. Further, mitigation requires a training component that will ensure construction workers are well aware of sensitive species and habitats. Through minimizing the area of disturbance and limiting construction activities to a period least likely to impact sensitive species (dry season and non - nesting season) and educating construction workers, potential impacts will be less than significant. Impact 13I0-6 The project would conflict with local policies or ordinances intended to protect biological resources, such as a tree preservation policy. 13I0-7 Prior to construction, a qualified arborist shall determine which trees need to be removed and whether they are protected. For protected trees to be removed, they shall be replaced at a trunk diameter ratio of 1:1 for healthy trees, 2:1 for marginal trees, and those in poor health do not require replacement. Trees shall be replaced onsite, as feasible, otherwise suitable off -site location shall be identified. 13I0-8 The City shall prepare a replanting plan that identifies where, how many and what type of trees shall be replanted. The replanting site shall be monitored yearly and an annual report sent to CDFW and USACE. At the end of the five -year monitoring period, the site shall be considered successful if at least 75 percent of the tree plantings survive. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Mitigation measures limit disturbance and require replacement for protected trees with potential to be affected by project activities. Further, the health of all trees that need to be removed as a result of the project will be identified and replaced on an appropriate ratio, which will avoid a net reduction to Petaluma's tree coverage. Mitigation measures are consistent with the requirements of Chapter 17 Tree Preservation of the Implementing Zoning Ordinance and promote the health and longevity of Petaluma's trees. Therefore, with mitigation, impacts to protected trees will be less than significant. 2 -7 CULTURAL RESOURCES Impact CULT -2: The project would result in substantial adverse changes to a historic resource. CULT -1: The City shall implement an archeological data recovery plan (ADRP) prior to commencement of construction. The ADRP shall identify the scientific /historical research questions that are applicable to the expected resource, the data classes the resource is expected to possess, and how the expected data classes would address the applicable research questions, amongst other things. Further, no destructive data recovery methods shall be applied where non- destructive methods are practicable. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: The Mitigation measure requiring an ADRP would ensure that interpretable information regarding subsistence patterns, trade, and responses to environmental change that have yet to be extensively investigated in the Sonoma Region and potentially existing at SON -225/H is recovered and interpreted to the extent practicable by a professionally qualified archeologist. Proper recovery and treatment of previously undisturbed historic /archeological resources would ensure impacts to historic resources are less than significant. Impact CULT -3: The project could adversely affect expected prehistoric site deposits. CULT -2: The City of Petaluma shall retain the services of a qualified archeologist who has expertise in California Prehistory to monitor ground disturbing activity within 200 feet of the top of the bank on either side of the Petaluma River. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Implementation of mitigation ensures that currently unknown archeological resources will not be inadvertently disturbed or destroyed as a result of construction activities. The qualified archeologist will be given the authority to stop work or redirect crews if an intact archeological deposit is encountered and until such time that it has been thoroughly evaluated and recommendations on how to proceed have been made. If it is determined by the archeologist and the City that identified deposits may have significance, then an ADRP shall be implemented. The monitoring, evaluation, and treatment measures prescribed by CULT -2 ensure that potential impacts to prehistoric site deposits are less than significant. Impact CULT -4: The project could result in potentially significant impacts to unknown archeological resources, including human remains. 2 -8 CULT -3: In the event of accidental discovery of cultural resources, work would be suspended at that location and City of Petaluma staff would be contacted. A qualified cultural resource specialist would be retained and would perform any necessary investigations to determine the significance of the find and provide recommendations on how to proceed. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Implementation of mitigation ensures that if unknown archeological resources (including human remains) are encountered, all work would suspend until such a time that a qualified cultural resource specialist could perform investigation and recordation or protection measures as deemed appropriate by the City of Petaluma. Should human remains be encountered, mitigation measures require that they be identified, treated, and managed in accordance with Sections 5097.97 and 5097.98 of the California Public Resources Code and Section 7050.5 of the California Health and Safety Code. The mitigation measures imposed on the project limit the potential to harm or otherwise mishandle potentially significant archeological resources such that impacts will be less than significant. Impact CULT -5: The project could adversely affect unidentified paleontological resources. CULT -4: In the event of paleontological discoveries, the City of Petaluma shall notify a qualified paleontologist who shall document the discovery as needed, evaluate the potential resource, and assess the significance of the find under the criteria set forth in the guidelines adopted by the Society of Vertebrate Paleontology CEQA Guidelines Section 15064.5. In the event of an unanticipated discovery of a breas, true, and /or trace fossil during construction, excavations within 100 feet of the find shall be temporarily halted or diverted until the discovery is examined by a qualified paleontologist and a determination of proper procedures is made. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Mitigation measures would require that a qualified paleontologist document, evaluate, and assess any potential paleontological resources encountered during construction. The measure further requires that appropriate procedures are determined in consultation with appropriate agencies prior to re- commencement of earthmoving activities and that an excavation plan is developed as necessary. With proper evaluation and treatment overseen by a professional paleontologist, impacts will be less than significant. 2 -9 GEOLOGY Impact GEO -5: The project could expose people or structures to substantial adverse effects related to seismic hazards. GEO -1: The City of Petaluma, or its technical consultant, shall prepare a geotechnical investigation and report prior to completing project design. The report shall be prepared in accordance with Section 17.31.180 of the City's Grading and Erosion Control Ordinance and shall include an adequate description of the geology of the site, and conclusions and recommendations regarding the effect of geologic conditions on the proposed project. The City shall implement all site - specific mitigation measures recommended in the geotechnical investigation prior to or during construction, as appropriate. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Implementation of mitigation measures require that the project be designed to minimize exposure of the structure to seismic related hazards by ensuring that the project limits public and structural exposure to potential substantial adverse effects resulting from ground shaking, ground failure, and /or liquefaction. Site - specific construction recommendations such as the use of quality fill, proper compaction, over excavation, and grading requirements will be implemented to ensure impacts are less than significant. Impact GEO -6: The project would be located on a geologic unit or soil that is unstable or that may become unstable as a result of the project. GEO -1: (See above) Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: The geotechnical report will characterize the on -site geotechnical conditions in order to make appropriate recommendations related to grading procedures and design criteria. Proposed recommendations may include providing fill material, location and compaction design requirements, over excavating the existing soils, and /or providing specific grading requirements. The report will be prepared in accordance with the California Building Code and City of Petaluma General Plan policy. As such, impacts will be less than significant. Impact GEO -7: The project would be located on expansive soil that could pose substantial risks to life or property. GEO -1: (See above) Impact after Mitigation: Less than Significant 2 -10 Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: The geotechnical report will characterize the on -site geotechnical conditions in order to make appropriate recommendations related to grading procedures and design criteria. Proposed recommendations may include providing fill material, location and compaction design requirements, over excavating the existing soils, and /or providing specific grading requirements. The report will be prepared in accordance with the California Building Code and City of Petaluma General Plan policy and will specifically prescribe measures to address expansive soils. With mitigation, impacts will be less than significant. HYDROLOGY AND WATER QUALITY Impact HYD -9: The project would place structures within a 100 -year flood hazard area which would impede or redirect flows. HYD -1: The City shall prepare a hydraulic design study at later stages of project design that determine the project's potential to alter the river's flood flows at the bridge location and upstream and downstream of the bridge. The hydraulic analysis would be conducted to quantify the rise in base flood elevation in the floodway after compliance with the City's no net fill policy. If this design level evaluation determines that the project would still result in a base flood elevation increase in the regulatory floodway (even if the increase is minimal), the City would obtain a CLOMR for the project from FEMA, and request a NFIP map revision. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: The City's no net fill policy would ensure reasonable hydraulic equivalence to existing conditions. Mitigation includes measures such as benching or widening the channel near the bridge crossing to accommodate surface flows, which would likely result in no net increase in base flood elevations within the FEMA- designated floodway. Therefore, upon implementation of the mitigation measure, the project bridge features would not significantly impede or redirect flood flows, nor would they significantly alter the 100 -year flood plain area. Thus, impacts would be less than significant. Impact HYD -10: The project would substantially alter the existing drainage pattern of the site or area. HYD -1: (See above) Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. 2 -11 Rationale for Finding: Mitigation would reduce potential impacts related to the placement of the bridge bents, abutment, and outfalls or their associated erosion protection by limiting the area of disturbance, providing slope protection and stabilization and preventing upstream and downstream erosion. This will be accomplished by adhering to the City's no net fill policy and /or design components that would accommodate marginal increase in surface flow elevations. Therefore, with mitigation, impacts will be less than significant. TRANSPORTATION Impact TRANS -7: The project could increase hazards due to a design feature or incompatible uses. TRANS -1: To ensure that safe access for transit vehicles is provided into the Operations Facility, the City shall relocate the access driveway farther away from the Rainier Avenue/North McDowell Blvd. intersection. Reconfiguration of the access driveway shall also provide a break in the median and extend the left turn pocket so that transit vehicles can turn left from eastbound Rainier Avenue into the Operations Facility. This break in the median shall be marked with a "No Left Turn Except for Buses" sign to dissuade use by non - transit vehicles. Impact after Mitigation: Less than Significant Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: The mitigation measure will result in modifications to the Transit Operations Facility access driveway thereby maintaining functionality and avoiding a potential design hazard. The median break and signage will discourage use by non - transit vehicles and ensure that functionality is preserved for the Operations facility. Therefore, impacts related to design hazards would be less than significant. Impact TRANS -8: The project could cause substantial temporary construction related traffic impacts. Trans -2: The City of Petaluma Public Works and Utility Department or its contractor shall prepare a construction management plan. Finding: Changes or alterations have been required in, or incorporated into, the Project which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: Temporary construction impacts would be reduced by informing the public of construction schedules, possible detours, and timing, which would allow the public to select alternate routes in advance of construction activities. By providing adequate advance notice of closures and construction, and alternate pedestrian/ bicycle routes as necessary to support possible closures and construction, this temporary construction impact would be minimized. Further, development of a construction management plan will establish a delivery and export schedule that considers the least impactful time of day to minimize conflict with commuters and peak travel times. Therefore, with implementation of mitigation measures, temporary traffic - related construction impacts will be reduced to less than significant levels. 2 -12 Impact TRANS -9: The project could conflict with an applicable congestion management program including intersection Level of Service Standards. TRANS -3: The City of Petaluma shall include in its project design an additional westbound left turn lane and a northbound right overlap phase at the intersection of Petaluma Boulevard North/Rainier Avenue. The City shall also provide a median refuge (at least 5 feet wide) for pedestrians crossing Rainier Avenue. Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. Rationale for Finding: With an additional westbound left turn lane and a northbound right overlap phase, the project's impacts on study intersections under Opening Year conditions would be reduced to less than significant because this intersection would operate at LOS D in the PM peak hour. Further, the installation of a median refuge would provide the necessary pedestrian improvements to accommodate the additional crossing distance. With implementation of mitigation, impacts would be less than significant. CUMULATIVE IMPACTS Impact CUMULATIVE TRANS -1: Intersection level of service would operate at unacceptable LOS E and F under cumulative conditions. All intersections would operate at acceptable levels of service under cumulative conditions with the project except: East Washington Street/Highway 101 Southbound Ramps; Rainier Avenue /Petaluma Boulevard North (without Shasta Avenue Extension); and Petaluma Boulevard North /Sycamore Lane (Shasta Avenue). CUMULATIVE TRANS -1: The exact location of the impact would depend on the construction timing of Shasta Avenue extension. If Shasta Avenue extension is not constructed during the buildout of the General Plan, the project would need to provide the intersection configuration at the Petaluma Boulevard North /Rainier Avenue intersection described in Mitigation Measure TRANS -3. If the Shasta Avenue extension is constructed, then the project could potentially have an impact at the Petaluma Boulevard North/Sycamore Lane (Shasta Avenue) extension. Restriping the existing westbound approach to Petaluma Boulevard North /Sycamore Lane (Shasta Avenue) to provide an exclusive left -turn lane and a shared left /through /right -turn lane plus an exclusive northbound right -turn lane would improve the intersection to LOS C in the PM peak hour. In order to reduce impacts to pedestrians resulting from increased crossing distances, a median refuge (at least five feet wide) shall be installed for pedestrians crossing the south leg of Petaluma Boulevard. Finding: Changes or alterations have been required in, or incorporated into the Project, which avoid or substantially lessen the significant environmental effect identified in the EIR. 2 -13 Rationale for Finding: The project would improve the LOS condition at the E. Washington/Hwy 101 SB ramps relative to the no project condition (it would reduce traffic volumes by —17 %). The other two deficient intersections are dependent on the future Shasta Avenue extension. The new intersection at Petaluma Blvd. North /Rainier Ave. could be modified to achieve acceptable LOS under a pre- Shasta scenario by implementation of TRANS -3, which would introduce an additional westbound left turn lane and a northbound right overlap phase and thereby achieve an acceptable LOS D. Under a Shasta Ave. scenario, the intersection of Petaluma Blvd. North /Rainier Ave. would operate acceptably at LOS B and C during the a.m. and p.m. peak hour, respectively. However, with Shasta Ave, the intersection of Petaluma Boulevard North /Sycamore Lane (Shasta Avenue) would degrade to unacceptable LOS F. Mitigation would correct this deficit by introducing an exclusive left -turn lane and a shared left /through /right -turn lane plus an exclusive northbound right -turn lane, thereby improving the intersection to LOS C in the p.m. peak hour. It should be noted that the Shasta Avenue extension project would be required to go through the City approval and CEQA documentation process to identify its impacts and mitigations prior to its construction. Presumably, it would identify the need to improve the Petaluma Boulevard North, Sycamore Lane (Shasta Avenue) intersection. Therefore, with mitigation, the project's cumulative impacts to level of service would be less than significant. 2 -14 EXHIBIT B FINDINGS REGARDING ALTERNATIVES CEQA Guidelines Section 15126(a) states that an EIR shall describe a range of reasonable alternatives to the project or the location that would feasibly accomplish most of the basic objectives of the Project and could avoid or substantially lessen any of the Project's significant impacts. The EIR evaluated the alternatives listed below. The City Council considered the alternatives but finds them to be infeasible for the specific economic, legal, social, technological, or other considerations set forth below pursuant to CEQA Section 21081(a)(3). ALTERNATIVE A: NO PROJECT / NO BUILD Under this alternative, the proposed project would not be constructed and the site would remain as it currently exists. No roadway would be constructed connecting Petaluma Boulevard North on the west to North McDowell Boulevard on the east. No grading, road building, or construction would take place. In addition, there would be no changes to existing roadways, such as turn lanes, to allow access to the Rainier extension and no installation of a new signal at Petaluma Boulevard North. The trees on the site would remain unchanged. Traffic would continue to use existing roads, and there would be no construction impacts from the project. Finding — Infeasible. This alternative would avoid all of the Project's significant impacts. However, it would not achieve any of the Project's objectives and would not provide for new arterial as identified in the City's General Plan. ALTERNATIVE B: 4 -Lane Roadway, No Future Connections Unlike the proposed project, the design of this roadway would preclude future connections at the Sid Commons driveway, Shasta Avenue extension, and the Petaluma Outlet Mall Expansion by having a slightly longer bridge and therefore roadway elevation profile. As with the project, grading, road building, and construction would take place on the site. In addition, there would be changes to existing area roadways, such as turn lanes, to allow access to the Rainier extension and installation of a new signal at Petaluma Boulevard North. Lastly, the Rainier extension would be constructed in an undercrossing beneath Highway 101; the Petaluma River and SMART tracks would be spanned by a bridge; and trees on the site would be removed. Finding — Infeasible. This alternative would lessen some of the impacts, all of which would be reduced to levels below significance under the proposed project with mitigation. Although this alternative achieves most of the project objectives, it would preclude future connections, which have been identified as an important need to achieve buildout of the General Plan. ALTERNATIVE C: 2 -Lane Roadway, Future Connections The design of this roadway, with a 2 -lane configuration, would allow for future connections at the Sid Commons driveway, Shasta Avenue extension, and the Petaluma Outlet Mall Expansion. Like the project, grading, road building, and construction would take place on the site. In addition, there would be changes to existing area roadways, such as turn lanes, to allow access to the Rainier extension and installation of a new signal at Petaluma Boulevard North. Lastly, the Rainier extension would be constructed in an undercrossing beneath Highway 101, the Petaluma River and SMART tracks would be spanned by a bridge, and trees on the site would be removed. 2 -15 Finding — Infeasible. This alternative would lessen some of the impacts, all of which would be reduced to levels below significance under the proposed project with mitigation. Although this alternative achieves most of the project objectives, it would not relieve traffic congestion, which would result in LOS in excess of the City's standards. This alternative would not provide as much of a traffic congestion relief relative to the proposed project alternative since it would only provide for half of the added capacity to the roadway system (2 lanes rather than 4 lanes). This alternative would only partially meet the project objectives. 2 -16 EXHIBIT C STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to CEQA Guidelines section 15093, the City Council of the City of Petaluma adopted a Statement of Overriding Considerations for those impacts identified in the General Plan EIR as significant and unavoidable (Resolution 2008 -084 N.C.S., May 8, 2008). Although the City Council adopted a Statement of Overriding Considerations for the General Plan EIR, pursuant to the court decision in Communities for a Better Environment v. California Resources Agency, 103 Cal. App. 4th 98, (2002), the City must adopt specific overriding considerations for this Project. The City Council has considered the information contained in the EIR and has fully reviewed and considered all of the public testimony, documentation, exhibits, reports, and presentation included in the record of proceedings. The Council finds that each determination made in this Statement of Overriding Considerations is supported by substantial evidence set forth in the CEQA Findings and /or herein and /or in the record of proceedings. The unavoidable environmental effects identified in the General Plan EIR that are applicable to the Project will be substantially lessened by mitigation measures adopted with the General Plan and by mitigation measures adopted for the proposed Project. Even with mitigation, implementation of the Project carries with it certain unavoidable adverse environmental effects. The Council specifically finds that to the extent that the identified adverse or potentially adverse impacts for the Project have not been mitigated to acceptable levels, there are specific economic, social, environmental, land use and other considerations that support approval of the Project. The project will contribute to the following significant and unavoidable environmental impacts identified in the General Plan EIR: AIR QUALITY Impact 3.10 -6 Implementation of the General Plan may result in a cumulatively considerable incremental contribution to the significant cumulative impact of Global Climate Change. General Plan Policies /Mitigation Measures which substantially lessen this impact: Policy 4 -P -7, Program A: Reduces vehicle related air pollution by enforcing multi -modal transportation strategies. Policy 4 -P -14: Integrates Intelligent Transportation Technologies into the City transportation system. Policy 4 -P -23: Provides for the staffing of a Program Manager with a focus on Green Technology. Policy 4 -P -24: Requires compliance with AB 32 and its governing regulations. Policy 4 -P -25: Connects additional adopted State standards designed to reduce Greenhouse Gas Emissions into the City's jurisdictional authority. Policy 4 -P -26: Calls for the implementation of measures contained in the municipal Climate Action Plan. 2 -17 Policy 4 -P -29: Requires training City staff on new technology and improving energy efficiency in public facilities. Policy 4 -P -32: Calls for the development and implementation of a municipal Environmentally Preferable Purchasing Program. Policy 4 -P -26: Calls for the implementation of measures contained in the municipal Climate Action Plan. Finding: Policies, changes or alterations have been required in or incorporated into the Plan which will lessen, but not avoid the significant effect identified in the General Plan EIR. Explanation: The Rainier Cross -Town Connector will emit GHG emission during construction and at operation that would contribute to this previously identified significant and unavoidable impact as described in the General Plan EIR. The General Plan EIR found the following: "The City prepared a Revised Draft EIR which quantified GHG emissions, identified the most recently available GHG strategies from a variety of sources, including the California Air Resources Board, and incorporated an extensive list of GHG reduction measures into the Plan, to supplement existing Policies regarding resources conservation, energy efficiency, smart land use and multi -modal transportation. The City is preparing a Climate Action Program. It has identified extremely aggressive municipal and community goals for the GHG reduction through its Resolution 2005 -118. Evaluation and mitigation of the effects of climate change by local agencies is currently in a state of regulatory and technological uncertainty. The effects of national, State and regional GHG reduction measures in Petaluma and the effects of local GHG reduction measures in Petaluma on the larger regional State and global environmental are uncertain and difficult to qualify. Therefore, the EIR concludes that it cannot be determined to a reasonable degree of certainty that buildout under the Plan will not result in a cumulatively considerable incremental contribution to the significant cumulative impact of global climate change. Therefore, this impact remains significant and unavoidable." NOISE Impact 3.9 -1: At buildout, implementation of the proposed General Plan would generate increased local traffic volumes in the Planning Area that would result in a substantial increase to existing exterior noise levels that are currently above the City standards. General Plan Policies /Mitigation Measures which substantially lessen this impact: Policy 10 -P -3, Programs A, B, D, E, F and G: Provides for the elimination or minimization of noise problems by minimizing the increase of noise levels in the future. Finding: Policies, changes or alterations have been required in or incorporated into the Plan which will lessen, but not avoid the significant effect identified in the General Plan EIR. Explanation: The Rainier Cross -Town Connector will generate construction worker vehicle trips during construction and will introduce a new roadway at operation, which will contribute to traffic related noise levels on roadways Citywide. The General Plan EIR previously identified traffic related noise as a significant and unavoidable impact as described in the General Plan EIR 2 -18 per the following: "Under the various elements of Policy 10 -P -3, the city will locate and design transportation facilities to minimize noise effects of adjacent areas. It will determine acceptable uses and installation requirements in noise - impacted areas using Land Use Compatibility Standards in General Plan Figure 10 -2. It will require a professional acoustical engineer to provide technical analysis design mitigation measures for development proposed in areas with noise levels greater than 65 dB CNEL, discourage location of new noise sensitive uses in such area, and when permitted require mitigation to achieve interior noise levels not in excess of 45 dB CNEL. The city will establish noise - emission standards for city vehicles and continue to require noise control or mitigation for construction related noise, including from construction vehicles. While sound walls are discouraged, Plan Program 10 -P -3 -F permits them as necessary, particularly along Highway 101 and the NWPRS rail corridor [now SMART rail corridor]. While the identified Policy Programs will reduce traffic related noise, the effect will remain significant and unavoidable." TRANSPORTATION Impact 3.2 -1: Increased motor vehicle traffic would result in unacceptable level of service (LOS) at study intersections. Traffic at six intersections will operate at LOS E or worse at buildout, thus creating a significant impact at these intersections, under the revised LOS criteria called for by the General Plan. The Rainier Cross -Town Connector would contribute to the deficient LOS under the cumulative condition at the North McDowell Boulevard / Rainier Avenue intersection. General Plan Policies /Mitigation Measures which substantially lessen this impact: Policy 5 -P -1, Programs A, B, D and E: Provide for the development of a multi -modal interconnected system to greatly expand upon the opportunity of travel on multiple routes by multiple modes. Policy 5 -P -5: Draws in full multi -modal components into the evaluation of potential mobility impacts. Policy 5 -P -8, Programs A and B: Identifies quality of life and community character as priorities in the task of designing the multi -modal components of the community's mobility infrastructure. Policy 5 -P -10, Program A: Sets the Level of Service D (LOS D) or better for motor vehicles while recognizing a lower LOS may be acceptable if improvements are found to conflict with Guiding Principles. Policy 5 -P -11, Program A: Sets forth the major components to the mobility infrastructure and requires new development to assist in their funding. 2 -19 Finding: Policies, changes or alterations have been required in or incorporated into the Plan which will lessen, but not avoid the significant effect identified in the General Plan EIR. Explanation: The Rainier Cross -Town Connector will contribute to a Citywide shift in traffic pattern distribution that will result in deficient LOS at the Rainier Ave./North McDowell Boulevard intersection. The General Plan EIR previously identified this intersection as a significant and unavoidable impact as described in the General Plan EIR per the following: "There are no feasible mitigation measures identified that would reduce the impacts to the six study area intersections to less than significant other than measures that would conflict with other Plan Guiding Principles. Feasibility of mitigation in this case includes consideration of whether a possible mitigation measure meets overall project objectives. Here, those project objectives are contained in the Plan's Guiding Principles set out at Section i -3 of the Plan. The competing interests of building all roadway systems to meet peak travel period demands and preserving the overall community character of the city has been resolved in Policy 5 -P -10, Program A, which notes that a level of service lower than LOS D for motor vehicles may be deemed acceptable by the City in instances where potential vehicle traffic mitigations such as adding additional lanes or modifying the signal timing, would conflict with the following Guiding Principles: Guiding Principles #2, preserve and enhance Petaluma's historic character; and Guiding Principles #6, provide a range of attractive and viable transportation alternatives, such as bicycle, pedestrian, rail and transit; and Guiding Principles #7, enhance downtown by preserving its historic character, increasing accessibility and ensuring a broad range of business and activities and increasing residential activities. It has been determined that installing additional lanes or expanding vehicle capacity at these location would conflict with these Guiding Principles. The deliberative process led the community and decision makers to recognize that the non - vehicular modes of travel would be adversely impacted if roadway improvement were undertaken to weigh more heavily towards a priority of vehicle demands. Building roadways to meet peak hour LOS demands were balanced with the overall community desire to retain a roadway system that meets a more balanced 24 -hour volume demand." BENEFITS OF THE PROJECT 1. The Project will enhance east -west connectivity. 2. The Project will alleviate congestion at several deficient intersections. 3. The Project will provide for multi -modal connectivity by introducing pedestrian and bicycle facilities. 2 -20 CONCLUSION The City Council has considered the information contained in the Project EIR and has fully reviewed and considered all of the public testimony, documentation, exhibits, reports and presentation included in the record of these proceedings. The City Council finds that each determination made in this Statement of Overriding Considerations is supported by substantial evidence set forth herein and /or in the CEQA Findings and /or in the record of proceedings. Based on the forgoing, and pursuant to Public Resources Code Section 21081 and CEQA Section 15093, the City Council finds that all the specific economic, legal, social, technological, or other benefits that the Project will produce, as described herein, outweigh the remaining significant and unavoidable adverse environmental impacts of the Project and render those impacts acceptable. The City Council further finds that any one of the overriding considerations set forth therein is sufficient to render the above described adverse environmental impacts acceptable. 2 -21 DATE: June 23, 2015 TO: Planning Commission FROM: Olivia Ervin, Environmental Planner Heather Hines, Planning Manager ATTACHMENT 3 Agenda Item 8A SUBJECT: Rainier Cross -Town Connector Final Environmental Impact Report RECOMMENDATION ENDATION It is recommended that the Planning Commission conduct the required public hearing on the Final Environmental Impact Report (FEIR) for the Rainier Cross -Town Connector and adopt the following resolution: Resolution recommending that the City Council certify the FEIR and approve the Mitigation Monitoring and Reporting Program (MMRP) for the Rainier Cross -Town Connector- Project (Attachment 1). BACKGROUND A Rainier Connector was previously contemplated by the City of Petaluma (City) as part of the larger interchange project evaluated for U.S. Highway 101 between East Washington Street to the south. and Corona Road to the north. The need for a Highway 101/Rainier Avenue interchange was .identified as early as 1965 by Caltrans and the City. Caltrans completed and approved a Supplemental Project Authorization Report and a Project Study Report (PSR) for a Rainier Avenue interchange in 1980 and 1988, respectively. Caltrans revisited-the interchange location and spacing requirements in 1992. Because the proposed Rainier Avenue interchange was less than one mile fiom the existing East Washington Street interchange, Caltrans required that auxiliary lanes be added in both directions along Highway 101 between the proposed Rainier Avenue interchange and the existing East Washington Street interchange. Subsequent to Caltrans' completion of an approved PSR for the interchange, the City of Petaluma certified an EIR in 1994 for the project. The 1994 EIR studied a modified diamond interchange with loop ramp alternative; however, the design and construction phases for the interchange were abandoned. In 2005 and 2006, City staff met with Caltrans to discuss the interchange project following Caltrans' Project Development Procedures and began preparation of a PSR for the Highway 101/Rainier Avenue Interchange project. During the review process Caltrans notified the City that the new interchange would require approval of an exception to Caltrans' design standards that require a minimum interchange spacing of one mile. In January 2010, the Petaluma City Council separated the interchange and cross -town connector into two independent elements to allow coordination of the cross -town connector with the Sonoma County Transportation Authority (SCTA) Marin Sonoma Narrows (MSN) C2 project that includes mainline and ramp improvements along Highway 101 from just south of Caulfield Lane to just south of Old Redwood Highway. In 2009, Caltrans requested that the City suspend the development of a PSR for the Highway 101/Rainier Avenue Interchange Project and proceed with a PSR for the Rainier Avenue Cross - Town Connector Project, and assuming an undercrossing structure at Highway 101 is installed by the SCTA MSN C2 project, prepare an environmental document for the Rainier Avenue Cross -Town Connector. (Since that time, Caltrans has determined that a PSR would not be the appropriate document for the portion of the project within Caltrans right -of -way as its estimated capital cost is under $1 million.) The appropriate document would be an encroachment permit. The City met with Caltrans and SCTA on November 3, 2009 to discuss further including the undercrossing structure needed at Highway 101 for the Rainier Avenue Cross -Town Connector Project as part of the SCTA MSN C2 project through Petaluma. The MSN C2 project proposes to locally raise the profile of Highway 101 crossing the Sonoma Marin Area Rail Transit (SMART) corridor to correct and make standard the existing non - standard stopping sight distance for the crest curve on Highway 101 that does not meet Caltrans' current design standards. The MSN C2 project has been designed and the Record of Decision was published in October 2009. Consensus was reached on May 11, 2011 between the City, Caltrans, and SCTA to include the undercrossing structure component of the Rainier Avenue Cross -Town Connector element into the MSN C2 design. SCTA initiated a revalidation of the approved environmental document for the SCTA MSN C2 project that included the undercrossing structure where the extension of Rainier Avenue from North McDowell Boulevard to the west to Petaluma Boulevard North would cross under Highway 101. As a conclusion of these steps and decisions, construction of the Rainier Avenue Cross -Town Connector Project would require minor modifications to the area under the Highway 101 mainline bridge abutment slopes. Specifically, Abutment 1 and Abutment 3 would require minor embanlcment modifications and construction of new slope paving in front of the undercrossing abutments. Following the Council's decision to separate the interchange and connector into two distinct elements, the environmental review for the proposed Rainier Cross Town Connector Project was initiated in 2011. In June 2014 the Draft Environmental Impact Report (EIR) was released for public comment. The Final EIR for the project was released on May 28, 2015 and is the focus of this Staff Report. The following table provides a summary of the recent history of actions taken for the proposed Rainier Cross -Town Connector Project. 2 Table 1. History of Actions Date Action May 11, 2011 Consensus reached between City, Caltrans, and SCTA to include the undercrossing structure component of the Rainier Avenue Cross -Town Connector element into the MSN C2 design Project Description The project would consist of a new 0.65 -mile long 4 -lane arterial roadway connecting North McDowell Avenue on the eastern side of Highway 101 to Petaluma Boulevard North on the western side of the City. The Rainier Connector would extend at grade from the signalized North McDowell Avenue intersection, cross under Highway 101 at an elevated portion of the freeway that will be constructed as part of the SCTA MSN C2 project, and cross over the Petaluma River and SMART corridor via an elevated bridge. The Rainier Connector would return to at grade and continue to Petaluma Boulevard North, where it would terminate at a signalized T- intersection. The project would introduce a dedicated right -turn lane and two future eastbound left -turn lanes at the existing signalized Rainier Avenue and North McDowell Boulevard intersection. The project would terminate as a "T" intersection at Petaluma Boulevard North with a westbound right -turn lane and left-turn lane, and two eastbound receiving lanes separated by a median. The new roadway would have on- street bicycle lanes and sidewalks with planter strips on both sides. The median and planter area widths would vary depending on the roadway location. The project would include landscaping in the median, where feasible, and planter areas. No planter areas are proposed on the bridge portion of the roadway. The median ranges from 14 feet to 24 feet wide in order to allow for future connections. Best management practices (BMPs) for temporary and permanent erosion control and the treatment of storm water would be implemented. These BMPs would include temporary and permanent fiber rolls, concrete washouts, street sweeping, drainage inlet protection, rock slope protection at new outfalls, biofiltration swales, hydroseeding and/or erosion control blankets and temporary covers. 3 -- 3 Highway 101 Undercrossing The project would cross under Highway 101 at an undercrossing structure to be constructed as part of the SCTA MSN C2 project. Additional excavation would be needed beneath the undercrossing structure at Highway 101 in order to construct the proposed roadway and install utilities. The undercrossing roadway would be an adequate width to include a median, bicycle lanes, curbs, gutters, sidewalks, lighting, and drainage facilities. These facilities could be modified in the future in the event that a Rainier Avenue/Highway 101 interchange is constructed. Storm water runoff from the undercrossing portion of the roadway would be collected by an underground drainage system consisting of pipes and drainage inlets. The roadway would meet applicable Caltrans Highway Design Manual (HDM) design standards for that portion within State right -of -way (the cross -town connector must meet vertical clearance requirements where it passes under Highway 101). Petaluma River /SMART Corridor Bridge The project would include construction of a bridge elevated above the Petaluma River and Sonoma Marin Area Rail Transit (SMART) tracks. The bridge would include a. 14 -foot wide raised median, two travel lanes in each direction, 6 -foot wide bicycle lanes, 6 -foot sidewalks with concrete barriers and chain link railings on both sides, and street lighting. The bridge would be approximately 88 feet wide, 508 feet in length, would meet the minimum vertical clearance requirements over the SMART Corridor tracks, and would be designed per the American Association of State Highway Transportation Officials (AASHTO) Load and Resistance Factor Design (LFRD) Bridge Design and California Amendments. In the preliminary design, the bridge would be constructed of 299 60 -foot long cast -in -steel shell piles, hammer driven to approximately 50 feet in depth. Construction would include one bent located west of the SMART corridor right -of -way and one bent between the river and the SMART tracks, and bridge abutments. The shell piles would be located out of the river at normal high water levels; however, temporary enclosures (cofferdams) would be used to divert the river during construction as needed. The cofferdams would be designed so that water flows passively and would not require pumping. Temporary structures to support the bridge during construction would be installed in the diverted portion of the Petaluma River. Pile driving would be required for construction of the temporary structures, and these piles would be the same size or smaller as those used for the bridge supports. Cofferdams would be removed for the rainy season, but the temporary support structures may stay in place. Storm water on the bridge would either be collected by the roadway drainage system or gravity flow to bridge deck drains. Project Phasing The analysis conducted in the EIR for Rainier Cross -Town Connector project anticipates that construction would begin in 2017. This date is based on the project's dependence on implementation of the SCTA MSN C2 project, as construction of the undercrossing structure of Highway 101 would be contingent on raising the profile of Highway 101 as part of the MSN C2 project. The analysis assumes that the proposed Rainier Cross -Town Connector would be constructed in a single phase that is estimated to take 30 months to construct. Construction of the bridge portion of the proposed roadway is expected to require a majority of the 30 -month construction window. Completion of the Rainier Cross -Town Connector construction is 3- 4 anticipated for year 2020. A future interchange at Rainier Avenue and Highway 101 and the future Shasta Avenue collector roadway, as identified in the City's General Plan are not a part of the Rainier Avenue Cross - Town Connector project. However, as both are identified in the City's General Plan they are considered as projects that may be constructed in the future and are analyzed in the cumulative impacts analysis. COMMUNITY REVIEW The public, interested parties and state and federal agencies have had an opportunity to provide written and/or oral comment during the following review periods and public meetings: • During the EIR NOP comment period between August 11, 2011 and Sept. 26, 2011 • At the EIR NOP public scoping meeting on August 30, 2011 • During the public review period on the DEIR between July 24, 2014 and Sept. 8, 2014 • At the Planning Commission Hearing on the DEIR on August 12, 2014 • At the City Council Hearing on the DEIR on September 8, 2014 Notices have been published in the Argus Courier and sent to residents and property owners within 500 feet of the subject property, as well as interested parties, state and federal agencies who requested notification, and all individuals that have provided comment. Copies of the DEIR and associated Appendices have been made available at the Petaluma Library, the Community Center, City Hall, and on the City's website. Planning Commission DEIR Review — August 12, 2014 The Planning Commission held a public hearing to provide comments and receive public testimony on the DEIR at its meeting on August 12, 2014. Comments from the hearing included the following: 1. GHG Methodology. Clarify methodology for GHG analysis. Describe how operational GHG would be reduced because of reduction in VMT created by the project. Construction emissions should not be amortized over the life of the project. 2. Petaluma Transit Operations Facility. Concerns about conflict with transit vehicles blocking the left turn lane on Rainier Ave near North McDowell. 3. Construction truck trips /project phasing. Expand detail on construction related traffic, lane closures and delays. 4. CEQA Baseline. Concern that a future baseline is being used to assess impacts. The impact analysis uses existing baseline to forecast future year conditions. The No Project scenario is shown for informational purposes. 5. Hydrology. Concern that new improvements within the floodplain will result in flooding. 6. Project Benefit. LOS analysis does not appear to improve congestion relative to existing condition. 7. Impacts from Mitigation. Concern that indirect impact from mitigation measures has not been fully analyzed. -3 5 8. Mitigation to offset fill to waters of the State should occur onsite. City Council DEIR Review — September 8, 2014 The City Council held a public hearing to provide comments and receive public testimony on the DEIR at its meeting on September 8, 2014. Comments from the Council hearing included the following: 1. Construction. Concern that the presumed start date of 2017 for construction was overly optimistic and that staging areas, detour routes, etc. are omitted in the DEIR. 2. Clarify the Shasta Ave. connection to Rainier and its consideration in the DEIR. 3. Future Connections. Concern was raised that insufficient detail was provided for future connections to Rainier. 4. Flooding and City's No Net Fill Policy. 5. Cumulative Analysis. Concern that DEIR does not reflect induced traffic trips resulting from development of Rainier. 6. Deferred Mitigation. Concern that DEIR puts of mitigation until later. 7. Traffic Congestion Relief. The DEIR does not clearly show that congestion relief is realized by the proposed project. The Final EIR includes all comments received on the DEIR and provides itemized responses to address each comment. DISCUSSION The following discussion summarizes the consistency of the proposed project with applicable planning documents, identifies the current funding status, and provides an overview of the Final EIR including the concerns identified during the public review period on the DEIR and the response to comments presented in the FEIR. PLAN CONSISTENCY The Rainier Cross -Town Connector Project is consistent with applicable planning documents including the General Plan, the Petaluma River Access and Enhancement Plan and the Petaluma Bicycle and Pedestrian Plan. 2025 General Plan Consistency The City's 2025 General Plan sets forth 14 guiding principles that provide the basis for the goals, policies and programs therein. Number 13, which is to integrate and connect the east and west sides of town, directly identifies the Rainier extension as a means to accomplish this objective. The Rainier extension mitigates traffic impacts that would occur under full buildout of the General Plan. As identified in the General Plan, the extension of Rainier is envisioned as a Cross -Town Connector in conjunction with a Highway 101 interchange. As described above, the City Council separated these elements into two distinct components. The focus of this EIR is the Cross -Town Connector component, which meets the objective of the General Plan by enhancing east -west connectivity. The proposed roadway alignment has been designed in a manner that would 3 -- 6 accommodate connectivity to Highway 101 via interchange ramps should such improvements be proposed in the future. The proposed Rainier Cross -Town Connector Project is consistent with the City's General Plan 2025, in that it provides east -west connectivity across Petaluma, relieves traffic congestion on the street network, and provides opportunities for access to parcels designated for future development. Petaluma River Access and Enhancement Plan Consistency The Petaluma River Access and Enhancement Plan provides a framework for preservation and restoration of the Petaluma River corridor. The Plan addresses corridor improvements, land uses, and accessibility along the 6.5 -mile section of the Petaluma River within the city limits. Its four major components include restoration of the river's natural resources, construction of a multi -use trail, a vibrant waterfront district adjacent to Downtown, and mixed uses along the river corridor. The project falls within the Corona Road to Lynch Creek Segment of the Petaluma River Access & Enhancement Plan, which depicts a future pedestrian trail along the north river bank upstream of the Rainier / River overcrossing and a future pedestrian trail along both the north and south river bank downstream. Construction activities will result in the removal of vegetation along the riverbank and temporary disturbance potentially within and adjacent to the River. However, mitigation measures as set forth in the DEIR require that impacts be avoided as feasible, minimized as practicable and offset. Mitigation measures further require that any offsets first be considered within and adjacent to the project area prior to acquiring offsite mitigation via established mitigation banks. The measures set forth in the DEIR ensure that temporary disturbance to the Petaluma River do not result in a conflict with the River Access and Enhancement Plan. At operation the Rainier Cross -Town Connector will cross over the Petaluma River via an elevated bridge. There are no access points or trail elements along the Petaluma River that are proposed as part of the Rainier Project. Full pedestrian and bicycle facilities are proposed on both sides of Rainier. While no direct access to the River is proposed by the Rainier Connector Project, the alignment does not preclude the future development of trails in accordance with the Petaluma River Access and Enhancement Plan. Petaluma Bicycle and Pedestrian Plan Consistency The Rainier Cross -Town Connector is also identified in the City's Bicycle and Pedestrian Plan, which calls for Class li bicycle facilities along the entire length of the proposed roadway. The Plan states that the most significant barrier to increasing bicycling is the lack of sufficient east - west commuter routes with a minimum of Class II bike lanes. The Rainier Cross -Town Connector proposes 6 -foot wide on- street striped bike lanes on both sides of the roadway. Sidewalks ranging from a minimum of 6 feet to a maximum of 14 feet in width are proposed on both sides of the roadway. Project plans provide for bicycle and pedestrian facilities along the entire length of the proposed roadway consistent with the Bicycle and Pedestrian plan. j- 7 FUNDING Although funding for construction of the project is incomplete at this time, completion of the EIR allows Caltrans to conduct the necessary undercarriage improvements (raising the profile at the Highway 101 undercrossing); thereby permitting the project to move forward at the time that funding is secured. ENVIRONMENTAL REVIEW As described above under Community Review, the environmental review process initiated with the release of the NOP on August 11, 2011. In July 2014 the DEIR was released for public review and was considered before the Planning Commission and City Council during public hearings in August and September 2014, respectively. SB 743 On September 27, 2013 SB 743 was signed into law, thereby formalizing a new approach to the way that transportation impact analyses have traditionally been conducted. The legislative intent of SB 743 is to revise the current practice of traffic analysis conducted for CEQA review in order to more appropriately balance the needs of congestion management with statewide goals related to infill development, promotion of public health, and reducing greenhouse gas emissions. One of the primary changes that SB 743 promulgates is a shift from using the delay metric known as level of service (LOS) to an approach that relies on vehicle miles traveled (VMT). There are several steps that must occur before SB 743 can be implemented. In August of 2014 the Governor's Office of Planning and Research (OPR) released Updating Transportation Impacts Analysis in the CEQA Guidelines, which provides a preliminary discussion of draft updates for the implementation of SB 743. A second iteration of the draft guidelines is expected to be released in the spring of 2015 and the final guidelines are anticipated for release in 'the summer of 2015. By the end of 2015, upon completion of the " rulemaking" process, the Guidelines are expected to become law. It is expected that in 2016 lead agencies including the City of Petaluma will be required to update guidance in accordance with the new law. Typically, a 120 -day period is granted to lead agencies in order to come into compliance with new legislation. In the event that OPR includes an implementation buffer then additional time may be available for lead agencies to come into compliance. As the notice of preparation (NOP) for the Rainier Cross -Town Connector Project was released in 2011, well before SB 743 had been adopted, the Traffic Impact Analysis 'and EIR use the traditional LOS metric and delays approach to assess potential impacts associated with circulation. Given the timeline for the environmental review of the project and the rulemaking process for adoption of Guidelines that would implement SB 743, the use of the traditional LOS metric is appropriate and consistent with the standard threshold set forth in the City's General Plan, which establishes LOS D as the minimum standard. At the time that the City's General Plan standard is updated in accordance with SB 743, projects will be required to demonstrate compliance with adopted methodology for evaluating traffic impacts including the use of vehicle miles traveled in lieu of level of service, should that be the eventual outcome. The NOP and DEIR for the subject Rainier Cross -Town Connector were released in advance of SB 743 being 3-8 implementable, as guidelines, procedures and completion of the rulemaking process have not yet been finalized. FEIR Summary By the close of the public review period (September 8, 2014) on the Draft Environmental Impact Report for the Rainier Cross -Town Connector Project, staff received written comment from the following agencies, organization and individuals: 1. California Department of Fish and Wildlife 2. California Department of Transportation (Caltrans) 3. Planning Commissioner Jennifer Pierre 4. Councilmember Mike Healy 5. Dennis Kelly 6. David Keller, Petaluma River Council 7. David Libchitz 8. Frederick Etzel 9. Sonoma -Marin Area Rail Transit (SMART) 10. Wayne Leach, Simon Premium Outlets All the written and oral comments received during the public review period are included in the Final Environmental Impact Report (FEIR) and are accompanied by written response to comments. As indicated above, a total of 10 comment letters were received during the 45 -day public comment period on the DEIR. Copies of all written comments received on the Draft EIR, a record of oral comments made at the Planning Commission meeting on August 12, 2014, and the City Council meeting on September 8, 2014, are contained within the FEIR. . The FEIR addresses all comments raised on environmental issues, and provides clarification and revisions to the Draft EIR where appropriate. The FEIR also includes Corrections and Additions to the Draft EIR (Section 3) and the Mitigation Monitoring and Reporting Program (MMRP), which identifies each mitigation measure, sets forth the requirement for implementation and identifies the party responsible for ensuring compliance (Section 4). Corrections and Additions to the Draft EIR The FEIR Section 3 identifies text in the DEIR that has been changed and specifies str4ke+i,,.o for deletions and underline for insertions. Minor modifications to the DEIR include clarification on the project description and minor corrections to the environmental impact analysis. The changes to the DEIR were promulgated pursuant to comments received and are intended to provide clarification, update information, and enhance understanding of the analysis, site conditions, and potential impacts of the project. The FEIR does not meet any of the tests for recirculation in CEQA Guidelines section 15088.5 as no significant new information has been added, no new significant impacts identified, and no considerably different mitigation measures have been developed. None of the changes, revisions, 3-9 or clarifications provided constitutes substantial new information that would warrant recirculation. Overview of Comments and Responses Section 2 of the FEIR provides all comment letters, identifies each comment by number, and includes an individual response for each comment. Transcripts of the Planning Commission and City Council hearings on the DEIR identify the oral comments received and are followed by responses to comments. Several of the comments received on the DEIR overlap and were responded to using a Master Response approach (presented in Section 2.3 of the FEIR. Individual responses to each comment received are also provided in Section 2.4 of the FEIR. The following discussion provides a brief summary of the overlapping comments received, more detailed responses are provided in the FEIR. Baseline Analysis Several comments were raised regarding the use of baseline conditions in the environmental analysis. Specifically, concern was expressed that the analysis in the DEIR improperly uses a future baseline to assess potential impacts associated with traffic and circulation. The DEIR describes the existing environmental conditions and uses that baseline for analyzing most environmental issues. However, for the purposes of air quality, greenhouse gas emissions and traffic analyses the DEIR applies a 2020 baseline reflecting the City of Petaluma's growth projections and transit system improvements expected to be in place. Typically, CEQA analyses utilize a baseline that is reflective of conditions at the time the NOP is released. However, in certain situations it is appropriate to use a future baseline. In the Neighbors for Smart Rail v. Exposition Metro Line Construction Authority (2013) 57 Cal. 4th 439, 457, the court states, "A departure from this norm can be justified by substantial evidence that an analysis based on existing conditions would tend to be misleading or without information valued to the EIR users." For the subject Rainier Cross -Town Connector Project, an analysis of traffic congestion under existing conditions would be misleading for several reasons. First of all, the new roadway would not be operational in advance of 2020. The Rainier Cross - Town Connector project cannot proceed until Caltrans has completed the SCTA MSN C2 improvements, which will raise the profile of Highway 101 at the location of the proposed undercrossing. Caltrans anticipates that work on the MSN C2 project will being in year 2018. Once the improvements to Highway 101 are completed, construction of the Rainier Connector may proceed. The expected duration of construction for the roadway is 30 months, which is a realistic estimate for a project of this scale. Thus, the DEIR appropriately assumes that operation of the Rainier Cross -Town Connector would commence in year 2020 at the earliest. Secondly, an analysis of existing conditions would not capture increased vehicle traffic associated with ongoing growth and development that is expected to occur between now and 2020. Any new development will add vehicle trips to the City's circulation system. An evaluation of existing conditions would preclude these new trips and understate congestion. ,3- 10 The intent of CEQA is to disclose potentially significant environmental impacts and to provide meaningful information to inform decision makers. The DEIR provides an analysis of traffic and circulation conditions in year 2020. Conducting an analysis of traffic congestion under current conditions would be misleading and would understate traffic impacts since there are currently fewer cars on the road now relative to the volume of traffic that there will be in 2020 under continued growth and development in accordance with the City's General Plan. Finally, as a major infrastructure project intended to alleviate traffic congestion over the long- term build out of the General Plan, a reasonable future baseline provides a means to evaluate the ability of the new roadway to reduce congestion. The permanent effects of such a long -term infrastructure investment should take into account increases in population and programmed changes to the transportation system. For the Rainier Cross -Town Connector DEIR, the potential impacts of traffic and circulation (as well as noise and air quality) are evaluated against projected conditions for opening year 2020. Since the population within the City of Petaluma as well as traffic is reasonably anticipated to increase during the interim years prior to operation, using a future year baseline that coincides with the opening year of the project provides the public and decision makers with a realistic evaluation of the potentially significant impacts of the project. Thus, as further explained in the Master Responses 2 and 3 in the FEIR, the DEIR appropriately utilizes a future year baseline in order to assess potential impacts from the proposed Rainier Cross -Town Connector, which is anticipated to be operational no sooner than year 2020. Cumulative Analysis Concern was raised regarding the methodology utilized for the cumulative analysis. Specifically, commenters noted that future development projects will generate vehicle trips that will contribute to congestion on roadways and the DEIR must capture these. As described in Master Response 1, the cumulative analysis does include all traffic resulting from full build -out of the General Plan, including future improvements to infrastructure and build out of nearby vacant land. The cumulative analysis is consistent with the General Plan and captures vehicle trips from all potentially future development as identified in the Land Use map. The Rainier analysis provides a side -by -side comparison of cumulative traffic conditions by showing level of service and delays at study area intersection with the proposed Rainier Connector in place and without the Rainier Connector. The cumulative analysis also considers future potential connections to Rainier including the Shasta Avenue extension, Sid Commons driveway and the Petaluma Outlet mall Expansion driveway. Additionally, a future cumulative scenario that considers potential connections as well as a fall interchange at Highway 101/Rainier Avenue was also evaluated and presented in the DEIR (Section 6.4). The analysis does not evaluate in detail the design of these future potential connections as they are unknown at this time. Rather, the analysis presents peak hour volume and capacity data for -3--11 mainline conditions of Highway 101 and sets forth LOS and delay time at study area intersections assuming that future connections are in place. The cumulative analysis is consistent with the approach and methodology used in the General Plan EIR and fully captures the additional trips generated by population growth, infill development, and future development on currently vacant parcels pursuant to the General Plan Land Use map. Construction Impacts Comments were received regarding the level of detail provided in the DEIR associated with construction including schedule, staging areas, routing, and adequacy of mitigation. A potentially significant impact was identified due to the temporary increase in construction - related traffic, which could introduce 8,000 truck trips over the course of , the 30 -month construction period. Construction activities will add traffic trips to the existing street network due to construction equipment, delivery and off -haul of material, as well as construction worker commutes. Temporary partial lane closures along project area roadways may occur during construction activities. Other impacts associated with construction traffic include blocking bicycle or pedestrian facilities and introducing incompatibility due to the shared roadway of vehicles and heavy -duty construction equipment. Mitigation measures TRANS -2 requires that the City prepare a construction management plan that identifies truck routes and staging, develops traffic control measures such as scheduling of major deliveries, use of detour signs (as necessary), lane and sidewalk closure procedures (if required), the need for flaggers or strategic traffic control at key intersections, and notification procedures. Construction truck traffic would be limited to the designated truck routes in Petaluma including McDowell Boulevard, East Washington Street, Lakeville Street, and Petaluma Boulevard North, north of Lakeville Street. Implementation of TRANS -2 would reduce the project's temporary traffic construction impacts to levels below significance. The DEIR identifies the location of staging areas in Section 3.3.4.5. Staging would occur on either side of the Petaluma River and would shift within the plan line as the roadway developed. Staging areas would be fully located within the identified development area of the proposed roadway and thus would not result in any additional impacts beyond what has been identified through the analysis in the DEIR. Construction will require removal of riparian vegetation, protected trees, and will result in work within the channel of the Petaluma River including dewatering. Mitigation measures aim to limit impacts to these biological resources through a combination of avoidance, minimization and offsets, including restrictions on the time of year that certain activities may occur. For example tree removal must avoid the bird - nesting season (Feb. 1 through Aug. 30) or be preceded by nesting bird surveys. Additionally, work, within and adjacent to the Petaluma River must occur during the dry season between June 15 and October 15. As a substantial portion of the construction area is not subject to scheduling restrictions, construction activity will occur year round. As the construction schedule is development, specific activities will be scheduled to occur outside the identified seasonal restriction to meet the - 12 requirements of mitigation. The FEIR clarifies that the overall construction period (30- month) can accommodate the seasonal restrictions. The FEIR further clarifies that the effects of mitigation were considered and evaluated in sufficient detail in the DEIR. Specifically, measure HYD -1 indicates that later stages of design may incorporate benching, terracing or widening of the channel to accommodate the City's no net fill policy. The areas where such features may occur, should they be determined to be required at the final design stage, are within the area that was evaluated for the removal of vegetation and construction of the new roadway and bridge improvements. The FEIR further explains that other than the temporary access to the River for bridge falsework construction, all project impacts are assumed to occur within the eventual right -of -way, which the City will have to acquire or otherwise be granted access. Should design level plans indicate that construction activities or improvements could occur outside of the identified work area, then those effects would be subsequently evaluated. If the construction disturbance area or expected start dates change substantially from the analysis in the DEIR, the environmental analysis may need to be updated and re- evaluated to determine if the EIR would require modification and recirculation in accordance with CEQA Section 21166. Flooding /Hydrology Commenters expressed concern that the effects of hydrology and flooding were not fully addressed in DEIR. The DEIR explains that the project site is currently undeveloped and construction of the roadway would introduce structures and impervious surfaces within the floodway and within the 100 -year floodplain, which has the potential to impede, redirect flows, or increase runoff. The potential changes to the flood conveyance of the River as well as the contribution of the project to peak flood flows are fully analyzed in the DEIR. As is appropriate at this stage of design a preliminary hydrological analysis was prepared and indicated that the project has the potential to raise the base flood elevation by 0.03 feet in the floodplain and floodway immediately upstream of the bridge and would result in no change downstream. In order to mitigate potential impacts and in accordance with the City's no net fill policy, a design level hydrological analysis utilizing specific bridge abutment design shall be conducted to determine the bridge's potential to increase the base flood water surface elevation within the regulatory floodway (Measures HYD -1). The FEIR (Master Response 7) explains that the design level hydrologic model would incorporate any proposed benching, widening or adjustments to the bridge features. The final design will be refined in order to meet the City's no net fill standard. For example, shifting bridge abutments 1 to 3 feet or more apart could potentially eliminate an increase of 0.03 feet in base flood elevation. Similarly widening, benching or other refinements to the final design could be implemented so long as they remain within the area of analysis for the project. The DEIR also discusses the potential impacts to flooding that may result from the new 8.6 acres 3--13 of impervious surfaces (new bridge, sidewalks, and roadway) that the project will introduce. Using the Flood Control Design manual prepared by Sonoma County Water Agency, pre and post - project runoff were calculated to increase by about 6 to 7 cubic feet per second. The FEIR clarifies that the timing of the runoff from the project site is unlikely to coincide with the peak flow of the river given that runoff from the new roadway will occur promptly (under Y, hour) due to its proximity to the river, whereas the timing of the peak flow runoff from the greater watershed would be delayed. As such, any added runoff from the project site would be evacuated well before the peak flows reached the location of the new bridge. Thus, there is no measureable change in the water surface elevation downstream as a result of the new impervious surfaces. The City's no net fill requirement is intended to preclude new development from contributing to flooding due to the introduction of fill and/or otherwise increasing surface flood elevations. The FEIR explains that the Rainier hydraulic modeling analyzes the potential effect of the proposed improvements, but not other future construction projects in the area. Other future projects are not included in the hydraulic analysis since the level of development is unknown at this time and would be considered speculative. However, at the time that future development is proposed each project will be subject to environmental review, compliance with the City's standard for no net fill and, as appropriate, may be subject to quantitative hydraulic modeling to assess potential impacts on surface flood elevations from introduction of new impervious surfaces. Project Benefits Commenters note that an obvious relief in traffic congestion was not readily apparent based on the analysis conducted as part of the DEIR; rather, certain intersections would experience an increase in delay times and a degradation of level of service. The Rainier Cross -Town Connector has long been envisioned as a means to reduce traffic congestion associated with implementation of the City's General Plan. The DEIR presents intersection level of service (LOS) data as well as delays at study area intersections under the opening year condition and at build out of the General Plan (cumulative condition). The tables in the DEIR circulation section and cumulative impact discussion provide a side -by -side comparison on traffic conditions both with and without the proposed project. CEQA strives to identify the adverse impacts of the project, rather than identify the project benefits. However, in an effort to better demonstrate the net affect of Rainier on traffic congestion, the FEIR provides Tables B and C, which show the net change in vehicle delay and LOS between the no project scenario and the with project scenario. In general Rainier is projected to reduce delay times and improve the LOS at existing intersections, whereas new intersections are projected to experience increased delay times. Operation of a new east -west connector via the proposed Rainier Cross -Town Connector will shift the traffic distribution pattern thereby alleviating some of the congestion at certain intersections. However, there will continue to be specific choice points within the circulation system where traffic accumulates and delays occur. Under the "with project scenario" at opening year and including implementation of measure TRANS -3, all study area intersections would 3-14 operate at acceptably at LOS D or better. Under the cumulative condition a "with Shasta" and "without Shasta scenario" are evaluated. Without Shasta the cumulative traffic conditions result in deficient LOS at two study area intersection. With Shasta, the cumulative traffic conditions with mitigation would achieve acceptable LOS D, however do to a shift in traffic distribution, delays would increase by several seconds at new intersections. The FEIR provides further discussion of cumulative conditions under Master Response 5. The FEIR considers how Rainier would affect travel time on Washington Street. Table D provides the net change between the "no project condition" and the "with project condition ". Travel time is reduced between 9 and 42 percent and the average speed increases between 1.2 and 4.5 miles per hour under the with Rainier scenario. Thus, the FEIR clarifies that project would improve travel conditions along Washington Street. The FEIR provides further discussion of affects to Washington Street congestion under Master Response 6. The FEIR for the Rainier Cross -Town Connector clarifies that the new roadway would result in reduced travel times for certain routes, decreased delay times at study area intersection, and a shift in traffic patterns that would increase delays at other intersections. As a major infrastructure project, the Rainier would introduce a new east -west travel corridor thereby alleviating some of the demand placed on the few existing east -west roadways that bypass the Petaluma River, Highway 101 and the SMART tracks. Impacts that are Significant and Unavoidable The DEIR did not identify any potentially significant impacts of the project on the environment that cannot be mitigated. However, the DEIR identifies cumulative impacts associated with General Plan buildout, that in combination with existing and planned future development would have the potential to result in significant and unavoidable impacts to air quality, noise and traffic. Findings and Overriding Considerations CEQA Guidelines Section 15091 requires public agencies to make one or more written findings for each of the significant environmental effects identified in. an EIR in conjunction with project approval. CEQA Guidelines Section 15093 requires a statement of overriding considerations for significant and unavoidable impacts. Although no significant and unavoidable impacts of the project were identified, the project has the potential to result in cumulatively considerable unavoidable significant impacts previously identified in the City's General Plan EIR to the following resource categories: air quality, noise and traffic. While the proposed Rainier Cross - Town Connector project will not cause significant and unavoidable impacts, it will cumulatively contribute to previously identified significant and unavoidable impacts. As such, the City Council would need to adopt a separate Statement of Overriding Considerations for significant and unavoidable impacts, similar to those adopted at the time the General Plan was adopted. Planning Commission Hearing on the FEIR (June 23, 2015) Per the City's CEQA Guidelines, the Planning Commission requested that the FEIR return to the commission for consideration. The commission's discussion is expected to focus on the changes in the DEIR and the responses to public comments on the DEIR, per CEQA Guidelines Section 3-15 15089(b). The Planning Commission will comment on the adequacy of the document and decide whether or not to recommend the document to the City Council for certification. Subsequent Actions on the FEIR At a noticed public meeting the City Council will consider whether to certify the Final EIR and take other CEQA related actions. If the EIR is certified, the mitigation monitoring and reporting program as presented in the FEIR will also be adopted, unless the City Council identifies alternative mitigation measures or determines that mitigation is not feasible. Public Comment on FEIR On May 28, 2015 a Notice of Public Hearing was published in the 4rgus Courier and notices were sent to residents and property owners within 500 feet of the proposed Rainier Cross -Town Connector Alignment, as well as interested parties who requested notification. The project file and FEIR have also been made available for review during normal business hours at the City of Petaluma Community, Development Department, Planning Division, located at 11 English Street in Petaluma. Copies of the FEIR have been made available at the Petaluma Library, the Community Center, City Hall, and on the City's website. Additionally, copies of the documents have been made available for purchase by the-public for the cost of printing. Written comments pursuant to the public hearing notice that were received prior to the distribution of the staff report are attached. ATTACHMENTS Attachment 1: Resolution recommending certification of the Final Environmental Impact Report and adoption of a Mitigation Monitoring and Reporting Program. Attachment 2: Public comment on the FEIR. Attachment 3: Final Environmental Impact Report (Previously provided, hand delivered on May 28, 2015). (DEIR previously provided on July 24, 2014.) 3-16 ATTACHMENT 1 RESOLUTION NO. RESOLUTION OF THE CITY OF PETALUMA PLANNING COMMISSION RECOMMENDING TO THE CITY COUNCIL CERTIFICATION OF AN ENVIRONMENTAL IMPACT REPORT, AND ADOPTION OF A MITIGATION MONITORING AND REPORTING PROGRAM FOR THE RAINIER CROSS -TOWN CONNECTOR PROJECT, PURSUANT TO THE CALIFORNIA ENVIRONMENTAL QUALITY ACT WHEREAS, The City of Petaluma Public Works Department ( "Applicant ") proposes a 0.65 mile, four lane arterial roadway featuring bridge, median, pedestrian, bicycle facilities and new signalized intersection. The Rainier Cross -Town Connector will connect North McDowell Avenue on the eastern side of Highway 101 to Petaluma Boulevard North on the western side of the City ( "Project "); and WHEREAS, the Project boundaries constitute a roadway and appurtenant improvements that would extend at grade from the signalized north McDowell Avenue Extension, cross beneath Highway 101 under an elevated portion of the freeway that will be constructed as part of the Marin - Sonoma Narrows HOV Project, would cross over the Sonoma Marin Area Rail Transit (SMART) Corridor and Petaluma River via a bridge, and return at grade proximate to Petaluma Boulevard North where it will terminate at a signalized T- intersection; and WHEREAS, the Notice of Preparation of the Draft Environmental Impact Report for the Project was mailed to all responsible and affected agencies on August 11, 2011, pursuant to Public Resources Code Section 21080.4 and California Environmental Quality Act ("CEQA") Guidelines Section 15082; and WHEREAS, a Draft Environmental Impact Report ( "Draft EIR ") was prepared for the Plan in accordance with Public Resources Code Section 21000 et seq. and CEQA Guidelines Section 15000 et seq., and circulated for public review between July 24, 2014 and Sept. 8, 2014, with a notice inviting comments on the Draft EIR given in compliance with CEQA Guidelines Section 15085; and WHEREAS, Draft EIR relies on the EIR for the City of Petaluma General Plan 2025, certified by City Council Resolution No. 2008 -058 N.C.S on April 7, 2008, for information and analysis relating to certain cumulative impacts and incorporates said analysis and conclusions to the extent applicable, as identified in the Draft EIR; and WHEREAS, the City distributed copies of the Draft EIR in conformance with CEQA to the public agencies which have jurisdiction by law with respect to the project and to other interested persons and agencies and sought the comments of such persons and agencies; and, WHEREAS, the Planning Commission held a public meeting and hearings on August 12, 2014 to consider the Draft EIR; and WHEREAS, the City Council held a public meeting and hearing on September. 8, 2014 to consider the Draft EIR; and WHEREAS, written and oral comments to the Draft EIR have been received and responses to those comments have been prepared in the form of a Final Environmental Impact Report for the Project ( "Final EIR "); and t °1 Page 1 WHEREAS, the Planning Commission held a noticed public meetings on June 23, 2015, at which time it considered the Final EIR, accepted public testimony and made a recommendation to the City Council; and WHEREAS, the Project does not have the potential to have a significant adverse impact on wildlife resources as defined in the State Fish and Game Code, either individually or cumulatively, though it is not exempt from Fish and Game filing fees; and WHEREAS, the Project is not located on a site listed on any Hazardous Waste Site List compiled by the State pursuant to Section 65962.5 of the California Government Code; and WHEREAS, the EIR identified several potentially significant impacts that will be reduced to a less than significant level with specified mitigation measures, and pursuant to CEQA Guidelines Section 15091(d), a Mitigation Monitoring and Reporting Program has been prepared and set forth with the Final EIR to ensure that all mitigation measures which serve to reduce environmental impacts of the Project are fully implemented; and NOW THEREFORE, BE IT RESOLVED that the Planning Commission recommends that the City Council: 1. Certify the Environmental Impact Report as an adequate description of the impacts of the Project in compliance with CEQA, the State CEQA Guidelines, and the City of Petaluma Environmental Guidelines. 2. Adopt the Mitigation Monitoring Program set forth within the Final EIR. _;-I S Page 2 Ervin, Olivia From: geneehlers @comcast.net Sent: Friday, June 05, 2015 8;27 AM To: Ervin, Olivia Subject: Rainier Cross -Town Connector 6/3/'15 Dear Sir or Madam, We are writing in regard to the proposed Rainier Cross -Town Connector. We live on Prince Albert Court and are strongly opposed to the Rainier Cross -Town Connector. We have definitely noticed a marked increase in the noise, traffic, and litter now that the F'riedman's shopping center (Deer Creek Village) has been completed. Now if the cross town connector is constructed imagine how much more noise, traffic, and litter we will have to incur on a daily basis. We ask that you vote NO to building a cross town connector at Rainier. Thank you Gene and Joan Ehlers 229 Prince Albert Court Petaluma, CA 94954 3 -19 Ervin, Olivia From: Molly Farquhar <mollymac77 @gmail.com> Sent: Wednesday, June 10, 2015 8 :55 PM To: Ervin, Olivia Subject: Cross town connector I am a resident of Petaluma on the East side close to Ranier. This project has seen one delay after another. I have noticed that there are many homes and businesses south of East Washington who use the Caulfield overpass in order to get to the West side of town and then go North to D street in order to reach Petaluma Blvd. The Lakeville and D street intersection is not built for that amount of traffic and it might make sense to extend Caulfield straight over to Petaluma Blvd. This would give both the people on the East and the West side of town an alternate route to either the East Washington or (if it is ever a reality) the Ranier underpass. I hope somebody will have a discussion about this idea. Thank you for your consideration, Mary Farquhar 92 Park Place Drive Petaluma, California 94954 '9-9-0 CITY OF PETAL[.7IVIA, CALIFORNIA MEMORANDUM ContnrnrriO )DevelopineiztDepartfl:ent, fl English Street, Petalmna, CA 94952 _Phone (707) 778 -4301 Fax (707) 778 -4498 , E- Xnail. edd @cipetalwna.ca -us DATE: June 23, 2015 TO: Chair Lin and Members of the Planning Commission FROM:. Olivia Ervin, Environmental Planner SUBJECT: Response to Caltrans Comment Letter on the Final Environmental Impact Report —Rainier Cross -Town Connector The Planning Division received a comment letter from Caltrans on the Final EIR for the Rainier Cross -Town Connector Project. It should be noted that Caltrans also provided a comment letter on the DEM which is included as comment letter 2, beginning on page 2 -23 of the FEIR. Following release of the FEIR, Caltrans provided a subsequent comment letter, dated June 19, 2015, which is attached here. Below is a summary of the additional comments raised along with responses to comments. Comment A: Response 2 -6; 2 -8: This comment has not been addressed. Our previous comment asked if the data has been verified according to 2014 conditions, not 2012 conditions. It is best to . use current data, as data's usefulness diminishes with time. - Response A: As explained in response to comments 2 -6 and 2 -8 traffic count data was collected in 2007 and later verified in 2012. As presented in Table 14.12 -2, the counts collected in 2007 were found to be higher than the counts collected in 2012, and therefore represent conservative traffic conditions. There was not a subsequent verification conducted in 2014. Rather, as is appropriate, the DEIR data coincides with the Notice of Preparation which was released in 2011. In any event, the baseline traffic volumes as anticipated for opening year 2020 are used to assess traffic impact and serve as the foundation of the traffic analysis. The 2020 traffic data show an elevated traffic volume relative to the existing condition, be it 2014 or earlier, since population growth is presumed to add more volume to network roadway. As explained in the FEIR Master Response 2, the use of a future baseline is appropriate for the analysis(see page 2-7 of the FEIR). The baseline analysis is conservative since 2020 traffic volumes, as opposed to.2007 or 2014 traffic volumes are used. Comment B: Response 2 -7: As we are unable to obtain volumes from PeMS vehicles detection station (VDS) sites 42815, 42819, 42831, and 42833 for the date range specified in the report, we cannot confirm that the values used in Table 4 -12 -6 are reliable. Please specify which dates were actually used for each VDS. Response B: As requested, the dates for which data was available are provided below by VDS location: • 42815 and 42831 —September 15-22,2010 • 42822 —March 3-11,2010 ® 42819— September 17 -23, 2010 • 42833 —March 17 -25, 2010 Should you have any questions or concerns please feel free to contact me at 707 - 778 -4556 or oervin@ci.petaluma.ca.us. STATE OF CALIFORNIA -- CALIFORNIA STATE TRANSPORTATION AGENCY EDMUND G. BROWN Sr. Governor DEPARTMENT OF TRANSPORTATION DISTRICT 4 P.O. BOX 23660, MS-101) OAKLAND, CA 94623 -0660 PHONE (510) 286 -5528 FAX (510) 286 -5559 TTY 711 http://www.dot,ca.gov/dist4/ June 19, 2015 Ms. Olivia Ervin Planning Division City of Petaluma I I English Street Petaluma, CA 94952 Dear Ms. Ervin: Serious Drought. Help save waterl SON1011030 SON - 101 -5.61 SCH# 2011082032 Rainier Cross -Town Connector — Final Environmental Impact Report (FEIR) Thank you for including the California Department of Transportation (Caltrans) in the environmental review process for the project referenced above. The proposed project would construct a new city road overcrossing of US 101 in Petaluma. The overcrossing would occur at Rainier Avenue, approximately halfway between the existing overcrossings at Corona Road (to the northwest) and East Washington Street (to the southeast). Caltrans' new mission, vision, and goals signal a modernization of our approach to California's transportation system. We review this local development for impacts to the State Highway System in keeping with our mission, vision, and goals for sustainability /livability /economy, and safety/health. We provide these comments consistent with the State's smart mobility goals that support a vibrant economy, and build communities, not sprawl. The following comments are based on the FEIR provided to us. Highway Operations Response 2 -6; 2 -8: This comment has not been addressed. Our previous comments asked if the data has been verified according to 2014 conditions, not 2012 conditions. It is best to use current data, as data's usefulness diminishes with time. Response 2 -7: As we are unable to obtain volumes fiom PeMS vehicle detection station (VDS) sites 42815, 42819, 42822, 42831, and 42833 for the date range specified in the report, we cannot confirm that the values used in Table 4 -12 -6 are reliable. Please specify which dates were actually used for each VD S. Please feel free to call or email Greg Currey at (510) 286 -5623 or gregory.currey @dot.ca.gov with any questions regarding this letter. "Provide a safe, sustainable, integrated and efficienl transportation system to enhance Cal fbima' economy dnd livability Ms. Olivia Ervin/City of Petaluma June 19,201-5 Page 2 Sincerely, PATRICIA MAURICE District Branch Chief Local Development — Intergovernmental Review c: Scott Morgan, State Clearinghouse "Provide a safe, sustainable, integrated and efficient Ivansportation system to enhance Califonda s economy and livability" a 3 ATTACHMENT 4 PUBLIC COMMENT LETTER From: REKB @aol.com<mailto:REKB @aol.com> mailto:REKB @aol.com_ _ Sent: Friday, June 26, 2015 2:21 PM To: - City Clerk Subject: Rainier Cross Town Connector Environmental Report. TO: City Council Members SUBJECT: Rainier Cross Town Connector Environment Report Comments. Environmental Mitigation is not achieved with political promises, but with city funds. If the city can not identify specific funding, then the Environmental Report should state: mitigation not achievable: No funds to achieve mitigation. Rainier boils down to one issue: $$$$. Petaluma is technically bankrupt, but legally still in business only because it is government. The roadway mess we have today makes clear the importance of planning for the future. That failure belongs solely to City Council. Let's look at the logic of carrying this Rainier Connector business through. Your new budget says City Council will only spend $2.5 million on roadway repair (if you do not reduce it further). The city faces a back log of over $100 million due to under funding of repairs on the approximately 370 miles of roadway throughout Petaluma growing exponentially - now at $8 million per year. So following through with this Rainier Street connection will suck up all future roadway repair. This project will be creating the conditions that will require City roads to go without repair for 20 -30 years which will create an environmental disaster. That issue is nowhere in the Environmental Report. Again, Environmental Mitigation requires money; so where is the money? I ran a word search and found "dollars" and $ only once in the entire report. Yes, it is true! It is as if money is irrelevant when it is absolutely central. The only way that Petaluma economic Hari Karl can be avoided would be if the Rainier Connector would create sufficient tax revenues to pay for itself entirely. It is impossible for the Connector to pay its own way though tax revenue generation. It does not improve a crucial aspect: highway 101 access. The City of Petaluma lacks the capital to even seed this project. I am not informing you anything you do not know. Widening of Highway 101 will only marginally change access but then visitor /shopper traffic will immediately encounter the Petaluma potholes, intersections, bottle necks, and traffic patterns. City Hall lacks any competence to gauge if increased traffic flow would translate into increase sales taxes. City Staff has no idea of how much commerce neighboring cities will lure customers away simply because the connector worsens our 370 miles of rotten city streets and lousy access to highway 101. Besides, the two regional employment centers are north and south of Petaluma. So why should traffic go the wrong direction specifically shop in Petaluma? City Council represents various lobby groups, not the people of Petaluma. So, people have generally concluded City Council is the source of all this connivance that has created the roadway mess, the fiscal mess, and distrust... no not distrust...— disgust. Find some backbone and acquire land but tell the people no construction until Petaluma roads are fixed. Sincerely Richard E. K. Brawn 141 Grevillia Drive Petaluma, CA 94952 4 -1