HomeMy WebLinkAboutPlanning Commission Resolution 2018-21A 06/26/2018RESOLUTION 2018-21 A
CITY OF PETALUMA PLANNING COMMISSION
ADOPTING A MITIGATED NEGATIVE DECLARATION
AND MITIGATION MONITORING AND REPORT PROGRAM
FOR THE SAFEWAY FUEL CENTER PROJECT
LOCATED AT 335 SOUTH MCDOWELL BOULEVARD
APN: 007-820-046
FILE NO: PLSR-13-0012
WHEREAS, Rutan & Tucker, LLP., on behalf of property owner Washington Square Associates, LLC.,
submitted an application for Site Plan and Architectural Review approval to demolish an existing 13,770
square foot vacant building and construct a new 5,931 square foot fueling canopy, 16 fuel dispensers, a
697 square foot convenience store, and associated landscaping and appurtenant parking ("Project")
located at 335 South McDowell Boulevard at APN 007-820-046; and
WHEREAS, the Project is subject to the Petaluma General Plan 2025, adopted by the City on May
19, 2008; and,
WHEREAS, in evaluating certain potential environmental effects of the Project in the Initial Study,
including but not limited to effects on air quality, biology, cultural resources, geology and soils, hazardous
materials, noise, and traffic, the City relied on the General Plan 2025 EIR certified on April 7, 2008 (General
Plan EIR) by adoption of Resolution No. 2008-058 N.C.S., which is incorporated herein by reference; and,
WHEREAS, the General Plan EIR identified potentially significant environmental impacts and
related mitigation measures and the City also adopted a Statement of Overriding Considerations for
significant impacts that could not be avoided; and,
WHEREAS, the City prepared an Initial Study (Exhibit 1) for the proposed Project consistent with
CEQA Guidelines §15162 and §15163 and determined that a Mitigated Negative Declaration was
supported by substantial evidence in the records and that no new or additional significant environmental
irnpacts beyond those identified in the General Plan EIR would result from implementation of the Project;
and,
WHEREAS, pursuant to Section 15074 of the CEQA Guidelines, a Mitigation Monitoring and
Reporting Program was prepared (and is labeled Exhibit 2), attached hereto and made a part the record
hereof; and
WHEREAS, on or before April 5, 2018 the City's Notice of Intent to Adopt a Mitigated Negative
Declaration based on the Initial Study, providing for a 30 -day public comment period commencing April
5, 2018 and ending May 7, 2018; and a Notice of Public Hearing to be held on May 8, 2018 before the
City of Petaluma Planning Commission, were published and mailed to all residents and property owners
within 500 feet of the Project; and,
WHEREAS, the Planning Commission held a duly noticed public hearing on May 8, 2018, at which
time all interested parties had the opportunity to be heard; and,
WHEREAS, on May 8, 2018, the Planning Commission continued the item to a date certain of June
26, 2018 to allow interested parties an opportunity to review technical studies and comments received
about the project; and
WHEREAS, a notice of public hearing was published in the Argus Courier on June 13, 2018 and
Planning Commission Resolution No. 2018-21 A Page 1
mailed to all occupants and property owners within 500 feet of the Project and all commenters on the
project; and,
WHEREAS, the Planning Commission held a duly noticed public hearing on June 26, 2018, at which
time all interested parties had the opportunity to be heard; and,
WHEREAS, the Planning Commission considered the Project, the Mitigated Negative Declaration
and supporting Initial Study, Response to Comments, the staff reports dated May 8, 2018 and June 26,
2018 analyzing the Project, and received and considered all written and oral public comments on
environmental effects of the Project which were submitted up to and at the time of the public hearings;
and
WHEREAS, the Initial Study applies the BAAQMD's California Environmental Quality Act - Air Quality
Guidelines, May 2012, including the BAAQMD thresholds of significance adopted in June 2010. As lead
agency under CEQA, the City of Petaluma has the discretion to rely upon the BAAQMD CEQA Guidelines
and thresholds of significance since they include the best available scientific data and most conservative
thresholds available for comparison of the Project's emissions. Comparison of the Project's emissions
against these thresholds provides a conservative assessment as the basis for a determination of
significance; and,
WHEREAS, pursuant to further analysis in the Initial Study, including evaluation using the BAAQMD
CEQA Guidelines and thresholds of significance, the Project does not make a considerable contribution
to a significant cumulative air quality or greenhouse gas emissions impact found to be significant and
unavoidable in the General Plan 2025 EIR, because the Project's emissions are below significance
thresholds identified; and,
WHEREAS, the Mitigated Negative Declaration reflects the City's independent judgment and
analysis of the potential for environmental impacts from the Project; and,
WHEREAS, the Mitigated Negative Declaration and related project and environmental
documents, including the General Plan 2025 EIR and all documents incorporated herein by reference,
are available for review in the City Community Development Department at Petaluma City Hall, during
normal business hours. The custodian of the documents and other materials which constitute the record
of proceedings for the proposed project is the City of Petaluma Community Development Department,
1 1 English St. Petaluma, CA 94952, Attention: Milan Nevajda; and
WHEREAS, the Initial Study for the Project identified no potentially significant impacts, and therefore
the Project would not result in any significant impacts to the environment.
NOW THEREFORE, BE IT RESOLVED BY THE PLANNING COMMISSION OF THE CITY OF PETALUMA AS
FOLLOWS:
A. The foregoing recitals are true and correct and incorporated herein by reference.
B. Based on the its review of the entire record herein, the Planning Commission makes the following
findings:
The proposed construction of the Safeway Fuel Station project at 335 South McDowell
Boulevard is, for the reasons discussed in the May 8 and June 26, 2018 2018 Planning
Commission staff reports, consistent with the following Petaluma General Plan policies: Policy
1-P-2 (Promote infill development), Policy 1-P-6 (mixed-use development) 1-P-11 (Land use
intensification at strategic locations), Policy 1-P-14 (street trees), Policy 2-P-5 (Strengthen the
visual and aesthetic character of major arterials), Policy 4-P-10 (Electric Charging stations),
Policy 5-P-42 (expand bus transit), Policy 6-P-29 (Integrate Art), Policy 10-P-3 (Protect Public
Health and Welfare), and Policy 10-P-4 (Transport of Hazardous Materials).
Planning Commission Resolution No. 2018-21 A Page 2
2. The Project is consistent with the "Community Commercial" General Plan land use designation
because the project contributes to the variety of commercial services provided to the larger
the region from this area of Community Commercial property.
C. Based on its review of the entire record herein, including the Mitigated Negative Declaration, the
Initial Study, Response to Comments, all supporting, referenced and incorporated documents and
all comments received, the Planning Commission finds that there is no substantial evidence that
the Project will have a significant effect on the environment, that the Mitigated Negative
Declaration reflects the City's independent judgment and analysis, and that the Mitigated
Negative Declaration, Initial Study and supporting documents provide an adequate description
of the impacts of the Project and comply with CEQA, the State CEQA Guidelines and the City of
Petaluma Environmental Guidelines.
ADOPTED this 26th day of June, 2018, by the following vote:
Commission Member
Aye
No
Absent
Abstain
Councilmember Healy
X
Chair Benedetti- Petnic
X
Alonso
X
Bauer
X
Gomez
X
Marzo
X
Vice Chair Wolpert
X
Gina Benedetti - Petnic, Chair
ATTEST: APP ED AS TO FORM:
�
,�
Heather Hines, commission Secretary Eric Danly, City A--tiorney
Planning Commission Resolution No. 2018-21A Page 3
Exhibit 1
SAFEWAY FUEL CENTER
335 South McDowell Boulevard
Prepared By:
City of Petaluma
11 English Street
Petaluma, CA 94952
18 5 g
March 29, 2018
Planning Commission Resolution No. 2018-21A Page 1
of Petaluma
CITY OF PETALUMA
SAFEWAY FUEL CENTER- 335 SOUTH MCDOWELL BOULEVARD
CEQA ENVIRONMENTAL CHECKLIST AND INITIAL STUDY
OVERVIEW AND BACKGROUND
Fuel Center IS/MND
Project Title:
Safeway Fuel Center
Lead agency name and address:
City of Petaluma
11 English Street
Petaluma, CA 94952
Contact person and phone number:
Olivia Ervin, Environmental Planner
(707) 778-4556
Project Location:
335 South McDowell Boulevard
APN: 007-820-046
Project sponsor's name and address:
Matthew Francois
Rutan & Tucker, LLP.
Five Palo Alto Sqaure, 3000 EI Camino Real, Ste. 200
Palo Alto, CA 94306
Property Owners:
Natalie Mattei
Senior Real Estate Manager
Safeway Inc.
11555 Dublin Canyon Road
Pleasanton, CA 94588
925 226-5754
General plan designation:
Community Commercial
Zoning:
Commercial C2
Description of project:
The project consists of the redevelopment of 0.71 acres
located in the Washington Core Subarea and includes Site
Plan and Architecture Review (SPAR). Site improvements
include the construction of a Safeway Fuel Center with 16
covered fuel pumping positions, a 697 ft2 retail convenience
store, landscaping and appurtenant parking. Site
preparation will include the demolition of the existing
13,770 ft2 commercial building and associated existing site
improvements.
Surrounding land uses and setting;
The project site is located at the southeast corner of the
briefly describe the project's
Washington Square shopping center, at the northwest
surroundings:
corner of the South McDowell/Maria Drive intersection. The
project site is bounded by commercial retail to the west and
north, single-family residential south of the project site,
across South McDowell Blvd, and institutional and
recreational uses to the east across Maria Drive.
Other public agencies whose approval
BAAQMD J number in order to allow for demolition.
is required (e.g. permits, financial
BAAQMD Authority to Construct Permit to allow for
approval, or participation agreements):
operation of a Gas Station.
Have California Native American tribes
The Federated Indians of Graton Rancheria did not request
traditionally and culturally affiliated with
consultation within the statutory timeframe provided by
the project area requested consultation
Public Resources Code §21080.3.1. Notice was sent to
pursuant to Public Resources Code
Graton Rancheria on June 8, 2017. The City of Petaluma
section 21080.3.1? If so, has
has not received a response from Graton Rancheria.
consultation begun?
March 2018 Page 2 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
SAFEWAY FUEL CENTER
TABLE OF CONTENTS
Safeway Fuel Center IS/MND
PAGE #
1. OVERVIEW AND BACKGROUND..............................................................................................................4
1.1.
PROJECT DESCRIPTION.....................................................................................................................5
1.1.
PROJECT LOCATION...........................................................................................................................7
Health Risk Thresholds of Significance........................................................................................16
1.2.
ENVIRONMENTAL SETTING................................................................................................................8
Air Quality Construction Emissions..............................................................................................18
2. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED.....................................................................9
Table 4
3. EVALUATION OF ENVIRONMENTAL IMPACTS....................................................................................10
3.1.
AESTHETICS.......................................................................................................................................10
3.2.
AGRICULTURAL AND FORESTRY RESOURCES............................................................................13
3.3.
AIR QUALITY.......................................................................................................................................14
3.4.
BIOLOGICAL RESOURCES...............................................................................................................23
3.5.
CULTURAL RESOURCES..................................................................................................................26
3.6.
GEOLOGY AND SOILS.......................................................................................................................28
3.7.
GREENHOUSE GAS EMISSIONS......................................................................................................31
3.8.
HAZARDS/HAZARDOUS MATERIALS..............................................................................................35
3.9.
HYDROLOGY AND WATER QUALITY...............................................................................................39
3.10.
LAND USE AND PLANNING...............................................................................................................41
3.11.
MINERAL RESOURCES......................................................................................................................42
3.12.
NOISE...................................................................................................................................................43
3.13.
POPULATION AND HOUSING: ..........................................................................................................
48
3.14.
PUBLIC SERVICES.............................................................................................................................49
3.15.
RECREATION......................................................................................................................................50
3.16.
TRANSPORTATION AND CIRCULATION..........................................................................................51
3.17.
TRIBAL CULTURAL RESOURCES....................................................................................................58
3.18.
UTILITIES AND SERVICE SYSTEMS.................................................................................................59
3.19.
MANDATORY FINDINGS OF SIGNIFICANCE (Cal. Pub. Res. Code §15065) .................................63
4. REFERENCE DOCUMENTS: .................................................................................................................... 65
TABLE OF FIGURES
Figure1 Site Aerial............................................................................................................................................7
Figure2 General Plan Land Use.......................................................................................................................7
Figure 3 Safeway Fuel Center Rendering (South)..........................................................................................8
Figure 4 Safeway Fuel Center Rendering (North)...........................................................................................8
Figure 5 Safeway Fuel Center Layout..............................................................................................................8
LIST OF TABLES
Table 1
Air Quality Thresholds of Significance.........................................................................................15
Table 2
Health Risk Thresholds of Significance........................................................................................16
Table 3
Air Quality Construction Emissions..............................................................................................18
Table 4
Air Quality Operational Emissions................................................................................................18
Table 5
Health Risk Exposure Construction..............................................................................................20
Table 6
Community Health Risk Exposure.................................................................................................20
Table 7
Cumulative Health Risk Exposure.................................................................................................21
Table8
GHG Emissions................................................................................................................................33
Table 9
Construction Phase Noise Levels..................................................................................................46
Table 10
Summary of Existing Plus Project Conditions.............................................................................53
Table 11
Summary of Background Plus Project Conditions......................................................................54
Table 12
Summary of Cumulative (2025) plus Project Conditions............................................................55
March 2018 Page 3 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
1. OVERVIEW AND BACKGROUND
Fuel Center IS/MND
General Plan: The Petaluma General Plan 2025, adopted in 2008, serves the following purposes:
• Reflects a commitment on the part of the City Council and their appointed representatives and staff to
carry out the Plan;
• Outlines a vision for Petaluma's long-range physical and economic development and resource
conservation; enhances the quality of life for all residents and visitors; recognizes that human activity
takes place within the limits of the natural environment; and reflects the aspirations of the community;
• Provides strategies and specific implementing policies and programs that will allow this vision to be
accomplished;
• Establishes a basis for judging whether specific development proposals and public projects are in
harmony with Plan policies and standards;
• Allows City departments, other public agencies, and private developers to design projects that will
enhance the character of the community, preserve and enhance critical environmental resources, and
minimize impacts and hazards; and
• Provides the basis for establishing and setting priorities for detailed plans and implementing programs,
such as Development Codes, the Capital Improvement Program (CIP), facilities and Master Plans,
redevelopment projects, and the Urban Growth Boundary (UGB).
General Plan EIR: Because CEQA discourages "repetitive discussions of the same issues" (CEQA Guidelines
section 15152b) and allows limiting discussion of a later project that is consistent with a prior plan to impacts
which were not examined as significant effects in a prior EIR or to significant effects which could be reduced by
revisions in the later project (CEQA Guidelines section 15152d), no additional benefit to the environment or
public purpose would be served by preparing an EIR merely to restate the analysis and the significant and
unavoidable effects found to remain after adoption of all General Plan policies/mitigation measures. All General
Plan policies adopted as mitigation apply to the subject Project.
The General Plan EIR reviewed all potentially significant environmental impacts and developed measures and
policies to mitigate impacts. Nonetheless, significant and unavoidable impacts were determined to occur under
the General Plan. Therefore, the City adopted a statement of overriding considerations, which balances the
merits of approving the project despite the potential environmental impacts. The impacts identified as significant
and unavoidable in the General Plan EIR are:
• Increased motor vehicle traffic which would result in unacceptable level of service (LOS) at six
intersections covered in the General Plan:
o McDowell Boulevard North/Corona Road, Lakeville Street/Caulfield Lane, Lakeville Street/East
D Street, Petaluma Boulevard South/D Street, Sonoma Mt. Parkway/East Washington Street,
and McDowell Boulevard North/Rainier Avenue.
• Traffic related noise at General Plan buildout, which would result in a substantial increase in existing
exterior noise levels that are currently above City standards.
• Cumulative noise from proposed resumption of freight and passenger rail operations and possible
resumption of intra -city trolley service, which would increase noise impacts.
• Air quality impacts resulting from General Plan buildout to population levels that could conflict with the
Bay Area 2005 Ozone Strategy. (This regional air quality plan has since been replaced by the Bay Area
2017 Clean Air Plan, which is further discussed in Sections 3.3 Air Quality and 3.7 Greenhouse Gases.)
• A possible cumulatively considerable incremental contribution to greenhouse gas emissions from
development under the General Plan.
Because CEQA discourages "repetitive discussions of the same issues," this environmental document tiers off
of the General Plan EIR (SCH NO.: 2004082065), which was certified on April 7, 2008, to examine site-specific
impacts of the proposed project, as described below. A copy of the City of Petaluma's General Plan and EIR
are available at the Community Development Department, 11 English Street, Petaluma, California 94952,
March 2018 Page 4 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma
Fuel Center IS/MND
during normal business hours and online at littp:Hcitvofnetaluma.net/cdd/plan-qeneral-plan,html.
/cityofnetaluma.net/cdd/plan-general-plan,html.
1.1. PROJECT DESCRIPTION
The Safeway Fuel Center project proposes the development of a fuel station located at 335 South McDowell
Boulevard. The General Plan Land Use Designation is Community Commercial with a zoning designation of
Commercial 2 (C2). Gas Station is a permitted use under the Commercial 2 zoning. The project site is comprised
of 32,450 ft2 at the southeast corner of the Washington Square Shopping Center and is surrounded by
commercial, residential and institutional uses.
Site Preparation and Demolition
Site preparation will involve demolition of the existing 13,770 ft2 multi -tenant commercial building (c.1974) and
removal of existing site improvements including pavement, curbs, parking spaces and two ornamental trees.
The building is currently vacant and was previously occupied by retail uses. The existing commercial building
was subject to a limited asbestos and lead based paint survey that identified the presence of asbestos
containing material (ACM), but lead based paint (LBP) was not identified. All demolition activities are required
to adhere to applicable regulations in order to ensure safe removal and disposal of ACMs.
Site preparation will also include grading and the introduction of fill material to increase the site surface grades
to an elevation matching that of the adjacent parcels. Existing public utilities will remain in place and will be
used to service the new facilities onsite. The project will introduce an infiltration/bio-filtration trench that serves
to collect and filter stormwater emanating from the site. The gradient onsite will be constructed such that all
surface flows onsite are directed to the trench drain with filtered inserts or the infiltration/bio-filtration trench in
order to pre -treat runoff containing sediment and hydrocarbons (Civil C-2).
New Construction/Fuel Station
The project proposes the construction of a fuel center featuring 16 fuel positions (8 pumps with two fuel positions
per pump) located beneath a 62 by 95 foot canopy and a 697 square foot convenience store to compliment the
fuel station use. Associated site improvements include vehicle parking adjacent to the convenience store (1
accessible stall, 4 standard stalls, and one electric vehicle charging station), landscaping, and an exit driveway.
The convenience store is proposed to be located along the southeast edge of the project site abutting Maria
Drive with parking located to the west. The proposed fuel pump island will be located within the center portion
of the site.
Construction activities are expected to take place over a six-month period. The construction will consist of site
preparation and demolition, construction of the fuel pumping stations and convenience store, paving and
application of architectural coatings.
The convenience store will front onto Maria Drive and will feature an architectural treatment that is reflective of
the Safeway brand and consistent with the materials and colors at the existing Safeway store within the
shopping complex. The fueling station canopy will exhibit a clearance height of 16' and a maximum height of
20'6" above grade. Materials of the canopy are proposed to consist of textured cement, painted plaster and
finished with neutral tones and colors.
The convenience store building has a height of 15'8" from grade to top of roof. The finish materials for the
fapade include stucco, cement and concrete. The north elevation faces interior to the pump island and contains
the primary entrance and features two aluminum doors with large storefront windows. The southern elevation
faces the Maria Drive frontage and contains a pedestrian entrance through a single aluminum doorway.
All four elevations are treated with a series of vertical windows complimented by a row of horizontal windows
above. Trellis screens to support climbing vines are provided on all four elevations. The project includes LED
lights located on the canopy ceiling and three yard lights distributed around the periphery of the site. The fueling
station and associated convenience store have been designed in accordance with (C2) development standards
and is subject to site plan and architectural review (SPAR).
March 2018 Page 5 of 65
Planning Commission Resolution No. 2018-21A
Citv of Petaluma Safeway Fuel Center IS/MND
As proposed, the project will introduce approximately 8,000 square feet of landscaping including vegetation, a
bio -filtration trench and permeable cobbles that will replace the existing landscaping (2,971 square feet). The
preliminary landscape plan incorporates drought tolerant plant materials of various species contained within a
landscape strip that wraps around the South McDowell Boulevard frontage and the Maria Drive frontage. The
landscaping plan retains several existing trees and introduces groundcover, shrubs and new trees within the
landscaping strip. A continuous hedge of evergreen shrubs is proposed adjacent to the parking stalls in order
to provide a vegetative screen.
Site Operations
The proposed hours of operation for the fuel center is from 6:00 am until 11:00 pm daily. The fueling pumps will
dispense both unleaded and diesel fuels that will be available from 8 multi -product fuel dispensers. A total of
16 fuel pump stations will provide an opportunity for the simultaneous fueling of SUVS, full size pick-up trucks
as well passenger vehicles. The annual throughput of gasoline will not exceed 8.5 million gallons. The fuel
dispensers will be served by two 20,000 -gallon underground storage tanks. The operation of the fuel station
will require twice daily truck deliveries of fuel that will occur in the morning and evening for a period of
approximately thirty to forty minutes. Truck idling during delivery will be limited to less than 5 minutes. The
delivery trucks will align parallel to the underground storage tanks, on the western portion of the site. The
location of the trucks during fuel delivery is designed to avoid conflict with fuel dispensing activity and not
interfere with vehicle queuing.
The convenience store is proposed to operate from 6:00 am until 11:00 pm and will sell pre-packaged items,
drinks and coffee as well basic auto related items including motor oil. No truck deliveries of merchandise to the
convenience store will occur, as retail products will be brought over by cart from the adjacent Safeway Store.
Site Access
The site is currently accessed via a driveway located on Maria Drive and from the interior of the shopping center.
At operation ingress will be provided via the existing entrance driveway on Maria Drive and from the internal
drive aisles that transect the shopping center. Egress will be provided by an exit only driveway onto Maria Drive
and an exit only driveway at the southwest portion of the project site which outlets to a drive aisle within the
shopping center. Directional signs will be installed at all egress/ingress points to indicate the "DO NOT ENTER"
and "DO NOT BLOCK" areas. The queuing area for vehicles waiting to fuel has been designed to accommodate
at least 12 vehicles outside of the fuel canopy area.
As proposed, Safeway will employ personnel to serve as "Fuel Ambassadors." These employees will be
positioned in and around the fueling area to direct vehicles to open pumps and provide assistance within the
fueling area. "Fuel ambassadors" are proposed during peak hours (7-9 am and 4-6 pm weekdays and 11 am -
1 pm on Saturdays) to ensure that cross flow traffic through the parking lot is not impeded and that efficient
circulation of vehicles and customers is maintained.
Off -Site Improvements
The proposed fuel station parcel abuts the existing Transit Center located along the west side of Maria Drive.
In order to maintain adequate site distance when buses are parked at the stop, the project proposes a bus turn
out area that will improve the line of site for vehicles exiting the Maria Drive fuel station exit. The Transit Center
is proposed to be modified to increase the width of the bus turnout area, which will allow buses to queue outside
of the Maria Drive travel lane. Additionally, the Transit Center amenities will be enhanced to include a new
shelter, seating, landscaping and ancillary improvements.
Project Entitlements: The applicant has applied to the City of Petaluma for Site Plan and Architectural Review
(SPAR).
March 2018 Page 6 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
1.1. PROJECT LOCATION
Fuel Center IS/MND
For discussion purposes, the project site is presumed to be oriented north/south with McDowell Blvd. and Hwy
101 to the west (see project north below). The project site is located at 335 South McDowell Boulevard in
Petaluma, CA, which is a developed commercial parcel within an urbanized area (Figure 1). The assessor
parcel number of the subject site is 007-820-046. The 0.75 -acre parcel is located in the southeastern portion of
the Washington Square shopping center, which is also the northwest corner of the South McDowell
Boulevard/Maria Drive intersection. The project site is bounded by commercial retail to the north and west,
single-family residential to the south of the project site across South McDowell Blvd., and institutional and
recreational uses to the east, across Maria Drive. To the northeast of the Shopping Center is land designated
Medium Density Residential, which underwent a land use amendment as part of the approved Maria Drive
Apartments Project (See Figure 2). Other development projects located in close proximity to the project site
include the Addison Ranch Apartment Complex at 200 Greenbriar, which is currently under construction to
provide an additional 100 residential units within the existing Apartment Complex.
Figure 1: Site Aerial
Figure 2: General Plan Land Use
Legend
Safeway Fuel Center
Medium Density Residential
Low Density Residential
Mixed -Use
City Park
Community Commercial
Education
Source: GP 2025 Figure 1-1 Land Use
Project
North
March 2018 Page 7 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma
Figure 3: Safeway Fuel Center Rendering
(South)
Fuel Center IS/MND
Figure 4: Safeway Fuel Center Rendering (North)
1.2. ENVIRONMENTAL SETTING
Petaluma is located in southwestern Sonoma County along
the 101 corridor approximately 15 miles south of Santa Rosa
and 20 miles north of San Rafael. It is situated at the
northernmost navigable end of the Petaluma River, a tidal
estuary that drains to the San Pablo Bay. The City originated
along the banks of the Petaluma River, spreading outward
over the floor of the Petaluma River Valley as the City
developed. The Valley itself is defined by Sonoma Mountain
on the northeast and by the hills extending northward from
Burdell Mountain on the west. To the south are the Petaluma
Marshlands and the San Francisco Bay beyond.
Petaluma's Urban Growth Boundary (UGB) defines the limits
within which urban development may occur and encompasses
approximately 9,911 acres. The UGB was implemented in
1987 (as the Urban Limit Line), formally adopted as the UGB
in 1998 via Measure I, and will expire in 2018 without
subsequent action. The General Plan and EIR evaluated
potential impacts associated with existing and proposed
development within the UGB.
The project site consists of an underutilized lot with an existing
commercial building constructed circa 1974. The site is an
urbanized area within central Petaluma that is well served by
public utilities and services. The site is located within the
Figure 5: Safeway Fuel Center Layout
Washington Square Shopping Center, which is a community serving retail center with Safeway serving as the
largest retailor. The project site and vicinity are largely developed and have been since the late 1960s. The
project site is well connected to the rest of the City and outer environs as it maintains frontage on two major
arterials and has connectivity to Highway 101.
The project site is generally flat and paved with asphaltic concrete. At present, there is a limited amount of
landscaping that includes ornamental shrubs and trees totaling approximately 2,971 square feet of the total site
(32,450 square feet). Two of the twelve existing trees are proposed for removal and will be replaced with the
introduction of four Red Maples and four Photinia Fraseris. Tree removal and replacement is further discussed
in Section 3.4, Biological Resources, below.
March 2018 Page 8 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
2. ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED
Fuel Center IS/MND
The environmental factors checked below would be potentially affected by this project, involving at
least one impact that is a "Potentially Significant Impact Unless Mitigation is Incorporated" as indicated
by the checklist on the following pages.
1.
Aesthetics
X
8.
Hazards & Hazardous
X
15.
Recreation
by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be
prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
Materials
ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a "potentially significant impact" or "potentially
2.
Agricultural &
adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has
9.
Hydrology / Water
16.
Transportation / Traffic
X
Forestry Resources
because all potentially significant effects (a) have been analyzed adequately in an earlier EIR
Quality
or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided
or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or
3.
Air Quality
X
10.
Land Use / Planning
17.
Tribal Cultural
Resources
4.
Biological Resources
X
11.
Mineral Resources
18.
Utilities /
Service Systems
5.
Cultural Resources
X
12.
Noise
X
19.
Mandatory Findings of
Si nificance
6.
Geology / Soils
X
13.
Population / Housing
7.
Greenhouse Gas
14,
Public Services
Emissions
DETERMINATION (To be completed by the Lead Agency)
On the basis of this initial evaluation:
I find that the proposed project COULD NOT have a significant effect on the environment. A
NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on the environment,
there will not be a significant effect in this case because revisions in the project have been made
X
by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will be
prepared.
I find that the proposed project MAY have a significant effect on the environment, and an
ENVIRONMENTAL IMPACT REPORT is required.
I find that the proposed project MAY have a "potentially significant impact" or "potentially
significant unless mitigated" impact on the environment, but at least one effect 1) has been
adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has
been addressed by mitigation measures based on the earlier analysis as described on attached
sheets. An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the
effects that remain to be addressed.
I find that although the proposed project could have a significant effect on the environment,
because all potentially significant effects (a) have been analyzed adequately in an earlier EIR
or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided
or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or
mitigation measures that are imposed upon the proposed project, nothing further is required,
March 28, 2018
Signature: Olivia Ervin, Environmental Planner Date
March 2018 Page 9 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
3. EVALUATION OF ENVIRONMENTAL IMPACTS
Fuel Center IS/MND
The following discussion addresses the potential level of impact relating to each aspect of the environment.
3.1. AESTHETICS
Less Than
Potentially Significant Less than No
Would ther0 ect: Significant with Significant Impact
p 1 Impact Mitigation Impact
a) Have a substantial adverse effect on a scenic vista? El 0 El M
b) Substantially damage scenic resources, including, but
not limited to, trees, rock outcroppings, and historic
buildings within a state scenic highway? E] El El M
c) Substantially degrade the existing visual character or
quality of the site and its surroundings? El El M El
d) Create a new source of substantial light or glare which
would adversely affect day or nighttime views in the area? M El El
Sources: 2025 General Plan and DEIR; and Site Plans.
Aesthetics Setting:
The project site is comprised of approximately 0.71 acres of land located in the Washington Core Subarea
(Figure 2-1 of the General Plan) within the Urban Growth Boundary, The Washington Core Subarea supports
a diverse mix of uses that include local and regional -serving commercial, community fair grounds and
residential. The subject project site is located contiguous to the southeast planning area, which is largely defined
by residential and institutional land uses. The site is bounded by regional/local serving commercial to the north,
institutional to the east, residential to the south and commercial to the west. There are no visual resources on
the project site or visible from the project site.
The project will involve demolition of the existing 13,770 square footcommercial retail building and development
of a 16 pump fueling station and associated convenience store parking and landscaping. The existing
commercial building to be demolished is a rectilinear, horizontally oriented building characteristic of strip mall
development. The outside is clad in brick and the existing landscape is minimal and consists of a narrow
landscape strips with grasses, shrubs and equally spaced trees. The balance of the proposed project site
features paved areas that are devoted to parking stalls and driveway aisles.
Redevelopment of the site will involve the introduction of a 697 square foot convenience store with frontage on
Maria Drive and the construction of a canopy covering 16 position fueling station located west of the store. The
convenience store and associated fueling station will feature a composite of neutral colored materials, horizontal
orientation and limited detailing. Proposed landscaping includes the introduction of street trees, evergreen
hedges to serve as screening and a variety of low maintenance, low water use plants oriented along South
McDowell Boulevard and the Maria Drive frontage. Proposed vegetation includes Red Maple, Photinia Fraseri
STD., Abbotts Gold (Pittosporum Tenuifolium), African Boxwood (Myrsine Africana), Fortnight Lily (Dietes
Irridoides), Confetti (Abelia X), Maordi Maiden/ New Zealand Flax (Phormium Tenax), Blue Oat Grass
(Helicotrichon Sempervirens), Dwarf Blue Fescue (Festuca Glauca), Lantana (Lantana Montedividensis) and
yellow Flower Carpet Rose.
March 2018 Page 10 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma
Aesthetics Impact Discussion:
Fuel Center IS/MND
3.1(a) (Scenic Vista) No Impact: The 2025 General Plan EIR identifies vistas of Sonoma Mountain and the
Petaluma Valley as significant visual resources with notable viewpoints seen from the Washington Street
Overpass, McNear Peninsula and Rocky Memorial Dog Park. The proposed fuel station is not located in the
direct vicinity to any of the notable viewpoints and would neither obstruct nor diminish any existing viewsheds.
The project is proposed on a developed parcel located within the bounds of the UGB. Since the site is
surrounded by existing development on all sides the project is considered infill. The GP EIR states that within
the built city, infill development would not have a significant effect on the visual quality of the city, because new
development would likely be similar in scale and character to existing development. Accordingly, the proposed
development would not be expected to have a substantial adverse impact on panoramic views or create
incongruous visual elements because the height and massing of new development would be similar to the
existing development in the vicinity and would not interfere with a scenic vista.
The proposed fuel station is compatible in scale and style with the existing Safeway Grocery Store. There is a
substantial increase in the landscaping area proposed relative to the existing condition. Therefore, development
of the proposed Fuel Center would have no impacts to scenic vistas or views of significant landscape features.
3.1(b) (Resources viewed from a State Designated Scenic Highway) No Impact: No State Scenic Roadway
traverse the planning area. Therefore, no scenic resources, including, but not limited to; trees, rock
outcroppings, and/or historic buildings visible from a State Scenic Highway would be impacted.
3.1(c) (Visual Character and Quality) Less Than Significant Impact: The addition of a fuel station to the
Washington Square Shopping Center will not significantly depart from the existing character of the shopping
center. The existing 13,770 square foot building onsite will be demolished under the proposed project and
replaced with the proposed 697 square foot convenience store and fueling area.
The proposed redevelopment will reduce the building scale and massing relative to the existing condition. The
existing building onsite consists of a solid mass oriented perpendicular to South McDowell Boulevard. It is
composed of beige colored concrete masonry units and an aluminum roof. There are a series of tenants with
entryways facing onto Maria Drive. The proposed Safeway Fuel Center will be oriented towards South McDowell
Boulevard. The 687 square foot convenience store represents a substantial reduction in scale and mass, and
the open area of the fuel canopy allows for increased visibility compared to the existing building onsite. As
proposed, the Fuel Center would be improved with an architectural styles that reflect the existing style at the
adjacent Safeway Grocery Store.
The project site is proximate to residential and institutional uses. Redevelopment would alter the visual
environment relative to the existing condition. However, the character of the Shopping Center will be largely
retained. The project will introduce landscaping and vegetative screening beyond what is currently present by
increasing the planting area. Furthermore, the project location within the existing commercial development is
consistent with the overall character that defines the Washington Square Shopping Center.
As such, the project is not expected to alter the character of the surrounding residential neighborhood as it is
associated with the commercial shopping center. The adjacent roadways including Maria Drive and South
McDowell Boulevard provide a distinct separation between the limit of the shopping center and that of the
residential and institutional land uses in proximity. The proposed Safeway Fuel Center will not create any
substantial visual dissonance that would degrade the existing visual quality of the surrounding area. Therefore
impacts to the visual character of the site and the surrounding land uses would be less than significant.
3.1(d) (Light and Glare) Less Than Significant Impact with Mitigation: The Washington Square Center is
an active commercial land use that contains a number of retailors and a large parking lot outfitted with
streetlights. Onsite uses and uses in the project vicinity emit light and glare typical of a retail/commercial.
The proposed fuel station will feature a canopy above the fueling pumps that will contain one recessed LED
canopy light (Series Type A60 -SL) per fuel pump and will exhibit an average illuminance of 23.10. The foot-
candles (fc) emitted from the recessed canopy lights will not exceed 28 fc under the canopy and will be limited
March 2018 Page 11 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
to 0.0 or 0.1 fc at the periphery of the site. The direction of the light will be downcast and directed underneath
the canopy. A wall light (Visa lighting #Extol) will be installed on the fagade of the convenience store.
A series of three -yard lights will be strategically placed throughout the site, in order to provide safety lighting
and visibility. The proposed project is required to conform to Petaluma's implementing zoning ordinance (IZO)
§ 21.040.D, which specifies lighting standards for all new exterior lights such as the provision that the cone of
direct illumination be sixty degrees if the luminary is greater than 6 feet above the ground.
In addition to the proposed on-site lighting fixtures, the project will introduce headlights and taillights from vehicles
entering, exiting and queuing. Vehicles will enter the Gas Station internally from the Shopping Center drive aisle
and will orient towards S. McDowell Boulevard for fueling (See Figure 5). Although vehicles will be turned off while
fueling, headlights may remain on while queuing or fueling. Additionally, headlights will be in the on position during
entry and exit and could result in impacts due to direct light and glare. In order to reduce light intrusion onto
adjacent properties, the site will feature screening and landscaping up to a height of 4 feet coupled with trees up
to 35 feet that will serve to block and/or filter light and glare generated by vehicles utilizing the fuel station and
associated convenience store. The landscape buffer is adequately sized at 28 feet in width to accommodate a
suitable range of groundcover, shrubs and trees for planting an effective landscaping screen. In order to ensure
that landscaping achieves sufficient screening of headlights mitigation measure AES -1 is set forth below and
requires that the Final Landscaping Plan provide an appropriate plant pallet to achieve the necessary height and
density to block light and glare from headlights using the fuel station. With implementation of AES -1 potential
impacts due to light and glare intrusion will be reduced to less than significant levels.
Mitigation Measures:
AES -1: The Final Landscaping Plan shall provide sufficient screening by placement of grasses, shrubs and other
groundcover species to effectively screen out glare from headlights oriented towards South McDowell Boulevard
and towards Maria Drive. A variety of heights shall be introduced through the landscaping plan including a dense
4 -foot high screen that blocks glare emanating from headlights.
March 2018 Page 12 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
3.2. AGRICULTURAL AND FORESTRY RESOURCES
b) Conflict with existing zoning for agricultural use, or ❑ E]
a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning
of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public El
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
d) Result in the loss of forest land or conversion of
forest land to non -forest use? ❑ E
e) Involve other changes in the existing environment
which, due to their location or nature, could result in El 1:1 E]
conversion of Farmland, to non-agricultural use or
conversion of forest land to non -forest use?
Sources: 2025 General Plan and DEIR.
Agricultural Setting:
Agricultural lands within the Urban Growth Boundary (UGB) are limited to "Farmland of Local Importance",
"Grazing Land", and "other land" and there are no identified forestlands within the City of Petaluma. No
agricultural or forestland designations are present on or near the project site.
Agricultural Resources Impact Discussion:
3.2(a -e) (Farmland Conversion, Williamson Act, Forestland/Timberland Conflict) No Impact: The project
site does not include any agricultural or forested lands. The project, as proposed, consists of infill development
located on a developed lot and will not impact prime farmland, unique farmland or farmland of statewide
importance. The project will not interfere with Williamson Act contracts or any existing agricultural uses.
In the absence of forested lands there is no potential for the project to conflict with existing forested land zoning
or encourage the loss or conversion of forested land to another use. As the project is infill within the UGB it will
not provide an impetus for the conversion of farmland or forest to any alternative use. Therefore, the project will
have no impact to agricultural and forestry resources.
Mitigation Measures: None Required.
March 2018 Page 13 of 65
Planning Commission Resolution No. 2018-21A
Less Than
Potentially
Significant
Less than No
Significant
with
Significant Impact
Would the project:
Impact
Mitigation
Impact
Incorporated
a) Convert Prime Farmland, Unique Farmland, or
Farmland of Statewide Importance (Farmland), as
shown on the maps prepared pursuant to the
El
El
Farmland Mapping and Monitoring Program of the
California Resources Agency, to non-agricultural use?
b) Conflict with existing zoning for agricultural use, or ❑ E]
a Williamson Act contract?
c) Conflict with existing zoning for, or cause rezoning
of, forest land (as defined in Public Resources Code
section 12220(g)), timberland (as defined by Public El
Resources Code section 4526), or timberland zoned
Timberland Production (as defined by Government
Code section 51104(g))?
d) Result in the loss of forest land or conversion of
forest land to non -forest use? ❑ E
e) Involve other changes in the existing environment
which, due to their location or nature, could result in El 1:1 E]
conversion of Farmland, to non-agricultural use or
conversion of forest land to non -forest use?
Sources: 2025 General Plan and DEIR.
Agricultural Setting:
Agricultural lands within the Urban Growth Boundary (UGB) are limited to "Farmland of Local Importance",
"Grazing Land", and "other land" and there are no identified forestlands within the City of Petaluma. No
agricultural or forestland designations are present on or near the project site.
Agricultural Resources Impact Discussion:
3.2(a -e) (Farmland Conversion, Williamson Act, Forestland/Timberland Conflict) No Impact: The project
site does not include any agricultural or forested lands. The project, as proposed, consists of infill development
located on a developed lot and will not impact prime farmland, unique farmland or farmland of statewide
importance. The project will not interfere with Williamson Act contracts or any existing agricultural uses.
In the absence of forested lands there is no potential for the project to conflict with existing forested land zoning
or encourage the loss or conversion of forested land to another use. As the project is infill within the UGB it will
not provide an impetus for the conversion of farmland or forest to any alternative use. Therefore, the project will
have no impact to agricultural and forestry resources.
Mitigation Measures: None Required.
March 2018 Page 13 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma
3.3. AIR QUALITY
Fuel Center IS/MND
Less Than
Potentially Significant Less than No
Significant with Significant Impact
Would the project: Impact Mitigation Impact p
a) Conflict with or obstruct implementation of the
applicable air quality plan? E ® ❑
b) Violate any air quality standard or contribute
substantially to an existing or projected air quality
violation? El 1:1 El
c) Result in a cumulatively considerable net
increase of any criteria pollutant for which the
project region is in non -attainment under an
applicable federal or state ambient air quality
standard (including releasing emissions which
exceed quantitative thresholds for ozone
precursors)?
d) Exposure of sensitive receptors to substantial
pollutant concentrations? ® El
e) Create objectionable odors affecting a
substantial number of people? ® ❑
Sources: 2025 General Plan and DEIR; Bay Area Air Quality Management District (BAAQMD) Bay Area 2017
Clean Air Plan; BAAQMD CEQA Guidelines, May 2017; BAAQMD Regulation 8 Organic Compound Rule 7
Gasoline Dispending Facilities, November 6, 2002; Safeway Fuel Center Air Pollutant and Greenhouse Gas
Emissions Assessment, prepared by Illingworth & Rodkin, January 8, 2014, Revised September 18, 2017;
Safeway Fuel Center Health Risk Assessment, prepared by Illingworth & Rodkin, January 8, 2014, Revised
September 19, 2017; and Limited Asbestos and Lead -Based Paint Survey, prepared by Cardno ATC,
Mav 29. 2013.
Air Quality Setting:
The City of Petaluma including the project site is located within the San Francisco Bay Area Air Basin (Bay Area
Air Basin), which is under the jurisdiction of the Bay Area Air Quality Management District (BAAQMD). BAAQMD
is charged with managing air quality for the region through the implementation of planning, regulation,
enforcement, technical innovation and education. The intent of which is to achieve conformance with
established air quality standards that are set by the U.S. Environmental Protection Agency for the Federal Clean
Air Act and the California Air Resources Control Board for the California Clean Air Act.
The BAAQMD operates several air quality monitoring stations, whereas the closest station to the City of
Petaluma is located in eastern Sebastopol, approximately 16 miles northwest. The Sebastopol station records
pollutant concentration levels for carbon monoxide (CO), Nitrogen Dioxide (NO2), Ozone (03), and Particulate
Matter (PM2.5).
The Bay Area Air Basin is designated as non -attainment for both the one-hour and eight-hour state and national
ozone standards; 0.09 parts per million (ppm) and 0.070 ppm, respectively. The Basin is also in non -attainment
for the PM10 and PM2.5 state standards, which require an annual arithmetic mean (AAM) of less than 20 pg/m3
for PMio and less than 12 pg/m3 for PM2.5. In addition, the Bay Area Air Basin is designated as non -attainment
for the national 24-hour PM2.5 standard. All other national ambient air quality standards within the Bay Area Air
Basin are in attainment.'
1 2017 Bay Area Clean Air Plan, prepared by the Bay Area Air Quality Management District, April 2017.
March 2018 Page 14 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
Air quality emissions of carbon monoxide (CO), ozone precursors (ROG and NOx) and particulate matter (PMio
and PM2.5) from construction and operation are evaluated pursuant to the BAAQMD CEQA Air Quality
Guidelines established in May 20102 and most recently updated in May 2017. The most recent version of the
BAAQMD CEQA Guidelines includes revisions made to address the Supreme Court's opinion issued for the
California Building Industry Association v. Bay Area Air Quality Management District, in December 2015.3
The May 2017 Guidelines update does not address outdated references, links, analytical methodologies or
other technical information that may be in the Guidelines or Thresholds Justification Report.
The BAAQMD is currently working to update any outdated information in the Guidelines, and anticipates release
of an updated document in 2018.4 Based upon its own judgment and analysis, the City of Petaluma recognizes
that BAAQMD thresholds represent the best available scientific data and has elected to rely on BAAQMD
Guidelines dated May 2017 in determining screening levels and significance.
Thresholds of significance as established by BAAQMD for construction and operation are provided in Table 1
below.
Table 1
Air Quality Thresholds of Significance
Pollutant
Construction Thresholds
lbs per day)
Operational Threshold
(Ibs per da
ROG
54
54
Nox
54
54
PM10
82
82
PM2.5
54
54
CO
Not Applicable
9.0 ppm (8 -hour avg.) or
20.0 ppm (1 -hour avg.)
Fugitive Dust
Construction Dust
Ordinance or other Best
Management Practices
Not Applicable
Source: BAAQMD's CEQA Guidelines: May 2017.
In addition to the Guidelines, BAAQMD has established rules in order to ensure that projects conform to air
quality regulation. The Safeway Fuel Center Project is subject to several of the Rules established by BAAQMD
including Regulation 11, Rule 2 for the control and management of asbestos containing materials, Regulation
8, Rule 7 to control for the emission of reactive organic compound (ROG) from a stationary source emitter due
to fuel dispensing onsite, and Regulation 7 which controls for odors.
The subject Safeway Fuel Center, as a proposed fuel dispensing operation, is considered a stationary source
emitter, and is regulated to control for the emission of reactive organic compound (ROG) pursuant to Regulation
8, Rule 7 of the BAAQMD Rules and Regulations. Rule 7 requires that stationary source emitters such as the
Safeway Fuel Center install enhanced vapor recovery (EVR) systems. Since the Safeway Fuel Center would
emit more than 10 pounds of ROG (i.e., volatile organic compounds or VOCs) in a single day, the Best Available
Adopted by Board of Directors of the BAAQMD in June 2010 (Resolution No. 2010-6).
In March 2012, the Alameda County Superior Court ordered BAAQMD to set aside use of the significance thresholds
within the BAAQMD 2010 CEQA Guidelines and cease dissemination until they complete an assessment of the
environmental effects of the thresholds in accordance with CEQA. The Court found that the thresholds, themselves,
constitute a "project" for which environmental review is required. In August 2013, the First District Court of Appeal
reversed the Alameda County Superior Court's decision. The Court held that adoption of the thresholds was not a
"project" subject to CEQA because environmental changes that might result from their adoption were too speculative
to be considered "reasonably foreseeable" under CEQA. In December 2015, the California Supreme Court reversed
the Court of Appeal's decision and remanded the matter back to the appellate court to reconsider the case in light of
the Supreme Court's opinion.
Alison Kirk, BAAQMD, Email Correspondence, June 6, 2017.
March 2018 Page 15 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
Control Technology (BACT) requirement of Regulation 2-2-301 would be triggered. BACT for Gasoline
Dispensing Facilities is considered the use of California Air Resource Board (GARB) -certified Phase -I and
Phase -II vapor recovery equipment. The Safeway Fuel Center obtained a permit to construct and operate from
the BAAQMD and an extension was filed in October 2017.5 According to the BAAQMD's permit evaluation, the
project would meet the requirement by using CNI EVR Phase I equipment and VST Balance EVR Phase II
equipment with the Veeder-Root Vapor Polisher and Veeder-Root ISD controls. These two systems are certified
by CARB under Executive Orders VR -104 and VR -204 respectively.
To ensure that the Safeway Fuel Center does not emit ROG emissions that would trigger requirements for
emission offsets, or exceed screening triggers that would require a health risk assessment, BAAQMD
conditioned the facility to a gasoline throughput not to exceed 25.71 million gallons of fuel per year. Even though
the project's annual throughput is expected to be approximately 8.5 million gallons per year, which is less than
one-third of the screening triggers set by BAAQMD, a Health Risk Assessment has been prepared for the
project (see Section 3.3(d) below).
Regulation 2, Rule 5 of the BAAQMD Rules and Regulations controls for the evaporation of vapors, including
Toxic Air Contaminant (TAC) such as benzene. TACs are defined by CARB as those pollutants that "may cause
or contribute to an increase in deaths or serious illness, or which may pose a present or potential hazard to
human health." TACs are chemical compounds that result from industry, agriculture, fuel combustion, and
commercial operations. In the context of the subject project expected TACs include diesel particulate matter
(DPM), non -diesel total organic gases (TOG), fine particulate matter (PM2.5), and benzene. DPM consists of
diesel exhaust that contains a mixture of gases, vapors, and fine particles. TOGs are emitted by gasoline
powered vehicles from running exhaust and evaporative running losses. Benzene is a component of gasoline,
diesel fuel and vehicle exhaust that is emitted through the evaporation of gasoline vapors. TACs are regulated
at the state and federal level on the basis of risk to human health. BAAQMD prepared a Health Risk Screening
Analysis for the Safeway Fuel Center because the increased benzene emissions for the project exceed the
TAC risk triggering level specified in Table 2.5-1 of Regulation 2, Rule 5. According to BAAQMD's evaluation,
the Safeway Fuel Center passed the toxic risk screening level of less than ten in a million cancer risk with the
BAAQMD-imposed annual throughput limit of 25.71 million gallons .6
BAAQMD has established thresholds of significant for exposure to TAC and PM2.5 as part of the aforementioned
Guidelines. These thresholds are utilized in order to identify potentially significant health risk impacts that may
result from exposure to sensitive populations. Table 2 below provides the Community Risk Thresholds for
determining significance due to a health risk introduced by development.
Table 2
Health Risk Thresholds of Significance
Source: BAAQMD's CEQA Guidelines: May 2017.
Single sources would be considered to have a potentially significant health risk impact if they would exceed any
of the established thresholds set forth in Table 2. Cumulative sources would be considered to have potentially
significant impact if any of the thresholds in Table 2 were exceeded due to the aggregate total of all past,
present and foreseeable sources within the 1,000 foot radius of the fence line of a source or from the location
of a sensitive receptor plus the contribution from the project.
The following discussion analyzes the project's potential to result in an air quality impacts due to construction
and the proposed onsite use.
5 BAAQMD 2013. Authority to Construct for Permit Application No. 405215 at S. McDowell Blvd. & Maria Drive,
Petaluma CA 94954, dated October 10, 2013.
6 Ibid.
March 2018 Page 16 of 65
Planning Commission Resolution No. 2018-21 A
Excess Cancer
Risk
Non -Cancer
Hazard Index
PM2.5
/m3
Single Source
>10 in 1 million
>1.0
>0.3
Cumulative Source
>100 in 1 million
>10.0
>0.8
Source: BAAQMD's CEQA Guidelines: May 2017.
Single sources would be considered to have a potentially significant health risk impact if they would exceed any
of the established thresholds set forth in Table 2. Cumulative sources would be considered to have potentially
significant impact if any of the thresholds in Table 2 were exceeded due to the aggregate total of all past,
present and foreseeable sources within the 1,000 foot radius of the fence line of a source or from the location
of a sensitive receptor plus the contribution from the project.
The following discussion analyzes the project's potential to result in an air quality impacts due to construction
and the proposed onsite use.
5 BAAQMD 2013. Authority to Construct for Permit Application No. 405215 at S. McDowell Blvd. & Maria Drive,
Petaluma CA 94954, dated October 10, 2013.
6 Ibid.
March 2018 Page 16 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma
Air Quality Impact Discussion:
Fuel Center IS/MND
3.3(a) (Air Quality Plan) Less than Significant Impact: The BAAQMD adopted the 2017 Bay Area Clean Air
Plan (CAP) in April 2017 to comply with state air quality planning requirements set forth in the California Health
& Safety Code. The 2017 CAP includes a wide range of control measures designed to decrease emissions of
the air pollutants that are most harmful to Bay Area residents, such as particulate matter (PM), ozone (Os), and
toxic air contaminants (TACs); to reduce emissions of methane and other "super -greenhouse gases (GHGs)"
that are potent climate pollutants in the near-term; and to decrease emissions of carbon dioxide by reducing
fossil fuel combustion.
The proposed control strategy for the 2017 CAP consists of 85 distinct measures targeting a variety of local,
regional and global pollutants. The control measures have been developed for stationary sources,
transportation, energy, buildings, agriculture, natural and working lands, waste management, water, and super-
GHG pollutants. Implementation of some of the control measures could involve retrofitting, replacing, or
installing new air pollution control equipment, changes in product formulations, or construction of infrastructure
that have the potential to create air quality impacts.
The BAAQMD CEQA Guidelines set forth criteria for determining consistency with the CAP. In general a project
is considered consistent if a) the project supports the primary goals of the CAP (to protect air quality, protect
public health, and protect the climate), b) includes control measures and c) does not interfere with
implementation of the CAP measures. Development of the proposed Safeway Fuel Center Project is consistent
with the CAP as it supports the primary goals by providing a new fueling center proximate to existing retail
which would reduce overall vehicle miles traveled, includes basic control measures and would not result in any
conflicts in implementing the CAP. Therefore, the project would have less than significant impacts due to a
conflict with the regional air quality plan.
3.3(b -c) (Air Quality Standard, Criteria Pollutant) Less than Significant Impact with Mitigation: A project -
specific Air Pollutant and Greenhouse Gas Emissions Assessment was prepared by Illingworth and Rodkin
(September 2017) that analyzed construction emissions, tailpipe emissions, and evaporative emissions (See
Appendix A). In accordance with BAAQMD direction, the Assessment utilized the California Emissions
Estimator Model, Version 2016.3.1 (CaIEEMod) to quantify projected construction and operational emissions
generated by the proposed Safeway Fuel Center. As described in the methodology discussion of the
Assessment, a Gasoline/Service Station with 16 fuel pump stations, was entered into the model.
In order to evaluate the emissions generated by vehicles idling due to queuing and wait times during peak hour
fueling activity, the Air Pollutant and Greenhouse Gas Emissions Assessment utilized CARB's EMFAC2014
motor vehicle emission factor model. The idling analysis assumed that the peak -hour would have 12 vehicles
(light-duty autos or light-duty trucks) queuing constantly, which would be three vehicles for each line of pumps;
this represents the worst-case scenario based on the maximum queuing space available. The analysis also
assumed that the peak hour represents 10 percent of the daily queuing emissions.
The transfer and storage of gasoline results in emissions of VOCs also assumed to be ROGs. These gases,
when combined with NOx, lead to ozone formation. The emission factors developed by BAAQMD are based on
the Gasoline Service Station Industry -wide Risk Assessment Guidelines prepared by the California Air Pollution
Officers Association's (CAPCOA) Toxics Committee. BAAQMD's emission computations are based on annual
throughput that account for emissions from fuel storage tank loading, breathing, and motor vehicle
refueling/dispensing for underground tanks that meet current requirements for enhanced vapor recovery.
The Air Pollutant and Greenhouse Gas Emissions Assessment prepared by Illingworth and Rodkin used a ROG
emission factor of 0.670 pounds of Precursor Organic Compounds (i.e,, ROG) per 1,000 gallons of fuel
throughput. Annual and daily emissions were computed to reflect the anticipated annual throughput of
approximately 8.5 million gallons. While the BAAQMD conditioned the facility to a gasoline throughput not to
exceed 25.71 million gallons of fuel per year, the proposed project was analyzed assuming an annual
throughput of 8.5 million gallons. In the future, should the applicant decide to increase the annual throughput
limit beyond 8.5 million gallons per year, subsequent environmental review in accordance with CEQA
regulations may be required by the City of Petaluma.
Air Quality Emissions during Construction
March 2018 Page 17 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
The project's emission generation during construction are compared to the BAAQMD thresholds of significance
as set forth above in Table 1. Construction of the Safeway Fuel Center will result in air quality emissions
associated with demolition of the existing building onsite, removal of the pavement and landscaping and the
redevelopment of the proposed fueling bays, convenience store, and associated parking and landscaping.
Constructed -related air quality emissions result from the generation of fugitive dust, operation of heavy-duty
equipment, trips from the delivery of material and workers commuting to the project site, and off gassing from
paving and the application of architectural coatings. Table 3 provides the projected air quality emissions
expected to be generated from construction of the subject Safeway Fuel Center.
Table 3
Air Quality Construction Emissions
Pollutant
lbs per da
Construction
Emissions
Construction
Threshold
Threshold
Exceeded?
ROG
1.3
54
No
NOX
10.8
54
No
PM10
0.7
82
No
PM2.5
0.7
54
No
Source: Air Pollutant and Greenhouse Gas Emissions Assessment, prepared by I&R, September 2017.
Table 3 above shows that none of the pollutant concentrations generated during construction of the proposed
project would result in emissions that exceed established thresholds. However, demolition and construction
activities will result in the generation of fugitive dust, which must be controlled in accordance with the City's
Dust Control Ordinance and BAAQMDs Best Management Practices (BMP). In order to ensure that potential
impacts associated with the generation of fugitive dust are reduced to level below significance construction
activities shall implement all BMP as set forth under Mitigation Measure AQ -1.
Demolition activities are regulated pursuant to Regulation 11, Rule 2 for the control and management of
asbestos containing materials. Given that the proposed project requires the demolition of an existing structure
that contains asbestos, mitigation measure AQ -2 is set forth below (also see the Hazardous Materials
discussion below). AQ -2 requires that adherence to applicable regulation be implemented in the event that
friable asbestos is present within the onsite building to be demolished. With implemented of AQ -1 and AQ -2
potential impacts due to the generation of fugitive dust and the presence of asbestos would be reduced to levels
below significance.
Air Quality Emissions at Operation
Operation of the Safeway Fuel Center will result in air quality emissions associated with the use of energy and
water onsite, vehicle trips generated by the project, exhaust emissions from vehicles idling onsite, and the
evaporative emissions from the storage and use of gasoline. Table 4 below provides the projected air quality
emissions expected to be generated from operation of the subject Safeway Fuel Center.
Table 4
Air Quality Operational Emissions
Emission Source ROG NO, PM10 I PM2.5
Annual Emissions In TONS
Motor Vehicles/Building Operation
0.85
1.31
0.58
0.16
Vehicle Exhaust Idling
0.07
0.08
<0.01
<0.01
Evaporative Gasoline
2.85
0.00
0.00
0.00
Total Emissions
3.77
1.39
0.59
0.17
BAAQMD Thresholds
10
10
15
10
Exceeds Threshold?
No
No
No
No
Average Daily Emissions In POUNDS PER DAY
Average Daily Emissions 20.7 7.6 3.2 1.0
BAAQMD Threshold 54 54 82 54
Exceeds Threshold? No No No No
Source: Air Pollutant and Greenhouse Gas Emissions Assessment, prepared by Illingworth and Rodkin,
September 2017.
March 2018 Page 18 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
As shown in Table 4 above, none of the pollutant concentrations generated during operation of the proposed
project would result in emissions that exceed established thresholds. Project generated traffic, vehicle idling,
and fuel vapor emissions are below the established annual and daily thresholds set forth by BAAQMD for criteria
pollutants.
BAAQMD regulates Gasoline Dispensing Facilities in accordance with Regulation 8, Rule 7. BAAQMD has
reviewed the application for the subject Fuel Dispensing activity and issued a compliance determination
supporting the Authority to Construct Permit on October 10, 2013 (attachment 3 to the Air Pollutant and
Greenhouse Gas Emissions Assessment).? Issuance of this permit indicates that BAAQMD has reviewed
proposed fuel dispensing equipment, considered the source emitter and determined that the equipment would
comply with all air quality rules and regulations. As summarized above and demonstrated in the Air Pollutant
and Greenhouse Gas Emissions Assessment, at operation the subject project would not violate air quality
standards or cumulatively contribute to an existing violation. Therefore, operational impacts to air quality from
the Safeway Fuel Center would be less than significant.
In summary, the project would not violate any air quality standards or contribute substantial pollutant
concentration that would exacerbate non -attainment conditions. However, in order to ensure that potential air
quality impact associated with the generation of fugitive dust is reduced to levels below significance, the
contractor shall implement measure AQ -1 during all construction activities. During demolition AQ -2 shall be
implemented to protect workers and the environmental from potential exposure due to the presence of asbestos.
With adherence to mitigation measures AQ -1 and AQ -2, as set forth below, the proposed project would have
less than significant impacts to air quality.
3.3(d) (Sensitive Receptors) Less than Significant Impact: A project specific Health Risk Assessment (HRA)
was prepared by Illingworth and Rodkin (September 2017) that analyzed construction emissions, tailpipe
emissions, truck delivery emissions and evaporative emissions (See Appendix B). The HRA evaluates the
exposure of sensitive receptors to substantial air quality pollutants. Sensitive receptors are defined by CARB
as persons with elevated sensitivity to air pollutants including children under 14, the elderly over 65, athletes,
and people with cardiovascular and chronic respiratory diseases. Land uses that may contain higher
concentrations of sensitive receptors include residential neighborhoods, hospitals, elementary schools, and
parks.
The nearest sensitive receptors in proximity to the project site, and their distances from the project's limits of
work, include the North Bay Children's Center located at the northeast corner of South McDowell and Maria
Drive (60 feet), McDowell Elementary School (475 feet) and associated recreational playfield (60 feet), and
residences along South McDowell Boulevard (80 feet).
The proposed project would generate TACs and fine particulate (PM2.5) emissions during construction in the
form of exhaust from heavy-duty construction equipment and during operation from project generated vehicle
trips and delivery truck exhaust, vehicles idling onsite (queuing), and emissions from fuel dispensing. As
mentioned above, CalEEMod was utilized to estimate the project's generation of PM2.5. The U.S. EPA ISCST3
model was used for dispersion modeling purposes to assess exposure to nearby sensitive receptors from
fugitive dust and exhaust. (Also see Appendix B for assumptions and methodology used for the HRA.)
Table 5 shows the health risk exposure to nearby sensitive receptors during construction activities. The
exposure risks are provided for the maximally exposed individual (MEI), which consists of a child at the North
Bay Children's Center (school) and inhabitants of the residential units along South McDowell Blvd. All other
nearby sensitive receptors would be exposed to health risks below those presented in the following table.
7 BAAQMD is currently processing an extension of the Authority to Construct Permit through 2019.
March 2018 Page 19 of 65
Planning Commission Resolution No. 2018-21A
Citv of Petaluma
Table 5
Fuel Center IS/MND
Source: Health Risk Assessment, prepared by Illingworth and KodKin, September 2U1 /.
As seen in Table 5, construction activities would generate TAC and PM2.5 that would result in exposure levels
that are below established thresholds of significant. Therefore, potential impacts due to increased cancer risk,
hazard index or PM2.5 resulting from construction -generated emissions would be less than significant.
The health risk exposure to nearby sensitive receptors during operation will result from project generated traffic,
vehicles idling onsite during queuing, delivery truck exhaust, brake and tire wear, and fuel evaporation
emissions from loading, breathing, storing and dispensing. As described above, the operation of vehicles results
in exhaust that contains PM2.5 and TAC. Additionally tire and brake wear contribute to PM2.5 concentrations.
The primary constituent from evaporation that would result from the onsite fueling activity is benzene.
Table 6 below shows the combined exposure risk, from the combination of construction activity and operation
impacts, projected for the maximally exposed individual (MEI). The MEI for the Safeway Fuel Center consists
of a child at the North Bay Children's Center (school) and inhabitants of the residential units along South
McDowell Blvd. All other nearby sensitive receptors would be exposed to community health risk levels that are
less than those presented below.
Table 6
Communitv Health Risk Exposure
Receptor Excess Non -Cancer Annual PM2.5
Cancer Risk Hazard Index Concentration
(Der million) (ua/m3)
Residential (30 -year lifetime)
Construction Impacts
Health
Risk Exposure Construction
0.21
Receptor
1.2
Excess
Cancer Risk
(per million
Non -Cancer
Hazard Index
Annual PM2.5
Concentration
/m3
Residential - infant
0.000
2.4
0.003
0.02
Residential - adult
0.00
<0.1
0.003
0.02
School - child
School Child (9 -years)
5.8
0.04
0.21
BAAQMD Threshold
5.80
10.0
1.0
0.3
Exceeds Threshold?
0.015
No
No
No
Source: Health Risk Assessment, prepared by Illingworth and KodKin, September 2U1 /.
As seen in Table 5, construction activities would generate TAC and PM2.5 that would result in exposure levels
that are below established thresholds of significant. Therefore, potential impacts due to increased cancer risk,
hazard index or PM2.5 resulting from construction -generated emissions would be less than significant.
The health risk exposure to nearby sensitive receptors during operation will result from project generated traffic,
vehicles idling onsite during queuing, delivery truck exhaust, brake and tire wear, and fuel evaporation
emissions from loading, breathing, storing and dispensing. As described above, the operation of vehicles results
in exhaust that contains PM2.5 and TAC. Additionally tire and brake wear contribute to PM2.5 concentrations.
The primary constituent from evaporation that would result from the onsite fueling activity is benzene.
Table 6 below shows the combined exposure risk, from the combination of construction activity and operation
impacts, projected for the maximally exposed individual (MEI). The MEI for the Safeway Fuel Center consists
of a child at the North Bay Children's Center (school) and inhabitants of the residential units along South
McDowell Blvd. All other nearby sensitive receptors would be exposed to community health risk levels that are
less than those presented below.
Table 6
Communitv Health Risk Exposure
Receptor Excess Non -Cancer Annual PM2.5
Cancer Risk Hazard Index Concentration
(Der million) (ua/m3)
Residential (30 -year lifetime)
Construction Impacts
2.4
0.003
0.21
Traffic (vehicle trips and idling)
1.2
0.013
0.02
Truck Deliveries
0.02
0.000
0.00
Benzene (fuel evaporation)
1.40
0.08
0.00
Total Residential
5.02
0.096
0.23
School Child (9 -years)
Construction Impacts
5.80
0.04
0.21
Traffic (vehicle trips and idling)
0.28
0.015
0.01
Truck Deliveries
0.01
0.000
0.00
Benzene (fuel evaporation)
0.39
0.09
0.00
Total School Child
6.48
0.0145
0.22
Significant Threshold
10.0
1.000
0.30
Exceeds Threshold?
No
No
No
Source: Health Risk Assessment, prepared by Illingworth and Rodkin,
September 2017.
As seen in Table 6, the combined exposure to TACs from the proposed project, including construction and
operational activities such as increased vehicle traffic from idling, truck deliveries, as well as benzene from fuel
evaporation, would be at levels below the significance thresholds. TACs and PM2.5 concentrations would be
below levels that substantially increase the cancer risk and hazard index. Therefore, potential impacts to
sensitive receptors due to increased cancer risk, hazard index or PM2.5 concentration resulting from all proposed
March 2018 Page 20 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
activities associated with the Safeway Fueling Center would be less than significant.
Table 7 below shows the cumulative exposure risk projected for the MEI, which consists of a child at the North
Bay Children's Center (school). The cumulative exposure is a combination of the project specific contributions,
as well as emissions from nearby linear sources, including traffic along South McDowell Boulevard and US 101.
All other nearby sensitive receptors would be exposed to cumulative health risks less than those presented
below.
Table 7
Cumulative Health Risk Exposure
Receptor Excess Non -Cancer Annual PM2.5
Cancer Risk Hazard Index Concentration
(per million► I (ua/m3)
Cumulative Sources at MEI
Total School Child
6,5
0.15
0.22
Traffic (S. McDowell Blvd.)
8.8
<0.01
0.33
Traffic (US 101)
<6.9
<0.01
<0.05
Cumulative Including Project
<22.2
<0.17
0.60
Cumulative Significance Threshold
100.0
10.0
0.80
Exceeds Threshold?
No
No
No
Source: Health Risk Assessment, prepared by Illingworth and Rodkin, September
2017.
As seen in Table 7, the cumulative exposure to TACs and PM2.5 concentrations would be at levels below the
significance thresholds for the cumulative health risk exposure. Therefore, potential impacts to sensitive
receptors due to increased cancer risk, hazard index or PM2.5 concentration resulting from all proposed activities
associated with the Safeway Fueling Center in additional to linear emitters in the vicinity would be less than
significant.
In summary, the HRA evaluated the project's potential to increase health risk to nearby sensitive receptors from
construction and operation of the project. The analysis found that the combination of TAC emissions from
construction and operation would not exceed the thresholds of significance for community risk impacts in terms
of excess lifetime cancer risk, annual PM2.5 concentrations and Hazard Index. Both single -source and
cumulative source thresholds for community risk would not be exceeded. Therefore, the Safeway Fuel Center
would have a less than significant impact in terms of exposing nearby sensitive receptors to substantial air
pollutant concentrations.
3.3(e) (Odors) Less than Significant Impact: As a fueling center, the proposed project will result in the
generation of odors on a temporary basis during construction and at operation. Temporary construction odors
are short term in nature and typically consist of exhaust from heavy-duty equipment, and off gassing from paving
and architectural coatings. Operational odors from the proposed gas station would occasionally be noticeable
onsite. However, these odors from gasoline vapor dissipate quickly and would not be detectable offsite.
Therefore impacts from substantial odor concentrations would be less than significant,
Mitigation Measures:
AQ -1: The contractor(s) shall implement basic and additional air quality construction measures set forth by
BAAQMD, including the following:
a) Water all active construction areas (staging, parking, soil piles, graded areas, unpaved driveways,
etc.) at least twice daily.
b) Cover all haul trucks transporting soil, sand, or other loose materials offsite.
c) Sweep daily (with water sweepers) all paved access roads, parking areas, and staging areas.
Sweep streets daily (with water sweepers) if visible soil material is deposited onto adjacent roads.
d) Suspend construction activities that cause visible dust plumes that extend beyond the construction
site.
e) A certified mechanic shall verify that equipment is properly tuned and maintained in accordance
with manufacturer specifications.
March 2018 Page 21 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma
Fuel Center IS/MND
f) Idling times shall be limited to 5 minutes or less pursuant to the "no idling" rule for in -use off-road
diesel -fueled vehicles. Signage shall be posted at the construction site indicating the idle time
limitation.
g) All diesel -powered off-road equipment larger than 50 horsepower and operating at the site for more
than two days continuously shall meet U.S. EPA particulate matter emissions standards for Tier 2
engineer or the equivalent.
h) Diesel -powered generators or air compressors shall not be used on-site for more than two days
continuously, unless under emergency conditions,
i) Post a publicly visible sign with the telephone number of designated person and person to contact
at the Lead Agency regarding dust complaints. This person shall respond and take corrective action
within 48 hours. The Air District's phone number shall also be visible to ensure compliance with
applicable regulations.
AQ -2: The demolition and removal of asbestos -containing building materials shall be subject to applicable
California Occupational Safety and Health Administration (CAL -OSHA) and BAAQMD Regulations, and
the applicant shall obtain a Job Number from the BAAQMD. The applicant shall present the Job
Number to the City Building Department and notify the BAAQMD at least 10 working days before
demolition commences. Federal and state construction worker health and safety regulations shall be
followed during demolition activities due to the presence of asbestos containing material (ACM). All
ACM shall be removed by a qualified contractor and disposed of in accordance with existing hazardous
waste regulations.
March 2018 Page 22 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
3.4. BIOLOGICAL RESOURCES
Fuel Center IS/MND
Potentially Less Than Less than No
Would the project: Significant Significant Significant Impact
Impact with Impact
Mitigation
Incoraorated
a) Have a substantial adverse effect, either directly or
through habitat modifications, on any species identified
as a candidate, sensitive, or special status species in
local or regional plans, policies, or regulations, or by El El
the California Department of Fish and Wildlife
(Formerly Fish and Game) or U.S. Fish and Wildlife
Service?
b) Have a substantial adverse effect on any riparian
habitat or other sensitive natural community identified in
local or regional plans, policies, regulations or by the El
El ❑
California Department of Fish and Wildlife (formerly Fish
and Game) or U.S. Fish and Wildlife Service?
c) Have a substantial adverse effect on federally
protected wetlands as defined by Section 404 of the
Clean Water Act (including, but not limited to, marsh, El
El ❑
vernal pool, coastal, etc.) through direct removal, filling,
hydrological interruption, or other means?
d) Interfere substantially with the movement of any
native resident or migratory fish or wildlife species or
with established native resident or migratory wildlife E
❑ El
corridors, or impede the use of native wildlife nursery
sites?
e) Conflict with any local policies or ordinances
protecting biological resources, such as a tree El El ❑
preservation policy or ordinance?
f) Conflict with the provisions of an adopted Habitat
Conservation Plan, Natural Community Conservation
Plan, or other approved local, regional, or state habitat E] El El
conservation plan?
Sources: 2025 General Plan and DEIR; DEIR Figure 3.8-1: Habitat Areas and Special Status Species; Open
Space Lands Map of the Petaluma General Plan: Figure 6-1; Holland's Preliminary Descriptions of Terrestrial
Natural Communities of California (Holland, 1986)
Biological Resources Setting:
Biological resources are protected by statute including the Federal Endangered Species Act (FESA), the
California Endangered Species Act (CESA), and the Clean Water Act (CWA). The Migratory Bird Treaty Act
(MBTA) affords protection to migratory bird species including birds of prey. These regulations provide the legal
protection for plant and animal species of concern and their habitat.
As reported in the 2025 General Plan EIR several plant and animal species with special -status have been
recorded or are suspected to occur within the Urban Growth Boundary of the City of Petaluma. The City also
contains species that are identified in the California Natural Diversity Database (CNDDB) due to rarity and
threats, and are considered sensitive resources.
March 2018 Page 23 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
Within the Urban Growth Boundary, biological resources are largely limited to the Petaluma River and its
tributaries, which contain aquatic and riparian resources as well as wetlands. The National Wetland inventory
identifies fresh emergent wetlands in the southern portion of the Petaluma River and Northern coastal salt
marsh wetland and brackish marsh wetland in the lower reaches of the Petaluma River. The Petaluma River
Access and Enhancement Plan (1996) contains policies and guidelines to protect these important biological
resources.
The 0.71 -acre project site is located within an established commercial shopping center in the Washington Core
Subarea. According to Holland's Preliminary Descriptions, the project site can be described as "urban habitat"
that may include "ornamental landscaping, non-native grass and weed associations (ruderal Vegetation), and/or
scattered agricultural crop and orchard plantings" (Holland). The project site is bounded by commercial/retail,
residential and institutional uses. It is located directly adjacent to two major thoroughfares, S. McDowell
Boulevard and Maria Drive. As an existing Shopping Center, the project site does not exhibit any habitat value.
Biological Resources Impact Discussion:
3.4(a) (Special Status Species) Less Than Significant With Mitigation: The project site does not directly
support any species identified as candidate, sensitive, or special status species in local or regional plans,
policies or regulations, or by the California Department of Fish & Wildlife (CDFW) or U.S. Fish & Wildlife Service
(USFWS). The Washington Square Shopping Center consists of existing commercial buildings, paved parking
areas and limited ornamental landscaping. There is no suitable habitat onsite or in the immediate vicinity that
would directly support special status species or serve as potential foraging habitat.
There are two on-site trees (liquidambar) that are proposed for removal as part of the site preparation process.
Onsite trees may provide perching and potential nesting opportunities to bird species including migratory birds
that are protected under the Migratory Bird Treaty Act (MBTA). Although tree removal is limited to two ornamental
species within a parking lot area, there remains a potential that protected bird species may be impacted.
Adherence to General Plan policy 4-P-4, as well as the California Department of Fish and Game Code Section
3503 (protection of birds' nests and the MBTA) will ensure that potential impacts to migratory bird species are
avoided. Measure BIO -1, set forth below, stipulates timing for tree removal in order to avoid the breeding
season, or to conduct pre -construction bird surveys prior to construction activities occurring within the breeding
season. In order to protect migratory bird nests, should construction activities occur within the breeding season
(between February 1 and August 31) a pre -construction survey shall be conducted by a qualified biologist, as
required pursuant to mitigation measure BIO -1 below. With implementation of BIO -1, potential impacts to
migratory birds due to the removal of trees onsite will be reduced to levels below significant.
3.4(b) (Riparian Habitat) No Impact: The project site is currently developed with a commercial/retail building,
paved parking areas and limited landscaping. As such, the property does not provide riparian habitat or
otherwise support sensitive natural communities. The property is not directly adjacent to any waterways or
riparian habitat. The nearest waterway is the East Washington Creek, which is tributary to the Petaluma River
and located north of the shopping center. The proposed project will replace an existing commercial building
with a fueling station and is not expected to substantially alter the intensity and use of the site compared to the
existing condition. As no biological resources are present onsite or in the immediate proximity, the project will
not adversely affect any known biological resources. Therefore, the project will have no impact to natural
communities or riparian habitat as a result of development and operation of the proposed Safeway Fuel Center.
3.4(c) (Wetlands) No Impact: No federally protected wetlands, including but not limited to, marsh, vernal pools
or coastal wetlands, exist within the project site boundaries or vicinity. The project site consists of the Washington
Square Shopping Center and supports commercial land uses. There are no protected federal wetlands onsite.
Therefore, the proposed project will not have a substantial adverse effect on federally protected wetlands as
defined by section 405 of the Clean Water Act.
3.4(d) (Wildlife/Fish Movement & Nursery) No Impact: The project site is currently developed with
commercial retail uses within an urban environment. Surrounding the site is a mix of commercial, institutional,
and residential uses. No migratory corridors have been identified onsite or in the immediate vicinity that would
be adversely affected as a result of the proposed project. The project would not interfere with the movement of
March 2018 Page 24 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife
corridors, or impede the use of native wildlife nursery sites. Therefore, there would be no impact to migratory
corridors as a result of the proposed Safeway Fuel Center.
3.4(e) (Tree Preservation) No Impact: The existing vegetation present on the project site is limited to
ornamental landscaping and does not include any landmark, heritage or trees protected under a tree
preservation policy or ordinance. There are two liquidambar trees present within the parcel that are proposed
for removal, neither of which is subject to the City's tree preservation policy or ordinance. The proposed project
will not conflict with any local policies protecting biological resources including a tree preservation policy or
ordinance. Therefore, implementation of the Safeway Fuel Center would have no impact due to a conflict in a
policy or program intended to protect biological resources.
3.4(f) (Habitat Conservation Plan) No Impact: At present, no Natural Community Conservation Plan, or other
approved local, regional, or State Habitat Conservation Plan exist for the City of Petaluma. The already
developed project site, located within an established commercial shopping center surrounded by residential
development, does not support any animal or plant habitat. The project will not conflict with the provisions of an
adopted Habitat Conservation Plan or any other Natural Community Conservation Plan approved by a local,
regional or state body. Therefore, the project would have no impact due to a conflict with an adopted
Conservation Plan.
Mitigation Measures:
BIO -1. In order to avoid potential impacts to nesting birds covered by State and federal law (California
Department of Fish and Game Code and the MBTA), the applicant shall avoid the removal of trees,
shrubs, or weedy vegetation between February 1 and August 31, during the bird nesting period. If no
vegetation or tree removal is proposed during the nesting period, no surveys are required. If it is not
feasible to avoid the nesting period, a pre -construction survey for nesting birds shall be conducted by
a qualified wildlife biologist no earlier than 14 days prior to the removal of trees. Survey results shall be
valid for the tree removals for 21 days following the survey. If the trees are not removed within the 21 -
day period, then a new survey shall be conducted. In the event that an active nest for a protected
species of bird is discovered temporary protective breeding season buffers that avoid direct or indirect
mortality of these birds, nests or young shall be established. The appropriate buffer distance is
dependent on the species, surrounding vegetation and topography and shall be determined by a
qualified biologist to prevent nest abandonment and direct mortality during construction.
March 2018 Page 25 of 65
Planning Commission Resolution No. 2018-21A
City of Petaluma Safeway Fuel Center IS/MND
3.5. CULTURAL RESOURCES
Less Than
Potentially Significant Less than No
Significant with Significant Impact
Would the project: Impact Mitigation Impact p
a) Cause a substantial adverse change in the
significance of a historical resource as defined in ❑ ❑ ❑
§ 15064.5?
b) Cause a substantial adverse change in the
significance of an archaeological resource
❑
®
❑
❑
pursuant to § 15064.5?
c) Directly or indirectly destroy a unique
paleontological resource or site or unique geologic
❑
®
❑
❑
feature?
d) Disturb any human remains, including those
❑
®
❑
❑
interred outside of formal cemeteries?
Sources: 2025 General Plan and DEIR: and CEQA Guidelines 15064.5.
Cultural Resources Setting:
The City of Petaluma features a rich variety of historic and cultural resources that contribute to the City's
character and identifiable sense of place. The City contains resources that date to the inhabitation of the Coastal
Miwok Tribe and a number of historic structures that visibly chronicle the evolution of the City from early
settlement through present today. Such resources include artifacts, buildings, structures, landscapes, sites,
objects, and larger districts.
Within the UGB there exist 14 Native American Resources, 19 historic sites and 3 historic districts; Oakhill -
Brewster, Downtown Commercial, and A -Street, The Downtown Historic District has been designated as a
National Historic District. There are upwards of 300 properties that have been identified as potentially eligible
for listing on a local, state, or national register of historic places. In order to perpetuate the unique character
found in Petaluma, the City has adopted goals and policies that serve to compliment and reinforce the sense
of place. The City has implemented programs to regularly update and/or expand surveys of local historic
resources and pursue incentives and programs that will aid in preservation efforts. Existing policies and
regulations governing historic preservation within the City can be found in Chapter 3 of the 2025 Petaluma
General Plan and Chapter 15 of the Implementing Zoning Ordinance.
The proposed project will serve as redevelopment in an existing shopping center within the Washington Core
Subarea. The project site is not located within any designated historic district and does not contain any identified
historic buildings, structures, or landmarks.
Cultural Resources Impact Discussion:
3.5(a) (Historical Resources) No Impact: The project site does not contain any identified historic resources
and does not constitute a historically significant site. The project will involve demolition of the existing
commercial building, site improvements to construct the Fuel Center and the removal of two trees. None of the
features proposed for demolition and/or removal constitute a historically significant building, feature or
landscape. In the absence of any historic resources on, or in direct proximity to the project site, development
and operation of the proposed Safeway Fuel Center would not result in any adverse effects to the significance
of historic resources. Thus, the project will have no impact to the significance of historical resources.
3.5(b -c) (Archaeological Resources/ Unique Paleontological Resources) Less Than Significant With
Mitigation: No known prehistoric, archaeological or paleontological resources have been identified within, or
March 2018 Page 26 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
in proximity to, the project site. Groundbreaking activity and site development performed when the site was
initially developed c.1970 did not expose any archeological resources. While the City of Petaluma does have a
rich archeological history due to the presence of the Coast Miwok Indians during prehistoric times archeological
resources are typically limited to undisturbed lands in the vicinity of ridgetops, midslope terraces, alluvial flats,
ecotones, and sources of water. Although the subject site is not located within any areas of elevated potential
for the occurrence of archeological resources, there remains a potential for the discovery of buried archeological
resources during ground disturbing activities.
In the event that archaeological resources are discovered during site grading, mitigation measure CUL -1
requires that all ground disturbing activity shall be halted immediately until a qualified archaeologist or
paleontologist can evaluate the artifacts identified and recommend further action. Potentially significant
archeological resources include, but are not limited to concentrations of artifacts or culturally modified soil
deposits, stone, shell, bone, or other cultural materials such as charcoal, ash, and burned rock indicative of
food procurement or processing activities, or prehistoric domestic features including hearths, fire pits, or house
floor depressions or other such historic artifacts (potentially including trash pits and all by-products of human
land use greater than 50 years of age). Implementation of CUL -1 will ensure that in the event of accidental
discovery the potential for the project to adversely impact or result in a change to the significance of
archeological resources would be reduced to less than significant levels.
3.5(d) (Human Remains) Less Than Significant with Mitigation: No evidence suggests that cemeteries or
human remains have been interred within the boundaries of the project site. However, in the event that during
ground disturbing activities, human remains are discovered to be present, all requirements of state law shall be
duly complied with including the immediate cessation of ground disturbing activities near, or in any area
potentially overlying adjacent human remains. CUL -2 below sets forth the necessary measures to comply with
State and Federal law associated with buried human remains. With implementation of measures CUL -2
potential impacts due to the accidental discovery of historically significant human remains will be reduced to
less than significant levels.
Mitigation Measures:
CUL -1. If during the course of ground disturbing activities, including, but not limited to excavation, grading and
construction, a potentially significant prehistoric, historic, or paleontological resource is encountered, all
work within a 100 foot radius of the find shall be suspended for a time deemed sufficient for a qualified
and city -approved cultural resource specialist to adequately evaluate and determine the significance of
the discovered resource and provide treatment recommendations. Should a significant archeological or
paleontological resource be identified a qualified archaeologist or paleontologist shall prepare a resource
mitigation plan and monitoring program to be carried out during all construction activities.
CUL -2. In the event that human remains are uncovered during earthmoving activities, all construction
excavation activities shall be suspended and the following measures shall be undertaken:
1. The Sonoma County Coroner shall be contacted to determine that no investigation of the cause
of death is required.
2. If the coroner determines the remains to be Native American the coroner shall contact the Native
American Heritage Commission within 24 hours.
3. The project sponsor shall retain a City -approved qualified archaeologist to provide adequate
inspection, recommendations and retrieval, if appropriate.
4. The Native American Heritage Commission shall identify the person or persons it believes to be
the most likely descended from the deceased Native American, and shall contact such descendant
in accordance with state law.
5. The project sponsor shall be responsible for ensuring that human remains and associated grave
goods are reburied with appropriate dignity at a place and process suitable to the most likely
descendent.
March 2018 Page 27 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
3.6. GEOLOGY AND SOILS
Would the project:
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less than No
Significant Impact
Impact p
a) Expose people or structures to potential
substantial adverse effects, including the risk of
loss, injury, or death involving:
i. Rupture of a known earthquake fault, as
delineated on the most recent Alquist-Priolo
Earthquake Fault Zoning Map issued by the
State Geologist for the area or based on other
❑
El
El
substantial evidence of a known fault? Refer
to Division of Mines and Geology Publication
42.
ii. Strong Seismic ground shaking?
El
®
n ❑
iii. Seismic -related ground failure, including
El
❑
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liquefaction?
iv. Landslides?
E
® El
b) Result in substantial soil erosion or the loss of
❑
®
1-1 El
topsoil?
c) Be located on a geologic unit or soil that is unstable,
or that would become unstable as a result of the
project, and potentially result in on or off-site
landslide, lateral spreading, subsidence, liquefaction
or collapse?
d) Be located on expansive soil, as defined in Table
18-1-B of the Uniform Building Code (1994), creating
substantial risks to life or property?
El
®
El ❑
e) Have soils incapable of adequately supporting the
use of septic tanks or alternative waste water disposal
systems where sewers are not available for the
❑
F1
❑
disposal of waste water?
Sources: 2025 General Plan and DEIR; GP DER Fiq. 3.7-5 Geoloqic Hazards.
Geology and Soils Setting:
The City of Petaluma is located within California Building Code (CBC) Seismic Zone 4 and is susceptible to the
effects of regional seismic activity that in the past has produced moderate to strong ground shaking reaching
intensity levels of V to VIII according to the modified Mercalli scale. The nearest known active fault trace
identified by the state under the Alquist-Priolo Earthquake Fault Zoning Act of 1972 is the Rodgers Creek
segment of the Hayward- Rodgers Creek Fault Zone. The traces of the Rodgers Creek Fault have not been
active within the last 200 years, but have exhibited activity within the last 11,000 years. There are no earthquake
fault zones and no known active faults within the City's UGB, Nonetheless, seismic events in the region have
the potential to result in geologic hazards from strong seismic ground shaking.
March 2018 Page 28 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma Safeway Fuel Center IS/MND
Expansive soils and soil erosion also remain a concern within the City of Petaluma. The clay rich soils in
Petaluma typical of low-lying regions and valley floodplains have a tendency to shrink or swell according to
fluctuations in moisture content. Without proper geotechnical considerations, buildings, utilities and roads can
be damaged by expansive soils due to soil properties that can cause cracking, settling and weakening of
foundations. To reduce the potential risks posed by the presence of expansive soils, the City's building code
requires that any construction site that is intended for human occupancy and suspected to contain expansive
soils be investigated and mitigated accordingly.
The City's General Plan DEIR Figure 3.7-5 identifies the geologic hazard areas of the City. The subject site is
located outside of areas with elevated risk for landslides and liquefaction.
The project site is located within the established Washington Square Shopping Center and is currently occupied
by an existing 13,770 square foot retail building. The primary geotechnical concerns of the site are associated
with seismic activity and expansive soils.
Geoloav and Soils Impact Discussion:
3.6(a. i) (Faults) No Impact: The project site is not located within an identified Alquist-Priolo Earthquake Fault
Zone and no identified active faults traverse the project site. Therefore, no impacts from surface rupture due to
the presence of an Alquist-Priolo Earthquake Fault Zone are expected to occur onsite.
3.6(a. ii) (Ground -Shaking) Less Than Significant Impact With Mitigation: The proximity of the City's UGB
to the Hayward Rodgers Creek Fault Zone places it within Zone IX, Violent of the Mercalli Intensity Shaking
Severity level. As such, the project site holds potential to expose people and structures to potentially substantial
adverse effects resulting from strong seismic ground shaking. An earthquake in the Hayward Rodgers -Creek
fault zone with a 7.1 magnitude has the potential to create peak ground acceleration up to or greater than 0.6g.
The resultant vibrations would likely cause primary damage to buildings and infrastructure with secondary
effects being ground failures in loose alluvium and poorly compacted fill. Both the primary and secondary effects
of seismic activity pose a risk of loss of life or property.
Conformance with standards set forth in the CBC, Title 24, Part 2, (CBC 3.7-20, Chapter 3: Setting, Impacts
and mitigation measures) and the California Public Resources Code, Division 2, Chapter 7.8 (The seismic
Hazards Mapping Act) will ensure that potential impacts from seismic shaking are reduced to less than
significant levels. Mitigation measures GEO-1 is set forth below in order to ensure compliance with the existing
building regulations. With the implementation of measure GEO-1, potential impacts associated with strong
ground shaking will be reduced to levels below significance.
3.6(a. iii -iv) (Ground Failure/Landslides) Less Than Significant Impact: Liquefaction is the rapid
transformation of saturated, loosely packed, fine grained sediment to a fluid like state as a result of ground
shaking. Landslides can occur as a result of ground shaking and the presence of liquefied subsurface materials.
Landslides have been known to occur in Sonoma County, but are typically limited to slopes steeper than 15%
and confined to areas underlain by geologic units that have demonstrated stability problems in the past. The
project site is generally flat and is located outside areas identified as having high to very high potential for
liquefaction as delineated in the GP DEIR, Fig. 3.7-5: Geologic Hazards. Based on the site's flat topography
and the soil profile of medium -grained Holocene alluvium, potential impacts associated with liquefaction and
landslides will be less than significant.
3.6(b) (Erosion) Less Than Significant Impact with Mitigation: Development of the Safeway Fuel Center
will require site preparation and grading activities that have the potential to result in soil erosion if not properly
controlled. Preparation for site grading will involve demolition/ removal of the existing commercial structure and
a limited number of site improvements that include curbs, parking spaces, and two trees. In order to ensure that
potential impacts related to soil erosion are reduced to levels below significant, mitigation measure GEO-2, set
forth below, requires the applicant to submit an erosion control plan that identifies measures to be implemented
during construction and establishes provisions for grading activity during the rainy season. With implementation
of the GEO-2, impacts associated with soil erosion will be reduced to less than significant levels.
3.6(c) (Unstable Geologic Unit) Less Than Significant Impact: The project site is generally flat and exhibits
a minimal grade with no apparent soil migration within the project site boundaries. No signs of soil creep or
March 2018 Page 29 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
lateral spreading are readily apparent on or near the project site, nor is the project site located in an area known
to be particularly susceptible to landslides, lateral spreading, subsidence or collapse. The project site is not
known to contain an especially unstable geologic unit that may become unstable as a result of development
activities. Adherence to standard CBC stipulations are sufficient to ensure that impacts related to landslides,
lateral spreading, subsidence, liquefaction and collapse would remain at less than significant levels with the
introduction of a new fuel station and associated convenience store. Therefore, the project would have less
than significant impacts due to the presence of a geologic unit or soil that is unstable, or that would become
unstable as a result of the project.
3.6(d) (Expansive Soils) Less Than Significant Impact With Mitigation. Expansive soils are a concern within
the Urban Growth Boundary including the project site. In order to ensure that the potential presence of
expansive soils does not result in significant impacts, the applicant must comply with Seismic Zone 4 Soil and
Foundation Support Parameters outlined in Chapters 16 and 18 of the California Building Code and grading
requirements outlined in Chapters 18 and A33 of the California Building Code. Furthermore, to ensure that the
design and construction measures adequately account for expansive soils, a soils report shall be prepared by
the applicant and approved by the City prior to the commencement of any construction activities. Mitigation
measure GEO-3 will ensure that the appropriate corrective measures are employed to address expansive soils
including but not limited to pre -watering prior to the placement of foundations, removal of expansive material
and replacement with non -expansive fill, and/or the use of soil stabilizers. This measure in addition to
compliance with standard regulations will ensure that potentially expansive soils onsite are properly treated to
avoid impacts associated with shrinking and swelling. Therefore, with implementation of mitigation measure
GEO-3 potential impacts due to the presence of expansive soils will be reduced to levels below significance.
3.6(e) (Septic Tanks) No Impact: The proposed project will be connected to the existing sewer system that
treats all wastewater effluent generated within the UGB. There are no septic tanks or alternative wastewater
disposal systems proposed as part of the Safeway Fuel Center. Therefore, there will be no impact resulting
from the adequacy of soils to support septic tanks or other wastewater disposal system.
Mitigation Measures:
GEO-1. Foundation and structural design for buildings (convenience store and canopy) shall meet the
California Building Code regulations for seismic safety (i.e., reinforcing perimeter and/or load bearing
walls, bracing parapets, etc.).
GEO-2. Prior to issuance of a grading permit, an erosion control plan along with grading and drainage plans
shall be submitted to the City Engineer for review. All earthwork, grading, trenching, backfilling, and
compaction operations shall be conducted in accordance with the City of Petaluma's Grading and
Erosion Control Ordinance #1576, Title 17, Chapter 17.31 of the Petaluma Municipal Code. These
plans shall detail erosion control measures such as site watering, sediment capture, equipment
staging and laydown pad, and other erosion control measures to be implemented during construction
activity on the project site,
GEO-3. _Prior to issuance of a grading permit, a soils and geological report shall be submitted to the City
Engineer for review pursuant to the City of Petaluma's Ordinance #1576, Title 17, Chapter 17.31.180.
The soils report shall detail the strength and characteristics of the soils onsite and provide conclusions
and recommendations for grading procedures and design criteria as appropriate. Techniques used
to correct expansive soils include controlled pre -watering prior to the placement of foundations,
removal of expansive material and replacement with non -expansive fill, and/or the use of soil
stabilizers.
March 2018 Page 30 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
3.7. GREENHOUSE GAS EMISSIONS
Fuel Center IS/MND
Less Than
Potentially Significant Less than No
Significant with Significant Impact
Would the project: Impact Mitigation Impact p
Incorporated
a) Generate greenhouse gas emissions, either
directly or indirectly, that may have a significant
impact on the environment?
b) Conflict with an applicable plan, policy or
regulation adopted for the purpose of reducing the
emissions of greenhouse gases?
❑
❑
®
❑
❑
❑
®
❑
Sources: 2025 General Plan and DEIR; Climate Action 2020 and Beyond Sonoma County Regional Climate
Action Plan, July 2016; BAAQMD CEQA Guidelines, Regulation 8 Organic Compound Rule 7 Gasoline
Dispending Facilities, BAAQMD, November 6, 2002; Safeway Fuel Center Air Pollutant and Greenhouse Gas
Emissions Assessment, prepared by Illingworth & Rodkin, January 8, 2014, Revised September 18, 2017.
Greenhouse Gas Setting:
Greenhouse gases (GHGs) are generated both from natural geological and biological processes and through
human activities including the combustion of fossil fuels and industrial and agricultural processes. Other than
water vapor, the GHGs contributing to global climate change include carbon dioxide (CO2), nitrous oxide (N20),
methane (CH4), chlorofluorocarbons, hydrofluorocarbons and perfluorocarbons. In the United States, carbon
dioxide emissions account for about 85 percent of the GHG emissions.
To address GHG's at the State level, the California legislature passed Assembly Bill 32 in 2006, which requires
that statewide GHG emissions be reduced to 1990 levels by 2020. Senate Bill 375 has also been adopted,
which seeks to curb GHG emissions by reducing urban sprawl and vehicle miles traveled.
The City of Petaluma has taken steps to address GHG emissions within city limits. The City adopted Resolutions
2002-117, 2005-118, and 2018-009 (incorporated herein by reference), which calls for the City's participation
in the Cities for Climate Project effort and established GHG emission reduction targets.
A Climate Action Plan has been prepared in partnership with the County and other local jurisdictions (July
2016). This effort implements General Plan Policy 4-P-27. A number of General Plan policies serve to reduce
GHG emissions associated with project construction, design and operation. General Plan Goal 5-G-8, which
calls for the City to "expand the use of alternative modes of mobility serving regional needs," is being
implemented in part through the Sonoma Marin Area Rail Transit (SMART) Plan, which as of Fall 2017 provides
light rail commuter service to Petaluma. The light rail effort is estimated to take more than 1.4 million car trips
off Highway 101 annually and reduce GHGs by at least 124,000 pounds per day. In addition, General Plan
policy 3- P-127 requires that projects prepare a Construction Phase Recycling Plan that would address recycling
of major waste generated by demolition and construction activities. Particularly relevant for the Fuel Center
project is policy 4-P-10 which requires electric vehicle charging and alternative fuel facilities at all new gas
stations.
In 2016, the City adopted an update to the California Building Standards Code, which contains the mandatory
California Green Building Standards Code (CalGreen). All new development within the City of Petaluma must
comply with these standards, which generally achieve energy efficiency approximately 15% beyond Title 24 as
well as construction waste reduction rate of 65%. As such, new development is expected to be more energy
efficient, use fewer resources and emit fewer GHGs.
On January 22, 2018, the City of Petaluma adopted Resolution No. 2018-009 N.C.S reaffirming the City's intent
to reduce greenhouse gas emissions as part of a coordinated effort through the Sonoma County Regional
Climate Protection Authority. As presented in the Sonoma County Climate Action Plan, the City of Petaluma
could achieve GHG reduction through a combination of state, regional and local measures. Reduction
March 2018 Page 31 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
measures at the state level are promulgated through state laws and mandates addressing topics, including but
not limited to vehicle fuel efficiency standard, green building standards, low carbon fuel standards and the
Renewable Portfolio Standard. When realized locally in Petaluma, these measures will achieve a GHG
reduction in the amount of 119,000 metric tons of carbon dioxide equivalence (MTCO2e). Separate regional
efforts implemented within Petaluma by entities such as the Regional Climate Protection Authority, Sonoma
County Water Agency, County of Sonoma Energy Independence Office, Sonoma County Transportation
Authority, and Sonoma Clean Power will result in an additional GHG reduction of 28,200 MTCO2e. Under the
City of Petaluma's authority, the Sonoma County Climate Action Plan identifies 12 goals and 24 measures that
would achieve an additional GHG reduction of 18,490 MTCO2e, Taken altogether, the state, regional and local
measures combined can achieve a GHG reduction of 166,350 MTCO2e within Petaluma.
Under a business as usual approach (i.e., without state, regional or local GHG reduction measures), the City of
Petaluma is projected to emit 542,970 MTCO2e by 2020. With implementation of reduction measures, GHG
emissions would be reduced to 376,620 MTCO2e. This represents a 31% reduction of GHG emissions relative
to the 1990 per capita emission levels.
At present, the Sonoma County Regional Climate Action Plan is an advisory document to assist the City in
achieving its stated intent to reduce GHG emissions. Development projects within the City of Petaluma are
encouraged to comply with the intent of the Climate Action Plan and realize GHG reductions through voluntary
application of reduction measures.
The BAAQMD CEQA Air Quality Guidelines, established in May 20108 and most recently updated in May 2017,
include thresholds of significance for greenhouse gas emissions. The most recent version of the BAAQMD
CEQA Guidelines includes revisions made to address the Supreme Court's opinion (California Building Industry
Association v. Bay Area Air Quality Management District, December 2015).9 The BAAQMD is currently working
to update any outdated information in the Guidelines, and anticipates release of an updated document in early
2018.10
The BAAQMD Guidelines use a three -tiered approach for setting a significance threshold for the project -level
contributions to cumulative GHG impacts. Based on the BAAQMD Guidelines, a project is considered less -
than -significant if it either:
a) Complies with a legislatively adopted GHG Reduction Strategy which meets or exceeds one of the following
three options:
i. Reduces emissions to 1990 levels by 2020,
ii. Reduces emissions 15% below baseline (2008 or earlier) emission level by 2020, or
iii. Meets the plan efficiency threshold of 6.6 MT CO2e/service population/year;
b) Emits a total of less than 1,100 metric tons (MT) CO2e per year; or
c) Emits less than 4.6 MT/service population/year. Metric tons per capita for service population per year;
service population includes residents and any employees.
8 Adopted by Board of Directors of the BAAQMD in June 2010 (Resolution No. 2010-6).
9 In March 2012, the Alameda County Superior Court ordered BAAQMD to set aside use of the significance thresholds
within the BAAQMD 2010 CEQA Guidelines and cease dissemination until they complete an assessment of the
environmental effects of the thresholds in accordance with CEQA. The Court found that the thresholds, themselves,
constitute a "project" for which environmental review is required. In August 2013, the First District Court of Appeal
reversed the Alameda County Superior Court's decision. The Court held that adoption of the thresholds was not a
"project" subject to CEQA because environmental changes that might result from their adoption were too speculative
to be considered "reasonably foreseeable" under CEQA. In December 2015, the California Supreme Court reversed
the Court of Appeal's decision and remanded the matter back to the appellate court to reconsider the case in light of
the Supreme Court's opinion.
10 Alison Kirk, BAAQMD, Email Correspondence, June 6, 2017.
March 2018 Page 32 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
In 2007, the City prepared a revised Air Quality section for the General Plan EIR to address greenhouse gas
emissions. Appendix A of the 2007 Revised EIR includes all of the applicable policies from the General Plan
that reduce Greenhouse Gas Emissions.
The Sonoma County Regional Climate Action Plan presents recommended GHG reduction measures specific
to the City of Petaluma to achieve identified GHG emission reduction targets. Neither the Petaluma General
Plan nor the Sonoma County CAP is considered a "qualified" GHG reduction strategy by the BAAQMD.
Therefore, the discussion of each of these documents is provided for information purposes only and with regard
to the threshold of significance applied for this topic, the BAAQMD's screening threshold of 1,100 metric tons
(MT) of carbon dioxide equivalents per year (CO2e/yr) is used to evaluate project level significance.
Greenhouse Gas Emissions Impact Discussion:
3.7(a -b) (Significant GHG Emissions/ GHG Plan Conflict) Less than Significant Impact: In evaluating
whether the subject project would have a potential to reach or exceed established thresholds for GHG, a project -
specific Air Pollutant and Greenhouse Gas Emissions Assessment was prepared by Illingworth & Rodkin that
quantifies GHG emissions from construction and operation (Appendix A). Impacts from GHG emissions are
assessed using the BAAQMD's 2011 CEQA significance thresholds. In addition, the following discussion also
evaluates compliance of the proposed project with AB 32 GHG reduction measures, and General Plan 2025
measures designed to reduce GHG emissions.
As described above, projects proposed in areas where a qualified BAAQMD GHG Reduction Strategy has not
been adopted are reviewed against a screening threshold of 1,100 MT carbon dioxide equivalents per year
(CO2e/yr). This threshold generally corresponds to the project sizes set out in Table 3-1 of the 2017 BAAQMD
CEQA Guidelines. The screening size for GHG emissions for a convenience market with gas pumps is 1,000
square feet. Although the proposed convenience store is 697 square feet, a GHG analysis was conducted as
part of the Air Pollutant and Greenhouse Gas Emissions Assessment by Illingworth and Rodkin.
As described in Appendix A, the California Emissions Estimator Model (CaIEEMod) Version 2016.3.1 was used
to predict GHG emissions from demolition, construction and operation of the proposed Safeway Fuel Center.
CaIEEMod provides emission projections for transportation, areas sources, electricity consumption, natural gas
combustion, electricity usage associated with water use and wastewater discharge, and solid waste disposal.
Construction of the proposed Safeway Fuel Center will result in GHG emissions from demolition, heavy-duty
construction equipment, worker trips, and material delivery and hauling. GHG emissions from construction
activities are short-term and will cease once construction is complete. Although, the BAAQMD has not
established thresholds of significance for GHG emissions resulting from construction activities, the project's
GHGs emissions were evaluated relative to the operational thresholds.
As shown in Table 8 below, construction -related GHG emissions will result in 66 metric tons, which is well below
the threshold of 1,100 metric tons. GHG emissions generated from construction of the proposed fuel center will
not directly or indirectly result in a significant impact to the environment. Therefore, environmental impacts from
construction generated GHGs will be less than significant.
As described in the Air Pollutant and Greenhouse Gas Emissions Assessment, at operation of the proposed
project, GHG emissions are projected to be 947 MT of CO2e per year, as shown in Table 8 below. The projected
GHG emission level is below the BAAQMD threshold of 1,100 MT of CO2e/yr. Therefore, impacts to air quality
resulting from GHG emissions at operation of the Safeway Fuel Center would be less than significant.
Table 8
GHG Emissions
Emission Source CO2e
metric tons
Construction 66
March 2018 Page 33 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma
BAAQMD Threshold
1,100
Exceeds Threshold?
No
Operation
Motor Vehicles and Building Operation
708
Vehicle Exhaust Idling
239
Evaporative Gasoline
0
Total Emissions
947
BAAQMD Thresholds
1,100
Exceeds Threshold?
No
Source: Air Pollutant and Greenhouse Gas Emissions Assessment,
prepared by Illingworth and Rodkin, September 18, 2017.
Fuel Center IS/MND
Consistency with GHG Regulations and General Plan 2025 Measures
The proposed Safeway Fuel Center is consistent with applicable GHG regulations and General Plan policies. The
project is required to comply with the CalGreen Building standards and 2016 Building & Energy Efficiency
Standards. The project proposes the installation of an electrical vehicle -charging stall, pursuant to General Plan
policy 4-P-10. As a condition of project approval, the project will develop a Construction Phase Recycling Plan
pursuant to policy 2-P-122 to address the disposal of materials from demolition and construction. As proposed,
the project is consistent with relevant General Plan policies and GHG regulations. Therefore, potential impacts
due to the generation and emission of greenhouse gases would be less than significant.
Mitigation Measures: None Required.
March 2018 Page 34 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
3.8. HAZARDS/HAZARDOUS MATERIALS
Fuel Center IS/MND
Would the project:
Less Than
Potentially Significant Less than No
Significant with Significant Impact
Impact Mitigation Impact
Incorporated
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
❑ ® ❑ El
disposal of hazardous materials?
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
El
hazardous materials into the environment?
c) Emit hazardous emissions or handle hazardous
or acutely hazardous materials, substances, or
waste within one-quarter mile of an existing or
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proposed school?
d) Be located on a site that is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would create a significant hazard to the public or the
E] E] El
environment?
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport of public use
airport, would the project result in a safety hazard
El El
for people residing or working in the project area?
f) For a project within the vicinity of a private airstrip,
would the project result in a safety hazard for people
El El El Z
residing or working in the project area?
g) Impair implementation of or physically interfere
with an adopted emergency response plan or
❑ ❑ ❑
emergency evacuation plan?
h) Expose people or structures to a significant risk
of loss, injury or death involving wildland fires,
including where wildlands are adjacent to urbanized
areas or where residences are intermixed with El El El Z
wildlands?
Sources: 2025 General Plan and DEIR; and Limited Asbestos and Lead -Based Paint Survey, prepared by
Cardno ATC. Mav 29, 2013.
Hazardous Material Setting: The California Department of Toxic Substances Control (DTSC) defines a
hazardous material as: "a substance or combination of substances that, because of its quantity, concentration
or physical, chemical, or infectious characteristics, may either: 1) cause, or significantly contribute to an increase
in mortality or an increase in serious, irreversible, or incapacitating illness; or 2) pose a substantial present or
potential hazard to human health or environment when improperly treated, stored, transported, disposed of, or
otherwise managed." Hazardous materials are generally classified based on the presence of one or more of
the following four properties: toxicity; ignitability; corrosivity; and reactivity.
March 2018 Page 35 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
Regulations governing the use, management, handling, transportation and disposal of hazardous materials and
waste are administered by federal, state and local governmental agencies. Federal regulations governing
hazardous materials and waste include the Resource Conservation, and Recovery Act of 1976 (RCRA); the
Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA); and the
Superfund Amendments and Re -authorization Act of 1986 (SARA).
In California hazardous materials and waste are regulated by the Department of Toxic Substances (DTSC).
Pursuant to the California Planning and Zoning Law the DTSC maintains a hazardous waste and substances
site list, also known as the "Cortese List." There are no known Cortese sites within the City of Petaluma. In
California the Secretary for Environmental Protection established the Unified Hazardous Materials and
Hazardous Waste Management Program, also known as "Unified." The Unified program is intended to
consolidate and ensure consistency in the administration of requirements, permits and inspections for six
programs, including the Underground Storage Tank (UST) program.
The six programs established by the Unified Program are administered and implemented locally through
"Certified Unified Program Agencies" (CUPA). The Petaluma CUPA manages the acquisition, maintenance and
control of hazardous materials and waste generated by industrial and commercial business under the auspices
of the Petaluma Fire Department. Under COPA, projects that intend to store, transport or generate hazardous
waste must apply for and obtain a permit and submit a Hazardous Materials Release Response Plan and
Inventory on an annual basis.
The proposed project will involve the demolition of the existing 13,770 square foot commercial structure,
constructed in 1974, and associated paving and landscaping improvements. At operation the proposed
Safeway Fuel Center will contain a convenience store, 16 fuel pumping stations, two underground fuel storage
tanks each with a capacity of 20,000 gallons, and associated improvements such as landscaping. All new
underground storage tanks must be double -walled, with an interstitial monitoring device to detect leaks. The
regulations for this program are contained in Chapter 6.7, Division 20 of the Health and Safety Code and
Subchapter 16 of Title 23 of the California Code of Regulations, California Underground Storage Tank
Regulations, and are implemented by the Regional Water Quality Control Board (RWQCB).
Facilities that use or store potentially hazardous materials in quantities that are above reporting thresholds must
prepare a Hazardous Materials Business Plan (HMBP). The Safeway Fuel Center is subject to the preparation
of a HMBP in order to satisfy federal and state right -to -know laws and provide detailed information for use by
emergency responders.
In order to determine the presence of Asbestos Containing Materials (ACM) and/or the presence of Lead -Based
Paint (LBP) a limited asbestos and lead-based paint survey was performed by Cardno ATC on May 16, 2013
in accordance with the U.S. EPA Asbestos Hazard Emergency Response Act (AHERA) Inspection Protocol.
The survey utilized semi -destructive sampling methods to collect suspect materials; the surveyor collected 49
bulk asbestos samples and 5 paint chip samples to test for LBP. The findings indicate the presence of asbestos
containing materials (ACM); however, no lead based paint (LBP) was found to be present (see expanded
discussion below, full report is provided in Appendix C).
The primary hazardous materials considerations related to the project include proper disposal and removal of
potentially hazardous materials during demolition and the proper handling and storage of fuel at operation.
Hazards/Hazardous Materials Impact Discussion:
3.8(a -b) (Routine Transport/ Upset and Accident Involving Release) Less Than Significant Impact with
Mitigation: The proposed project will involve the demolition of the existing 13,770 commercial structure
(c.1974) followed by construction and operation of the Safeway Fuel Center. The existing commercial building
was surveyed for the presence of asbestos containing material (ACM) and lead based paint. Demolition of the
existing building has the potential to result in impacts due to the presence of ACM. Although the project site will
contain potentially hazardous materials on both a temporary and permanent basis, adherence to best
management practices and compliance with all applicable regulations regarding proper storage, handling and
labeling will ensure that potential impacts remain at levels below significance.
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Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
Demolition Asbestos Materials
A limited asbestos and lead-based paint survey was performed by Cardno ATC on May 16, 2013. Forty-nine
asbestos samples were collected from the subject building and a total of 57 layers were analyzed using
Polarized Light Microscopy with Dispersion Staining (PLM) techniques. The difference in sample collected
versus samples tested is due to the analysis protocols requiring separation and analysis of all discernable layers
within a given sample. The asbestos survey results indicate presence of asbestos in 18 of the samples
collected; the concentration of asbestos ranges from 1% to 35%.
The EPA defines asbestos containing materials (ACM) as any material exhibiting a composition with 1% or
more of asbestos and requires that ACM must be removed prior to demolition. The removal of ACM must be
performed in accordance with CAL OSHA regulations and work performed on ACM constituting more than 100
linear or square feet requires a California State registered and licensed asbestos abatement contractor perform
the work in accordance with CAL -OSHA standards.
Materials determined to contain less than one percent asbestos, particularly gypsum board and joint compound
samples, shall be subject to a point count analysis which will provide much more accurate results as required
per Mitigation Measure HAZ-1. Until this test is performed, these materials will continue to be considered friable
Regulated Asbestos Containing Materials (RACM). If it is found that such materials do in fact contain <1%
asbestos, the material may be disposed of as non -hazardous asbestos containing construction waste. Any
materials determined by the limited asbestos and lead based paint survey and subsequent point count analysis
to contain ACM shall be removed in accordance with those measures outlined in the Limited Asbestos Report
and recommendations set forth in the Point Count Analysis and will be handled in accordance with Section 11-
2-303 as required per mitigation measure HAZ-1. With implementation of measure HAZ-1 potential impacts due
to the presence of asbestos containing material will be reduced to levels below significance.
Lead Based Paint
Materials are considered by the Department of Housing and Development (HUD) to have lead-based paint if
samples are found to contain more than 5,000 parts per million (ppm). Of the five samples collected, none were
found to contain a concentration of lead above 5,000 ppm. All five samples exhibited concentrations below the
laboratory detection limit of less than 0.020% by weight. As such, potential hazards associated with LBP will be
less than significant.
Construction Temporary Storage of Potentially Hazardous Materials
Site preparation, construction activities and material delivery may result in the temporary presence of potentially
hazardous materials including, but not limited to gasoline, diesel fuels, lubricants, paints, solvents, insulation,
and electrical wiring. Although there may be potentially hazardous materials onsite during construction the
applicant will comply with all existing federal, state and local safety regulations governing the transportation,
use, handling, storage and disposal of potentially hazardous materials. In order to prevent release of potential
hazards during construction the applicant is required to institute Best Management Practices and create and
implement a worker health and safety plan. The applicant shall comply with all federal and state regulations as
overseen by the Petaluma COPA. If and when construction activities involve the on-site storage of potentially
hazardous materials, a declaration form will be filed with the Fire Marshall's office and a hazardous materials
storage permit must be obtained. Due compliance with Federal, State and Local regulations will ensure that
hazards to the public or the environment through the routine transport, use, or disposal of hazardous materials
will be less than significant levels.
Operation: Storage and Use of Potentially Hazardous Materials
Gasoline storage and dispensing facilities contain potentially hazardous materials including liquid fuels as well
as gas vapors. Additionally, other potentially hazardous materials including lubricants, oils, and petroleum-
based products will likely be available at the convenience store. At operation, the Safeway Fuel Center will
routinely handle, store and dispense potentially hazardous materials. The operation of such facilities are
regulated by a number of Federal and State agencies.
The project proposes a twice-daily delivery of fuel to take place between the hours of 6 am and 8 am in the
morning and after 5 pm in the evening. Two 20,000 -gallon underground storage tanks will contain a combined
total up to 40,000 gallons of fuel storage onsite. It is anticipated that the throughput usage will amount to 8.5
million gallons. The transfer and storage of gasoline will result in the emission of volatile organic compounds
March 2018 Page 37 of 65
Planning Commission Resolution No. 2018-21A
City of Petaluma Safeway Fuel Center IS/MND
(VOCs), also referred to as reactive organic gases (ROGs). Such compounds are emitted through the loading,
breathing and dispensing of fuels. With the anticipated throughput of 8.5 million gallons, evaporative gasoline
emissions could reach 2.85 tons annually which is well below BAAQMD's significance threshold of 10 tons.
The State of California requires that fueling stations incorporate proper control equipment necessary to
minimize vapor emitted from the facility such as enhanced vapor recovery systems. As proposed, the fuel
dispensing valves will control and minimize vapor emissions (also see expanded discussion in Sect. 3.3, Air
Quality). Additionally, the facility will be constructed in accordance with California's Fire, Building and Health
Codes that require measures such as automatic shut offs, signage and onsite spill containment for USTs.
The operator shall obtain a permit from the Petaluma CUPA and submit a Hazardous Materials Release
Response Plan and Inventory in accordance with CUPA standards. Compliance with all Federal, State and
Local regulations outlined herein, as well as adherence to best management practices will ensure that potential
impacts to people and the environment due to hazardous or potential hazardous materials remain less than
significant.
3.8(c) (Emit of Handle within 1/4 Mile of School) Less Than Significant Impact: The project site is located
approximately 150 feet from an existing school. As previously discussed, adherence to existing federal, state
and local regulations will ensure that all potentially hazardous materials onsite are properly labeled, transported
and stored. Established policies and programs set forth by the EPA, DTSC, CAL/OSHA and other regulatory
agencies provide that the presence of potential hazardous materials occurs in the safest possible manner by
reducing the opportunity for accident release or spills and ensuring that a response plan is in place. Such
policies include corrosion and overfill protection, as well as leak detection for underground storage tanks. Above
ground storage is also regulated through the federal Oil Spill Prevention, Control Countermeasures regulation.
The Petaluma Fire Prevention Bureau regulates hazardous materials including fuel storage. The Fuel Center
is required to adhere to local, state and federal regulation regarding the storage and sale of petroleum. A
Hazardous Materials Business Plan will be prepared and implemented that addresses spill prevention and
response in the event of accidental release. Thus, potential impacts due to the proximity of the school to the
proposed gas station would be less than significant.
3.8(d) (Government Code §65962.5 Site) No Impact: There are no Cortese sites located within the City of
Petaluma, including that of the project site. The project will not create a significant hazard to the public or the
environment due to an identified Cortese site. Therefore, the project would have no impact associated with a
hazardous materials site.
3.8(e -f) (Public and Private Airport Land Use Plan) No Impact: The project is not located within the
boundaries of an airport land use plan or located in close proximity to a private airstrip; the nearest airport is
the Petaluma Municipal Airport located approximately 1.5 miles (geodesic distance) northeast of the project
site. Therefore, no impacts associated with airport -related hazards are expected.
3.8(g) (Impair Emergency Response Plan) No Impact: The project would not impair implementation of, or
physically interfere with, an adopted emergency response plan or emergency evacuation plan. The project will
not alter any emergency response or evacuation routes. Site plans include ingress and egress access that
accommodate emergency vehicles and provide connectivity to the existing circulation and street system.
Therefore, the proposed Project will have no impact on the emergency response plan or emergency evacuation
plan.
3.8(h) (Wildland Fire) No Impact: The project site located in the Washington Core Subarea within the UGB
and is bounded by commercial, residential and institutional development. There are no wildlands located within,
or adjacent to, the project site. Therefore, no impacts related to the exposure of people or structures to a
significant risk of loss, injury or death involving wildland fires are expected.
Mitigation Measures:
HAZ-1. Prior to demolition activities, the applicant shall perform a point -count analysis on the Gypsum Board and
Joint Compound Samples determined to contain less than one percent asbestos. Where the material is
found to contain greater than 1 percent asbestos and is friable, the material must be handled in
March 2018 Page 38 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma
Fuel Center IS/MND
accordance with BAAQMD Regulations Section 11-2-303. Proper handling and disposal procedures that
promote safe working conditions and minimize release of component materials into the environment shall
be performed.
3.9. HYDROLOGY AND WATER QUALITY
Less Than
Potentially Significant Less than No
Would thero ect: Significant with Significant Impact
p ) Impact Mitigation Impact
Incorporated
a) Violate any water quality standards or waste discharge
requirements? ❑ ❑ ® ❑
b) Substantially deplete groundwater supplies or interfere
substantially with groundwater recharge such that there
would be a net deficit in aquifer volume or a lowering of
the local groundwater table level (e.g., the production rate El ❑ ® El
pre-existing nearby wells would drop to a level which
would not support existing land uses or planned uses for
which permits have been granted)?
c) Substantially alter the existing drainage pattern on the
site or area, including through the alteration of the course
of a stream or river, in a manner that would result in ❑ ❑ ® ❑
substantial erosion or siltation on- or off-site?
d) Substantially alter the existing drainage pattern on the
site or area, including through the alteration of the course
of a stream or substantially increase the rate or amount
of surface runoff in a manner, which would result in ❑ ❑ ® ❑
flooding on- or off-site?
e) Create or contribute runoff water that would exceed the
capacity of existing or planned stormwater drainage
systems or provide substantial additional sources of ❑ ❑ ® ❑
polluted runoff?
f) Otherwise substantially degrade water quality? ❑ ❑ ® ❑
g) Place housing within a 100 -year flood hazard area as
mapped on a federal Flood Hazard Boundary or Flood
Insurance Rate Map or other flood hazard delineation ❑ ❑ ❑
map?
h) Place within a 100 -year flood hazard area structures ❑ ❑ ❑
that would impede or redirect flood flows?
i) Expose people or structures to a significant risk of loss, ❑ ❑ ❑
injury or death involving flooding, including flooding as a
result of the failure of a levee or dam?
j) Inundation by seiche, tsunami, or mudflow? ❑ ❑ ❑
Sources: 2025 General Plan and DEIR.
Hydrology and Water Quality Setting: The Petaluma River is the primary watercourse within the City of
Petaluma and drains the Petaluma watershed (an area of approximately 46 square miles). The Petaluma River
March 2018 Page 39 of 65
Planning Commission Resolution No. 2018-21A
City of Petaluma Safeway Fuel Center IS/MND
is tidally influenced and flows in a southeast direction into San Pablo Bay. The Petaluma River is used for
recreational boating and water sports as well as long-standing river dependent industrial operations.
Section 402 of the Clean Water Act regulates the discharge of pollutants to waters of the U.S. The National
Pollution Discharge Elimination System (NPDES) Construction General Permit, 2009-0009-DWQ requirements
apply to grading, grubbing, and other ground disturbance activities.
The City of Petaluma collects Storm Drainage Impact Fees as a means of mitigating storm drainage impacts
occurring as a result of development. The criteria provides for either the payment of fees or the construction of
on- or off-site detention areas, based upon the type of project and amount of runoff generated, as calculated
for a 100 -year storm. Fees collected are used by the City for the acquisition, expansion, and development of
storm drainage improvements.
Chapter 15.80 of the City's Municipal Code regulates stormwater discharges. Grading and erosion control
requirements are set forth in Chapter 17.31 of the Municipal Code. Low Impact Development (LID) requirements
establish limitations on the stormwater runoff emanating from development sites. New development, including
the Safeway Fuel Center, is required to mimic pre -developed conditions, protect water quality, and retain runoff
from impervious surfaces introduced onsite.
Hydrology and Water Quality Impact Discussion:
3.9(a) (Water Quality Standards) Less than Significant Impact: The Safeway Fuel Center is required to
adhere to water quality discharge requirements. As a fuel station, the Safeway Fuel Center has the potential to
result in the discharge of stormwater that contains elevated hydrocarbons and/or sediment loads. The applicant
has proposed the installation of an infiltration/bio- filtration trench located along the property frontage to S.
McDowell Boulevard that would receive and filter on-site runoff. The infiltration trench will utilize a 5 foot wide
cobble swale composed of 3 to 6 inch cobbles underlain by a combination of filter fabric, soil mix, permeable
gravel (Class 2) and a 6 inch perforated collection pope with filter fabric sleeve. The cobble trench is expected
to provide a level of filtration necessary to maintain water quality and encourage peak flow attenuation. The
installation of the bio -filtration/ infiltration trench and adherence to best management practices for erosion
control during construction activities will ensure that water quality standards and waste discharge requirements
are met. Therefore, any potential impacts would remain at levels below significance.
3.9(b) (Groundwater Supply and Recharge) Less Than Significant Impact: The City has adequate water
resources to accommodate development of the Safeway Fuel Center without depleting, degrading or altering
groundwater supplies or interfering substantially with groundwater recharge. Demolition of the existing
commercial building onsite will permanently remove any water demand incurred by tenants. Although water will
be required for the proposed landscaping, convenience store and other ancillary uses onsite, the proposed
Safeway Fuel Center will result in decreased water use relative to the existing condition. The subject project
would not result in a lowering of the aquifer or the local groundwater table. The project's water demand is
consistent with the water demands evaluated in the 2015 Urban Water Management Plan (UWMP), which found
sufficient water supplies are available to meet existing and planned future development within the UGB.
Groundwater reserves will not be impacted by the proposed development. Therefore, the subject Safeway Fuel
Center would have less than significant impacts due to the depletion of groundwater supplies or the lowering of
the groundwater aquifer.
3.9(c -d) (Drainage Pattern or Runoff) Less than Significant Impact: The project would not alter the course
of an existing surface drainage feature. Stormwater runoff generated by impervious surfaces will be conveyed
to the bio -filtration trench located along the frontage of South McDowell Blvd. There is no expectation that the
project will induce substantial erosion or siltation on or off site, or that it would substantially increase the rate or
amount of surface runoff in a manner that would result in flooding. Existing flow volume and direction would
largely be retained. Therefore, impacts would be less than significant.
3.9(e -f) (Stormwater Drainage System Capacity) Less than Significant Impact: In order to accommodate
runoff generated by a 100 -year peak storm event, the site will feature an infiltration/ bio -filtration trench located
along South McDowell frontage that will contain and filter stormwater flows. The bio -filtration trench will include
several layers of filtration comprised of mixed sandy soils, cobbles and filter fabric sleeve that will capture litter,
March 2018 Page 40 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
suspended solids, hydrocarbons and/or particulate metals contained in surface runoff. Additionally, the project
proposes an increase in landscaped area from 2,971 square feet to 7,298 square feet, thereby increasing the
ratio of pervious to impervious surfaces relative to the existing condition onsite. The reduction in impervious
surfaces and the installation of a bio -filtration trench will ensure that the project does not contribute an increased
amount of runoff to the storm drain system or degrade water quality. Therefore, impacts associated with
drainage capacity and water quality degradation are expected to be less than significant.
3.9(g -i) (Flooding Hazard) No Impact: The project site is not located in a designated 100 year flood zone per
the current Flood Insurance Rate Maps (FIRMS) dated February 19, 2014, Community Panel Number
06097C1001 F. The FIRMS indicate that the project site is located outside of the 0.2% annual floodplain. As
such, the project would not place structures within a zone subject to a flooding hazard or impede or redirect
flow. Therefore, the Safeway Fuel Center would have no impacts related to hazards associated with flooding.
3.90) (Seiche, Tsunami, Mudflow) No Impact: The site is not located near a large water body that would be
a source of a seiche or tsunami, nor is there a heightened potential for mudflow. Therefore, the Safeway Fuel
Center would have no impacts associated with inundation from such conditions.
Mitigation Measures: None required.
3.10. LAND USE AND PLANNING
Potentially
Less Than
Less than No
Significant
Significant
Significant Impact
Impact
Would the project:
with
Mitigation
Impact
Incorporated
a) Physically divide an established community? El
❑
El
b) Conflict with any applicable land use plan, policy,
or regulation of an agency with jurisdiction over the
project (including, but not limited to the general plan,
specific plan, local coastal program, or zoning El E] ® ❑
ordinance) adopted for the purpose of avoiding or
mitigating an environmental effect?
c) Conflict with any applicable habitat conservation El ❑ El
plan or natural community conservation plan?
Sources: 2025 General Plan and DEIR; and Petaluma Economic Development Strategy, 2010.
Land Use and Planning Setting: The predominant land uses within the City's Urban Growth Boundary include
residential, commercial, industrial, open space, and public lands. Approximately 0.8% of the UGB lands are
designated for commercial use. The 2025 General Plan proposes commercial/retail development that would
increase commercial development by 2.87 million square feet relative to 2005 conditions. At buildout,
commercial/retail uses are expected to total 7.06 million square feet or account for approximately 3% of the
land uses.
As proposed, the project will remove 13,770 square feet of commercial space and replace it with a covered fuel
station and associated convenience store (697 square feet). Accordingly, the project would result in a net
decrease of commercial space amounting to 13,073 square feet.
The land use that characterizes the project site is designated "community commercial," which is typified by
regionally -oriented retail and commercial centers. According to the "Petaluma Economic Development Strategy"
the shopping area located at the intersection of E. Washington Street and S. McDowell Blvd serves as one of
the two primary generators of retail sales in the City. Gasoline service stations are the second-largest profit
generator in the "automotive" category and contribute to the 10 million in annual regional sales.
March 2018 Page 41 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
The project site is located in an urbanized area of Petaluma and is adjacent to community -serving commercial,
residential and institutional uses. The project site has been developed since at least 1970 and currently features
community -serving retail uses. The site is directly adjacent to two major travel corridors including Washington
Street and South McDowell Boulevard. Washington Street is a major four lane east -west arterial with access to
US HWY 101. South McDowell Boulevard is a four lane, north -south arterial providing connectivity between
Redwood Highway and Lakeville Highway.
Land Use and Plannina Impact Discussion:
3.10(a) (Divide An Established Community) No Impact: The project proposes the redevelopment of an
existing parcel with a fuel station and convenience store associated with the adjacent Safeway Grocery. The
project site is bounded by existing commercial, institutional and residential uses. Division of an established
community typically occurs when a new physical feature, in the form of an interstate or railroad, transects an
area, thereby removing or severely limiting access within an established community. The division of an
established community can also occur through the removal of an existing road or pathway, which would reduce
or remove access between a community and outlying areas.
Redevelopment of the subject site will not result in a departure from the existing use or intensity of the site,
which is presently defined by commercial uses. There is no expectation that the project would substantially
reduce mobility or access. Therefore, the project would have no impact due to the division of an established
community.
3.10(b) (Land Use Plan, Policy, Regulation Conflict) Less than Significant: The proposed project is
required to comply with all General Plan policies and the Zoning Ordinance. As redevelopment of an existing,
underutilized lot within the UGB, the project is able to achieve several of the goals outlined in the 2025 General
Plan. The project meets Guiding Principle (9) by expanding retail opportunities that serve the community and
provide revenue, while also maintaining the existing character. As a fuel station, the project is expected to
generate revenues while not substantially detracting from the existing character of the site or vicinity. The project
also meets policy 2-P-76 by contributing to the variety of retail services available to the neighborhood and region
at the East Washington Square Shopping Center.
The project includes elements intended to meet the sustainability goals outlined in the General Plan 2025. The
fuel station will provide an electric charging station thereby meeting the requirement established in policy 4-P-
10. Sustainable site practices include limiting impervious services, using drought resistant landscaping, bio-
filtration trenches and the installation of bike racks, which meet the intent of policy 8-P-36 and programs set
forth in 8-P-39. The siting of the fuel station and convenience store within an existing shopping center complies
with policy 9-P-14 and 9-P-16. As the project will not departure substantially from the existing conditions and/or
use of the site, the project is not expected to conflict with any applicable land use plan, policy, or regulation.
As a regional and community -serving commercial land use, the proposed project would be complimentary to
the existing commercial uses located in the E. Washington Square Shopping Center. The proposed Safeway
Fuel Center project does not involve a re -zone or a change in land use and is consistent with General Plan
goals, policies and programs. Therefore, potential impacts due to a conflict with an applicable land use plan,
zoning ordinance, or other adopted policy would be less than significant.
3.10(c) (Habitat Conservation Plan) No Impact: The project is not subject to a habitat conservation plan or a
natural community conservation plan. There are no conservation plans that apply to the UGB. Therefore, the
project will have no impact to any conservation plan or natural community plan.
Mitigation Measures: None Required.
3.11. MINERAL RESOURCES
March 2018 Page 42 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma
Fuel Center IS/MND
Would the project:
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
p
a) Result in the loss of availability of a known
Significant
Less than No
Would the project result in:
Significant
Impact
mineral resource that would be of value to the
Significant Impact
Impact p
Incorporated
region and the residents of the state?
El
El
El
b) Result in the loss of availability of a locally -
El
El
®
local general plan or noise ordinance, or applicable
important mineral resource recovery site delineated
1:1
® ❑
standards of other agencies?
on a local general plan, specific plan or other land
❑
El
El
use plan?
Sources: 2025 General Plan and DEIR.
❑
®
❑
El
Mineral Resources Impact Discussion:
3.11(a -b) (Mineral Resources or Plan) No Impact: There are no known mineral resources within the UGB.
No valuable mineral resources have been identified on or near the site that would be impacted by activities
associated with the proposed project. The project site has not been identified as a locally important mineral
resource recovery site. Therefore, the project will not make a known mineral resource unavailable, nor will it
conflict with access to a locally important mineral resource site.
Mitigation Measures: None required.
3.12. NOISE
b) Exposure of persons to or generation of
Less Than
Potentially
Significant
Less than No
Would the project result in:
Significant
Impact
with
Mitigation
Significant Impact
Impact p
Incorporated
c) A substantial permanent increase in ambient
a) Exposure of persons to or generation of noise
levels in excess of standards established in the
El
El
®
local general plan or noise ordinance, or applicable
El
1:1
® ❑
standards of other agencies?
d) A substantial temporary or periodic increase in
b) Exposure of persons to or generation of
excessive groundborne vibration or groundborne
El
®
❑
n
noise levels?
c) A substantial permanent increase in ambient
noise levels in the project vicinity above levels
El
El
®
❑
existing without the project?
d) A substantial temporary or periodic increase in
ambient noise levels in the project vicinity above
levels existing without the project?
❑
®
❑
El
e) For a project located within an airport land use
plan or, where such a plan has not been adopted,
within two miles of a public airport or public use
airport, would the project expose people residing or
El
El
n
working in the project area to excessive noise
levels?
March 2018 Page 43 of 65
Planning Commission Resolution No. 2018-21A
City of Petaluma
f) For a project within the vicinity of a private
airstrip, would the project expose people residing
or working in the project area to excessive noise El 1
levels?
Fuel Center IS/MND
Sources: 2025 General Plan and DEIR; IZO 21.040; and Environmental Noise Assessment prepared by
Illingworth & Rodkin, April 14, 2014
Noise Setting: Noise is generally characterized as "unwanted sound" that is either annoying or disturbing.
Noise sources within the City's Urban Growth Boundary include vehicular traffic, trains, and industrial activities
such as mechanical equipment and refrigeration units.
The City of Petaluma regulates the noise environment through Section 21.040 of the Implementing Zoning
Ordinance (IZO). The IZO stipulates an hourly average level of 60 dBA as the maximum that may be generated
on one land use that may affect another land use; the allowable levels are adjusted to account for the ambient
noise levels and in no case shall the maximum allowed noise level exceed 75 dBA after adjustments are made.
The 2025 General Plan also provides policies and programs to protect the health and welfare of the community
from undesirable noise levels. Figure 10-2 of the General Plan shows the Land Use Compatibility Standards
for various land uses and provides the relative acceptability level. Commercial land uses are considered
normally acceptable in a noise environment up to 70 dB (Ldn or CNEL). The Noise Contours Figure (Fig. 10-1)
indicate the noise levels at the site are projected to be 65 dB CNEL at General Plan build out.
A site specific Noise Assessment was prepared for the subject project by Illingworth and Rodkin (see Appendix
D). The Noise Assessment analyzed noise levels generated by proposed construction activities, on-site
operations, and project generated traffic on area roadways. The existing noise environment in the project vicinity
is characterized primarily by roadway traffic noise and shopping center activities. Surrounding land uses include
the retail shopping center to the west and north, single-family residential uses to the south across South
McDowell Boulevard and institutional and recreational uses east of the project site across Maria Drive.
To quantify the existing noise environment of the project vicinity Illingworth & Rodkin performed a five-day noise
measurement survey along South McDowell Blvd., opposite the project site and at the school located across
Maria Drive. The long-term measurements were performed between November 8, 2013 and November 13,
2013. Noise measurements were collected using a Larson Davis Laboratories (LDL) Type 1 Model 820 Sound
Level Meter fitted with a'/2 inch pre -polarized condenser microphone and widescreen.
Noise survey results indicate an overall average day/night noise level (Ldn) of up to 70 dBA as measured south
of McDowell Boulevard and an Ldn of 66 dBA as measured east of Maria Drive. The average daytime results
generated by both locations exceed the General Plan ambient level of 60 dBA and therefore, in accordance
with Section 21.040 4(a)" of the IZO, the daytime ambient noise level has been adjusted upward by 5 dB to a
level of 65 dBA. Although the nighttime average (Leq), measured from McDowell exceeds the General Plan
ambient level of 60 dBA, since the exceedance is less than 5 dBA, the established 60 dBA level will remain in
effect. The nighttime noise level east of Maria Drive did not exceed 60 dBA.
Noise Impact Discussion:
3.12 (a, c) (Noise Standards/ Ambient Noise Levels) Less than Significant Impact: The City of Petaluma
regulates the noise environment through Section 21.010 of the IZO. As stated above, commercial uses in areas
with an Ldn up to 70 dBA would generally be acceptable. A Noise Assessment was prepared for the subject
project that characterized the existing noise environment and projected the future noise environmental
associated with operation of the proposed Safeway Fuel Center. As described above, the existing noise
environment exhibits an Ldn of 70 dBA in the project vicinity. The predominant nose sources in the area are
due to noise generated along Highway 101 from vehicles as well as vehicles traveling along S. McDowell Blvd.
Section 21.010.A.4 (a): If the measured ambient level is greater than 60 dB, the maximum noise exposure standard
shall be adjusted in 5 dB increments for each time period as appropriate to encompass or reflect the measured
ambient noise level. In no case shall the maximum allowed threshold exceed 75 dB after adjustments are made.
March 2018 Page 44 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
The proposed project will introduce temporary noise emitters onsite during construction (see discussion b,d
below) and will result in permanent noise sources at operation. It should be noted that relative to the existing
condition, consisting of activity associated with the 13,770 square foot retail building, onsite noise levels at
operation are expected to be relatively consistent. At operation noise sources at the proposed Safeway Fuel
Center will include:
• Parking lot activity including engine starts, door slams, and patron noise concentrated in the gas fueling
area and parking area north of the convenience store;
• Fuel truck deliveries; and
• Mechanical equipment associated with the Fuel Center Convenience store
Parking/Fueling Area Noise
Noise will be generated within the fueling and parking areas by patron's voices and vehicular sounds including
engine starting and doors closing. Sound levels produced by parking lot activity are expected to range from 35
dBA to 57 dBA at front facades of residences located across South McDowell Boulevard and 39 dBA to 58 dBA
at the westernmost school building. These projected parking lot noise levels do not exceed noise performance
standards as outlined in the IZO. When sound losses between the measurement position and the facades are
considered, the anticipated Leq noise level at South McDowell facades for nighttime and daytime range from 62
to 72 dBA and 47 to 61 dBA, respectively. The daytime noise at the westernmost school building ranges from
57 to 64 dBA (the school is not occupied at night, so nighttime measures are not provided). Based on the day
and nighttime noise levels generated by activities within the parking lot area, noise levels would not exceed the
range of current daytime and nighttime noise levels in the vicinity and impacts would be less than significant.
Truck Delivery Noise
Delivery of fuel will occur once between the hours of 6 am and 8 am and a second delivery will occur after 5
pm. Each fuel delivery is expected to take between 30-45 minutes however; the period of elevated noise
generated by fuel truck delivery will be limited to 5 minutes as engines will be shut off during the delivery
process. In analyzing truck delivery noise, the Noise Assessment utilized the 5 -minute per hour (Los) exterior
noise exposure limit. This limit is conservative as it accounts for activities lasting between five and fifteen
minutes per hour. The IZO establishes limits for the maximum allowed exposure as 80 dBA during daytime and
70 dBA at nighttime, at the residences along the south side of South McDoweel Boulevard. The noise exposure
limits for the westernmost school building are 75 dBA during the daytime and 70 dBA at nighttime.
Noise generated by truck deliveries is expected to reach 62 dBA to 67 dBA at the front facades of the South
McDowell residences and between 63 dBA and 68 dBA at the westernmost school building. Accounting for the
noise measurements and sound losses between the measurement positions and adjacent receptors, noise
levels at the front facades were found to range from 67 to 74 dBA during the daytime and from 56 to 72 dBA
during nighttime. These projected noise levels are within the range of what is accepted under the IZO.
Therefore, noise generated by fuel delivery trucks would not exceed the existing ambient noise environment
and potential impacts would be less than significant.
Mechanical Equipment Noise
Equipment such as heating, ventilation and air conditions (HVAC), refrigeration units, and other mechanical
equipment located in the attic space and vented to the rooftop of the fuel center convenience store will contribute
to the ambient noise environment at operation. Refrigeration equipment will be located inside the building will
have a negligible effect on the exterior noise environment. Noise generated by the HVAC system is expected
to range from 34 dBA to 44 dBA at the facades of the residences located across from the project site on South
McDowell Blvd. and from 40 dBA to 50 dBA at the westernmost school building. These levels are below the
unadjusted ambient (Leq) exterior noise exposure limits and below all measured average hourly daytime and
nighttime noise levels. Review of noise measurement results and consideration of noise losses between
measurement positions and receptors indicate Leq noise levels at the front facades of residences located on
South McDowell across from the project site range from 62 to 72 dBA in the daytime and 47 to 61 dBA at the
nighttime. Daytime noise levels at the westernmost school building range from 57 to 64 dBA. Noise generated
by mechanical equipment would be below the ambient noise levels in the project vicinity.
Traffic Noise
Traffic generated by the project is not expected to substantially increase traffic noise to such an extent that it
would adversely impact the existing noise environment. The projected increase in traffic noise was calculated
March 2018 Page 45 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma Safeway Fuel Center ISIMND
by comparing project -related traffic volumes to existing and cumulative traffic volumes for roadways within or
leading to the project site using the am and pm peak hour traffic volumes set forth in the traffic report prepared
by TJKM Consultants on March 14, 2014. In accordance with Section 10,2 of the Petaluma Health and Safety
Element and because the existing traffic noise levels on McDowell Blvd. currently exceed the prescribed noise
level of 60 dBA, an increase in the noise level by 4 dBA or more would constitute a significant impact.
As current noise levels along Maria Drive and parallel to the project site do not exceed what is normally
acceptable for schools (70 dBA) the increase in noise levels generated by the project site would have to exceed
5 dBA at the Maria Drive study area to constitute a significant impact. Under existing and cumulative conditions
for the project, site traffic generated noise will not exceed 2 dBA south of McDowell Boulevard or east of Maria
Drive. As such, noise levels resulting from increased traffic volumes associated with the proposed Safeway
Fuel Center would not exceed normally acceptable noise levels. Therefore, impacts related to excessive traffic -
generated noise will be less than significant.
Operational Noise
Noise levels produced by on-site operations are projected to fall within or below the range of ambient noise
levels and is would not cause a permanent increase in the ambient noise environment. Operational noise is
below the noise exposure limits allowed by the City of Petaluma and anticipated traffic noise is below the
established thresholds of 4 dBA and 5 dBA, respectively. The project is not expected to expose people to or
generate noise in exceedance of established standards. Therefore, potential impacts due to excessive noise
levels would be less than significant.
3.12 (b,d) (Groundbourne Vibration and Noise) Less than Significant Impact with Mitigation: Project
construction activities have the potential to result in a temporary and periodic increase in the ambient noise
environment and limited groundborne vibration. No pile driving or extensive work that would generate
substantial groundborne vibration is anticipated. Construction activities are expected to take place over a period
of 120 days and will include demolition/removal of existing structures and pavement, excavation for fuel tanks,
trenching for utility connections, as well as construction associated with foundations, building erection, paving
and installation of landscaping. Noise levels associated with construction will fluctuate depending on the type
of construction activity and mix of equipment. Table 9 show average noise levels for each anticipated stage of
construction.
Table 9 Construction Phase Noise Levels
Construction Phase
Construction Equipment
Ground Clearing
84
Excavation
89
Foundations
78
Erection
87
Finishing (Paving)
89
Source: US EPA, Legal Compilation on Noise, Vol. 1, p. 2-104, 1973.
Typical Ranges of Noise Levels dBA at 50 Feet from Construction.
Demolition and construction activities at a distance of 50 feet from the source typically generate noise levels
that range from 80 to 90 dBA. The nearest noise sensitive receptors to the project site are located approximately
90 to 110 feet away. Noise levels decrease at a rate of approximately 6 dBA per doubling of distance. As such,
average noise levels between the noise source and receptor are expected to range from 70 dBA to 85 dBA
during the most active construction periods.
Although existing residences and the adjacent school have the potential to be intermittently exposed to noise
levels ranging from 70 to 85 dBA, project construction would not exceed 60 dBA Leq or the ambient noise
environment by 5 dBA Leq for a period greater than one year. Construction activities will result in temporary
noise impacts that can be minimized to reduce noise levels generated onsite. At a minimum the project is
required to adhere to the standards set forth in Section 21.040.A.3.a of the IZO. In order to ensure that noise
levels generated during construction are minimized, mitigation measure NOI-1 shall be implemented. With
adherence to mitigation measure NOW potential impacts to the temporary noise environment would be reduced
to levels below significance.
March 2018 Page 46 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma
Fuel Center IS/MND
3.12(e -f) (Airport Noise) No Impact: The project site is not located within a private airstrip, an airport land use
plan or within two miles of a public airport or public use airport and would therefore not expose people residing
or working in the project area to excessive noise levels. The Community Noise Equivalency Level (CNEL) noise
contours from the Petaluma Municipal Airport do not affect the subject site. The project would not expose people
working onsite to significant noise levels generated by the Petaluma Municipal Airport. Therefore, noise from
the Petaluma Airport will have no impact to people residing or working onsite.
Mitigation Measures:
NO] -1. Due to the proximity of sensitive receptors, construction activities shall be required to comply with the
following and shall be noted accordingly on construction contracts:
1. Construction activities for all phases of construction, including servicing of construction
equipment shall only be permitted during the hours of 7:30 am and 7:00 pm Monday through
Friday and between 9:00 am to 7:00 pm on Saturdays, Sundays and holidays recognized by
the City of Petaluma.
2. Delivery of materials or equipment to the site and truck traffic coming to and from the site is
restricted to the same construction hours specified above.
3. All internal combustion engine driven equipment shall be equipped with intake and exhaust
mufflers that are in good condition and appropriate for the equipment.
4. Locate stationary noise generating equipment (e.g. compressors) as far as possible from
adjacent noise -sensitive receptors.
5. Acoustically shield stationary equipment located near noise sensitive receptors with temporary
noise barriers.
6. Utilize "quiet" air compressors and other stationary noise sources where technology exists.
7. The contractor shall prepare a detailed construction plan identifying the schedule for major
noise -generating construction activities. The construction plan shall identify a procedure for
coordination with the owner/occupants of nearby noise -sensitive land uses so that
construction activities can be scheduled to minimize noise disturbance.
8. Designate a "disturbance coordinator" responsible for responding to any complaints about
construction noise. The disturbance coordinator will determine the cause of the noise
complaint (e.g. bad muffler etc.,) and require that reasonable measures be implemented to
correct the problem.
March 2018 Page 47 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
3.13. POPULATION AND HOUSING:
Would the project:
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less than
Significant
Impact
No
Impact
p
a) Induce substantial growth in an area, either
directly (for example, by proposing new homes and
businesses) or indirectly (for example, through
F-1
❑
®
❑
extension of roads or other infrastructure)?
b) Displace substantial numbers of existing
housing, necessitating the construction of
F1
R
❑
replacement housing elsewhere?
c) Displace substantial numbers of people,
necessitating the construction of replacement
1:1
F-1
❑
housing elsewhere?
Sources: 2025 General Plan and DER.
Population and Housing Setting: The 2025 General Plan anticipates the population to reach 72,707 at
General Plan buildout, with an anticipated annual growth rate of 1.2%. As a fueling station that is part of a larger
regional -serving commercial shopping center, the proposed project will create a limited number of new jobs
within the City. The project would not induce substantial population growth or affect housing.
Population and Housing Impact Discussion:
3.13(a) (Substantial Growth) Less Than Significant Impact: The project proposes the development of a
fueling station and an associated convenience store within the established East Washington Square Shopping
Center. The project site is well served by the existing city street network and all public services and utilities are
currently available to the project site. As a small component of the larger regional and community serving
commercial center, the project is not expected to induce growth through the creation of jobs or housing. As
proposed, the project will result in a net decrease in square footage, through the removal of the existing 13,770
square foot retail building. Accordingly, the net effect of the project will reduce the overall retail square footage
relative to existing conditions. Thus, the project will neither directly nor indirectly induce growth. A small number
of retail jobs associated with the operation of the convenience store and the fueling area will be generated.
There will be no housing developed as part of the project, nor would the proposed use generate an increased
demand for housing. Given the project's limited size, the number of jobs will not be substantial nor will they
induce growth. Therefore, population and housing impacts that induce growth by introducing of a substantial
number of new jobs would be less than significant.
3.13(b -c) (Housing or Person Displacement) No Impact: The project involves the redevelopment of an
underutilized commercial/retail site. At present, no people or housing occupy the project site. The project will
result in the demolition of a 13,770 square foot retail space and will be replaced with a 16 pump fueling station
and convenience store. There are no housing units onsite that would be impacted and there are no housing
units proposed as part of the project. Therefore, the project will not result in any impacts from the displacement
of people or housing.
Mitigation Measures: None required.
March 2018 Page 48 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma
3.14. PUBLIC SERVICES
Fuel Center IS/MND
Less Than
Potentially Significant Less than No
Would the Project: Significant with Significant Impact
1 Impact Mitigation Impact
Would the project result in substantial adverse
physical impacts associated with the provision of new
or physically altered governmental facilities, need for
new or physically altered governmental facilities, the
construction of which could cause significant
environmental impacts, in order to maintain
acceptable service ratios, response times or other
performance objectives for any of the public services:
a) Fire protection?
El
❑
®
0
b) Police protection?
El
El
®
n
c) Schools?
El
❑
®
El
d) Parks?
El
El
®
R
e) Other public facilities?
El
El
®
El
Sources: 2025 General Plan and DEIR.
Public Services Setting: The project site is located in a developed area that is well served by existing public
services. The proposed use and intensity of the site is generally consistent with the existing retail/commercial
use and will not generate a heightened demand for public services. Nonetheless, the proposed Safeway Fuel
Center will contribute to the cumulative demands placed on City services. In order to offset the cost of improving
or expanding City services to accommodate the demand generated by the proposed development the City
charges one-time impact fees. Development impact fees finance public service improvements and are issued
to pay for new development's fair share of the costs necessary to maintain acceptable levels of service related
to fire and police protection services, parkland, schools, and other such public services.
Public Services Impact Discussion:
3.14(a -b) (Fire & Police Protection) Less Than Significant Impact: Fire and police protection is provided by
the City's Fire and Police Departments, respectively. The project, which involves a net decrease in
commercial/retail space, will not necessitate a significant increase in demand for fire or police services.
Standard conditions of approval require that the applicant pay all development impact fees applicable to a
commercial development project, including fire suppression facilities and law enforcement facilities impact fees.
The funds generated by the impact fees will ensure sufficient services are maintained and potential impacts will
remain at levels below significance.
3.14(c -d) ) (Schools/Parks) Less Than Significant Impact: Fuel stations are generally considered
local/regional serving commercial. They may provide a temporary influx of people into the immediate vicinity
but are not expected to result in population growth that would then create a heightened demand for school and
park facilities. The applicant will be required to pay school impact fees and general development impact fees
prior to the issuance of a building permit, The payment of those impact fees are expected to sufficiently offset
any impacts the project may have on local schools and parks. Therefore, potential impacts to parks and schools
from increased patronage will remain at levels below significant.
March 2018 Page 49 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
3.14(e) (Other Public Facilities) Less Than Significant Impact: The project will not generate a substantial
increase in demands that warrant the expansion or construction of any new public facilities. The project is
intended to redevelop an existing commercial lot and serve as local/regional commercial. As a fuel station the
intensity of the site will remain similar to the existing condition and would not induce a demand for expanded
public services beyond what is currently available. Therefore, impacts would be less than significant.
Mitigation Measures: None required.
3.15. RECREATION
Would the project:
Potentially
Significant
Impact
a) Would the project increase the use of existing
neighborhood and regional parks or other
recreational facilities such that substantial physical ❑
deterioration of the facility would occur or be
accelerated?
b) Does the project include recreational facilities or
require the construction or expansion of
recreational facilities which might have an adverse ❑
physical effect on the environment?
Sources: 2025 General Plan and DEIR;
Less Than
Significant Less than No
with Significant Impact
Mitigation Impact
❑ ❑
❑ ❑
Recreation Setting: The City of Petaluma offers a number of passive and active recreation opportunities within
the UGB with approximately 18% of land (1,300 acres) devoted to parks and open space. Park land
development and open space acquisition impact fees are required and help to mitigate any potential impacts to
parks and open space generated by development projects.
Recreation Impact Discussion:
3.15(a -b) (Park Deterioration/ Recreation Facilities) No Impact: The proposed fuel station will not generate
an increase in the use of existing neighborhood and/or regional parks or related recreational facilities. No new
park facilities are being proposed or will be required as part of the proposed Safeway Fuel Center. Therefore,
no impacts to recreational parks or amenities are expected.
Mitigation Measures: None Required.
March 2018 Page 50 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
3.16. TRANSPORTATION AND CIRCULATION
Fuel Center IS/MND
Would ther0 ect:
P 1
Less Than
Potentially Significant Less than No
Significant with Significant Impact
Impact Mitigation Impact
Incorporated
a) Conflict with an applicable plan, ordinance or policy
establishing measures of effectiveness for the
performance of the circulation system, taking into account
all modes of transportation including mass transit and
El El 0 El
non -motorized travel and relevant components of the
circulation system, including but not limited to
intersections, streets, highways and freeways, pedestrian
and bicycle paths, and mass transit?
b) Conflict with an applicable congestion management
program, including, but not limited to level of service
standards and travel demand measures, or other
standards established by the county congestion
management agency for designated roads or highways?
c) Result in a change in air traffic patterns, including
either an increase in traffic levels or a change in location
that results in substantial safety risks?
d) Substantially increase hazards due to a design feature
(e.g., sharp curves or dangerous intersections) or
® El El
incompatible uses (e.g., farm equipment)?
e) Result in inadequate emergency access?
® El
f) Conflict with adopted policies, plans, or programs
regarding public transit, bicycle, or pedestrian facilities, or
otherwise decrease the performance or safety of such
E ® F1
facilities?
Sources: 2025 General Plan and DEIR; Traffic Study for
Safeway Fuel Center, prepared by TJKM,
August 13, 2014; and Safeway Fuel Center Traffic Impact Study Update, prepared by CHS Consulting Group,
March 16, 2018.
Transportation and Circulation Setting: The City of Petaluma is bisected by U.S. 101, which serves as the
primary route between San Francisco and Marin and Sonoma Counties. U.S. 101 accommodates over 90,000
vehicles per day, within Petaluma. The circulation system within the City of Petaluma consists of approximately
140 miles of streets including arterials, collectors, connectors, and local streets.
The major arterials serving the project site include Washington Street and McDowell Boulevard with access
also provided via Maria Drive. Washington Street is a major, four -lane, east west arterial with access to Hwy
101. The roadway features Class II bike lanes on both sides west of McDowell Boulevard and there are plans
to extend the bike lanes to the eastern portions of Washington Street. Perpendicular to Washington Street is
McDowell Boulevard, which is a four lane, north -south arterial that extends from Redwood Hwy in the north and
Lakeville Highway in the east. McDowell Boulevard provides a Class II bike lane between Washington Street
and Frates Road. Maria Drive also provides access to the project site. Maria Drive is a two lane collector street
that primarily serves residential areas located within the vicinity of Washington Street and McDowell Boulevard.
This roadway had been designated by the City as a future Class III bikeway between Washington Street and
McDowell Boulevard.
March 2018 Page 51 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
Pedestrian and alternative transit accessibility near the project site is generally well established. All three major
roads in the study area feature sidewalks in the project vicinity. All study intersections, except the project
driveway, feature crosswalks and pedestrian signals providing controlled access to the site.
The Petaluma General Plan 2025 was adopted in May 2008 and specifies a Level of Service (LOS) standard
for streets wherein the minimum acceptable operation is LOS D. Policy 5-P-10 states, "Maintain an intersection
level of service (LOS) standard for motor vehicle circulation that ensures efficient traffic flow and supports multi-
modal mobility goals. LOS should be maintained at Level D or better for motor vehicles due to traffic from any
development project." The project will be subject to the payment of development impact fees, including the
Traffic Mitigation fee to offset its contribution to citywide traffic.
The City's Traffic Impact Study Guidelines are based on industry standards and indicate that a traffic study is
warranted if a project is anticipated to create either 500 trips per day or 50 trips per peak hour. If a project falls
within 10% of these thresholds the City may exercise discretion in whether or not to require a project specific
traffic study. The Safeway Fuel Center is expected to generate 210 am peak hour trips and 276 pm peak hour
trips. Based on the expected trip generation the project was required to prepare a Traffic Impact Study.
TJKM Transportation Consultants prepared a Traffic Study for the subject project dated August 13, 2014 (see
Appendix E). The Traffic Study reviewed onsite circulation, access, sight distance and evaluated the project's
traffic impacts on the surrounding circulation network including six intersections in the project vicinity. A
Technical Memorandum updating the Safeway Fuel Center Traffic Impact Study was prepared by CHS
Consulting Group in March 16, 2018 (see Appendix F).
General Plan Policies: Mobility
The following General Plan policies are particularly relevant to the proposed Safeway Fuel Center Project:
5-P-10: Maintain an intersection level of service (LOS) standard for motor vehicle circulation that ensures
efficient traffic flow and supports multi -modal mobility goals. LOS should be maintained at Level D or
better for motor vehicles due to traffic from any development project.
5-P-20: Ensure that new development provides connections to and does not interfere with existing and
proposed bicycle facilities.
5-P-22: Preserve and enhance pedestrian connectivity in existing neighborhoods and require well connected
pedestrian network linking new and existing development to adjacent land uses.
5-P-43: Support efforts for transit oriented development around the Petaluma Depot and along the Washington
Street, Petaluma Boulevard, McDowell Boulevard, Lakeville Street, and other transit corridors.
Transportation and Circulation Impact Discussion:
3.16(a -b) (Plan, Policy, Ordinance: Circulation System/ Congestion Management Plan) Less than
Significant Impact: The Traffic Study and Update prepared for the Safeway Fuel Center reviewed onsite
circulation and access and evaluated the project's traffic impacts on the surrounding circulation network
including the following intersections in the project vicinity:
1. E. Washington St/US 101 SB Ramps (Signalized)
2. E. Washington St/US 101 NB Ramps (Signalized)
3. E. Washington St/McDowell Blvd. (Signalized)
4. E. Washington St./Maria Dr. (Signalized)
5. McDowell Blvd. / Maria Dr. (Signalized)
6. Maria Drive/Project Driveway (One way stop)
The Traffic Impact Study and Update evaluated existing conditions, existing plus project conditions, existing
plus approved (Background) conditions, background plus project conditions, cumulative conditions, and
cumulative plus project conditions. As described below, all project area intersections operate acceptably and
are expected to continue to do so under all scenarios evaluated. The addition of project generated traffic would
not be substantial, nor would it adversely impact LOS or result in a conflict due to congestion. With the Safeway
Fuel Center project all study area intersections will continue to operate acceptably during the near-term and
long-term modeling periods.
March 2018 Page 52 of 65
Planning Commission Resolution No. 2018-21 A
Citv of Petaluma Safeway Fuel Center IS/MND
It should be noted that the Traffic Study prepared by TJKM did not include the recent modifications to the
geometrics at the East Washington Street/ US 101 SB Ramp intersection. The analysis utilized the old lane
configuration of a single left turn for the southbound onramp to US 101. The current intersection configuration
contains dual left turn lanes for the southbound onramp to Highway 101 from E. Washington Street. Accordingly,
the 2014 Traffic Study prepared by TJKM models a worse case condition for this intersection.
Updated traffic counts, to reflect current intersection configurations at the East Washington/US 101 ramps, as
well as the pipeline projects in the City's Major Development List12, are considered in CHS Consulting Group's
Traffic Impact Study Update, prepared March 2018 (see Appendix F). The updated traffic counts were taken on
March 14, 2017 (weekdays) and April 1, 2017 (Saturday). The analysis below incorporates information from the
2014 Traffic Study and the Traffic Impact Study Update (2018).
Existing Traffic/Circulation
All study area intersections currently operate at a level of service (LOS) "C" or above during weekday am and
pm peak hour traffic. The intersection of East Washington Street/McDowell Boulevard currently operates at
LOS "D" during the Saturday peak hour (between 11 am and 1 pm); all other intersections currently operate at
a LOS of "C" or above during the Saturday peak hour. Accordingly, all study area intersections currently operate
at acceptable levels of service. While acceptable under the City's thresholds, LOS "D" results in noticeable
congestion and queuing delays.
Existing Plus Project Condition
The proposed Safeway Fuel Center will operate between 6 am and 11 pm daily and will feature eight fuel pumps
with 16 fuel positions that dispense multi -fuel categories. The project site will also feature a 697 square foot
convenience store adjacent to the fuel center canopy and a total of six parking spaces with one designated
handicap accessible space. The project is expected to generate 210 trips during the am peak hour and 276
during the pm peak hour for weekday trips. The trip generation for the Saturday peak hour (between 11 am and
1 pm) is projected to generate 336 trips. The new trips represent the increased traffic generated by the project
relative to existing condition.
In order to maintain a conservative analysis all project traffic is assumed to enter and exit the project site via
the two-way Maria Drive site driveway located closest to the fuel center. This assumption represents an
anticipated worst-case scenario level of service since there are several other access driveways by which to
enter the Shopping Center,
Table 10 below shows the existing level of service and delay (as of 2017) for each of the project area
intersections, as well as the projected LOS under existing conditions with the contribution of the trips generated
by the proposed Safeway Fuel Center. With the addition of project trips, all of the study area intersections will
operate acceptably at LOS "D" or better for weekday and weekend peak hours. The Safeway Fuel Center would
result in a degradation of LOS relative to the existing condition for the weekday pm peak hours at the McDowell
Boulevard/Maria Drive intersection (LOS "A" to "B") and the Maria Drive/Project Driveway intersection (LOS "B"
to "C").
The proposed project would also result in a degradation of LOS relative to the existing condition for the Saturday
peak hours at the E. Washington Street/US 101 SB intersection (LOS "B" to "C"). However, the Safeway Fuel
Center would not cause substantial delays as all intersections are expected to operate at LOS "D" or greater.
Thus, under the existing plus project conditions scenario, the proposed project would have a less than
significant impact due to changes in LOS.
Table 10
Summary of Existina Plus Proiect Conditions
Study Area Intersections
Existing Conditions
Existing plus Project
AM Peak PM Peak Sat. Peak
AM Peak
PM Peak
Sat. Peak
Delay LOe ay LOS Delay LOS
Delay
Delay OS
Delay LOS
1. E. Washington St/US 101 SB
16.0 B 21.0 C 19.9 1 B
16.5 B
22.1 C
21.0
C
2. E. Washington St/US 101 NB
6.3 A 9.2 1 A 6.8 7 A
6.5 A
9.7 A
7.4
A
12 The Traffic Impact Study Update relied upon the Major Development List dated February 2017.
March 2018 Page 53 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
3.
E. Washington St/McDowell Blvd
130.1
C
34.0
1 C 1
41.5
1 DI
31.0
1 C
1 34.7
1 C 146.0
2.
D
4.
E. Washington St/Maria Dr
15.5
B
13.0
B
13.1
B
15.5
B
13.0
B
13.1
B
5.
McDowell Blvd/Maria Dr
8.8
A
8.9
A
10.5
B
9.6
A
10.8
B
11.5
B
6.
Maria Dr/Project Driveway
9.8
A
12.1
1 B
11.5
1 BI
11.0
B
1 15.3
C 1
14.9
B
Source: Safeway Fuel Center Traffic Impact Study
Update, prepared by
CHS Consulting Group, March
16,
2018.
As described in the Traffic Study, the intersection level of service for the weekend peak are similar to the
weekday peak condition. Accordingly, future weekend peak hours are expected to be similarly reflective of the
weekday peak conditions. Therefore no additional future year weekend analysis was conducted.
Background Plus Project Condition
This scenario includes analyses of the effects of the proposed project relative to the existing condition in addition
to background conditions. Background conditions include existing development plus approved projects within
the site vicinity such as developments that have final approval from the City, are under construction, and are
built but not fully occupied. As described in the Traffic Impact Study Update, background projects were
considered in the analysis. Table 11, set forth below, provides a summary of the level of service and delay
under the background condition in addition to trips generated by the proposed Safeway Fuel Center.
Under this scenario, study area intersections are subject to increased traffic volumes and delays relative to the
existing condition scenario. As seen in Table 11 below, the Washington Street/ McDowell Boulevard intersection
is anticipated to begin operating at LOS "E" during the pm peak hour without the project, as a result of traffic
generated by background projects already approved. The LOS "E" condition during the pm peak hour at this
intersection will experience an increase in delay of less than 2 seconds with the addition of project traffic. Staff
has reviewed the LOS "E" at this intersection and determined that the project's contribution of a 2 second delay
is minimal, and that the project's effect on traffic and circulation would not result in a substantial degradation to
LOS. All other project area intersections would remain at acceptable LOS "D" or greater under the background
scenario even with the additional trips generated by the proposed Safeway Fuel Center. Therefore, impact to
LOS and circulation would be less than significant for the background scenario.
Table 11
Summary of Background Plus Project Conditions
Study Intersections
Background Conditions
AM Peak PM Peak
Delay LOS Delay LOS
Background plus Project
AM Peak PM Peak
Delay LOS Delay LOS
1.
E. Washington St/US 101 SB
20.1 C
45.5
D
20.4
C
51.2
D
2.
E. Washington St/US 101 NB
7.3 A
14.6
B
7.7
A
15.5
B
3.
E. Washington St/McDowell Blvd
39.2 D
70.7
E
41.1
D
72.2
E
4.
E. Washington St/Maria Dr
23.5 C
23.7
C
23.5
C
23.7
C
5.
McDowell Blvd/Maria Dr
10.8 B
12.4
B
11.9
B
14.1
B
6.
Maria Dr/Project Driveway
10.6 B
14.7
B
12.1
B
20.8
C
Source: Safeway Fuel Center Traffic Impact Study Update, prepared by
CHS Consulting Group, March 16, 2018.
Cumulative plus Project Conditions
The cumulative traffic analysis consists of existing conditions in addition to traffic generated by background
projects, as well as ultimate buildout as characterized in the General Plan including infrastructure improvements
such as the Rainier Cross -Town Connector. The improvement in LOS for this scenario at the Washington
St./McDowell Blvd. intersection relative to the Background Condition is due to the presumed operation of the
Rainier Cross -Town Connector, which would provide an additional east/west travel corridor thereby alleviating
some of the demand along the Washington Street roadway. The EIR for the Rainier Cross -Town Connector
(SCH #2011082032) was certified in 2015.
The project's trip generation, distribution and assignment are identical to that assumed under previously
described scenarios. As seen in Table 12 below, all project area intersections will operate at acceptable level
of service D or better for both the am and pm peak hour traffic including the additional trips generated by the
proposed Safeway Fuel Center. Thus, the project would have a less than significant impact on the long-term
traffic and circulation through General Plan buildout as set forth in the General Plan 2025.
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Planning Commission Resolution No. 2018-21A
Citv of Petaluma
Table 12
Summary of Cumulative (2025) plus Project Conditions
Fuel Center IS/MND
Study Intersection
Cumulative Conditions
AM Peak PM Peak
Delay LOS Delay LOS
Cumulative plus Project
AM Peak PM Peak
Delay LOS Delay LOS
1.
E. Washington St/US 101 SB
28.2
C
30.1 C
28.2
C
32.3
C
2.
E. Washington St/US 101 NB
14.3
B
17.6 B
15.0
B
19.1
B
3,
E. Washington St/McDowell Blvd
31.6
C
51.2 D
32.4
C
52.7
D
4.
E. Washington St/Maria Dr.
22.0
C
30.5 C
22.0
C
30.5
C
5.
McDowell Blvd/Maria Dr
8.5
A
12.4 B
8.7
A
13.4
B
6.
Maria Dr./Project Driveway
9.6 1
A
11.1 B
10.5
B
13.2
B
Source: Safeway Fuel Center Traffic Impact Study
Update,
prepared by CHS Consulting Group, March
16, 2018.
Traffic Impact Summary
The project will not cause traffic levels to exceed, either individually or cumulatively, a level of service"D" or
below, including standards established by the County Congestion management agency for designated roads
or highways. Project area intersections are projected to operate at acceptable levels for the near-term and long-
term conditions. Although traffic volumes generated by the project will contribute to the level of congestion and
delays, the project's share of trips added to circulation network would be below levels of significance. The LOS
for planning area intersections will not be noticeably affected by the proposed project. The project will not cause
an increase in traffic that is substantial in relation to the existing traffic load and capacity of the street system.
Impacts associated with performance of the circulation plan due to project implementation will be less than
significant.
Further, the project's circulation plan has been reviewed and approved by the Petaluma Public Works & Utilities
Department (Engineering & Traffic Division) and the Fire Marshal. As a standard condition of project approval,
the applicant shall pay all development impact fees. These fees will contribute to improvements to City roadways
and assure that the project's fair share of increased traffic and use of the circulation system has been accounted
for. The payment of impact fees in addition to proposed site design measures will ensure the project's impact to
traffic and circulation will be less than significant.
3.16(c) (Air Traffic Patterns) No Impact: The project will not result in an increase in traffic in a manner that
changes the air traffic pattern. Nor will the project introduce a safety concern related to air traffic pattern due to
the location of facilities. The project is located over a mile south of the Petaluma Municipal Airport and does not
contain any elements that would affect the air traffic pattern. Therefore, the project would have no impacts that
affect air traffic.
3.16(d) (Design Feature Hazard) Less than Significant Impact with Mitigation: The proposed project will
introduce a new use on site that has the potential to alter vehicle access, interfere with internal circulation and
conflict with sight distances.
Site Access
Access to the project site is provided via any of the three project driveways located along Maria Drive, two
access driveways along McDowell Boulevard, and the driveway access provided via East Washington Street.
Primary access to the Safeway Fuel Center will be provided by Maria Drive and South McDowell Boulevard.
These access drives currently exist and other than improvement to the driveways along Maria Drive access
ways will remain unaltered. At operation site ingress will be provided via the existing entrance driveways on
Maria Drive and from the internal drive aisle that transects the shopping center. The two ingress/egress
driveways along Maria Drive will be improved with curb and gutters and will be stripped to delineate a pedestrian
cross -walk in alignment with the sidewalks. As with the current condition, these driveways will accommodate
two-way turning movements. Egress will be provided by an exit only driveway onto Maria Drive and an exit only
driveway at the northwest corner of the project site which outlets to a drive aisle within the shopping center.
The exit only driveway on Maria Drive, closest to South McDowell Boulevard will provide for a right out only
turning movement. Directional arrows, one-way entry pavement striping, signage and stenciling will be installed
at all internal project egress/ingress points to indicate the "DO NOT ENTER" and "DO NOT BLOCK" areas.
With the proposed access, associated signage and improvements, project driveways would not increase
hazards due to a design condition and potential impacts would be less than significant.
March 2018 Page 55 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
Eastside Transit Center
The proposed fuel station parcel abuts the existing Eastside Transit Center (ETC) located along the west side
of Maria Drive. It is situated in between the two access driveways into the Shopping Center from Maria Drive,
and immediately east of the proposed Fuel Center. In order to maintain adequate site distance when buses are
parked at the stop, the project proposes a bus turn out area that will improve the line of site for vehicles exiting
onto Maria Drive from the shopping center. The Transit Center is proposed to be modified to increase the width
of the bus turnout area, which will allow for buses to queue outside of the Maria Drive travel lane.
Four lines on Petaluma Transit (2, 3, 11, and 33) operate at half hour and hourly headways and stop at the
Eastside Transit Center. The transit schedule is such that lines, in most cases, will converge every 30 minutes,
potentially resulting in three buses lining up at ETC simultaneously. The constant activity at the bus station
coupled with the expected increase in traffic generated by the project warrants consideration of site distance
hazards.
The Traffic Study evaluated the sight distance triangle for vehicles exiting the two driveways into Maria Drive.
The evaluation of the existing conditions indicates a sight distance of 60 feet when buses are parked. A safe
stopping sight distance for a roadway with a posted speed limit of 25 mph is 155 feet. In order to alleviate
potential conflicts posed by the ETC, the applicant proposes a bus turnout area recessed into the shopping
center site. The turnout area is intended to accommodate buses such that they would be removed from the line
of sight of drivers entering and exiting the shopping center. As designed, the proposed improvements to the
ETC would accommodate three, 40 foot buses in-line and allow 10 foot spacing in between each bus. The
proposed turn out bay would be 12.5 feet wide. This design would allow for a line of sight of 155 feet for drivers
existing from either of the two driveways onto Maria Drive. Accordingly, as proposed modifications to the ETC
would be sufficient to meet the requisite line of sight requirements. Therefore the project would result in less
than significant impacts due to the introduction of a design hazard associated with the ETC.
Queuing
As proposed, the site plan would accommodate the simultaneous fueling of 16 vehicles. The fuel pumps are
spaced 25 feet from each other, which is an adequate distance to accommodate full sized picks -ups and SUVs.
The space between the rows of the fuel dispensing islands is 36 feet and will allow customers to exit the fueling
area without waiting for the vehicle fueling in front of them to exit. A minimum of 12 vehicles would be able to
queue outside of the fuel canopy (3 vehicles in each of the 4 fueling rows). A potentially significant impact could
occur due to a design hazard in the event that queuing vehicles blocked the internal travel aisle.
In order to ensure that vehicle queuing occurs within the designated stacking area the project shall implement
mitigation measure TRANS -1, which requires the use of "fuel ambassadors" to direct vehicles to vacant fuel
pumps. Fuel ambassadors will provide assistance during peak hours in order to ensure that cross flow traffic
through the parking lot is not impeded and that efficient circulation of vehicles and customers is maintained at
fueling stations. Once customers pull away from the pump they will have the option to exit the fuel center via
the right -out -only driveway onto Maria Drive or exit the Fuel Center to the north within the internal Shopping
Center drive aisle.
Based on the anticipated trip generation rates and the use of fuel ambassadors the internal circulation plan is
not expected to result in any significant design hazards due to queuing of vehicles. Additionally, the project will
include one-way entry pavement striping and "DO NOT ENTER" signage at the fuel station exit only location
nearest the Maria Drive/S. McDowell Boulevard intersection and a "DO NOT BLOCK" pavement legend along
the project driveway at entering approaches to the waiting areas. The inclusion of appropriate striping and
signage will ensure any latent demand can proceed through the project driveways if vehicles do not wish to
enter the fuel station waiting area during peak hours. Thus, with mitigation measure TRANS -1 potential impacts
associated with the introduction of design hazards will be reduced to less than significant levels.
Fuel Truck Delivery Path
The proposed fuel center is designed to provide efficient circulation in part by minimizing conflicts between fuel
pump bound traffic and fuel delivery trucks. Fuel delivery trucks will make one morning delivery between 6:00
am and 8:00 am and one evening delivery after 8:00 pm daily. The ingress and egress path of delivery trucks
will utilize the Maria Drive access point for egress. As analyzed in the Traffic Study, fuel trucks will have an
adequate turning radius to loop around the fueling station area and pull into the fuel delivery area. The fuel
March 2018 Page 56 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma Safeway Fuel Center IS/MND
dispensing area is located away from the ingress and egress driveways and will not conflict with ongoing fueling
activities. Additionally, the time for fuel delivery to occur is intentionally scheduled outside of the peak demand
period, thereby minimizing potential conflicts. No apparent issues or conflicts are indicated with the proposed
truck ingress/egress pathway. Therefore, impacts due to a design hazard associated with the delivery path and
fuel dispensing of delivery trucks would be less than significant.
3.16(e) (Emergency Access) Less than Significant Impact: The project's internal circulation plan has been
reviewed and meets all standard conditions imposed by the Petaluma Public Works and Fire Departments. Site
circulation was determined to be adequate, including sufficient internal street widths to allow for fire truck turn
around. Thus, the project's potential to result in impact due inadequate emergency access would be less than
significant.
3.16(f) (Transit, Bicycle, Pedestrian Facilities) Less than Significant Impact: The proposed Safeway Fuel
Center will not result in adverse impacts to pedestrian, bicyclist, public transit or other alternative transportation
facilities. The project will provide for sidewalks along the site's frontage to Maria Drive and N. McDowell
Boulevard and will provide onsite pedestrian paths to access the new convenience store. Additionally, sidewalk
and cross -walk improvements will be installed along Maria Drive at the ETC and the two access driveways from
Maria Drive. Potential impacts associated with pedestrian, bicycle and transit facilities are discussed below:
Pedestrian Facilities
Existing pedestrian facilities in the project vicinity include sidewalks, and crosswalks providing connectivity to
surrounding amenities and the elementary school. The proposed curb configuration along Maria Drive to
accommodate buses will include a sidewalk that provides continuous connectivity along Maria Drive. Due to
the proximity of the adjacent elementary school there will be elementary school bound pedestrians walking
across the McDowell Boulevard and Maria Drive intersection at the same time as the am peak hour traffic. The
project, as proposed, does not make any substantial changes to pedestrian facilities and is not expected to
pose a hazard to pedestrian safety, New crosswalk striping, sidewalks and curb improvements will enhance the
pedestrian facilities onsite and along Maria Drive proximate to the ETC. Therefore, impacts associated with
pedestrian safety will be less than significant.
Bicycle Facilities
Bicycle facilities adjacent to the project site include Class II and III bike lanes on Washington Street and
McDowell Boulevard, respectively. A Class III bike line is proposed for Maria Drive. As such the project will be
required to install signage as part of project approvals indicated the Class III bike route. The project does not
propose any elements that would interfere with existing or proposed bicycle facilities. Therefore, impacts to
bicycle facilities will be less than significant.
Transit Facilities
Petaluma Transit provides public transportation throughout the City via dedicated bus stops and planned routes.
The Eastside Transit Center is located contiguous to the project site and serves as a major transit hub. In order
to improve the site distance to acceptable levels the project includes reconfiguration of the bus pullout, sidewalk,
curb and associated amenities.
The proposed changes ensure that requisite sight distances are achieved, as described above. Improvements
also include new bus shelters, benches and landscaping. The proposed modifications to the ETC will not impact
access to services or reduce utility of the public transit facilities. The project is not expected to result in significant
impacts that would conflict with alternative transportation facilities or substantially reduce the performance or
safety of such facilities. Therefore, impacts would be less than significant.
Mitigation Measures:
TRANS- 1. In order to maintain queuing at acceptable levels during peak hours, the Safeway Fuel Center shall
dedicate a sufficient number of employee(s) to serve as fuel ambassadors during peak hours to
facilitate efficient and safe fueling of vehicles and maintain consistent egress/ ingress at internal
access points onsite.
March 2018 Page 57 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
3.17. TRIBAL CULTURAL RESOURCES
Fuel Center IS/MND
Less Than
Potentially Significant Less Than No
Would the project: Significant with Significant Impact
Impact Mitigation Impact
Incorporated
a) Would the project cause a substantial adverse
change in the significance of a tribal cultural
resource, defined in Public Resources Code section
21074 as either a site, feature, place, cultural
landscape that is geographically defined in terms of
the size and scope of the landscape, sacred place, or
object with cultural value to a California Native
American tribe, and that is:
i) Listed or eligible for listing in the California
Register of Historical Resources, or in a local
register of historical resources as defined in
Public Resources Code section 5020.1(k), or
ii) A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024. 1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.
Sources: City of Petaluma General Plan 2025 and EIR.
Setting
❑ ❑ ❑
❑ ❑ ❑
The Federated Indians of Graton Rancheria did not request consultation within the statutory timeframe provided
by Public Resources Code §21080.3.1. The City of Petaluma provided notice required under that statute in a
letter dated June 8, 2017. Graton Rancheria received the notification letter on June 12, 2017 and did not reply
to the City of Petaluma within the thirty (30) day time -period provided for consultation requests. Additionally, no
subsequent request or correspondence by the Graton Rancheria has been received by the City of Petaluma in
regards to the subject project.
Impact Analysis
3.17 (a -b) (Tribal Cultural Resource) No Impact: This section incorporates by reference all text included
within the Cultural Resources topic above. Given that body of substantial evidence, the project would have no
impact under the topic of tribal cultural resources.
Mitigation Measures: None Required.
March 2018 Page 58 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma
3.18. UTILITIES AND SERVICE SYSTEMS
Fuel Center IS/MND
Would the project:
Potentially
Significant
Impact
Less Than
Significant
with
Mitigation
Incorporated
Less than No
Significant Impact
Impact p
a) Exceed wastewater treatment requirements of the
❑
❑
❑
applicable Regional Water Quality Control Board?
b) Require or result in the construction of new water
or wastewater treatment facilities or expansion of
❑
❑
❑
existing facilities, the construction of which could
cause significant environmental effects?
c) Require or result in the construction of new storm
water drainage facilities or expansion of existing
❑
❑
❑
facilities, the construction of which could cause
significant environmental effects?
d) Have sufficient water supplies available to serve
the project from existing entitlements and resources,
❑
❑
® ❑
or are new or expanded entitlements needed?
e) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
❑
❑
❑
project's projected demand in addition to the
provider's existing commitments?
f) Be served by a landfill with sufficient permitted
capacity to accommodate the project's solid waste
❑
❑
❑
disposal needs?
g) Comply with federal, state, and local statutes and
regulations related to solid waste?
❑
❑
❑
Sources: 2025 General Plan and DEIR; Water Resource and
Conservation
2015 UWMP;
and Sonoma County Water
Aqencv 2015 UWMP.
Utilities and Service Systems Settings: The City charges one time impact fees on new private development
in order to offset the cost of improving or expanding City facilities. Impact fees are used to help fund the
construction or expansion of needed capital improvements. Petaluma collects impact fees for open space, park
land, wastewater, water capacity, storm drain, public art and others. As a project is located within a previously
developed area of the UGB, the subject site is well served by existing public utilities and will not necessitate the
expansion or enhancement of existing utilities and service systems.
Water Service System
The City's water supply is sourced from the Russian River Water System and supplemented with local
groundwater. Water from the Russian River Water System is obtained via the Petaluma Aqueduct through a
contract with the Sonoma County Water Agency (SCWA). The City's Water Resource and Conservation
Division (WR&C) provides municipal water service to approximately 60,000 customers and therefore must
comply with the Urban Water Management Plan Act, which requires the preparation of an Urban Water
Management Plan (UWMP) every five years.
The City's 2010 Urban Water Management Plan (UWMP) updates information from General Plan 2025
background and environmental documents and extended the term of water demand analysis through 2035. The
2010 UWMP was determined to be consistent with the General Plan 2025, The UWMP includes a water
March 2018 Page 59 of 65
Planning Commission Resolution No. 2018-21A
of Petaluma Safeway Fuel Center IS/MND
supply/demand analysis based on population trends and land uses set forth in the 2025 General Plan, the City's
existing water supply contract with the Sonoma County Water Agency (SCWA), and planned City water
recycling and water conservation programs.
In 2015, the City updated its UWMP including a baseline demand analysis in compliance with the interim 2015
Urban Water Use target, an Urban Water Use target analysis for 2020, projected urban Water Use through the
year 2040, and a description of programs to achieve the target demand reductions in the UWMP.
Instream flow requirements have also been established to protect fish and wildlife species and recreation.13
Based on regional water supply availability, the SCWA expects to be able to increase annual water deliveries
to Petaluma from approximately 7,200 acre-feet (AC -FT) in 2010 to 11,400 AC -FT by 2035.
Based on the evaluation of future Russian River supply including, minimum in -stream flow requirements, SCWA
expects to obtain water rights approvals necessary to increase its total diversions above 75,000 acre-feet per
year (AC-FTNR) by 2027 and to 80,000 AC-FTNR by 2035. This assumption is based on the most likely
outcome of decisions by regulatory agencies and implementation of the Restructured Agreement (executed in
2006) and proposed improvements to the water delivery system.
To assure that the City of Petaluma has sufficient water supplies to meet increased water demand, the General
Plan requires routine monitoring of water supplies against actual use and evaluation for each new development
project (see Policy 8-P-4).
Water Conservation
On January 17, 2014, Governor Brown proclaimed a state of emergency to exist through the State of California
due to severe drought conditions. On April 25, 2014, Governor Brown issued a follow-up proclamation declaring
a continued state of emergency throughout the State of California due to the ongoing drought. On April 1, 2015,
Governor Brown issued Executive Order B-29-15 and, in doing so, imposed requirements on state resources
agencies that will save water, increase enforcement to prevent wasteful water use, streamline the state's
drought response and invest in new technologies that will make California more drought -resilient.
On March 17, 2014, the State Water Resources Control Board (SWRCB) adopted emergency regulations for
water conservation.14 Those regulations were subsequently updated in response to Executive Order B-29-15
and, as approved by the SWRCB, are intended to increase water conservation in urban settings by 25%
statewide. For the City of Petaluma, the SWRCB established a 16% reduction in annual per capita water use.
Based on monthly water use reports provided to the SWRCB, the City of Petaluma has exceeded that mandate;
i.e., between June 2014 and May 2015, water by residential customers decreased by 33.56%.
On June 1, 2015, the Petaluma City Council adopted a resolution pursuant to the SWRCB directive and which
implements a Stage 2 Water Shortage Contingency Plan. In addition to furthering mandates of the SWRCB,
the City of Petaluma is also pursuing a host of other measures to increase water conservation (e.g., public
outreach, rebates and incentives) and will soon consider amendments to Municipal Code Chapter 15.17 (Water
Conservation Regulations).
The City of Petaluma has developed a Water Shortage Contingency Plan, which outlines four stages of water
shortage and implements water use reduction measures according to severity of the drought. The four stages
are as follows: Stage 1 (minimal); Stage 2 (Moderate); Stage 3 (Severe); and Stage 4 (Critical). In March of
2014 the City of Petaluma imposed voluntary measures in accordance with Stage 1 of the Water Contingency
Plan to reduce water usage by twenty percent. Although the City of Petaluma implemented Stage 2 mandates
to conserve water in 2015, as of August 16, 2016, the City was officially relieved of their state mandatory water -
saving target of 16 percent.
According to the City's Water Supply Self -Certification 2016, the City of Petaluma no longer has a mandatory
conservation target but encourages water customers to voluntarily reduce demand by 10 percent, which can
13 State Water Resources Control Board: Decision No. 1610 (http://www.waterboards.ca.gov/waterrights)
14 Office of Administrative Law File No. 2015-0320-01 EE.
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Planning Commission Resolution No. 2018-21 A
Citv of Petaluma Safeway Fuel Center IS/MND
be met by limiting outdoor irrigation and participating in the City's Water Conservation Programs. Also, effective
February 4, 2016, the City of Petaluma adopted an ordinance for new water conservation regulations.
Wastewater Treatment
The Ellis Creek Water Recycling Facility treats all wastewater generated by the City of Petaluma and
unincorporated Sonoma County community of Penngrove. The collection system is comprised of more than
190 miles of underground piping and nine (9) pump stations. The Facility's treatment capacity is about 6.7
million gallons per day (average dry weather flow). The facility treats approximately five (5) million gallons per
day, leaving approximately 1.7 million gallons in available treatment capacity. During the summer, recycled
water is introduced to the City's recycled water system and is used for irrigation of approximately 800 acres of
agricultural lands, two golf courses, and a vineyard. In the winter, secondary treated wastewater is conveyed
to the Petaluma River.
Storm Drains
Within the City of Petaluma storm drains convey runoff from impervious surfaces such as streets, sidewalks,
and buildings to gutters that drain to creeks and the Petaluma River and ultimately the San Pablo Bay. This
water is untreated and carries with it any contaminants picked up along the way such as solvents, oils, fuels
and sediment. The City has implemented a storm drain labeling program to provide a visual reminder that storm
drains are for rain water only. The City's Stormwater Management and Pollution Control Ordinance, set forth in
Chapter 15.80 of the City's Municipal Code establishes the standard requirements and controls on the storm
drain system. All existing and proposed development must adhere to the City's Stormwater Management and
Pollution Control Ordinance, as well as the policies set forth in the General Plan.
Utilities and Service Systems Impact Discussion:
3.18(a -b) (Exceed Wastewater Treatment Requirements, New On -Site Water or Wastewater Treatment
Facilities) No Impact: The project site is served by the Ellis Creek Wastewater Recycling Facility, which has
sufficient operating capacity to handle the flows generated by the proposed project. The proposed fuel station
would generate wastewater similar to or less than the existing land use of commercial/retail. The project's
generation of wastewater falls within the current capacity of the sanitary sewer lines and the City's Wastewater
Sewer Plan. The project will not necessitate the expansion or construction of new wastewater treatment
facilities. Therefore, the project will have no impacts related to exceeding wastewater treatment requirements
or requiring new or expanded wastewater facilities.
3.18(c) (Require New Stormwater Facilities) No Impact: The project is not expected to result in significant
environmental impacts due to the expansion of existing storm water drainage facilities or construction of new
facilities. The redevelopment of the project site will not result in an increase in impervious services; rather it is
expected to actually reduce impervious services by increasing landscaping area. At present, the storm drainage
infrastructure exhibits sufficient capacity and is expected to continue to do so at project buildout. Therefore,
there will be no impacts that will require the construction of new storm water drainage facilities or expansion of
new facilities that could cause potentially significant environmental effects.
3.18(d) (Sufficient Water Supplies) Less Than Significant Impact: Demolition of the existing commercial
building onsite will permanently remove any water demand incurred by tenants. Although water will be required
for the proposed landscaping, convenience store and other ancillary uses onsite, the proposed Safeway Fuel
Center will result in a negligible change in water use relative to the existing condition.
The existing water supplies, facilities and infrastructure are sufficient to meet the demands of the project without
the need for a substantial expansion or new construction. A condition from the Petaluma Department of Water
Resources and Conservation requires that the project comply with the City's Water Conservation Ordinance for
interior and exterior water usage. Water demand onsite will be limited through efficient irrigation of the
landscaping and water efficient fixtures and appliances indoors, consistent with requirements established by
the CalGreen Building Code. Therefore, the project's impacts to water supplies and infrastructure would be less
than significant.
3.18(e) (Wastewater Treatment) No Impact: The project is of the type and density anticipated in the 2025
General Plan. The project's contribution to wastewater flows were anticipated in the General Plan and have
March 2018 Page 61 of 65
Planning Commission Resolution No. 2018-21A
Citv of Petaluma Safeway Fuel Center IS/MND
been considered for operating capacity of the water treatment plant. The redevelopment of the project site with
a fuel station and convenience store is well within the flow capacity analyzed as part of the General Plan. The
project will not generate wastewater that exceeds the capacity of the City's existing wastewater treatment plant
when added to existing and projected commitments through General Plan buildout. Therefore, the project will
have no impacts related to the adequacy or capacity of wastewater treatment facilities.
3.18(f -g) (Landfill Capacity, Solid Waste Statutes) No Impact: The proposed Safeway Fuel Center will
contribute minimally to the generation of solid waste within the UGB. The amount of solid waste expected to be
generated by the project is considered small and is consistent with the service needs anticipated by the
Petaluma 2025 General Plan and evaluated in the General Plan EIR. Solid waste facilities are owned and
operated by the Sonoma County Department of Transportation and Public Works; the City maintains a franchise
solid waste hauling agreement requiring the franchise hauler, as part of its contractual obligations, to select
properly permitted, approved disposal location(s) with adequate capacity to serve city service needs. Although
the project will generate solid waste, the amount is minimal and will likely be less than what the previous use
generated.
The project applicant will adhere to all requisite regulations governing the disposal of solid waste. Policy 4-P-
21 requires waste reduction in compliance with the Countywide Integrated Waste Management Plan
(COLWMP) and any waste generated from demolition and construction activities will be reduced through the
development of a Construction Waste Management Plan. Solid waste generated during operation will be
collected using canisters for waste, green waste and recyclables provided by the Petaluma Refuse and
Recycling for Solid Waste Disposal and Recycling Services and transferred to Sonoma County Landfill site.
As the project is redevelopment of an existing site and will maintain the existing land use designation of
commercial retail while reducing intensity of the site it is expected that the project will have no impacts related
to the disposal of solid waste or violations of Federal, State and/or Local statutes and regulations governing
solid waste.
Mitigation Measures: None Required.
March 2018 Page 62 of 65
Planning Commission Resolution No. 2018-21 A
City of Petaluma Safeway Fuel Center IS/MND
3.19. MANDATORY FINDINGS OF SIGNIFICANCE (CAL. PUB. RES. CODE §15065)
A focused or full environmental impact report for a project may be required where the project has a significant
effect on the environment in any of the following conditions:
Less Than
Potentially Significant Less than No
Significant with Significant Impact
Would the project: Impact Mitigation Impact
Incorporated
a) Does the project have the potential to degrade the
quality of the environment, substantially reduce the habitat
of a fish or wildlife species, cause a fish or wildlife
population to drop below self-sustaining levels, threaten to ❑ ® ❑
eliminate a plant or animal community, reduce the number
or restrict the range of a rare or endangered plant or animal
or eliminate important examples of the major periods of
California history or prehistory?
b) Does the project have impacts that are individually
limited, but cumulatively considerable? ("Cumulatively
considerable" means that the incremental effects of a ❑ El ® El
project are considerable when viewed in connection with
the effects of past projects, the effects of other current
projects, and the effects of probable future projects)?
c) Does the project have environmental effects, which will
cause substantial adverse effects on human beings, either ❑ ® ❑
directly or indirectiv?
Mandatory Findings Discussion:
3.19(a) Less Than Significant Impact: The project is located within the UGB and is considered as part of the
development anticipated by the City's General Plan and analyzed in the EIR. The project is consistent with the
General Plan Land Use and goals, policies and programs. With implementation of mitigation measures set forth
above the project's potential impacts to the quality of the environment would be reduced to levels below
significance. As such, the project will not degrade the quality of the environment, reduce habitat, or affect
cultural resources. Therefore, the project will have less than significant impacts due to degradation of the
environment.
3.19(b) Less than Significant Impact: The Safeway Fuel Center project is consistent with the City's General
Plan land use designation for the site and the City's long-range plan for future development.
The project has the potential to incrementally contribute to the following impacts identified and analyzed in
the General Plan EIR:
Intersection LOS (Impact 3.2-1): The project would contribute vehicle trips to intersections identified in
the General Plan EIR as operating at an unacceptable LOS at build -out. While the proposed project
would not directly impact any of the 6 study intersections significantly impacted from implementation of the
General Plan EIR, the project would contribute trips to these intersections. However, as stated in Section
3.16 above, the project will not cause an increase in traffic that is substantial in relation to the existing
traffic load and capacity of the street system. Therefore, the project's contribution to intersection LOS
would not be considered cumulatively considerable.
• Noise (Impact 3.9-1, Impact 3.9-2): The project will increase vehicle trips on local roadways and, in
doing so, incrementally contribute to noise levels determined by the General Plan to be significant at
March 2018 Page 63 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
Safeway Fuel Center IS/MND
build -out. However, incremental contribution of vehicular trips is insufficient to result in a perceptible
change in noise level. Equipment such as heating, ventilation and air conditions (HVAC), refrigeration
units, and other mechanical equipment associated with the fuel center convenience store will
contribute to the ambient noise environment at operation. However, as stated in Section 3.12 above,
noise generated by mechanical equipment would be below the ambient noise levels in the project
vicinity. Therefore, the project's contribution to noise impacts would not be considered cumulatively
considerable.
Air Quality (Impact 3.10-3): The project would result in air quality impacts during operation, which
would incrementally contribute to a net increase of criteria pollutants for which the region is in
nonattainment, which was determined by the General Plan to be cumulatively considerable. As
described in Section 3.3 above, none of the pollutant concentrations generated during operation of the
proposed project would result in emissions that exceed BAAQMD established thresholds. Project
generated traffic, vehicle idling, and fuel vapor emissions are below the established annual and daily
thresholds set forth by BAAQMD for criteria pollutants and GHGs. Therefore, the project's contribution
to air quality impacts is not considered to be cumulatively considerable.
Hazards/Hazardous Materials (Impact 3.13-1, Impact 3.13-2): The project would routinely transport,
store, and dispense liquid fuel, which would incrementally contribute to a significant hazard to the
public or the environment, from the routine transport, use or accidental release of hazardous materials,
identified at buildout of the General Plan. However, as stated in Section 3.8, the operation of such
facilities are regulated by a number of Federal and State agencies in order to ensure optimal safety
conditions. The State of California requires that fueling stations incorporate proper control equipment
necessary to minimize vapor emitted from the facility such as enhanced vapor recovery systems. As
proposed, the fuel dispensing valves will control and minimize vapor emissions. Additionally, the facility
will be constructed in accordance with California's Fire, Building and Health Codes that require
measures such as automatic shut offs, signage and onsite spill containment for USTs. Last, the
operator will obtain a permit from the Petaluma CUPA and submit a Hazardous Materials Release
Response Plan and Inventory in accordance with CUPA standards. Therefore, the project's
contribution to hazards/hazardous materials impacts would not be considered cumulatively
considerable.
The project is also consistent with the surrounding land uses and implements the intent of the UGB through
redevelopment in an existing urbanized area. Public utility and service providers are capable of serving the
project with existing or planned facilities. Potential environmental impacts are expected to remain at levels
below significance, and long-term environmental goals are not expected to be adversely impacted by the
project. The Project does not increase the severity of any of the impacts from the levels identified and analyzed
in the General Plan EIR. Therefore the project's cumulative impacts will be less than significant.
3.19(c) Less Than Significant Impact: The project has the potential to result in adverse impacts to humans
due to aesthetics, air quality, biological resources, cultural resources, geology and soils, hazards/hazardous
materials, noise, and transportation/circulation. With the mitigation measures set forth above, the project will
have less than significant environmental effect that would directly or indirectly impact human beings onsite or
in the project vicinity. Therefore the project will have less than significant impacts due to substantial adverse
environmental effects.
Mitigation Measures: None Required.
March 2018 Page 64 of 65
Planning Commission Resolution No. 2018-21 A
of Petaluma
4. REFERENCE DOCUMENTS:
Fuel Center IS/MND
General Plan and Zoning Ordinance
General Plan Chapter 1. Land Use,
Growth Management, & the Built
Environment
General Plan Chapter 7. Community
Facilities, Services & Education
General Plan Chapter 2. Community
Design, Character, &Green Building
General Plan Chapter 8. Water
Resources
General Plan Chapter 3. Historic
Preservation
General Plan Chapter 9. Economic
Health & Sustainability
General Plan Chapter 4. The Natural
Environment
General Plan Chapter 10. Health &
Safety
General Plan Chapter 5. Mobility
General Plan Chapter 11. Housing
General Plan Chapter 6. Recreation,
Music, Parks, & the Arts
Implementing Zoning Ordinance/
Maps
Other Sources of Information
Petaluma UWMP
Published geological maps
SCWA UWMP
General Plan 2025 EIR
FEMA Flood Insurance Rate Mas
SMART Master Plan
BAAQMD CAP
BAAQMD CEQA Guidelines
Sonoma County Climate Action Plan
BAAQMD Regulation 2 and 8
Technical Appendices: The following resources were prepared in order to further identify project specific
parameters. Copies of these technical documents are incorporated herein by reference are available for review
during normal business hours at the City of Petaluma, 11 English Street, in the Community Development
Department.
A. "Safeway Fuel Center Air Pollutant and Greenhouse Gas Emissions Assessment, Petaluma,
California," Prepared by Illingworth & Rodkin Inc., January 8, 2014, revised September 18, 2017.
B. "Safeway Fuel Center Health Risk Assessment, Petaluma, California," Prepared by Illingworth &
Rodkin Inc., January 8, 2014, Revised September 19, 2017.
C. "Limited Asbestos and Lead -Based Paint Survey," Prepared by Cardno ATC, May 29, 2013.
D. "Safeway Fuel Center Environmental Noise Assessment, Petaluma, California," prepared by
Illingworth & Rodkin Inc., April 14, 2014.
E. "Revised Traffic Study for Safeway Fuel Center at Washington Square Shopping Center," prepared
by TJKM Transportation Consultants, August 13, 2014.
F. Safeway Fuel Center Traffic Impact Study Update, prepared by CHS Consulting Group, March 16,
2018.
March 2018 Page 65 of 65
Planning Commission Resolution No. 2018-21 A
Exhibit 2
., City of Petaluma, California
Community Development Department
' Planning Division
z85$ 11 English Street, Petaluma, CA 94952
Project Name: Safeway Fuel
File Number: File No. PLSR-13-0012
Address/Location: 335 South McDowell Boulevard, Petaluma, CA
MITIGATION MONITORING AND REPORTING PROGRAM
This Mitigation Monitoring and Reporting Program (MMRP) has been prepared in conformance with
Section 21081.6 of the California Environmental Quality Act (CEQA) and Section 15097 of the CEQA
Guidelines. This document has been developed to ensure implementation of mitigation measures and
proper and adequate monitoring/reporting of such implementation. CEQA requires that this MMRP be
adopted in conjunction with project approval, which relies upon a Mitigated Negative Declaration.
The purpose of this MMRP is to: (1) document implementation of required mitigation; (2) identify
monitoring/reporting responsibility, be it the lead agency (City of Petaluma), other agency (responsible or
trustee agency), or a private entity (applicant, contractor, or project manager); (3) establish the frequency
and duration of monitoring/reporting; (4) provide a record of the monitoring/reporting; and (5) ensure
compliance.
The following table lists each of the mitigation measures adopted by the City in connection with project
approval, the implementation action, timeframe to which the measure applies, the monitoring/reporting
responsibility, reporting requirements, and the status of compliance with the mitigation measure.
Implementation
The responsibilities of implementation include review and approval by City staff including the engineering,
planning, and building divisions. Responsibilities include the following:
The applicant shall obtain all required surveys and studies and provide a copy to the City prior to
issuance of grading permits or approvals of improvements plans.
2. The applicant shall incorporate all applicable code provisions and required mitigation measures and
conditions into the design and improvements plans and specifications for the project.
The applicant shall notify all employees, contractors, subcontractor, and agents involved in the
project implementation of mitigation measures and conditions applicable to the project and shall
ensure compliance with such measures and conditions.
Planning Commission Resolution No. 2018-21 A
4. The applicant shall provide for the cost of monitoring of any condition or mitigation measure that
involves on-going operations on the site or long-range improvements.
5. The applicant shall designate a project manager with authority to implement all mitigation measures
and conditions of approval and provide name, address, and phone numbers to the City prior to
issuance of any grading permits and signed by the contractor responsible for construction.
6. Mitigation measures required during construction shall be listed as conditions on the building or
grading permits and signed by the contractor responsible for construction.
7. All mitigation measures shall be incorporated as conditions of project approval.
8. The applicant shall arrange a pre -construction conference with the construction contractor, City staff,
and responsible agencies to review the mitigation measures and conditions of approval prior to the
issuance of grading and building permits.
Monitoring and Reporting
The responsibilities of monitoring and reporting include the engineering, planning, and building divisions,
as well as the fire department. Responsibilities include the following:
1. The Building, Planning, and Engineering Divisions and Fire Department shall review the
improvement and construction plans for conformance with the approved project description and all
applicable codes, conditions, mitigation measures, and permit requirements prior to approval of a
site design review, improvement plans, grading plans, or building permits.
2. The Planning Division shall ensure that the applicant has obtained applicable required permits from
all responsible agencies and that the plans and specifications conform to the permit requirements
prior to the issuance of grading or building permits or as otherwise specified herein.
3. Prior to acceptance of improvements or issuance of a Certificate of Occupancy, all improvements
shall be subject to inspection by City staff for compliance with the project description, permit
conditions, and approved development or improvement plans.
4. City inspectors shall ensure that construction activities occur in a manner that is consistent with the
approved plans and conditions of approval.
MMRP Checklist
The following table lists each of the mitigation measures adopted by the City in connection with project
approval, the timeframe to which the measure applies, the person/agency/permit responsible for
implementing the measure, and the status of compliance with the mitigation measure.
Page 2 of 9 Planning Commission Resolution No. 2018-21A April 2018
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Exhibit 3
RESPONSE TO COMMENTS ON
SAFEWAY FUEL CENTER PUBLIC DRAFT IS/MND
This document provides a response to comments received on the Public Draft Initial
Study/Mitigated Negative Declaration (IS/MND) that was prepared for the Safeway Fuel Center
Project. In accordance with the California Environmental Quality Act (CEQA) of 1970 (as
amended) (California Public Resources Code 21000 et. seq.), the Public Draft IS/MND was
circulated for a 30 -day public review and comment period from April 5, 2018 to May 4, 2018.
Notice of availability, notice of intent to adopt and notice of public hearing for the IS/MND was
posted with the Sonoma County Clerk, mailed to property owners within 500 feet of the project
site, published in the Argus Courier, posted to the City's website and submitted to the State
Clearinghouse for distribution to State Agencies.
COMMENTS RECEIVED
A number of written comment letters were received during the public review and comment period
for the IS/MND. Comments were also received orally from the general public and the Planning
Commissioners at the May 8, 2018 Planning Commission public hearing. The individuals providing
comments included neighbors, community members, school personnel and parents of students.
Agencies, organizations and individuals that submitted written or oral comments on the IS/MND
are listed below;
Agencies
1. California State Clearinghouse
2. California Department of Toxic Substances Control
3. California Department of Transportation
Local Entities & Individuals
1. Petaluma City Schools (Chris Thomas, Chief Business Official)
a. Environmental Science Associates (ESA) Memo (Heidi Rous and Tina Su)
2. McDowell Elementary School (Lauri C. Anderson, Principal)
3. Nancy Manchester
4. Kathleen Coon
5. Melodie Kee
6. Michael and Leone Gannon
7. Chris Thomas
8. Jean Bisel
9. Talia Page
10. Laura Gavre
11. Erin Chmielewski
12. Maureen Maguire
13. Robin Aquino
14. Jennifer Benedetti
15. Corinne Reif
16. Laura Steinfels
17. Jennifer Stock
18. Linda Hartrich
Planning Commission Resolution No. 2018-21A
19. Rebecca Hachmyer
20. Stacey Earl
21. Christy Giambastiani
22. Betsy Boyle
23. Public Speakers from Planning Commission Hearing (May 8, 2018):
a. Lauri Anderson
b. Chris Thomas
c. Genie Praetzel
d. Matthew Pederson
e. Dale Wannen
f.
Elizabeth Ambrosi
g.
Carol Waxman
h.
Frances Frazier
i.
Adriann Saslow
j.
Horst Steinfels
k.
Oliver Steinfels
1.
Rebecca Hachmeyer
m.
Alexander Saslow
n.
Maureen Rudder
o.
Tim Harvey
p.
Ginee Harvey
q.
Anna Simson
r.
Maribel Baron
s.
Makenna Pearson
24. McDowell Adult Students, Parents, and Community Members (petition dated 2/27/14,
403 signatories, submitted 5/8/18)
25. Parents of children who attend educational
5/7/18, 116 signatories)
programs at McDowell School (petition dated
SUMMARY OF COMMENTS AND RESPONSES
The responses to public comments have been prepared in consultation with Illingworth & Rodkin,
CHS Consulting Group, and the Bay Area Air Quality Management District (BAAQMD).
Information in this Responses to Comments document is based on the references to the IS/MND
and the following documents:
• Technical Memorandum, Petaluma Safeway Fuel Center: Pedestrian Counts and Safety
Analysis, prepared by CHS Consulting Group, June 6, 2018.
• Memo, Safeway Fuel Center Health Risk Assessment, Response to Comment Made by
ESA, prepared by Illingworth & Rodkin, May 8, 2018.
• Memo, Safeway Fuel Center Health Risk Assessment, Response to Follow -Up Questions,
prepared by Illingworth & Rodkin, June 6, 2018.
• BAAQMD Permit Application for Safeway Fuel Center, submitted by Safeway, Inc.,
July 15, 2013.
• BAAQMD, Evaluation Report, Application #405215, Safeway Fuel Center #3011, Facility
ID #200026, S. McDowell Blvd. & Maria Drive, Petaluma CA 94954, 2013.
• BAAQMD, Public Notice for Permit Application #405215, Gasoline Dispensing Facility,
Safeway Fuel Center #3011, S. McDowell Blvd. & Maria Drive, Petaluma CA 94954, dated
August 22, 2013.
Planning Commission Resolution No. 2018-21 A
• BAAQMD, Authority to Construct for Permit Application #405215, Facility ID #200026,
Safeway Fuel Center #3011, S. McDowell Blvd. & Maria Drive, Petaluma CA 94954, dated
October 10, 2013.
• BAAQMD, Authority to Construct Extension Application, submitted by Safeway, Inc.,
October 6, 2017.
• BAAQMD, Authority to Construct for Permit Application #405215, (AC Extension),
Facility ID #200026, Safeway Fuel Center #3011, S. McDowell Blvd. & Maria Drive,
Petaluma CA 94954, dated November 9, 2017.
California State Clearinghouse
The letter from this agency acknowledges that the City of Petaluma complied with the State
Clearinghouse review requirements for review of draft environmental documents. The State
Clearinghouse also forwarded a copy of the comment letter from the California Department of
Transportation. No response is necessary.
California Department of Toxic Substances Control (DTSC)
The letter from DTSC requests that a copy of the Phase I Environmental Site Assessment (ESA) be
provided to the DTSC. The Phase I ESA was subsequently provided to the DTSC. A follow up
letter states that the DTSC received the Phase I Environmental Site Assessment for the project and
that the DTSC has no further comments at this time. No further response is necessary.
California Department of Transportation Caltrans)
The letter from Caltrans requests that copies of the Traffic Study prepared by TJKM Transportation
Consultants and the Technical Memorandum prepared by CHS Consulting Group be submitted to
Caltrans for review. These two documents were provided to Caltrans upon request, and no further
response from Caltrans has been received to date.
The letter also states that the project should be conditioned to contribute fair share traffic impact
fees toward future improvements for the U.S. 101/East Washington Street interchange. As stated in
the IS/MND, and confirmed by CHS Consulting Group in their Technical Memorandum dated
March 16, 2018, the proposed project would not result in any significant impacts to the
transportation network, and no mitigation is required.
Improvements at the East Washington Street/U.S. 101 interchange (northbound and southbound
on- and off -ramps) have already been completed. The signal timing changes at the East Washington
Street/U.S. 101 interchange (northbound and southbound ramps) and the East Washington
Street/North McDowell Boulevard intersection, have also been completed.
As stated on page 55 of the IS/MND, as a standard condition of approval, the applicant shall pay
all development impact fees. These fees will contribute to improvements to City roadways and
assure that the project's fair share of increased traffic and use of the circulation system has been
accounted for. As described in the IS/MND, the payment of impact fees in addition to proposed site
design measures will ensure the project's impact to traffic and circulation will be less than
significant, and no other improvements or fees specific to Caltrans' facilities are required.
Master Response to Comments on Health Risk Exposure
This master response has been prepared to address issues that were raised by multiple commenters
regarding the health risks associated with the proposed Safeway Fuel Center. A number of
Planning Commission Resolution No. 2018-21 A
commenters expressed concerns regarding the proximity of the proposed Safeway Fuel Center to
the surrounding neighborhood and the public facilities located at the McDowell Elementary School
Campus, including the Elementary School (421 S. McDowell, Petaluma, Ca 94954), the North Bay
Children's Center (405 S. McDowell, Petaluma, CA 94954), Petaluma Adult School (classes held
at McDowell Elementary). The commenters assert that operation of the proposed project would
cause a significant environmental impact to residents and students, staff, and parents of the
McDowell Elementary School and North Bay Children's Center.
Bay Area Air Quality Management District
As stated in Section 3.3 Air Quality of the IS/MND, the Bay Area Air Quality Management District
(BAAQMD) is charged with managing air quality for the region, including the City of Petaluma.
The BAAQMD has established air quality thresholds of significance for carbon monoxide (CO),
ozone precursors (ROG and NOx) and particulate matter (PM 10 and PM2.5) from construction and
operation of proposed projects. These thresholds are identified in the BAAQMD CEQA Air Quality
Guidelines established in May 2010, and most recently updated in May 2017. As concluded on
pages 18-19 of the IS/MND, and as shown on Tables 3 and 4 therein, none of the pollutant
concentrations generated during construction or operation of the proposed project would result in
emissions that exceed air quality thresholds established by the BAAQMD.
The BAAQMD also regulates stationary sources of air pollution such as factories, industrial sites,
and gasoline stations. In addition to the Guidelines, BAAQMD has established rules in order to
ensure that stationary source emitters conform to air quality regulations. The Safeway Fuel Center
Project is subject to several of the rules established by BAAQMD including Regulation 8, Rule 7
to control for the emission of reactive organic compound (ROG) from a stationary source emitter
due to fuel dispensing onsite, and Regulation 7 which controls for odors. In accordance with
BAAQMD regulation (Regulation 2, Rule 2), the proposed project is subject to an Authority to
Construct permit for the gasoline dispensing facility, which is a pre -construction permit that is
issued before equipment is installed.
Safeway, Inc. submitted a permit application to BAAQMD for the proposed Safeway Fuel Center
on July 15, 2013 (Application #405215), including documentation of proposed measures for
compliance with the above referenced BAAQMD rules and regulations. In BAAQMD's review of
Safeway's application, it was determined that the Best Available Control Technology requirement
of BAAQMD's Regulation 2-2-301 was triggered. The triggering of this regulation requires Best
Available Control Technology for Gasoline Dispensing Facilities, which considers the use of
California Air Resources Board (CARB)-certified Phase -I and Phase -II vapor recovery equipment.
BAAQMD concluded that the Safeway Fuel Center would best meet the requirement of this
regulation by using CNI enhanced vapor recovery (EVR) Phase I equipment and VST Balance EVR
Phase II equipment with the Veeder-Root Vapor Polisher and Veeder-Root ISD controls. These
two systems are certified by CARB under Executive Orders VR -104 and VR -204 respectively.
As part of the Authority to Construct application review process, BAAQMD performed a Toxic
Risk Screening Analysis, as specified in Regulation 2-5, Table 2-5-1. For a Gasoline Dispensing
Facility that meets the best available control technology for toxics requirement, it must also achieve
a toxic risk screening level of less than ten in one million. The BAAQMD concluded that the
proposed project meets the screening level with a cap on throughput of 25.71 million gallons
annually. As such, the BAAQMD determined that the Safeway Fuel Center would be conditioned
to 25.71 million gallons per year, which would not exceed Health Risk standards per the
BAAQMD's Risk Management Policy.
Planning Commission Resolution No. 2018-21A
On August 2013, and in accordance with state law (California Health & Safety Code and District's
Regulation 2-1-412), BAAQMD distributed Public Notice to the parents or guardians of students
enrolled at McDowell Elementary School and all residences and businesses located within 1,000
feet of the proposed Safeway Fuel Center. The Public Notice stated that a permit application for the
Safeway Fuel Center had been filed with BAAQMD. Individuals and businesses were alerted that
there was a 30 -day period for public response to the proposal. The public comment period on
BAAQMD's notice ended on September 23, 2013. During the public comment period, the
BAAQMD received the following responses:)
• Two emails
• Six voice mails
• One letter from a nearby day care center accompanied by 31 signed form letters
• One petition signed by 21 individuals
One commenter was in favor of the new gas station and the balance were opposed to the project.
The primary concerns were increased traffic, with its associated impacts on air quality, safety, and
parking. Many commenters were also concerned about the increased gasoline vapor emissions and
the proposed gas station's proximity to the McDowell Elementary School and North Bay Children's
Center (preschool). None of the commenters identified any potential compliance issues with
BAAQMD regulations or any deficiency or error in BAAQMD's evaluation of the project.
BAAQMD responded to the comments received during the public comment period by email,
voicemail, or U.S. mail.
After consideration and responding to the comments received during the public comment period,
BAAQMD issued an Authority to Construct permit for the Safeway Fuel Center on October 10,
2013, as a ministerial action under. Regulation 2-1-311. BAAQMD conditioned the Safeway Fuel
Center to a gasoline throughput not to exceed 25.71 million gallons of fuel per year. Issuance of
this permit confirms that BAAQMD reviewed proposed fuel dispensing equipment, considered the
source emitter, recommended specific equipment, and determined that the use of that equipment
would comply with all air quality rules and regulations.
An extension for the Authority to Construct permit was filed by Safeway, Inc. on October 6, 2017.
On November 9, 2017, BAAQMD granted the extension for the Authority to Construct permit; the
Authority to Construct permit issued by BAAQMD will expire on November 9, 2019.
Sensitive Receptors
This discussion regarding facilities at the McDowell Elementary School Campus is intended to
bolster the description contained in the IS/MND. As stated on page 19 of the IS/MND, the nearest
sensitive receptors in proximity to the project site, and their distances from the project's limits of
work, include the North Bay Children's Center located at the northeast corner of South McDowell
and Maria Drive (60 feet), McDowell Elementary School (475 feet) and associated recreational
playfreld (60 feet), and residences along South McDowell Boulevard (80 feet).
McDowell Elementary School is located at 421 South McDowell Boulevard. The outdoor
recreational school facilities include a ball field; playground with adjacent grass area; and an asphalt
blacktop area with basketball courts, tetherball courts, and other outdoor recreational games. The
I Duncan Campbell, BAAQMD, Email correspondence, May 25, 2018.
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school also contains multiple buildings, an asphalt parking lot, and raised garden beds. In addition
to providing education for students in Early Transitional Kindergarten (4 years old) through sixth
grade, the school supports the McDowell Family Resource Center, which offers classes through the
Petaluma Adult School. Some of the classes offered include English as a Second Language,
Computer Applications, Parent Education, and Health Care Education. Additionally, the school
provides after-school care on its campus for McDowell and McKinley students from dismissal until
6:00 pm, in partnership with the Boys & Girls Club of Central Sonoma County.
The North Bay Children's Center is located at 405 South McDowell Boulevard. The facility offers
a half day preschool for children ages 3 to 5, and is open 8:00 am to 3:00 pm, Monday through
Friday. The North Bay Children's Center includes three buildings, an outdoor playground, an
asphalt play area, and raised garden boxes.
The McDowell Elementary School Campus is considered a sensitive receptor location since it
contains people (children and adults) that have an increased sensitivity to air pollution. Schools,
parks, playgrounds, day care centers, preschools and residential homes are all considered sensitive
receptor locations. The school facility and nearby residential units were evaluated as sensitive
receptors by BAAQMD and by the project level Health Risk Assessment, as disclosed in the
IS/MND.
Health Risk Assessment
A number of individuals submitted comments seeking clarification on the Health Risk Assessment
(HRA), primarily with regards to the established thresholds for the creation of a Health Risk,
methodology used in the HRA, and the health risks for each person (student, teacher, resident) from
implementation of the project.
One commenter, Petaluma City Schools, submitted a peer review, performed by ESA, on the HRA
that was prepared by Illingworth & Rodkin. ESA's peer review asserts that there were errors and
omissions in Illingworth & Rodkin's HRA prepared for the project, and that these errors prevented
a proper analysis of the project's impacts on students, staff, and teachers of the schools. ESA's peer
review asserts that the HRA is noncompliant with industry standards, makes inaccurate and
misleading assumptions, and that the toxic air contaminant (TAC) impact is likely a significant
environmental impact.
The following discussion clarifies the thresholds and methodology used in the HRA prepared by
Illingworth & Rodkin, elaborates on the health risks to sensitive receptors from the proposed
project, and addresses specific comments and questions on the HRA raised by the commenters.
BAAQMD Thresholds of Significance for Health Risk Exposure
The HRA prepared by Illingworth & Rodkin relies on the BAAQMD-established thresholds of
significance for local community risk and hazard impacts, which apply to the siting of a new
stationary source emitter (gasoline station). These thresholds are identified in the BAAQMD's
CEQA Air Quality Guidelines established in May 2010, and most recently updated in May 2017.
As detailed in the BAAQMD CEQA Guidelines (pages 2-4 and 2-5), local community risk and
hazard impacts are associated with TACs and PM2.5 because emissions of these pollutants can
have significant health impacts at the local level. If emissions of TACs or fine particulate matter
with an aerodynamic resistance diameter of 2.5 micrometers or less (PM2.5) exceed any of the
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thresholds of significance listed below, the proposed project would result in a potentially significant
health risk impact:
• Non-compliance with a qualified risk reduction plan; or
• An excess cancer risk level of more than 10 in one million, or a non -cancer (i.e., chronic or
acute) hazard index greater than 1.0 would be a cumulatively considerable contribution; or
• An incremental increase of greater than 0.3 micrograms per cubic meter (µg/m3) annual
average PM2.5 would be a cumulatively considerable contribution.
As described on page 2-5 of the BAAQMD CEQA Guidelines, a project would have a cumulative
considerable impact if the aggregate total of all past, present, and foreseeable future sources within
a 1,000 foot radius from the fence line of a stationary source emitter plus the contribution from the
project, exceeds the following:
• Non-compliance with a qualified risk reduction plan; or
• An excess cancer risk levels of more than 100 in one million or a chronic non -cancer hazard
index (from all local sources) greater than 10.0; or
• 0.8 µg/m3 annual average PM2.5.
Health Risk Assessment Methodology
The HRA evaluated the exposure of sensitive receptors to substantial air quality pollutants based
on an annual fuel throughput of approximately 8.5 million gallons, which is approximately one-
third of the throughput conditioned by the BAAQMD. The throughput was based on Safeway's
anticipated maximum demand, which is derived from market research and data from other operating
Safeway Fuel Centers.
As stated on page 2 of the HRA, emissions of toxic pollutants potentially associated with the project
were estimated using various emissions models. Concentrations of these pollutants in the ambient
air were estimated using the U.S. EPA ISCST3 dispersion model. The ISCST3 dispersion model is
a BAAQMD-recommended model for use in modeling analysis of these types of emission activities
for CEQA projects. Health risks were evaluated for a hypothetical maximum exposed individual
(MEI) located at the maximum impact of the sensitive receptor. The hypothetical MEI is an
individual assumed to be located where the highest concentrations of air pollutants associated with
Project emissions are predicted to occur, based on air dispersion modeling. As described in the
HRA, increased cancer risks were calculated using the modeled annual concentrations and
BAAQMD recommended risk assessment methods for an infant exposure (3rd trimester through 2
years of age), student exposure (9 years) and for adult exposure.
As stated on page 3 of the HRA, the State of California Office of Environmental Health Hazard
Assessment (OEHHA) and CARB develop recommended methods for conducting health risk
assessments. The most recent OEHHA risk assessment guidelines were published in February of
2015. These guidelines incorporate substantial changes designed to provide for enhanced protection
of children, as required by State law. CARB has provided additional guidance on implementing
OEHHA's recommended methods. The HRA for this project used the 2015 OEHHA risk
assessment guidelines and CARB guidance. BAAQMD has adopted recommended procedures for
applying the 2015 OEHHA guidelines as part of Regulation 2, Rule 5: New Source Review of Toxic
Air Contaminants. Exposure parameters from the OEHHA guidelines and the recent BAAQMD
HRA Guidelines were used in the HRA evaluation.
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Breathing Rate Factor
The HRA followed BAAQMD Air Toxics New Source Review (NSR) Program Health Risk
Assessment (HRA) Guidelines (December 2016) in evaluating health impacts at sensitive receptors
(see page 3 of HRA). The commenter is correct in that BAAQMD HRA guidance (section 2.2) for
gasoline dispensing facilities specifies using older 2003 & 2009 OEHHA risk assessment guidance.
For student (child) exposure, the only difference between the current BAAQMD guidance and the
previous 2003 & 2009 OEHHA guidance is in the value used for a child breathing rate. The current
BAAQMD guidance specifies a child breathing rate of 572 L/kg-day while the 2003 OEHHA
guidance specifies a breathing rate of 581 L/kg-day.
The HRA focused on identifying the maximum health impacts that would occur from
implementation of the project, both during construction and operation. The maximum health
impacts were identified for a child located at the North Bay Children's Center, as opposed to an
adult working at the school (teacher) or an adult or child residing in the adjacent neighborhood. An
adult exposure would occur for a longer duration (30 years instead of 9 years) at a lower age
sensitivity factor (ASF =1 for adult and 3 for a child/student) and at a lower breathing rate (261
L/kg for an adult instead of 572 L/kg for a child). Thus, the teacher cancer risk would be below
established thresholds, 70% that of a student and similarly less than significant.
The HRA used a breathing rate of 572 L/kg for a child (see Table 1 on page 5 of HRA). In their
memo dated May 8, 2018, Illingworth & Rodkin calculated health risk assuming a breathing rate
of 581 L/kg-day for a child. Illingworth & Rodkin determined that the school child cancer risk from
benzene emissions from the proposed gasoline dispensing facility would increase by 0.01 in one
million when using the 2003 OEHHA breathing rate of 581 L/kg-day compared to the current
BAAQMD guidance. That is, the contribution to increased cancer risk would change from 0.39 in
one million (BAAQMD Guidelines 2016) to 0.40 in one million (2003 & 2009 OEHHA guidance).
The change in cancer risk from this adjustment in the child breathing rate is negligible and impacts
remain well below the ten in one million threshold. Thus, applying OEHHA's breathing rate does
not change the conclusions of the HRA, nor alter any of the conclusions presented in the IS/MND.
Release Height Factor
Regarding construction -related health risk impacts, there have been various methods applied to
address dispersion modeling of construction sites. The HRA (page 8) used a release height of 6
meters (20 feet) to reflect the elevated exhaust stacks of equipment plus the plume rise associated
with the exhaust momentum and thermal buoyancy. The use of a 6 -meter release height is consistent
with release heights used by the CARB when modeling diesel particulate matter (DPM) health risk
impacts from construction activities. In describing the methodology used for modeling of DPM
emissions from area sources, CARB states "Sensitivity studies have shown that there is an initial
plume rise from the equipment due to upward buoyancy and momentum. The release heights of
these area sources were determined to be 5 — 10 meters depending on equipment type during
operation times." Thus, use of a 6 -meter area source release height is considered appropriate and
consistent with CARB regulatory modeling.
Regarding release heights for passenger truck and light-duty vehicles, for modeling exhaust and
fugitive PM2.5 dust emissions from vehicles on nearby roads, the emission release height for heavy-
duty vehicles (trucks) was 3.4 meters (11 feet) and the release height for light-duty vehicles was
1.3 meters (4.3 feet), as detailed on page 13 of the HRA. These values are based on release heights
recommended by the US Environmental Protection Agency for use in modeling vehicle PM2.5
emissions and are representative of the release heights from the mix of different types of trucks and
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other vehicles that comprise the general categories of heavy-duty and light-duty vehicles used in
construction.
Receptor Height Factor
The HRA used a receptor height of 1.5 meters for the nearby residences and a receptor height of
1.0 meter for children at the daycare and school areas. While the BAAQMD's Recommended
Methods for Screening and Modeling Local Risks and Hazards (May 2012) states that "the default
value is assumed to be 0.0 in (i.e., ground -level receptors), the user may enter 1.5 meter to represent
the height of an average adult." That is, use of a representative breathing height of a representative
individual is appropriate for use in calculating health risks. In this case, as used in the HRA, an
average breathing height of 1.5 meters for an adult is acceptable. For a child, use of 1.0 -meter
breathing height is a reasonable assumption for a child sitting or standing in the school area. It
would be unreasonable to assume that the children at the school were at a breathing height of 0.0
meters (i.e., lying down on the floor).
In their memo dated May 8, 2018, Illingworth & Rodkin calculated health risk assuming a 0.0 -
meter breathing height. Use of a 0.0 -meter receptor height instead of a 1.0 -meter receptor height
would result in benzene concentration being increased by a small amount (i.e., 0.0002 micrograms
per cubic meter), such that the computed cancer risk would not change. Therefore, the result of
under this scenario (throughput of 25.71 million gallons per year, with a child receptor height of
0.0 meters) as opposed to the previously calculated 1.0 -meter receptor height, does not change the
conclusions of the HRA, nor alter any of the conclusions presented in the IS/MND.
Throughput Volume
In their memo dated May 8, 2018, Illingworth & Rodkin estimated health risks assuming a
throughput of 25.71 million gallons per year, the amount conditioned by the BAAQMD, as opposed
to the 8.5 million gallons per year Safeway anticipates using and which was analyzed in the HRA.
Under this scenario (throughout of 25.71 million gallons per year), the operational risks at the
school would increase by a factor of 3 from 0.69 chances per million to 2.04 chances per million
such that the overall excess cancer risk, including project construction (5.8 per on million), would
be 7.9 chances per million. This remains below the excess cancer risk of 10 per one million
threshold and would similarly have a less than significant impact. This corroborates the conclusion
of BAAQMD's Toxic Risk Screening Analysis that was conducted as part of the Authority to
Construct Permit review, which determined that operation of a gasoline station with an annual
throughput of 25.71 million gallons would not pose a health risk to the community. Even with a
throughput of up to 25.71 million gallons per year, the conclusions of the HRA would not change.
Therefore, the conclusions related to health risk as presented in the IS/MND, that the proposed
gasoline station would not result in health risk impacts, would not be altered.
Methodology Summary
In summary, Illingworth & Rodkin appropriately performed the Health Risk Assessment in
accordance with industry standards and acceptable practices and in line with guidance provided by
regulatory agencies including BAAQMD, OEEHHA, and GARB. In response to comments
received, Illingworth & Rodkin performed additional modeling that incorporated suggested
adjustments to the methodology, as suggested by ESA's peer review letter, including: a slightly
higher child breathing rate, a child receptor height of 0.0 meters, and a throughput of 25.71 million
gallons per year. Even with the adjustments to the methodology as suggested by ESA's peer review
comment letter, the resulting health risk level remain below established thresholds and air quality
impacts are therefore considered to be less than significant.
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Community Health Risk Summar
The discussion below summarizes information contained in the HRA to clarify existing health risks
without the project, new health risks introduced by the project, and why the health risks are
considered less than significant under CEQA. The thresholds for health risk, at both the individual
and cumulative level are described above under "BAAQMD Thresholds of Significance for Health
Risk Exposure."
The HRA evaluated the project's potential to increase health risks to nearby sensitive receptors
from construction and operation of the project. For the short-term exposures associated with
construction, a one-year exposure and higher exposure factors (i.e., age sensitivity factors and
breathing rate for infants or children) were used for the health risk calculation.
Table 2 in the HRA (page 9) identifies the exposure risks associated with construction activities for
the maximally exposed individual (MEI), which consists of a child at the North Bay Children's
Center (preschool) and an infant and adult inhabiting a residence along South McDowell Boulevard
south of Maria Drive. All other nearby sensitive receptors would be exposed to health risks below
those presented in Table 2, and are therefore not discussed in the HRA. Results in the HRA
predicted excess cancer risks, annual PM2.5 concentrations, and the Hazard Index to be below the
BAAQMD significance thresholds for each sensitive receptor. Therefore, as presented in the
IS/MND, the project would have a less than significant impact with respect to community health
risks caused by construction activities of the Safeway Fuel Center project.
Operational community risk impacts identified in the HRA were based on traffic generated by the
proposed project (traffic traveling to/from project site, traffic idling at project site, truck traffic
accessing the site for importing fuel) and evaporative emissions from gasoline (vehicle fueling,
transfer and storage of gasoline). Using the maximum modeled diesel particulate matter (DPM),
total organic gases (TOG), and benzene concentrations, individual cancer risks were computed
using the most recent methods recommended by BAAQMD and OEHHA that include nearly
continuous exposures with adjustments for infants and children. Cancer risks were calculated for a
30 -year exposure assuming constant emissions at 2019 levels over the entire 30 -year period for
residences and a 9 -year period for school children (see page 13 of HRA). The risks were identified
as a worst-case exposure for each person (be it a resident, infant or adult, or a child attending
school). The community risk impacts are not additive (e.g., a child who attends North Bay
Children's Center and lives at a residence along South McDowell Boulevard south of Maria Drive
would either be exposed as a resident or a child attending school, not both). This is because each
receptor is modeled under constant exposure for 30 -years in the case of an adult, and 9 -years in the
case of the child.
Table 3 in the HRA (page 14) displays the operational health risk impacts. Table 3 also identifies
the combined health risks from construction activity and operation of the proposed project.
(Additional details regarding the assumptions used in the HRA for the combined health risks from
construction and operation, are presented in Illingworth & Rodkin's Memo dated June 6, 2018 in
Appendix B.) Table 3 of the HRA summarizes impacts from the proposed project (considered a
single -source emitter 2) at the individual level: Residential (a person inhabiting a residence on South
McDowell Boulevard) and School Child (a child attending the North Bay Children's Center). The
excess cancer risk, maximum annual PM2.5 concentration, and Hazard Index were compared with
2 Single source emitters are individually permitted facilities, such as the proposed Safeway Fuel Center.
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BAAQMD's thresholds related to single sources. The results in the HRA (Table 3) predicted excess
cancer risks, annual PM2.5 concentrations, and the Hazard Index to be below the BAAQMD
significance thresholds for each sensitive receptor. Therefore, the project would have a less than
significant impact with respect to community risk caused by construction and operation of the
proposed project.
Additionally, the HRA (Table 3) identifies other sources of TACs or PM2.5 within 1,000 feet of
the project site (cumulative sources 3): traffic on South McDowell and traffic on U.S. 101. (Note:
The health risks associated with these sources demonstrate the existing risks (without the project)
to children at the school and people inhabiting the residences along South McDowell Boulevard.)
Table 3 also demonstrate the effects of cumulative sources on the identified sensitive receptors
(Residential and School Child) combined with traffic along S. McDowell Boulevard and traffic
along US 101. The excess cancer risk, maximum annual PM2.5 concentration, and Hazard Index
were compared with BAAQMD's thresholds related to cumulative sources. The results in the HRA
(Table 3) predicted cumulative excess cancer risks, annual PM2.5 concentrations, and the Hazard
Index to be below the BAAQMD significance thresholds for each sensitive receptor. Therefore, as
concluded in the IS/MND, the project would have a less than significant impact with respect to
community risk caused by construction and operation of the proposed project, when combined with
other sources of TACs and PM2.5 within 1,000 feet of the project site.
Conclusion
As explained herein, based on the record, the City finds that all potentially significant impacts
related to health risk have been adequately addressed in the IS/MND and this Response to
Comments. As such, none of the conclusions of the air quality discussion in the Draft IS/MND have
changed, and no further analysis is necessary.
Master Response to Comments on Traffic
This master response has been prepared to address issues that were raised by commenters regarding
trip generation and pedestrian safety associated with the proposed Safeway Fuel Center project.
This response relies on information contained in the Traffic Impact Study (TIS) prepared by TJKM
Transportation Consultants for the Safeway Fuel Center in August 13, 2014 and the Technical
Memorandum (TM) updating the Safeway Fuel Center TIS, prepared by CHS Consulting Group in
March 16, 2018; both of these documents were included and referenced in the Public Draft
IS/MND. Additionally, the following is informed by a memo from CHS, dated June 6, 2018,
responding to comments raised during the public review period relating to pedestrian facilities and
safety.
Safeway Fuel Center Trip Generation Methodology
The 2014 TIS and the 2018 Technical Memorandum use the same methodology to estimate trip
generation. The 2014 TIS estimated the Project's trip generation based on the Institute of
Transportation Engineers (ITE) trip rates published in Trip Generation, 9t" Edition and empirical
data from field surveys of two existing Bay Area Safeway gas stations in Pleasant Hill and
Campbell. The Pleasant Hill and Campbell gas stations are similar to the proposed project in terms
of size, hours of operation, circulation layout, adjacent grocery store size, and local setting (in a
shopping plaza).4
3 Cumulative source emitters consists of the combination of individually permitted facilities within 1,000 feet along with other area source emissions
such as vehicles exhaust from roadways.
4 Page 12 of the 2014 Traffic Study prepared by TJKM , August 13, 2014.
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The 2018 Traffic Memo (page 3) clarifies that the 2014 TIS did not apply industry standard trip
reductions for commercial uses on or formerly occupying the Project site, nor did the 2014 TIS
apply reductions for internal, pass by, or diverted trips. Definitions of internal, pass -by, and diverted
trips are provided in the 2018 Memo in an effort to demonstrate that the analysis is conservative
and precludes industry standard trip reductions for gas station projects. The Traffic Memo explains
that internal, pass by, and diverted trips could result in the following reduction (but were not
applied):
• 39 percent of the trips to the Fuel Center will be internal trips
• 25 percent of the trips to the Fuel Center will be pass -by trips
• 25 percent of the trips to the Fuel Center will be diverted trips
® 11 percent of the trips to the Fuel Center will be "new" trips
The 2014 TIS and the 2018 Traffic Memo do not take any reductions for internal, pass by, and/or
diverted trips. The trip generation of the proposed Safeway Fuel Center project consists of 210
weekday a.m. peak hour trips, 276 p.m. peak hour trips, and 336 Saturday afternoon peak hour trips,
all of which are considered and analyzed in the level of service analysis of the 2018 TM. While the
internal, pass -by, and diverted vehicle trips were identified in the 2018 TM, these deductions were
not taken in the 2018 analysis.
Pedestrian Access
Commenters expressed concern regarding pedestrian safety at the intersection of South McDowell
and Maria Drive. Presently, this intersection is signalized, contains sidewalk on both sides and
contains pedestrian improvements including striping for pedestrian crosswalk, pedestrian signals
and curb ramps. The crosswalk distance is approximately 50 feet when crossing Maria Drive and
80 feet when crossing S. McDowell Boulevard.
To understand the existing collision and accident frequency at this intersection, CHS reviewed
collision data from the Statewide Integrated Traffic Records System (SWITRS) between 2012 to
2016 for the intersection of South McDowell Boulevard and Maria Drive. Results of collision data
are detailed in CHS's memo dated June 6, 2018.
CHS concluded that pedestrian counts at the Maria Drive/McDowell Boulevard intersection
indicate a low level of pedestrian activity during the a.m., midday, and p.m. peak periods, which is
reflective of a free flow level of service with no impedances to pedestrian movements during all
peak periods. The five-year collision history at the Maria Drive/McDowell Boulevard intersection
indicates a low rate of collisions over the last five-year reporting period with four vehicle collisions
per year on average. CHS concluded that there were no patterns of pedestrian involved collisions
that would suggest a safety concern at the Maria Drive/McDowell Boulevard intersection.
The City's Safe Routes to School Plan provides recommendations for pedestrian safety at the
McDowell Boulevard/Maria Drive intersection. The suggestions include minor sidewalk repairs,
widening the sidewalks, and including a pedestrian phase at the signal. Consistent with these
recommendations, as a condition of approval, the proposed project would be required to achieve
the following: 1) replace the existing sidewalks, driveways, and curb ramps that are broken or
cracked along the project site frontage to Maria Drive and South McDowell Boulevard; 2) install a
new, accessible, and directional pedestrian ramp at the McDowell/Maria intersection; and 3) install
a pedestrian crossing warning sign at the proposed driveway entrances.
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With the conditions of approval, pedestrian facilities at the intersection of Maria Drive/McDowell
Boulevard will be improved. There are no significant impacts identified related to pedestrian access,
safety concerns or lack of connectivity. Therefore, the MND concluded that impacts of the proposed
project to transit, bicycle and pedestrian facilities would be less than significant.
RESPONSE TO COMMENTS SUMMARY
The City of Petaluma carefully reviewed the information developed through the response to
comments process and determined that the project does not meet any of the conditions under
CEQA Section 15073.5. Therefore, the recirculation of a revised IS/MND or the preparation of an
Environmental Impact Report (EIR) is not required. Consistent with the CEQA Guidelines, this
Response to Comments document clarifies the information and analyses in the IS/MND.
The City of Petaluma will consider the Public Draft IS/MND, together with this Response to
Comments document, prior to making a decision on the IS/MND and the proposed project.
REFERENCES
The following materials are incorporated by reference and included as attachments to the June 26,
2018 Planning Commission staff report.
• Comment Letters
• Illingworth & Rodkin Response to Comments, May 8, 2018
• Illingworth & Rodkin Response to Follow Up Comments, June 6, 2018
• CHS Technical Memo, June 6, 2018
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