HomeMy WebLinkAboutRESOLUTION 2024-121 N.C.S. 09/16/2024 Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
Resolution No. 2024-121 N.C.S.
of the City of Petaluma, California
RESOLUTION OF THE CITY COUNCIL OF THE CITY OF PETALUMA
AUTHORIZING STAFF TO PREPARE A FINAL ENVIRONMENTAL IMPACT REPORT FOR THE
CREEKWOOD HOUSING PROJECT
WHEREAS, on September 10, 2024, after hearing and considering staff and public comments regarding the
Draft Environmental Impact Report (DEIR) for the Creekwood Housing Project (Project), the Planning
Commission of the City of Petaluma voted to recommend that City Council direct staff to proceed with
preparation of the Final Environmental Impact Report (FEIR) for the Project; and
WHEREAS, the Planning Commission further recommended that the Planning Manager provide a report out
to the Commission on the Final EIR in lieu of coming back before the Commission and that the FEIR proceed
directly to City Council for consideration to certify; and
WHEREAS, a duly noticed hearing was held on September 16, 2024 for the City Council to consider
information presented by staff and to receive public comment regarding the DEIR; and
WHEREAS, at the September 16, 2024 hearing, the City Council considered staff, public, and agency
comments on the Project,the staff report,the projects history, and the DEIR including all attachments, along with
the recommendation received from the Planning Commission to direct preparation of the Final EIR; and
WHEREAS, the DEIR prepared for the Project has been prepared in full compliance with the California
Environmental Quality Act("CEQA") and local CEQA Guidelines.
NOW, THEREFORE,BE IT RESOLVED,by the City Council of the City of Petaluma as follows:
1. The above recitals are hereby declared to be true and correct and are incorporated into the Resolution as
findings of the City Council.
2. Staff are hereby authorized and directed to prepare the FEIR for the Project in accordance with the City's
Environmental Review Guidelines and the requirements of CEQA.
Under the power and authority conferred upon this Council by the Charter of said City.
REFERENCE: I hereby certify the foregoing Resolution was introduced and adopted by the Approved as to
Council of the City of Petaluma at a Regular meeting on the 16' day of DocuSigned by: form:
September 2024,by the following vote:
5
i Attorney
AYES: McDonnell,Barnacle,Cader Thompson,Healy,Nau,Pocekay,Shribbs
NOES: None
ABSENT: None
ABSTAIN: None
DocuSigned by: Signed by:
ATTEST:
City Clerk Mayor
Resolution No. 2024-121 N.C.S. Pagel
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2 . EXECUTIVE SUMMARY
2.1 INTRODUCTION
The Executive Summary chapter of the EIR provides an overview of the proposed project (see
Chapter 3, Project Description, for further details) and provides a table summary of the
conclusions of the environmental analysis provided in Chapters 4.1 through 4.4. This chapter also
summarizes the alternatives to the proposed project that are described in Chapter 6, Alternatives
Analysis, and identifies the Environmentally Superior Alternative. Table 2-1 contains the
environmental impacts associated with the proposed project, the significance of the impacts, the
proposed mitigation measures for the impacts, and the significance of the impacts after
implementation of the mitigation measures. Environmental issues dismissed in the Initial Study
are discussed in Chapter 4.0, Introduction to the Analysis, of this EIR.
2.2 SUMMARY DESCRIPTION OF THE PROPOSED PROJECT
The project site consists of two parcels totaling approximately 5.2 acres that abut the eastern
boundary of Casa Grande Road in the City of Petaluma. The 280 Casa Grande Road parcel
contains an existing residence and undeveloped land covered in non-native grasses. The 270
Casa Grande Road parcel contains an existing residence, several associated outbuildings, a
landscaped backyard, and a small orchard in the northeast corner of the project site, within a
depressed area, near Adobe Creek (Creek). The Creek and its associated riparian corridor forms
the eastern boundary of the project site (Assessor's Parcel Number [APN] 017-410-042). The
remaining portions of the 270 Casa Grande Road parcel are generally characterized by grasses
that are routinely mowed or grazed to reduce fire hazards. According to the City's General Plan,
the project site is designated Medium Density Residential. The project site is zoned Residential
(R4).
The project site is bound to the west by Casa Grande Road and to the east by the Creek and its
associated riparian corridor. The project site's northern boundary abuts the Casa Grande Senior
Apartments. A single-family residence is located further to the north. A single-family residential
neighborhood is located to the east, across the Creek, with access from Spyglass Road. Further
east from the single-family residences is a multifamily neighborhood, to which Lakeville Circle
provides access. The project site's southern boundary abuts the recently completed Casa Grande
Subdivision. An existing single-family residential neighborhood is located further to the south and
abuts the southern property line of the Casa Grande Subdivision site. Casa Grande High School
and Crinella Park are located to the west, across Casa Grande Road, from the project site. It
should be noted that Sonoma Mountain High School, an alternative high school in the City, is also
located on the Casa Grande High School campus.
Project Description
The proposed project would include demolition of the on-site residence at 280 Casa Grande
Road, retention of the existing residence at 270 Casa Grande Road, and development of 59
dwelling units. The proposed dwelling units would be constructed across three blocks. Block 1
units would be arranged in tri-plex configurations. Units within Blocks 2 and 3 would primarily be
arranged in duet unit configurations. Each dwelling unit would include Usable Open Space (UOS)
in the form of semi-private or private yard areas. In addition,the project would include construction
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of various on-site road and utility improvements, landscaping, and a new off-site public multi-use
pathway, with a pedestrian bridge connection over the Creek.
The project would require City approval of a Vesting Tentative Parcel Map, Site Plan and
Architectural Review, and a Tree Removal Permit. In addition, the project would require other
approvals from responsible and trustee agencies, including, but not necessarily limited to, CDFW
approval of a 1600 Lake and Streambed Alteration Agreement and Regional Water Quality
Control Board (RWQCB) approval of a Section 401 Water Quality Certification, a National
Pollutant Discharge Elimination System (NPDES) Construction and MS4 General Permit.
Project Approvals
The proposed project would require City of Petaluma approval of the following entitlements:
• Vesting Tentative Parcel Map;
• Site Plan and Architectural Review; and
• Tree Removal Permit.
In addition to the above City approvals, the proposed project could require the following
approvals/permits from other responsible and trustee agencies:
• Section 401 Water Quality Certification (RWQCB- San Francisco Bay Region);
• Section 1600 Lake and Streambed Alteration Agreement (CDFW-Region 3);
• NPDES Construction General Permit (RWQCB -San Francisco Bay Region); and
• NPDES Phase II MS4 General Permit (RWQCB- San Francisco Bay Region).
While not a State Responsible Agency, the proposed project could require issuance of a Clean
Water Act Section 404 permit by the U.S. Army Corps of Engineers, if the project would result in
discharges of fill below the Ordinary High-Water Mark of the Creek.
Please refer to Chapter 3, Project Description, of this EIR for a detailed description of the
proposed project and entitlements, as well as a full list of the project objectives.
2.3 ENVIRONMENTAL IMPACTS AND PROPOSED AND
RECOMMENDED MITIGATION
Under CEQA, a significant effect on the environment is defined as a substantial, or potentially
substantial, adverse change in any of the physical conditions within the area affected by the
project, including land, air, water, mineral, flora, fauna, ambient noise, and objects of historic or
aesthetic significance. Mitigation measures must be implemented as part of the proposed project
to reduce potential adverse impacts to a less-than-significant level. Such mitigation measures are
noted in this EIR and are found in the following technical chapters: Biological Resources;
Greenhouse Gas (GHG) Emissions; Hydrology and Water Quality; and Transportation.
Additionally, the Initial Study prepared for the proposed project (see Appendix A) includes
mitigation measures that must be implemented as part of the proposed project associated with
the following resource areas: Cultural Resources; Geology and Soils; Hazards and Hazardous
Materials; Noise; and Tribal Cultural Resources. The mitigation measures required for the
proposed project, as presented in this EIR and the Initial Study, will form the basis of the Mitigation
Monitoring and Reporting Program. Any impact that remains significant after implementation of
mitigation measures is considered a significant and unavoidable impact. Environmental issues
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dismissed in the Initial Study are further discussed in Chapter 4.0, Introduction to the Analysis, of
this EIR.
A summary of the impacts identified in each technical chapter (Chapters 4.1 through 4.4) of the
EIR, as well as the Initial Study (see Appendix A) is presented in Table 2-1 included at the end of
this chapter. In addition, Table 2-1 includes the level of significance of each impact, any mitigation
measures required for each impact, and the resulting level of significance after implementation of
mitigation measures for each impact.
2.4 SUMMARY OF PROJECT ALTERNATIVES_
The following section presents a summary of the alternatives evaluated in this EIR for the
proposed project, which include the following:
• No Project (No Build)Alternative;
• No Bridge Alternative; and
• Affordable Housing Alternative.
For a more thorough discussion of project alternatives that were evaluated in this EIR, including
alternatives considered but dismissed, please refer to Chapter 6, Alternatives Analysis.
No Project (No Build) Alternative
The No Project (No Build) Alternative assumes that the project site would remain in its current
condition and would not be developed. As described in this EIR, the 280 Casa Grande Road
(Assessor's Parcel Number [APN] 017-040-016) parcel contains an existing residence and
undeveloped land covered in grasses. The 270 Casa Grande Road (APN 017-040-051) parcel
contains an existing residence, several associated outbuildings, a landscaped backyard, and a
small orchard in the northeast corner of the project site, within a depressed area, near the Creek,
which forms the eastern boundary of the project site. The remaining portions of the 270 Casa
Grande Road parcel are generally characterized by grasses that are routinely mowed or grazed
to reduce fire hazards. Grazing of both parcels is conducted by several sheep owned and cared
for by the current 270 Casa Grande Road property owner.
Although none of the impacts identified for the proposed project would occur under the No Project
(No Build) Alternative, the No Project (No Build) Alternative would not meet any of the project
objectives.
No Bridge Alternative
The No Bridge Alternative would include demolition of the on-site residence at 280 Casa Grande
Road, retention of the existing residence at 270 Casa Grande Road, development of 59 dwelling
units, construction of various on-site road and utility improvements, landscaping, and a new off-
site public multi-use pathway. However, the bridge connection over the Creek for the public multi-
use pathway would not be developed under the No Bridge Alternative. Given that the majority of
on- and off-site improvements required under the No Bridge Alternative would still be developed,
the Alternative would still require a Vesting Tentative Parcel Map, Site Plan and Architectural
Review, and a Tree Removal Permit. In addition, because the No Bridge Alternative would
generally result in similar development of the proposed project, Objectives#1 through #3, #6, and
#7 would be fully met. However, because the bridge connection would not be developed Objective
#4 would only be partially met, and Objective #5 would not be met.
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Relative to the proposed project, the No Bridge Alternative would result in fewer impacts related
to biological resources and hydrology and water quality and greater impacts related to GHG
emissions and transportation. The significant and unavoidable impacts to GHG emissions and
transportation that were identified for the proposed project would remain under the No Bridge
Alternative. Given that development of the No Bridge Alternative would involve a similar
disturbance footprint and development of the same land uses as compared to the proposed
project, impacts associated with the other CEQA topics in which the proposed project could have
significant impacts, as identified in the Initial Study (cultural resources, geology, hazards, noise,
and tribal cultural resources), would be anticipated to be similar in scale under the No Bridge
Alternative.
Affordable Housing Alternative
Under the Affordable Housing Alternative, the 59 residential units proposed to be developed on-
site would be offered as affordable housing. All other on- and off-site improvements proposed as
part of the project, including demolition of the on-site residence at 280 Casa Grande Road,
retention of the existing residence at 270 Casa Grande Road, construction of various on-site road
and utility improvements, landscaping, and a new off-site public multi-use pathway, with a bridge
connection over the Creek, would remain the same. Given that all on- and off-site improvements
required under the Affordable Housing Alternative would be the same as the proposed project,
the Alternative would still require a Vesting Tentative Parcel Map, Site Plan and Architectural
Review, and a Tree Removal Permit. In addition, because the Affordable Housing Alternative
would generally result in similar development of the proposed project, all project objectives would
be met.
The Affordable Housing Alternative would result in fewer impacts related to GHG emissions and
transportation, and similar impacts related to biological resources and hydrology and water
quality. Given that development of the Affordable Housing Alternative would involve the same
disturbance footprint and development of the similar land uses as compared to the proposed
project, impacts associated with the other CEQA topics in which the proposed project could have
significant impacts, as identified in the Initial Study (cultural resources, geology, hazards, noise,
and tribal cultural resources), are anticipated to be similar in scale under the Affordable Housing
Alternative.
Environmentally Superior Alternative
An EIR is required to identify the environmentally superior alternative from among the range of
reasonable alternatives that are evaluated. Section 15126(e)(2) of the CEQA Guidelines requires
that an environmentally superior alternative be designated and states, "If the environmentally
superior alternative is the `no project' alternative, the EIR shall also identify an environmentally
superior alternative among the other alternatives." In this case, the No Project (No Build)
Alternative would be considered the environmentally superior alternative, because the project site
is assumed to remain in its current condition under the alternative. Consequently, impacts
resulting from the proposed project would not occur under the Alternative.
The No Project (No Build) Alternative would not meet any of the project objectives. Both the No
Bridge Alternative and the Affordable Housing Alternative would meet most project objectives. As
previously noted, the No Bridge Alternative would fully meet Objectives #1 through #3, #6, and
#7. However, because the bridge connection would not be developed, Objective #4 would only
be partially met, and Objective #5 would not be met. The Affordable Housing Alternative would
meet all objectives.
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The No Bridge Alternative could result in greater impacts than the proposed project related to
GHG emissions and transportation; fewer impacts related to biological resources and hydrology
and water quality, and similar impacts to the proposed project for cultural resources, geology and
soil, hazards and hazardous materials, noise, and tribal cultural resources. The Affordable
Housing Alternative would result in fewer impacts related to GHG emissions and transportation,
and similar impacts to the proposed project for biological resources, cultural resources, geology
and soil, hazards and hazardous material, hydrology and water quality, noise, and tribal cultural
resources.
Based on the above, the Affordable Housing Alternative would be considered the environmentally
superior alternative to the proposed project.
2.5 AREAS OF KNOWN CONTROVERSY
Areas of controversy that were identified in NOP comment letters, and are otherwise known for
the project area, include the following:
• Concerns related to special-status wildlife species, such as California coast steelhead,
Pacific salmon, and migratory birds protected under the federal Migratory Bird Treaty Act;
special-status plant species; and designated critical habitat;
• Potential impacts to Adobe Creek and associated riparian habitat;
• Increased potential for flooding due to increases in impervious surface area;
• Concerns related to increases in traffic and vehicle miles traveled;
• Insufficient quality of Ely Boulevard in the project vicinity;
• Potential impacts to emergency evacuation routes;
• Safety concerns related to the lack of sidewalks in the vicinity of the proposed project;
• Concerns related to access to transit connections, types of transit connections, and the
connection between the project site and nearby activity centers;
• Aesthetic impacts of building the proposed bridge across the Creek;
• Increased traffic noise, as well as increases in pedestrian noise along the proposed bridge
across the Creek;
• Inadvertent discovery of Native American resources and/or human remains; and
• Inconsistency with City goals to develop housing in central Petaluma.
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Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
4.1. Biological Resources
4.1-1 Have a substantial adverse S 4.1-1 Prior to initial ground-disturbing activities, special- LS
effect, either directly or status plant surveys shall be conducted by a qualified
through habitat modifications, biologist in areas proposed for disturbance in
on special-status plant accordance with the USFWS Guidelines for
species. Conducting and Reporting Botanical Inventories for
Federally Listed, Proposed, and Candidate Plants,
the CNPS Botanical Survey Guidelines of the
California Native Plant Society, and CDFW Protocols
for Surveying and Evaluating Impacts to Special
Status Native Plant Populations and Natural
Communities. A report summarizing the results of the
special-status plant surveys shall be submitted for
review and approval to the City of Petaluma
Community Development Department. If special-
status plant species are not found, further mitigation
shall not be required.
If special-status perennial species are found within
the proposed impact area, such as Sanford's
arrowhead, the plants shall be dug up and
transplanted into a suitable avoided area on-site (or
elsewhere as appropriate to facilitate greatest
success of transplanting) prior to construction. If the
plant found is an annual, such as Pacific Grove
clover, then mitigation shall consist of collecting
seed-bearing soil and spreading it into a suitable
constructed wetland at a mitigation site. If special-
status plants would be impacted, as determined by a
qualified biologist, a mitigation plan shall be
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
developed and submitted for review and approval to
the City of Petaluma and California Department of
Fish and Wildlife (CDFW). Mitigation for the
transplantation and/or establishment of rare plants
shall result in no net loss of individual plants after a
five-year monitoring period.
4.1-2 Have a substantial adverse S 4.1-2(a) If feasible, initial ground-disturbing activities LS
effect, either directly or associated with the proposed project (e.g., grading,
through habitat modifications, vegetation removal, staging) shall take place
on western bumble bee. between September 1 and March 31 (i.e., outside the
colony active period) to avoid potential impacts on
western bumble bee. If completing all initial ground-
disturbing activities between September 1 and March
31 is not feasible, then at a maximum of 14 days prior
to the commencement of construction activities, a
qualified biologist with 10 or more years of
experience conducting biological resource surveys
within California shall conduct a preconstruction
survey for western bumble bees in the area(s)
proposed for impact.
The survey shall occur during the period from one
hour after sunrise to two hours before sunset, with
temperatures between 65 degrees Fahrenheit and 90
degrees Fahrenheit, with low wind and zero rain. If
the timing of the start of construction makes the
survey infeasible due to the temperature
requirements, the surveying biologist shall select the
most appropriate days based on the National
Weather Service seven-day forecast and shall survey
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
at a time of day that is closest to the temperature
range stated above. The survey duration shall be
commensurate with the extent of suitable floral
resources (which represent foraging habitat) present
within the area proposed for impact, and the level of
effort shall be based on the metric of a minimum of
one person-hour of searching per three acres of
suitable floral resources/foraging habitat. A
meandering pedestrian survey shall be conducted
throughout the area proposed for impact in order to
identify patches of suitable floral resources. Suitable
floral resources for western bumble bee include
species in the following families: Asteraceae,
Fabaceae, Rhamnaceae, and Rosaceae, as well as
plants in the genera Eriogonum and Penstemon.
At a minimum, preconstruction survey methods shall
include the following:
• Search areas with floral resources for
foraging western bumble bees. Observed
foraging activity may indicate a nest is
nearby, and therefore, the survey duration
shall be increased when foraging western
bumble bees are present,-
If western bumble bees are observed, watch
any special-status western bumble bees
present and observe their flight patterns.
Attempt to track their movements between
foraging areas and the nest,
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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270 and 280 Casa Grande Road Creekwood Housing Development Project
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Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
• Visually look for nest entrances. Observe
burrows, any other underground cavities,
logs, or other possible nesting habitat;
• If floral resources or other vegetation
preclude observance of the nest, small areas
of vegetation may be removed via hand
removal, line trimming, or mowing to a height
of a minimum of four inches to assist with
locating the nest,-
Look for concentrated western bumble bee
activity;
• Listen for the humming of a nest colony,and
• If western bumble bees are observed,
attempt to photograph the individual and
identify it to species.
The biologist conducting the survey shall record
when the survey was conducted, a general
description of any suitable foraging habitat/floral
resources present, a description of observed western
bumble bee activity, a description of any vegetation
removed to facilitate the survey, and their
determination of if survey observations suggest a
western bumble bee nest(s) may be present or if
construction activities could result in take of western
bumble bee. The report shall be submitted to the City
of Petaluma Community Development Department
prior to the commencement of construction activities.
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
If western bumble bees are not located during the
preconstruction survey, then further mitigation or
coordination with the CDFW is not required.
If any sign(s) of a bumble bee nest is observed, and
if the species present cannot be established as a
common bumble bee, then construction shall not
commence until either (1) the bumble bees present
are positively identified as common (i.e., not a
western bumble bee), or (2) the completion of
coordination with CDFW to identify appropriate
mitigation measures, which may include, but not be
limited to, waiting until the colony active season ends,
establishment of nest buffers, or obtaining an
Incidental Take Permit(ITP) from CDFW.
If western bumble bees are located, and after
coordination with CDFW take of western bumble
bees cannot be avoided, the project applicant shall
obtain an ITP from CDFW, and the applicant shall
implement all conditions identified in the ITP.
Mitigation required by the ITP may include, but not be
limited to, the project applicant translocating nesting
substrate in accordance with the latest scientific
research to another suitable location (i.e., a location
that supports similar or better floral resources as the
impact area), enhancing floral resources on areas of
the project site that will remain appropriate habitat,
worker awareness training, and/or other measures
specified by CDFW.
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
4.1-2(b) If western bumble bees are identified on-site by a
qualified biologist, the following provisions shall be
implemented to offset the loss or disturbance of
foraging habitat (native forbs and shrubs): plant
species that are known nectar sources of the western
bumble bee shall be replaced at a 2:1 ratio, or as
otherwise recommended by a qualified biologist and
CDFW, and shall be included in a revised
landscaping plan. The revised landscaping plan shall
be submitted to the City of Petaluma Community
Development Department for review and approval
prior to commencement of construction activities.
Plant species shall be sited in concentrated locations
selected in consultation with a qualified biologist and
CDFW, as necessary, to ensure the long-term
survival of such plants and to limit disturbance
throughout project operation. Plant species known to
benefit the western bumble bee include, but are not
limited to, Asteraceae, Fabaceae, Rhamnaceae, and
Rosaceae, as well as plants in the genera Eriogonum
and Penstemon. If western bumble bee are not
identified on-site, the requirements of this measure
shall be limited to the inclusion of native plant species
in the aforementioned taxonomic families within the
project landscaping plan, to the satisfaction of the
City of Petaluma Community Development
Department.
4.1-3 Have a substantial adverse S 4.1-3(a) Construction activities within 50 feet of Adobe Creek LS
effect, either direct) or Creek shall be conducted outside of the known
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
through habitat modifications, salmonid winter and fall runs (known to occur from
on anadromous fish. November to April for the project region). Prior to
issuance of grading permit, the foregoing provision
shall be noted on the final improvement plans, which
shall be subject to review and approval by the City of
Petaluma Community Development Department. The
City shall also coordinate with the National Oceanic
and Atmospheric Administration (NOAA)
Fisheries/West Coast Region to obtain its
concurrence that the language is acceptable, prior to
approval of final improvement plans.
4.1-3(b) Prior to the commencement of construction, standard
erosion-control best management practices (BMPs)
shall be implemented around the proposed
disturbance areas. A qualified biologist shall be
present during installation of the BMPs to ensure
special-status wildlife species are not harmed during
installation or become entrapped within the
disturbance area. The BMPs shall be included in the
final improvement plans and subject to review and
approval by the City of Petaluma Community
Development Department. The City shall also
coordinate with the NOAA Fisheries/West Coast
Region to obtain its concurrence that the BMPs are
acceptable, prior to approval of final improvement
plans.
4.1-3(c) Implement Mitigation Measures 4.1-7(a) and 4.1-7(b)
and Mitigation Measures 4.1-8(a) through 4.1-8(c).
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
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Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
Draft EIR
270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
4.1-4 Have a substantial adverse S 4.1-4(a) Within 14 days prior to the commencement of LS
effect, either directly or construction (including tree trimming and removal), a
through habitat modifications, qualified biologist approved by the U.S. Fish and
on foothill yellow-legged frog, Wildlife Service (USFWS) and/or CDFW shall
California red-legged frog, and conduct preconstruction surveys of all areas
northwestern pond turtle. proposed for ground disturbance within suitable
habitats for special-status species, including foothill
yellow-legged frog(FYLF), California red-legged frog
(CRLF), and northwestern pond turtle. The
preconstruction surveys shall occur in areas within
and adjacent to the project site to determine if the
foregoing special-status species are present and
shall not be completed more than five days prior to
the initiation of grading activities in habitats where
FYLF, CRLF, and northwestern pond turtle have
potential to occur.A report summarizing the results of
the preconstruction surveys shall be submitted for
review and approval to the City of Petaluma
Community Development Department.
If any special-status species are found, the qualified
biologist shall contact the CDFW (and USFWS) to
determine whether relocation and/or additional
exclusion buffers are appropriate. If CDFW approves
relocating the animal(s), the qualified biologist shall
be given sufficient time to move the animal(s) from
the work site before work construction activities
begin.
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-13
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
Following construction activities, results from any
sensitive species surveys shall be documented in a
memorandum and provided to the City of Petaluma
Community Development Department within 30 days
following the end of construction activities, or sooner,
if requested by City staff.
4.1-4(b) If disturbance is to occur within the ordinary high-
water mark (OHWM) of the Creek, the project
applicant shall complete Section 7 consultation with
the USFWS and the National Oceanic and
Atmospheric Administration (NOAA)
Fisheries/National Marine Fisheries Service (NMFS)
for potential impacts to federally listed species, prior
to the commencement of construction. Proof of
compliance with the foregoing provisions shall be
documented and submitted for review and approval
to the City of Petaluma Community Development
Department.
4.1-4(c) Within 14 days prior to the commencement of
construction activities, exclusionary fencing shall be
installed along the work area boundary, as
determined by a qualified biologist. Exclusionary
fencing shall act as a barrier to keep special-status
species from entering the work area.An Exclusionary
Fence Plan shall be prepared by a qualified biologist
and subject to review and approval by
USFWS/CDFW and the City of Petaluma Community
Development Department. The Exclusionary Fence
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-14
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
Plan shall include, but not necessarily be limited to,
the following components:
a. Areas approved for grading and clearing
shall be delineated with suitable fencing
materials and dimensions (such as
temporary high-visibility orange-colored
fence or silt fence at least four feet in height,
flagging, or other barriers and buried to a
depth of at least four inches) to act as a
barrier to keep special-status species from
entering the project site. Signs shall be
posted that clearly state that construction
personnel and equipment are excluded from
the marked area. The fencing shall be
inspected and approved by a qualified
biologist and maintained daily until all
construction activities are complete. The
fencing shall be removed only when all
construction equipment is not on-site any
longer. Construction activities shall not take
place outside the delineated project site.
b. To avoid attracting predators, food-related
trash shall be kept in closed containers and
removed daily from the exclusion zone.
c. At the end of each day, all construction-
related holes or trenches deeper than one
foot shall be covered to prevent entrapment
of special-status species.
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S=Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-15
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
d. Prior to the commencement of daily
construction activities, all conduits and pipes
shall be inspected for the presence of
animals. Removal of any animals shall be
done in consultation with the approved
qualified biologist.
e. Prior to the commencement of construction,
any vegetation removed prior to the start of
construction activities shall be placed away
from sensitive species exclusion areas so
that cut vegetation does not remain once
exclusionary fencing is installed. All removed
non-native, invasive vegetation shall be
discarded off-site and away from aquatic
resources to prevent reseeding.
4.1-4(d) Within 14 days prior to the commencement of
construction, a qualified biologist shall conduct an
Environmental Awareness Training session to
familiarize all construction personnel with
identification of special-status species and
associated habitats, general provisions and
protections afforded by the federal Endangered
Species Act (FESA) and California Endangered
Species Act (CESA), measures implemented to
protect such species, actions to be taken if protected
species are observed on-site, and a review of project
site boundaries and job site maintenance protocols
(i.e., worker-generated trash, worker vehicle and
construction equipment parking, and disposal of
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-16
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
construction wastes). All personnel shall sign an
affidavit acknowledging participation in the training
and understanding species legal status, penalties for
violations, and all protective measures. A wallet-sized
card or fact sheet handout shall be distributed to all
crews on-site. Proof of completion of the training for
all on-site personnel shall be kept on-site and
submitted for review and approval to the City of
Petaluma Community Development Department.
4.1-4(e) During project construction, grading activities shall
cease a half-hour before sunset and shall not
commence prior to a half-hour before sunrise.
Grading activities shall be prohibited during rain
events that meet the following conditions: within 24
hours of events predicted to deliver more than 0.2-
inch of rain and within 24 hours after rain events
exceeding 0.2-inch in measurable precipitation.
Grading shall not occur after 0.5-inch of rain has
occurred after November 1 in the year construction
grading work is occurring unless a one-week
extension based on fair weather is approved by the
City of Petaluma, CDFW, and the Regional Water
Quality Control Board (RWQCB). The foregoing
provisions shall be noted on the final improvement
plans, which shall be verified by the City of Petaluma
Community Development Department.
4.1-4(f) Prior to the commencement of any effort to advertise
or promote the sale of any of the proposed dwelling
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-17
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
units, all promotional materials, deeds/rental
agreements, etc., shall include information that
informs all tenants that dogs are to be leashed at all
times within development boundaries, including
within 50 feet of the riparian habitat within the study
area, in order to ensure that sensitive resources and
riparian habitat are preserved. Proof of compliance
with the foregoing provision shall be submitted for
review and approval to the City of Petaluma
Community Development Department.
4.1-4(g) Prior to the commencement of construction, the
project applicant shall include a design sheet of the
proposed trash enclosure and receptacles as part of
the improvement plan submittal. The design sheet
shall note that trash receptacles must be secured
within enclosures that exclude mesopredators (e.g.,
racoons and coyotes) to avoid attracting and
subsidizing such predators. On-site trash enclosures
and receptacles shall also be routinely maintained.
Inclusion of the design sheet shall be subject to
review and approval by the City of Petaluma
Community Development Department.
4.1-5 Have a substantial adverse S 4.1-5 During project construction, site preparation LS
effect, either directly or activities, including tree trimming and removal,
through habitat modifications, should occur between September 1 and January 31,
on Swainson's hawk and other outside of the bird nesting season. If vegetation
nesting birds and raptors removal or construction begins between February 1
protected under the MBTA and and August 31, preconstruction nesting bird surveys
CFGC. shall be conducted by a qualified biologist within
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-I8
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
seven days prior to vegetation removal or ground-
disturbing activities to determine the presence or
absence and location of nesting bird species.A report
summarizing the results of the preconstruction
nesting bird surveys shall be submitted for review and
approval to the City of Petaluma Community
Development Department. If a lapse in construction
activity occurs for more than seven consecutive days
or if construction activity is phased at the work site,
preconstruction and nesting bird surveys shall be
repeated.
If active nests are present within 500 feet of
construction areas, temporary protective construction
exclusion zones shall be established by a qualified
biologist in order to avoid direct or indirect mortality
or disruption of the birds, nests, or young. The
appropriate buffer distance shall be dependent on the
species, surrounding vegetation, and topography and
shall be determined by a qualified biologist, but shall
be a minimum of 500 feet for raptors and 100 feet for
songbirds. Exclusion zones shall remain in place until
all young have fledged or until the nest has been
naturally abandoned or predated. Work may proceed
if active nests are not found during surveys or once
nests are determined by a qualified biologist to be
inactive.
The non-disturbance buffers may be reduced if a
smaller, sufficiently protective buffer is approved by
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-19
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
the City after taking into consideration the natural
history of the species of bird nesting, the proposed
activity level adjacent to the nest, the nest occupants'
habituation to existing or ongoing activity, and nest
concealment(i.e., whether visual or acoustic barriers
occur between the proposed activity and the nest). A
qualified biologist may visit the nest, as needed, to
determine when the young have fledged the nest and
are independent of the site or the nest can be left
undisturbed until the end of the nesting season. If the
nest buffer is reduced but construction activities
cause a nesting bird to vocalize, make defensive
flights at intruders, get up from a brooding position, or
fly off the nest in a way that would be considered a
result of construction activities, then the exclusionary
buffer shall be increased such that activities are far
enough from the nest to stop the agitated behavior.
The revised non-disturbance buffer shall remain in
place until the chicks have fledged or as otherwise
determined by a qualified biologist in consultation
with the City.
Cleared vegetation during the nesting season shall
be collected and transported off-site during each
week to prevent birds from nesting in vegetative
debris.
Results from any survey for nesting birds shall be
documented in a memorandum and provided to the
City of Petaluma Community Development
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-20
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
Department within 30 days following the end of
construction activities.
4.1-6 Have a substantial adverse S 4.1-6 Prior to the commencement of construction, a LS
effect, either directly or qualified biologist shall conduct a preconstruction
through habitat modifications, survey of suitable habitat for special-status bats,
on pallid bat. including existing structures proposed for demolition
or removal, that could support special-status bats, at
most, 14 days prior to initiation of ground disturbance,
including tree trimming and removal. A report
summarizing the results of the preconstruction survey
shall be submitted for review and approval to the City
of Petaluma Community Development Department. If
a lapse in construction activity occurs for more than
seven consecutive days or if construction activity is
phased at the work site, preconstruction bat surveys
shall be repeated.
If special-status bat roosts are observed, ground
disturbance within 50 feet of roosts shall be restricted
to between August 31 and October 15 and between
March 1 and April 15 to avoid hibernation and rearing
periods. Removal of potential suitable bat roost trees
shall occur over a two-day phased process with a
qualified biologist present.
In addition, if bats or evidence of bat roosting are
observed, exclusionary fencing and/or construction
activity avoidance limits shall be put in place.
Exclusion devices may include features such as one-
way exits from roost habitat and shall be installed by
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-21
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
a qualified biologist, in consultation with CDFW, and
shall not occur outside of the date ranges listed above
to avoid hibernation or rearing periods.
Following construction activities, results from any
sensitive bat species survey shall be documented in
a memorandum, written by the qualified biologist, and
provided to the City of Petaluma Community
Development Department within 30 days following
the end of construction activities.
4.1-7 Have a substantial adverse S 4.1-7(a) Prior to the commencement of construction, the LS
effect on any riparian habitat or project applicant shall implement minimization and
other Sensitive Natural avoidance measures that may include, but not
Community identified in local necessarily be limited to, preconstruction species
or regional plans, policies, surveys and reporting, protective fencing around
regulations or by the CDFW or avoided biological resources, worker environmental
USFWS. awareness training, seeding disturbed areas
adjacent to open space areas with native seed, and
installation of project-specific stormwater BMPs.
Mitigation for impacts to riparian habitat may include,
but not be limited to, restoration or enhancement of
resources on- or off-site, purchase of habitat credits
from an agency-approved mitigation/conservation
bank, working with a local land trust to preserve land,
or any other method acceptable to CDFW. Mitigation
shall result in no net loss of riparian habitat. Prior to
the commencement of construction, the project
applicant shall apply for a Section 1600 Lake or
Streambed Alteration Agreement (LSAA) from
CDFW. The project applicant shall comply with an
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-22
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
terms and conditions contained within the final LSAA
for the proposed project, which may differ from the
above. Written verification of the Section 1600 LSAA
shall be submitted to the City of Petaluma Community
Development Department.
4.1-7(b) A 50-foot setback from riparian vegetation shall be
established prior to the commencement of grading
activities, except for construction of the stormwater
outfall facilities, pedestrian bridge connection, and
the off-site public multi-use pathway, where a lesser
setback shall be established in consultation with a
qualified biologist. Construction and staging of
vehicles and equipment shall not occur within 50 feet
of riparian vegetation and shall be parked only in
designated staging areas. Silt fencing shall be
installed along the outer edge of the project's
disturbance footprint and shall remain during grading
activities associated with the proposed project. The
foregoing provisions shall be based on
recommendations by a qualified biologist, comply
with agency approval, and noted on the final
improvement plans, which shall be subject to review
and approval by the City of Petaluma Community
Development Department.
4.1-7(c) Implement Mitigation Measures 4.1-8(b)and 4.1-10.
4.1-8 Have a substantial adverse S 4.1-8(a) Prior to the commencement of grading activities, a LS
effect on State or federally 50-foot setback from the OHWM of the Creek shall be
protected wetlands (including, established and noted on the improvement plans,
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-23
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
but not limited to, marsh, except for construction of the stormwater outfall
vernal pool, coastal, etc.) facilities and the off-site public multi-use pathway and
through direct removal, filling, bridge, where a lesser setback shall be established
hydrological interruption, or in consultation with a qualified biologist. Construction
other means. and staging of vehicles and equipment shall not occur
within the Creek channel. Silt fencing shall be
installed along the outer edge of the project's
disturbance footprint and shall remain during grading
activities. Inclusion of the 50-foot setback from the
OHWM of the Creek on the improvement plans shall
be subject to review and approval by the City of
Petaluma Community Development Department.
4.1-8(b) Prior to initiation of any ground-disturbing activities,
the project proponent shall submit a formal Aquatic
Resources Delineation to the USACE for verification
purposes and determination as to whether the project
activities will require a Clean Water Act (CWA)
Section 404 permit. A copy of the USACE's
determination shall be submitted to the City of
Petaluma Community Development Department. If a
Section 404 permit is not required, further mitigation
shall not be required. If a Section 404 permit is
required, the project proponent shall apply for a
Clean Water Act(CWA) Section 404 permit from the
USACE. Waters that would be lost or disturbed shall
be restored, replaced, or rehabilitated on a `no-net-
loss"basis. Habitat restoration, rehabilitation, and/or
replacement shall be at a location and by methods
acceptable to the USACE. If a Section 404 permit is
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-24
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
required, the project applicant shall also apply for a
Section 401 water quality certification from the
RWQCB prior to the issuance of grading permits and
adhere to the certification conditions. A copy of the
Section 404 and 401 permits detailing the provisions
with which the proposed project must comply shall be
submitted to the City of Petaluma Community
Development Department.
4.1-9 Interfere substantially with the LS None required. N/A
movement of any native
resident or migratory fish or
wildlife species or with
established native resident or
migratory wildlife corridors, or
impede the use of native
wildlife nursery sites.
4.1-10 Conflict with any local policies S 4.1-10 Prior to approval of the final improvement plans, the LS
or ordinances protecting project applicant shall obtain a Tree Removal Permit
biological resources, such as a from the City of Petaluma Community Development
tree preservation policy or Department. In addition, all protected trees to be
ordinance, or have a removed, as identified in the Tree Protection and
substantial adverse effect on Removal Plan prepared by Urban Forestry
the environment by converting Associates, Inc. for the proposed project, shall be
oak woodlands. replaced in accordance with the ratios established in
the Tree Replacement Calculations table in the Tree
Protection and Removal Plan. All trees to be
preserved and protected, as detailed in Table 2 of the
Tree Protection and Removal Plan shall be preserved
in accordance with the recommendations established
therein. Proof of compliance with the foregoing
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-25
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July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
provisions shall be submitted for review and approval
to the City of Petaluma Community Development
Department.
4.1-11 Cumulative loss of habitat for LCC None required. N/A
special-status species.
4.2 GHG Emissions
4.2-1 Generate GHG emissions, CC, SU 4.2-1 Prior to the approval of project improvement plans, CC, SU
either directly or indirectly,that the applicant shall implement the following measure:
may have a significant impact
on the environment, or conflict Consistent with BAAQMD's Transportation
with an applicable plan, policy, criterion b., a total of three EV Capable
or regulation adopted for the parking spaces shall be installed throughout
purpose of reducing the the nine undesignated on-street parking
emissions of GHGs. spaces within the project site, consistent with
the current CALGreen Tier 2 standards.
Compliance with the foregoing measure shall be
ensured by the City of Petaluma Community
Development Department.
4.3 Hydrology and Water Quality
4.3-1 Violate any water quality S 4.3-1(a) Prior to issuance of grading permits, the applicant LS
standards or waste discharge shall prepare a Storm Water Pollution Prevention
requirements or otherwise Plan (SWPPP). The developer shall file the Notice of
substantially degrade surface Intent (NOI) and associated fee to the State Water
or ground water quality during Resources Control Board (SWRCB). The SWPPP
construction. shall serve as the framework for identification,
assignment, and implementation of Best
Management Practices (BMPs). The SWPPP shall
be submitted to the Director of Public Works and
Utilities/City Engineer for review and approval and
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-26
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
shall remain on the project site during all phases of
construction. Following implementation of the
SWPPP, the contractor shall subsequently
demonstrate the SWPPP's effectiveness and provide
for necessary and appropriate revisions,
modifications, and improvements to reduce pollutants
in stormwater discharges to the maximum extent
practicable. The contractor shall implement BMPs to
reduce pollutants in stormwater discharges to the
maximum extent practicable.
4.3-1(b) Prior to issuance of grading permits, the project
applicant shall ensure that a final grading plan is
prepared by a State-registered civil engineer in
accordance with Petaluma Municipal Code (PMC)
Chapter 17.31. The final grading plan shall include,
but not be limited to, the following:
• A project vicinity map that shows the location
of the proposed grading activities within the
project site and off-site areas associated with
Adobe Creek(Creek);
• The property line boundaries of the project
site and off-site areas of disturbance
associated with the Creek;
• All existing improvements on and adjacent to
the project site;
• The existing and proposed contours of the
project site and off-site areas proposed for
disturbance;
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-27
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
• The existing and proposed drainage of the
project site and off-site areas;
• The extent and manner of tree cutting and
vegetation clearing, the disposal of
vegetation, and the measures to be taken for
the protection of undisturbed trees and
vegetation in on-site and off-site areas
proposed for disturbance, unless the
foregoing information is provided on the final
erosion and sediment control plan;
• Specifications of the proposed construction
methods and materials to be used in on-site
and off-site areas;and
• Any other information required by the
Director of Public Works and Utilities.
The final grading plan shall be submitted for review
and approval to the City of Petaluma Public Works
and Utilities Department.
4.3-2 Violate any water quality S 4.3-2 Prior to approval of final project improvement plans, LS
standards or waste discharge a final Stormwater Control Plan shall be submitted to
requirements or otherwise the Director of Public Works and Utilities/City
substantially degrade surface Engineer for review and approval. The final
or ground water quality during Stormwater Control Plan shall be in compliance with
operation. all applicable provisions of the National Pollutant
Discharge Elimination System (NPDES) Phase 11
MS4 General Permit (NPDES General Permit No.
CAS612008, Order No. R2-2022-0018) and shall
meet the standards of the California Stormwater
Quality Association (CASQA) Stormwater BMP
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
Handbook for New Development and
Redevelopment. Site design measures, source-
control measures, hydromodification management,
and Low Impact Development (LID) standards, as
necessary, shall be incorporated into the design and
shown on the improvement plans. The final plans
shall include calculations demonstrating that the
water quality BMPs are appropriately sized, using
methodology in the CASQA Stormwater BMP
Handbook for New Development and
Redevelopment. The final plans shall also
incorporate the proposed components for
maintaining the storm water-treatment facilities. The
final plans shall be submitted to the City of Petaluma
Public Works and Utilities Department for review and
approval.
4.3-3 Substantially alter the existing LS None required. LS
drainage pattern of the site or
area, including through the
alteration of the course of a
stream or river or through the
addition of impervious
surfaces, in a manner which
would: substantially increase
the rate or amount of surface
runoff in a manner which would
result in substantial erosion or
siltation on- or off-site;
substantially increase the rate
or amount of surface runoff in
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-29
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
a manner which would result in
flooding on- or off-site; create
or contribute runoff water
which would exceed the
capacity of existing or planned
stormwater drainage systems
or provide substantial
additional sources of polluted
runoff; or impede or redirect
flood flows.
4.3-4 In flood hazard, tsunami, or LS None required. LS
seiche zones, risk release of
pollutants due to project
inundation.
4.3-5 Cumulative impacts related to LS None required. LS
the violation of water quality
standards or waste discharge
requirements, and impacts
resulting from the alteration of
existing drainage patterns.
4, I Transportation
4.4-1 Conflict with a program, plan, S 4.4-1 Prior to issuance of grading and building permits, a LS
ordinance, or policy, except construction management plan shall be prepared by
LOS, addressing the the applicant for review and approval by the City of
circulation system during Petaluma Public Works and Utilities Department. The
construction activities. plan shall include, but not necessarily be limited to,
the following items:
a. Comprehensive traffic control measures,
including scheduling of major truck trips and
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-30
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Draft EIR
270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
deliveries to avoid peak traffic hours,
including school peak times, detour signs if
required, lane closure procedures if required,
sidewalk closure procedures if required,
cones for drivers, and designated
construction access routes.
b. Evaluation of the need to provide flaggers or
temporary traffic control at key intersections
along the truck route(s).
c. Notification procedures for adjacent property
owners, Casa Grande High School, and
public safety personnel regarding schedules
when major deliveries, detours, and lane
closures would occur.
d. Location of construction staging areas for
materials, equipment, and vehicles if there is
insufficient staging area within the work zone
of the proposed project.
e. Identification of truck routes for movement of
construction vehicles that would minimize
impacts on vehicular and pedestrian traffic,
circulation and safety, provision for
monitoring surface streets used for truck
movement so that any damage and debris
attributable to the proposed project's
construction trucks can be identified and
corrected by the proposed project applicant.
f. A process for responding to and tracking
complaints pertaining to construction activity,
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S=Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-31
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
including identification of an on-site
complaint manager.
g. Documentation of road pavement conditions
for all routes that would be used by
construction vehicles both before and after
proposed project construction. Roads found
to have been damaged by construction
vehicles shall be repaired to the level at
which they existed prior to construction of the
proposed project.
4.4-2 Conflict with a program, plan, LS None required. N/A
ordinance, or policy, except
LOS, addressing the
circulation system, including
transit, roadway bicycle, and
pedestrian facilities, during
operations.
4.4-3 Result in VMT which exceeds SU None required. N/A
an applicable threshold of
significance, except as
provided in CEQA Guidelines
Section 15064.3, subdivision
(b).
4.4-4 Substantially increase hazards LS None required. N/A
to vehicle safety due to a
geometric design feature (e.g.,
sharp curves or dangerous
intersections) or incompatible
uses (e.g., farm equipment), or
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-32
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
result in inadequate
emergency access.
Initial Study Impacts Requiring Mitigation
V-b. Cause a substantial adverse S V-1 If during the course of ground-disturbing activities, LS
change in the significance of a including, but not limited to, excavation, grading, and
unique archaeological construction, a potentially significant prehistoric or
resource pursuant to Section historic resource is encountered, all work within a
15064.5? 100-foot radius of the find shall be suspended for a
time deemed sufficient for a qualified and City-
approved archaeologist to adequately evaluate and
determine significance of the discovered resource
and provide treatment recommendations.
Should a significant archeological resource be
identified, a qualified archaeologist shall prepare a
resource mitigation plan and monitoring program to
be carried out during all construction activities.
Prehistoric archaeological site indicators include:
obsidian and chert flakes and chipped stone tools;
grinding and mashing implements (e.g., slabs and
handstones, and mortars and pestles); bedrock
outcrops and boulders with mortar cups; and locally
darkened midden soils. Midden soils may contain a
combination of any of the previously listed items with
the possible addition of bone and shell remains, and
fire-affected stones. Historic period site indicators
generally include: fragments of glass, ceramic, and
metal objects; milled and split lumber; and structure
and feature remains such as building foundations and
discrete trash deposits(e.g., wells,privy pits, dumps).
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
VII-d. Be located on expansive soil, S VII-1 Prior to the issuance of grading permits, the project LS
as defined in Table 18-1 B of the civil engineer shall show on the final improvement
Uniform Building Code (1994), plans that the project design adheres to all
creating substantial direct or engineering recommendations provided in the site-
indirect risks to life or property specific Geotechnical Investigation prepared for the
project by PJC & Associates, Inc. The
recommendations incorporated into the final
improvement plans shall include, but not be limited to,
those pertaining to the top 18 inches of soil beneath
exterior flatwork consisting of imported engineered
fill; demolition and stripping; excavation and
compaction;temporary slopes;and vertical loads and
lateral loads of post-tension slab-on-grade
foundations. Proof of compliance with all
recommendations set forth in the Geotechnical
Investigation shall be subject to review and approval
by the City Engineer.
IX-b. Create a significant hazard to S IX-1 Prior to issuance of a demolition permit by the City for LS
the public or the environment the on-site structure at 280 Casa Grande Road, the
through reasonably project applicant shall provide a site assessment that
foreseeable upset and accident determines whether the structure to be demolished
conditions involving the likely contains lead-based paint (LBP) or asbestos. If the
release of hazardous materials structure does not contain LBP or asbestos, further
into the environment? mitigation shall not be required; however, if LBP is
found, all loose and peeling paint shall be removed
and disposed of by a licensed and certified lead paint
removal contractor, in accordance with California Air
Resources Board recommendations and
Occupational Safety and Health Administration
(OSHA) requirements. If asbestos is found, all
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-34
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
Draft EIR
270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
construction activities shall comply with all
requirements and regulations promulgated through
the Bay Area Air Quality Management District
(BAAQMD) Asbestos Demolition and Renovation
Program. The demolition contractor shall be informed
that all paint on the building shall be considered as
containing lead and/or asbestos. The contractor shall
follow all work practice standards set forth in the
Asbestos National Emission Standards for
Hazardous Air Pollutants (Asbestos NESHAP, 40
CFR, Part 61, Subpart M) regulations, as well as
Section V, Chapter 3 of the OSHA Technical Manual.
Work practice standards generally include
appropriate precautions to protect construction
workers and the surrounding community, and
appropriate disposal methods for construction waste
containing lead paint or asbestos in accordance with
federal, State, and local regulations subject to
approval by the City Engineer.
IX-2 Prior to issuance of a demolition permit by the City for
the on-site structure at 280 Casa Grande Road, the
project applicant shall prepare an Off-Hauling and
Disposal Plan that incorporates industry standard
BMPs during proposed off-hauling activities
associated with waste from on-site demolition
activities. The following Best Management Practices
(BMPs) shall be incorporated:
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-35
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
• During loading activities, the project
contractor shall place two layers of heavy
plastic sheeting (minimum thickness of six
mils) beneath trucks to be used for off-
hauling activities to collect any spilled soil,
• After each truck is loaded and prior to
removing the plastic sheeting, visible dust or
soil spilled during loading shall be removed
from the top rails, fences, tires, and all other
surfaces by dry brushing methods at the
point of loading;
• Collected soil on the plastic sheeting shall be
removed periodically to avoid the spreading
of contaminated soil on truck tires;
• The soil shall be transported by a licensed
transporter;
• All off-hauling trucks shall be loaded at the
project site and appropriately covered
(tarped), in accordance with U.S.
Department of Transportation regulations;
• Loaded trucks shall use the most direct
routes to the disposal site(s) to provide the
least risk of exposure to surrounding
communities and avoid residential areas to
the maximum extent feasible and;
• Any additional BMPs determined necessary
by the City Engineer.
During loading activities, the project contractor shall
ensure that all applicable work practice standards set
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-36
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
Draft EIR
270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
forth in Section V, Chapter 3 of the OSHA Technical
Manual are followed, including appropriate
precautions to protect construction workers and the
surrounding community, in accordance with
applicable federal, State, and local regulations,
including those set forth by the Sonoma County
Environmental Health and Safety Division (SCEHD)
and the Department of Toxic Substances Control
(DISC). The Off-Hauling and Disposal Plan shall be
subject to approval by the City Engineer.
IX-3 Prior to improvement plan approval, the project
applicant shall ensure that the on-site septic systems
are abandoned in compliance with applicable
SCEHSD standards. Upon removal, the septic tanks
shall be inspected for leaks. Should any leaks be
identified, the project applicant shall conduct
additional testing of soils at the location of the on-site
septic systems for chemicals associated with the on-
site septic systems in accordance with applicable
USEPA Methods. Where concentrations exceed
applicable DTSC screening levels, the soil shall be
excavated and that portion of material shall be
transported and disposed of off-site at an appropriate
Class I or Class II facility permitted by DTSC, or other
options implemented as deemed satisfactory to
SCEHSD. The results of soil sampling and analysis,
as well as verification of proper remediation and
disposal, shall be submitted to the City of Petaluma
Planning Division for review and approval. Any
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-37
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
remediation shall be completed prior to acceptance
of the site improvements for that phase.
IX-4 Prior to improvement plan approval, the project
applicant shall hire a licensed well contractor to
obtain a well abandonment permit from the SCEHSD
for all on-site wells, and properly abandon the on-site
wells, pursuant to Department of Water Resources
Bulletin 74-81 (Water Well Standards, Part Ill), for
review and approval by the SCEHSD.
XIII-a. Generation of a substantial S XIII-1 The following criteria shall be included in the LS
temporary or permanent Improvement Plans. Exceptions to allow expanded
increase in ambient noise construction activities shall be reviewed on a case-
levels in the vicinity of the by-case basis, as determined by the Community
project in excess of standards Development Director.
established in the local general
plan or noise ordinance, or Limit construction hours to between 8:00 AM
applicable standards of other and 5:30 PM, Monday through Friday, and
agencies between 9:00 AM and 5:00 PM on Saturday.
Construction activities shall be prohibited on
Sundays and State, federal and local
holidays,
• High noise-producing activities, such as
excavation and grading and construction
finishing, shall only occur between the hours
of 8:00 AM and 5:00 PM to minimize
disruption at adjacent noise sensitive uses;
• Equip all internal combustion engine-driven
equipment with intake and exhaust mufflers
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-38
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
that are in good condition and appropriate for
the equipment;
• Locate stationary noise-generating
equipment (e.g., compressors) as far as
possible from adjacent residential receivers;
• Acoustically shield stationary equipment
located near residential receivers with
temporary noise barriers;
• Utilize "quiet" air compressors and other
stationary noise sources where technology
exists;
• The project contractor shall implement
appropriate additional noise-reduction
measures that include shutting off idling
equipment after five minutes (as feasible)
and notifying adjacent residences (at least
one time) in advance of construction work;
• Construction workers; radios shall be
controlled to not exceed ambient noise levels
beyond the limits of the project site
boundaries,-
Heavy equipment, such as paving and
grading equipment, shall be stored on-site
whenever possible to minimize the need for
extra heavy truck trips on local streets;
• Two weeks prior to the commencement of
construction, notification in writing shall be
provided to residents within 500 feet of the
project site and if during the school year,
officials at the Casa Grande High School
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-39
Docusign Envelope ID:492CF6C7-3C9A-449F-8AOB-FF7C50575E8E
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
campus, disclosing the construction
schedule, including the various types of
activities that would be occurring throughout
the duration of the construction period,and
• The project contractor shall designate a
"disturbance coordinator" responsible for
responding to any complaints about
construction noise. The disturbance
coordinator shall determine the cause of the
noise complaint (e.g., bad muffler, etc.) and
shall require that reasonable measures be
implemented to correct the problem.
XVIII-a. Listed or eligible for listing in S XVIII-1 To protect buried tribal cultural resources that may be LS
the California Register of encountered during ground disturbing activities, the
Historical Resources, or in a project shall implement Mitigation Measure V-1.
local register of historical
resources as defined in Public XV111-2 Prior to initiation of ground-disturbing activities, a
Resources Code Section qualified archaeologist retained by the project
5020.1(k). applicant shall conduct a short awareness training
session for all construction workers and supervisory
XVIII-b. A resource determined by the personnel. The course shall explain the importance
lead agency, in its discretion of, and legal basis for, the protection of significant
and supported by substantial archaeological resources, as well as the legal and
evidence, to be significant regulatory implications of knowingly destroying
pursuant to criteria set forth in cultural resources or removing historic or precontact
subdivision (c) of Public artifacts, human remains, and other cultural materials
Resources Code Section from the project site. Each worker shall also learn the
5024.1. In applying the criteria proper procedures to follow in the event cultural
set forth in subdivision (c) of resources or human remains/burials are uncovered
Public Resources Code during construction activities, including work
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
11 Page 2-40
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270 and 280 Casa Grande Road Creekwood Housing Development Project
July 2024
Table 2-1
Summary of Impacts and Mitigation Measures
Level of Level of
Significance Significance
Prior to After
Impact Mitigation Mitigation Measures Mitigation
Section 5024.1, the lead agency curtailment or redirection and to immediately contact
shall consider the significance their supervisor and the archaeological monitor. The
of the resource to a California worker education session shall include visuals of
Native American tribe. artifacts (prehistoric and historic) that might be found
in the project vicinity, and take place on the
construction site immediately prior to the start of
construction. All ground-disturbing equipment
operators shall be required to receive the training and
sign a form that acknowledges receipt of the training.
The signed form shall be submitted to the City of
Petaluma Community Development Department.
N/A=Not Applicable; LS=Less Than Significant; LCC=Less Than Cumulatively Considerable; S= Significant; CC= Cumulatively Considerable; SU =Significant
and Unavoidable
Chapter 2 - Executive Summary
Page 2-41