douglas avenue multi-family residential development project › 1128-1132 douglas ave - final...

One Embarcadero Center, Suite 740 San Francisco, CA 94111 650-373-1200 www.panoramaenv.com

City of Burlingame Douglas Avenue Multi-Family Residential Development Project Final Environmental Impact Report State Clearinghouse No. 2015062033

February 2017

One Embarcadero Center, Suite 740 San Francisco, CA 94111 650-373-1200 www.panoramaenv.com

City of Burlingame Douglas Avenue Multi-Family Residential Development Project Final Environmental Impact Report State Clearinghouse No. 2015062033 February 2017 Prepared for: City of Burlingame 501 Primrose Road Burlingame, CA 94010 Prepared by: Panorama Environmental, Inc. One Embarcadero Center, Suite 740 San Francisco, CA 94111 650-373-1200 [email protected]

TABLE OF CONTENTS

Douglas Avenue Multi-Family Residential Development Project Final EIR ● February 2017

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TABLE OF CONTENTS

List of Acronyms .................................................................................................................................. iii

1 Introduction ............................................................................................................................. 1-1 1.1 Proposed Project ............................................................................................................... 1-1 1.2 Environmental Review Process ........................................................................................ 1-2 1.3 Purpose of the Final Environmental Impact Report ..................................................... 1-2 1.4 Report Organization .......................................................................................................... 1-3 1.5 List of Agencies, Organizations, and Individuals Who Received the

Draft EIR or Notice of Availability .................................................................................... 1-4 1.6 List of Agencies, Organizations, and Individuals Commenting on the Draft EIR ..... 1-4

2 Responses to Comments on the Draft EIR ............................................................................. 2-1 2.1 Common Comments and Responses ............................................................................ 2-1 2.2 Public Meeting Comments ............................................................................................ 2-10 2.3 California Department of Transportation..................................................................... 2-30 2.4 HOA Board ........................................................................................................................ 2-33 2.5 Anonymous Resident of Burlingame ............................................................................ 2-35 2.6 Clarke So ........................................................................................................................... 2-45 2.7 Danielle Rienks Comment Letter #1 ............................................................................. 2-47 2.8 Danielle Rienks Comment Letter #2 ............................................................................. 2-54 2.9 Dion Heffran ..................................................................................................................... 2-64 2.10 Gerald Weisl ..................................................................................................................... 2-66 2.11 John Root .......................................................................................................................... 2-68

3 Revisions to the Text of the Draft EIR ...................................................................................... 3-1 3.1 Introduction ........................................................................................................................ 3-1 3.2 Draft EIR Revisions .............................................................................................................. 3-1

4 References .............................................................................................................................. 4-1

List of Appendices

Appendix A Mailing List of Individuals that Received the Notice of Availability

TABLE OF CONTENTS


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List of Tables

Table 1.5-1 Agencies and Organizations that Received the NOA ......................................... 1-4 Table 1.6-1 Agencies, Organizations, and Individuals that Commented on the Draft EIR . 1-5 Table 2.1-1 Proposed and Net New Project Daily and Peak Hour Trip Generation

1128-1132 Douglas Avenue Residential Project ..................................................... 2-2 Table 2.1-2 Proposed Project Residential Units and City Parking Space Requirements ...... 2-3 Table 2.1-3 Inconsistencies with City of Burlingame Plans and Policies Due to the

Height of the Proposed Project. ............................................................................... 2-6 Table 2.2-1 Proposed Project’s Consistency with Downtown Specific Plan Parking

Goals and Policies .................................................................................................... 2-21 Table 2.2-2 Enrollment Rate and Capacities at Burlingame High School,

San Mateo High School, and Aragon High School ............................................. 2-26

LIST OF ACRONYMS


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LIST OF ACRONYMS

A AN Anonymous Applicant Dreiling Terrones Architecture, Inc.

B BAAQMD Bay Area Air Quality Management District

C CEQA California Environmental Quality Act

City City of Burlingame

CNDDB California Natural Diversity Database

CS Clarke So

D DH Dion Heffran DPW Burlingame Department of Public Works DR Danielle Rienks

E EIR Environmental Impact Report

G GW Gerald Weisl

H HCP Habitat Conservation Plan HOA Home Owners’ Association

LIST OF ACRONYMS


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I ITE Institute of Traffic Engineering

L LOS level‐of‐service

M mgd millions of gallons per day MM Mitigation Measure mph miles per hour

N NCCP Natural Community Conservation Plan NOA Notice of Availability NPDES National Pollutant Discharge Elimination System

P PG&E Pacific Gas and Electric Company PM Public Meeting

R JR John Root

S SWRCB State Water Resources Control Board

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1 INTRODUCTION

1.1 PROPOSED PROJECT Dreiling Terrones Architecture, Inc., representing the owner (collectively “the Applicant”), submitted an application to the City of Burlingame (City) Department of Community Development to demolish 2 single family houses and a 4‐unit apartment building on 2 adjacent lots, and construct a 27‐unit, 5‐story apartment building (the currently proposed project was revised to reduce the number of residential units from 29 to 27). The project also includes moving a historic house from the project site and relocating it to another location in the City. The proposed project would be located on two adjacent lots at 1128 and 1132 Douglas Avenue. The historic house would be moved from 1128 Douglas Avenue to 524 Oak Grove Avenue. The existing house at the Oak Grove Avenue location would be demolished to accommodate the historic house. The proposed project sites are in the City of Burlingame in San Mateo County.

The applicant revised the project in response to comments on the Draft EIR as follows:

Number of units reduced from 29 to 27 − 1‐bedroom units reduced from 18 to 14 − 2‐bedroom units increased from 7 to 9 − Studio units (3) and 3‐bedroom units (1) remained the same.

The reduction in the total number of units and change in unit type reduced the overall parking requirement from 34 to 33 parking spaces (see table below).

Although an area for on‐site deliveries is not required for apartment buildings and there is no guest parking required on‐site for properties located within the Downtown Specific Plan area, the extra parking space located within the at‐grade parking area at the rear of the site has been designated as a guest/delivery parking space.

The fifth floor along the front façade has been stepped back 10 feet. This area has been converted to balconies for Units 502 and 503).

Parking Spaces for Proposed and Revised Project

Previous Proposal Revised Proposal

Units and Parking Spaces 3 studio units x 1 = 3 18, 1-bdr units x 1 = 18

7, 2-bdr units x 1.5 = 10.5 1, 3 bdr unit x 2 = 2 Total = 34 spaces

3 studio units x 1 = 3 14, 1-bdr units x 1 = 14

9, 2-bdr units x 1.5 = 13.5 1, 3 bdr unit x 2 = 2 Total = 33 spaces

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1.2 ENVIRONMENTAL REVIEW PROCESS A Draft Environmental Impact Report (EIR) was prepared to analyze the environmental impacts of the proposed project. The Draft EIR considered the proposed project and alternative projects that would reduce or avoid significant environmental impacts. The Draft EIR was circulated to affected public agencies and interested parties for a 45‐day review period from September 6, 2016 to October 20, 2016. Comments on the Draft EIR were to be submitted in writing by no later than Thursday, October 20, 2016.In conformance with California Environmental Quality Act (CEQA) Guidelines Section 15151, EIRs should be prepared with a sufficient degree of analysis to provide decision‐makers with information which enables them to decide on the project that considers environmental consequences. The Final EIR is required to examine mitigation measures and alternatives to the project intended to reduce or eliminate significant environmental impacts.

1.3 PURPOSE OF THE FINAL ENVIRONMENTAL IMPACT REPORT This document, together with the Draft EIR, constitutes the Final EIR for the Douglas Avenue Multi‐Family Residential Development Project in the City of Burlingame. Under CEQA, the Lead Agency (City of Burlingame) is required, after completion of a Draft EIR, to consult with and obtain comments from public agencies having jurisdiction by law with respect to the proposed project, and to provide the public with an opportunity to comment on the Draft EIR. The City of Burlingame, as the Lead Agency, is then required to respond to significant environmental issues raised in the review and consultation process, as described in CEQA Section 15132.

The Final EIR is used by the City and other Responsible Agencies in making decisions regarding the project. The CEQA Guidelines require that, while the information in the Final EIR does not control the agency’s ultimate discretion of the project, the agency must respond to each significant effect identified in the Draft EIR by making written findings for each of those effects. Per the State Public Resources Code (Section 21081), no public agency shall approve or carry out a project for which an EIR has been certified, which identifies one or more significant effects on the environment that would occur if the project is approved or carried out, unless both of the following occur:

(a) The public agency makes one or more of the following findings with respect to each significant effect: (1) Changes or alterations have been required in, or incorporated into, the

project which will mitigate or avoid the significant effect on the environment. (2) Those changes or alterations are within the responsibility and jurisdiction of

another public agency and have been, or can and should be, adopted by that other agency.

(3) Specific economic, legal, social, technological, or other considerations, including considerations for the provision of employment opportunities of

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highly trained workers, make infeasible the mitigation measures or alternatives identified in the environmental impact report.

(b) With respect to significant effects which were subject to a finding under paragraph (3) of subdivision (a), the public agency finds that specific overriding economic, legal, social, technological, or other benefits of the project outweigh the significant effects on the environment.

This project would not result in significant effects on the environment after mitigation measures are implemented. All documents referenced in this Final EIR are available for public review at the Burlingame City Hall at 501 Primrose Road in the City of Burlingame during front counter and phone hours, Monday through Friday, 8:00 a.m. to Noon, and 1:00 p.m. to 5:00 p.m. (closed on Wednesday afternoons).

The Final EIR will also be available for review on the City’s website, www.burlingame.org, and at the Burlingame Public Library at 480 Primrose Road in the City of Burlingame. In accordance with the CEQA guidelines, the Final EIR will be made available to the public and commenting agencies a minimum of ten days prior to the EIR certification hearing.

1.4 REPORT ORGANIZATION This document is organized as follows:

Chapter 1: Introduction. This chapter describes the proposed project, the environmental review process, and the purpose of the Final EIR. The agencies and individuals who received the Notice of Availability (NOA) of the Draft EIR and the agencies and individuals that commented on the Draft EIR are included in this chapter.

Chapter 2: Responses to Comments on the Draft EIR. This chapter contains copies of comments received during the public review period and responses to those comments. Each comment letter is coded with the initials of the commenter or agency/organization acronym. Each comment is bracketed in the margin of the letter and assigned a secondary, comment‐specific number. For example, the first comment in the letter from Caltrans is CT‐1. Each comment letter is followed by a response corresponding to the bracketed comment.

Chapter 3: Revisions to the Text of the Draft EIR. This chapter presents changes to the Draft EIR that reflect text changes initiated by City staff after publication of the Draft EIR and in response to comments to clarify, update, or correct the Draft EIR text. The text changes have not resulted in significant new information with respect to the proposed project, including any new potentially significant environmental impacts that cannot be mitigated to a less‐than‐significant level, or in any new mitigation measures. Corrections to the text and tables of the Draft EIR are contained in this chapter. Underlined text represents language that has been added to the Draft EIR; text with strikethrough has been deleted from the Draft EIR.

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Chapter 4: References. This chapter lists the references cited in this document.

1.5 LIST OF AGENCIES, ORGANIZATIONS, AND INDIVIDUALS WHO RECEIVED THE DRAFT EIR OR NOTICE OF AVAILABILITY

Table 1.5‐1 includes the agencies and organizations that received the NOA for the proposed project from the City of Burlingame. The NOA was also mailed to the residences within a 300‐foot radius of the proposed project. The mailing list for the NOA is included in Appendix A.

Table 1.5-1 Agencies and Organizations that Received the NOA

Name of Agencies and Organizations Contact and Title

Bay Area Air Quality Management District (BAAQMD) Robert Bartley, Air Quality Engineering Manager Technical Services

Burlingame School District Maggie MacIsaac, Superintendent

City of Millbrae Tonya Ward, Community Development Director

City of San Mateo Ron Munekawa, Chief of Planning

Pacific Gas & Electric Company (PG&E) Tom Zlatunich, Land Surveying & Engineering Support

Peninsula Corridor Joint Powers Board Jim Hartnett, Executive Director

Samtrans Corrine Goodrich, Manager of Strategic Development

San Francisco Bay Regional Water Quality Control Board

Bruce H. Wolfe, Executive Office

San Mateo County Tom Madalena, C/CAG and Jim Eggemeyer, Director of Planning and Building Division

San Mateo County Airport Land Use Committee Dave Carbone, C/CAG

San Mateo Union High School District Dr. Kevin Skelly, Superintendent

Town of Hillsborough Elizabeth Cullinan, Director of Building and Planning

1.6 LIST OF AGENCIES, ORGANIZATIONS, AND INDIVIDUALS COMMENTING ON THE DRAFT EIR

Table 1.5‐1 provides a summary of the agencies, organizations, and individuals commenting on the Draft EIR. Table 1.6‐1 also identifies the date the comment letter was received. Complete copies of all letters received are included before the responses to the comments.

A public meeting was held during the circulation period of the Douglas Avenue Multi‐Family Residential Development Project Draft EIR. The meeting was held on October 11, 2016 with the City of Burlingame Planning Commission in Burlingame City Hall. The public was invited to provide comments on the Draft EIR during this meeting. Planning Commissioners were also

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given the opportunity to comment on the Draft EIR. The verbal comments from this meeting on the Draft EIR were recorded in the Meeting Minutes. The Meeting Minutes are included in Section 2.5: Public Meeting Comments.

Table 1.6-1 Agencies, Organizations, and Individuals that Commented on the Draft EIR

Name, Title, and Affiliation Comment Code Date

State Agency

California Department of Transportation

CT September 20, 2016

Organizations

HOA Board HOA October 11, 2016

Individuals

Anonymous resident of Burlingame

AN October 18, 2016

Clarke So CS October 14, 2016

Danielle Rienks DR1 October 10, 2016

Danielle Rienks DR2 October 12, 2016

Dion Heffran DH September 7, 2016

Gerald Weisl GW October 14, 2016

John Root JR October 14, 2016

Individuals and Public Commissioners at the Public Meeting

PM October 11, 2016

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2 RESPONSES TO COMMENTS ON THE DRAFT EIR


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2.1 COMMON COMMENTS AND RESPONSES Comments that raise questions regarding the adequacy of the EIR or analyses in the EIR require substantive responses. Comments that contain only opinions regarding the proposed project do not require substantive responses in the Final EIR. Chapter 2 presents the comments received during the public review period and the City responses to the comments. Similar issues were raised in various comments; therefore, master responses addressing similar comments are included in Section 2.1. For each master response, the corresponding comment numbers are listed at the beginning of the response.

Section 2.2 includes a copy of the Meeting Minutes for the public hearing held on October 11, 2016 to discuss the Draft EIR, and responses to those comments made at the hearing. Furthermore, Sections 2.3 through 2.11 include a copy of and responses to each letter received during the public review period regarding the Draft EIR. Each comment letter is reproduced in its entirety, in the same order as listed in Table 1.5‐1. Each letter is followed immediately by responses to its comments. The comment number and text of the individual comment are presented before each response for ease of reference.

2.1.1 Master Response 1 – Impacts to Traffic and Parking Master Response 1 is in response to comments PM‐1, PM‐4, PM‐5, PM‐6.7, PM‐6.22, CS‐3, DR1‐10, DR2‐2, DH‐1, GW‐1, GW‐3, and JR‐3. These comments focus on the following topics:

Potential impacts to traffic from the increased number of residents of the proposed project

Effects to street parking Insufficient parking for the residents of the proposed building Lack of guest parking

The proposed project would be subject to the City of Burlingame R‐4 District Regulations, Off‐Street Parking Regulations, and Design Standards for Residential Areas of the Downtown Specific Plan. A focused transportation and parking analysis was conducted for the proposed project; the traffic and parking analysis is included in the Draft EIR in Appendix H. The analysis of project parking demand was based on City parking code requirements and parking studies performed for other multi‐family residential units.

2.1.1.1 Traffic Impact Transporation‐1 identifies the potential traffic impacts from the increased use of vehicles in the neighborhood. Table 3.13‐5 on page 3.13‐12 identifies the additional number of daily trips that would be generated by the proposed project. This analysis is considered conservative



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because it was based on a larger number of units than are currently proposed (29 rather than 27) and includes the trips for all residents and does not give credit for the estimated 10‐15 percent of residents who are likely to use public transit such as Caltrain (the train station is approximately two blocks from the proposed project).

The proposed project development is designed to allow residents to take full advantage of public transit opportunities and City code requirements for the Downtown areas reflect this trend. Residents living in downtown areas typically walk to many destinations.

Since the publication of the Draft EIR, the number of residential units included in the proposed project was reduced from 29 to 27, thereby reducing the impact on traffic below the level analyzed in the Draft EIR. The traffic impact on Page 3.13‐12 is revised as follows:

“The proposed project at 1128‐1132 Douglas Avenue would consist of 27 29 apartment units. Based on ITE daily and peak hour trip generation for multi‐family (apartment) units, the project would be expected to generate 180 193 daily trips with 14 15 AM peak hour trips and 17 18 PM peak hour trips as shown in Table 3.13‐54.

The net increase in proposed project trips would represent the difference between existing residential uses on‐site and proposed project trip generation. As shown in Table 3.13‐5, this net increase in site vehicle trips would amount to 134 147 daily trips with 10 11 AM peak hour trips (3 in, 7 8 out) and 12 13 PM peak hour trips (8 9 in, 4 out) for proposed project uses.”

Table 2.1-1 Proposed and Net New Project Daily and Peak Hour Trip Generation 1128-1132 Douglas Avenue Residential Project

Daily Trip AM Peak Hour Trip Rate/Unit PM Peak Hour Trip Rate/Unit

Land Use Category

Unit Rate Total In % Out % Total In % Out %

Apartment du 6.65 0.51 20 80 0.62 65 35

Size Daily AM Peak Hour Trips PM Peak Hour Trips

Project Uses Trips Total In Out Total In Out

Apartment 2729 180193 1415 3 1112 1718 1112 6

Proposed Project Trips 180193 1415 3 1112 1718 1112 6

Existing Project Trips (46) (4) (0) (4) (5) (3) (2)

Net New Project Trips 134147 1011 3 78 1213 89 4

Source: Institute of Transportation Engineers (ITE), Trip Generation, 9th Edition, Single-Family Detached Housing (#210) and Apartment (#220), 2012.



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The conclusion in the traffic analysis (Omni Means 2015) states:

“The proposed Douglas Avenue Multi‐Family Apartment project (29 units) would not significantly affect traffic flows in the project study area. Allowing for vehicle trips from existing residential development currently on‐site, the proposed project would be expected to generate 147 net new daily trips with 11 net new a.m. peak hour trips and 13 net new PM peak hour trips. Proposed project development would be consistent with land use assumptions contained within the City of Burlingame’s Downtown Specific Plan that assumed 1,232 residential units could be constructed within the Downtown area.”

It is reasonable to assume that the net increase in residential uses (21 units) from the proposed project has been included in the land use projections for the Downtown Specific Plan. The reduction in the number of units from 29 units to 27 units would reduce the traffic impact from 147 new daily trips analyzed in the Draft EIR to 134 new daily trips. The traffic analysis in the Downtown Specific Plan found that the intersections within the vicinity of the proposed project would not be significantly affected by the development planned in the Downtown Specific Plan. The traffic impact would be consistent with City standards and would be less than significant.

2.1.1.2 Parking Title 25, Chapter 25.70.032 of the City of Burlingame municipal code identifies the parking requirements for duplexes, apartments, hotels, and condominiums located within the Downtown Specific plan area. Page 3.13‐15 of the Draft EIR show that the 34 parking spaces were included in the project consistent with the requirements identified in the municipal code. The number of parking spaces that are included in the proposed project has been reduced to 33 to reflect the reduction in the number of units, as shown in Table 2.1‐1 below. The project would provide sufficient parking for the residents of the proposed building.

Table 2.1-2 Proposed Project Residential Units and City Parking Space Requirements

Type of Unit Number of Units Number of Parking

Spaces per Unit Total Spaces

Studio 3 1 3

1 Bedroom 1418 1 1418

2 Bedroom 97 1.5 13.510.5

3 Bedroom 1 2 2

Total 2729 32.5=33 33.5=34 parking spaces

2.1.1.3 Guest Parking Several comments raised concerns that off‐street parking would be affected by guests that would visit residents of the proposed building. Several of the commenters were concerned that the proposed project does not include guest parking in the design of the proposed project and recommended certain design elements to be incorporated into the project, such as a turnaround



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for parking, a white zone for short‐term parking, and obtaining a permit from Caltrain to use the parking adjacent to the Caltrain tracks.

The Downtown Specific Plan does not require guest parking, as stated on page 3.3‐16 of the Draft EIR and the project complies with Title 25, Chapter 25.70.032 of the City of Burlingame municipal code, as described above in Section 2.1.1.2. The Draft EIR does however, identify the potential impacts from guest parking (page 3.3‐15). The Draft EIR indicates that there would be a demand for 4‐5 parking spaces for guests, after considering that the proximity to the Caltrain station parking lot would reduce the overall demand for parking. Guest parking is available in the neighborhood, at the Caltrain station (one block away at the end of Douglas Avenue), and at public parking lots downtown. The conclusion in the parking analysis was that guest parking would not result in a significant impact.

Since the public meeting on October 11, 2016, the project has been revised to reduce the number of residential units from 29 to 27. This includes reducing the number of 1‐bedroom units from 18 to 14 and increasing the number of 2‐bedroom units from 7 to 9; the number of studio units (3) and 3‐bedroom units (1) remained the same. Based on the number of bedrooms per unit proposed for this project, the Zoning Code requires a total of 33 off‐street parking spaces for the residents of the units (1 space for each studio and one‐bedroom unit, 1.5 spaces for each two‐bedroom unit and 2 spaces for each unit containing three or more bedrooms). The project includes 12 at‐grade parking spaces at the rear of the lot and 22 below‐grade parking spaces in an underground garage, for a total of 34 off‐street parking spaces. Although an area for on‐site deliveries is not required for apartment buildings and there is no guest parking required on‐site for properties located within the Downtown Specific Plan area, one parking space located within the at‐grade parking area at the rear of the site has been designated as a guest/delivery parking space.

2.1.1.4 Additional Project Features Several commenters suggested that the project should include additional features, such as more parking, guest parking, and a turn‐around or circular driveway. The parking effect is less than significant and does not merit mitigation under CEQA. The Planning Commission, as the agency responsible for reviewing the design of the project, will determine if additional features should to be incorporated into the design of the project, if the project is approved. The additional features would further reduce less than significant traffic effects and may be added as conditions of approval.

2.1.2 Master Response 2 – Impacts from Deliveries and ITE Standards Master Response 2 responds to comments PM‐1, PM‐4, PM‐5, PM‐6.7, PM‐6.19, and JR‐4. These comments focus on the potential impacts to traffic and parking from the increased number of deliveries to residents at the proposed project. Commenters also asked about the ITE (Institute of Traffic Engineers) data and the ITE Standards used to calculate the impact in the Draft EIR.



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2.1.2.1 Deliveries and ITE Standards Several comments raised concern about the potential traffic and parking impacts from the additional delivery truck trips that would result from the proposed project. Several commenters were also concerned that the standard used to determine the impact from delivery trucks was outdated. The Draft EIR explains that the delivery trips that would be generated by the proposed project are incorporated into the overall calculation for total project trips. The proposed project trip generation was calculated by using the latest standards established by the Institute of Transportation Engineers (ITE). ITE collects vehicle trip data within different land uses. ITE published their latest Trip Generation Manual (9th edition) in 2012, which indicated that an apartment generates approximately 6.65 trips per dwelling unit (see Table 3.13‐1 on page 3.13‐4). The ITE standards provide the most recent field‐verified information and is routinely used by transportation planners and engineers. The ITE Standards are 4 years old and although on‐line sales may have increased in the last 4 years, there is no available data that shows that the number of deliveries has increased substantially in that period. It is reasonable and customary to use the most recently available ITE standards. Furthermore, many of the comments noted that delivery trucks are frequently on Douglas Avenue delivering packages. It is likely that packages going to the proposed building would be on delivery trucks that had already planned trips to deliver packages to other residences on Douglas Avenue. The proposed project would, therefore, not substantially increase the number of delivery truck trips.

2.1.2.2 Additional Project Features Several comments suggested that certain design elements be incorporated into the project to minimize the traffic and parking impacts from truck deliveries, including a turnaround design or a white zone for short‐term parking. The Focused Transportation and Parking Analysis (Omni Means 2015) report for this project notes that the City of Burlingame may want to consider installing a white curb or restrictive yellow space along a portion of the frontage of the proposed project to allow for the loading or unloading of passengers, freight, mail, or deliveries (page 8 of Appendix H of the Draft EIR). As previously noted, one parking space located within the at‐grade parking area at the rear of the site has been designated as a guest/delivery parking space. Although this space would not be accessible by a large delivery truck, it would be available for smaller trucks/vehicles providing services to the apartment building, such as building/site maintenance or repairs. The Department of Public Works noted that installation of a white curb or yellow restricted space is not possible since it would eliminate several on‐street parking spaces and provides no guarantee that a delivery vehicle would use the designated space rather than double‐park along the street. The Planning Commission is the agency responsible for reviewing the design of the project and will determine if a turnaround design would be required in response to public comment.

2.1.3 Master Response 3 – Height of the Proposed Project Master Response 3 responds to comments PM‐4, PM‐6.3, HOA‐1, CS‐1, DR1‐9, DR2‐1, DR2‐11, GW‐3, JR‐2. These comments focus on the potential impacts to the visual quality of the neighborhood caused by the height of the proposed project.



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The proposed height of the building (60 feet) requires that the applicant obtain a conditional use permit, but is below the City’s conditionally allowable height of 75 feet. The project has been revised so that the fifth floor is stepped back 10 feet from the rest of the building along the front façade.

Impact Aesthetics‐3 (pages 3.1‐14 to 3.1‐17 of the Draft EIR) describes how the proposed project, including the height, could potentially degrade the existing visual quality of the site and its surroundings. The Draft EIR presents an analysis of the potential visual quality impacts related to the height of the building and identifies the inconsistencies with any goals, objectives, policies, and implementation actions of the City of Burlingame that relate to height of buildings (see Table 3.1‐2 on pages 3.1‐15 to 3.1‐17). The goals, objectives, policies, and implementation actions that the proposed project would potentially conflict with due to the height of the proposed project are shown in Table 3.1‐2 of the Draft EIR and in Table 2.1‐2 below. Table 2.1‐2 shows the additional information that has been added to clarify how the proposed project is inconsistent with City policies regarding the height of buildings.

Table 2.1-3 Inconsistencies with City of Burlingame Plans and Policies Due to the Height of the Proposed Project.

Plans and Policies Consistency

General Plan Community Development Goal II: To maintain and enhance the identity of the City and encourage a maximum sense of identification by residents with the City. c. Establish a pattern of dominance and subordination in important visual features; create harmony with diversity.

Potentially Inconsistent. The height and bulk of the structure as proposed dominate the site, and adds one multistory, dominant type of structure on the street and removes two subordinate, two-story single-family structures. The project, consisting of a four-story façade with a stepped back fifth story, contributes a dominant structure and removes two subordinate structures but still allows the street to retain the diverse pattern as there are two-, three-, and four-story structures on the street.

Downtown Specific Plan Goal S-1: Improve the streetscape, particularly at the pedestrian scale.

Inconsistent. Consistent. Ground level treatment with consisting of a wide entrance walks, benches, and water features would add diversity to existing street experience and improves the streetscape at the pedestrian scale. Height of building would dominates a sense of pedestrian scale, but it is set back 18 to 31 feet from the front property line.



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5.3.1. Architectural Diversity Respect the mass and fine scale of adjacent buildings even when using differing architectural styles.

Partially Inconsistent. The Although the existing building is approximately 20-25 feet taller than any other building in the block, the proposed project is consistent with the adjacent modern style building and with other existing buildings on the block characterized by simple massing, flat walls and repetitive fenestration. Along the front façade, the top floor is set back 10 feet from the rest of the building, providing a sense of a four-story building when viewed from nearby locations.

Maintain the tradition of architectural diversity, but with human scale regardless of the architectural style used.

Partially Inconsistent. At a height of 57 feet, plus rooftop appurtenances and with repetitive design elements, the building exceeds a human scale as seen from the immediate neighborhood. However, human-scale elements, such as a front entry element, a pedestrian walk, water feature and benches are provided at street level, and individual balconies are provided on the upper floors.

5.3.2.1 Architectural Compatibility Massing and street facades shall be designed to create a residential scale.

Partially Inconsistent. Continuous repetition of elements on the upper stories is not consistent with enhancing visual interest and creating a sense of human scale, however this design element exists on multifamily residential buildings on this block. The proposed project provides human-scale elements at the street level, such as a front entry element, a pedestrian walk, water feature, and benches, and on the upper levels individual balconies provide residential scale and character.



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Plans and Policies Consistency Articulation, setbacks, and materials should minimize massing, break down the scale of buildings, and provide visual interest.

Partially Inconsistent. The Although the design of the upper stories is repetitive of the lower levels and on a single plane, with no variation in setbacks. the building is viewed as a single large mass, articulation is provided by way of using a different material on the ground level (horizontal wood siding), incorporating balconies throughout the building, horizontal sun shades above windows, projecting eaves, setting back the front right corner of the building, and articulating the walls along the front and left sides of the building.

5.4.1.1 Massing and Scale Transitions: Transitions of development intensity from higher density development building types to lower can be done through different building sizes or massing treatments that are compatible with the lower intensity surrounding uses. Massing and orientation of new buildings should respect the massing of neighboring structures by varying the massing within a project, stepping back upper stories, reducing mass by composition of solids and voids, and varying sizes of elements to transition to smaller scale buildings.

Partially Inconsistent. Massing has only moderate composition of solids and voids to transition to smaller scale buildings. Stepping back the upper floor along the front of the building varies the massing and helps to transition to smaller scale buildings.

5.4.1.1 Privacy: Privacy of neighboring structures should be maintained with windows and upper floor balconies positioned so they minimize views into neighboring properties, minimizing sight lines into and from neighboring properties, and limiting sun and shade impacts on abutting properties.

Inconsistent. Windows and upper floor balconies not reflective of minimizing sight lines into surrounding neighboring properties. The proposed 5-story building would shade an approximately 80 percent greater area than existing structures on the properties. Stepping back floors would reduce views to neighboring properties and reduce shading.

The Draft EIR identifies several inconsistencies with plans and policies and a potential significant impact to the visual character or quality of the site and its surroundings, including the impact from the height of the building. Mitigation Measure (MM) AES‐1 is proposed to reduce the impact to less than significant. MM AES‐1 requires the applicant to submit the revised plans to the Planning Commission for design review. As described in MM AES‐1 (page 3.1‐13 of the Draft EIR) the Planning Commission is the agency responsible for reviewing the design of the project and its compatibility with the City of Burlingame’s guidelines for a residential building in the Downtown Specific Plan R‐4 Base District. The Planning Commission will be the agency that determines if the height of the building is compatible with the City of Burlingame’s guidelines.

The Draft EIR presents an analysis of two Alternatives with a reduced height. Section 4: Alternatives describes Alternative 1, which reduces the height of the building from five stories to four stories with no changes in density and Alternative 3, which reduces the height of the building from five stories to four stories and reduces the density of the building. The City of



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Burlingame will decide whether to approve the proposed project or one of the Alternatives (including the no project alternative) after certification of the Final EIR.

2.1.4 Master Response 4 – Impacts to Trees Master Response 4 responds to comments PM‐4, AN‐5, AN‐15, DR1‐4, DR1‐14, DR2‐8, and JR‐9. These comments focus on the potential for additional impacts from damaging trees at the Douglas Avenue Project Site, such that the trees would need to be removed. Several of the comments raised a specific concern about the potential damage that could occur to the historic redwood tree located on the Douglas Avenue project site and the impact from removing the tree because of the damage.

The potential impact to protected trees that are not planned for removal is analyzed on pages 3.3‐18 and 3.3‐19. MM BIO‐2 requires that the applicant implement series of measures to avoid and minimize impacts to protected trees during construction. As summarized on page 3.3‐19, MM BIO‐2 requires measures to protect trees, including:

Placing fencing around protected trees, Taking immediate remedial action if a protected tree is damaged, Restricting stockpiling of soils around trees, and Restricting attaching signs, wires, or other devices to trees.

These measures are consistent with the tree protection guidelines established in the City of Burlingame Ordinance (Chapter 11.06.050).

The potential impact to the redwood tree would be from damaging the roots of the tree during construction. The Draft EIR addresses the concern about potential impacts to redwood tree roots on pages 3.3‐19 and 3.3‐20 of the Draft EIR. MM BIO‐2 includes specific measures to ensure that the redwood tree roots are protected. Pages 3.3‐21 and 3.3‐22 identifies that prior to any excavation activities, the Project Arborist will evaluate significant roots and make recommendations to protect the roots and preserve the health of the redwood tree. The evaluation and recommendations would be submitted to the City of Burlingame prior to excavation to allow the City arborist to determine whether the measures are adequate. MM BIO‐2 also includes measures for the actions that would be taken if roots smaller than 2‐inches and larger than 2‐inches are discovered during construction:

“When roots that are 2 inches or smaller are encountered during excavation, the wall of the trench next to the tree shall be hand trimmed, making clear cuts through the roots. Damaged, torn, and cut roots shall be given a clean cut to remove ragged edges. Trenches will be filled within 24 hours and when that is not possible the side of the trench next to the tree shall be shaded with four layers of dampened, untreated, and wetted burlap. When roots that are 2 inches or greater are encountered during excavation, the Project Arborist shall be notified and they will determine whether roots may be cut as mentioned above or whether they shall be excavated by hand or with compressed air under the roots. Roots 2‐inches or larger will be protected with dampened burlap.”



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A Project Arborist will implement MM BIO‐2 to ensure that the measures are enforced and properly implemented.

MM BIO‐2 has been approved by the City Arborist. MM BIO‐2 would ensure that the impacts to trees, including impacts to the redwood tree, would be less than significant.

2.2 PUBLIC MEETING COMMENTS The following text reflects comments stated or questions that were raised at the public hearing for the Douglas Avenue Multi‐Family Residential Development Project Draft EIR held on October 11, 2016. These comments were not transcribed verbatim, but rather they provide a representation of those comments and questions received. The following text also includes responses to those comments.



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2.2.1 Response PM-1 The comments that current buildings in the area include a 3‐story condominium and 4‐story building with the top floor stepped back so it is not visible from the street and that the commenter favors Alternative 3 are noted.

See Master Response 1 for the response to similar comments on the potential impacts to parking from the proposed project.

See Master Response 2 for the response to similar comments on the potential traffic and parking impacts from deliveries related to the proposed project and the ITE standards.

The comment that the proposed project does not fit in with the charm of the existing residential neighborhood is noted. MM AES‐1 provides for the Planning Commission to consider design modifications to improve the compatibility of the structure with the other structures in the neighborhood. Impact Aesthetics‐3 on pages 3.1‐14 to 3.1‐17 addresses the potential impact related to the project not fitting with the aesthetics of the surrounding neighborhood and thereby not fitting “with the charm of the existing residential neighborhood.” This analysis was conducted by identifying the potential inconsistencies with design standards established by City of Burlingame policies, goals, and objectives (see Table 3.1‐2). The final decision about the design of the proposed project will be made by the Planning Commission. For the response to similar comments about how the height of the proposed project fits with the existing neighborhood, see Master Response 3.

Regarding the comment that landscaping could soften the driveway, landscaping is included as a part of the proposed project and would soften the driveway appearance.

2.2.2 Response PM-2 The comment that Alternative 3 is supported is noted. The comments that the proposed project is inconsistent with design guidelines established in the Downtown Specific Plan based on the following elements is noted:

Window pattern is not varied Aluminum, flush windows are used instead of wood and inset The design is ordinary The windows, façade, and materials are nondescript The building is not richly detailed with quality material

The decision on the design of the project will be made by the Planning Commission.

2.2.3 Response PM-3 The alternatives have been analyzed in the EIR and a new EIR would not be needed unless a completely new alternative (with greater impacts) is presented. Mitigation measures would be included as Conditions of Approval for the project or any alternative. The comment that Alternative 2 is preferred is noted.



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2.2.4 Response PM-4 Comments PM‐4 are addressed in Master Responses, above:

See Master Response 4 for the response to similar comments on the potential impact to the redwood tree on the Douglas Avenue project site;

See Master Response 1 for discussion of the potential impacts to traffic from the proposed project; and

See Master Response 2 for discussion of the potential traffic and parking impacts from deliveries to the proposed building.

The Shadow Study for the proposed project was provided as Appendix B of the Draft EIR and considers all the existing buildings surrounding the Douglas Avenue project site.

The Draft EIR considers two Alternatives with a reduced height (see Master Response 3).

2.2.5 Response PM-5 A detailed shadow analysis was prepared for the project and was included in the Draft EIR as Appendix B. See Master Response 1 for a discussion of the potential impacts to parking from the proposed project. See Master Response 2 for a discussion of the potential traffic and parking impacts from deliveries from the proposed project

2.2.6 Response PM-6 Several comments were made by the Planning Commissioners. Each individual comment was given a number as shown in the Meeting Minutes and each individual comment is responded to individually.

2.2.6.1 Response PM-6.1 The allowable construction hours within residential areas in the City of Burlingame have been changed per Ordinance No. 1930 (Ordinance of the City of Burlingame Amending Section 18.07.110 of the Burlingame Municipal Code to Restrict Construction Hours), which became effective on October 19, 2016. The change includes a construction start time of 8:00 a.m. on weekdays, 9:00 a.m. on Saturdays, and no construction on Sundays and City‐recognized holidays. The project will be subject to this change. The proposed project will be required to comply with this new ordinance.

2.2.6.2 Response PM-6.2 The commenter requested additional rationale for the conclusions for Goal D‐3 and other goals in Table 3.1‐2 in the Aesthetics section of the Draft EIR. Additional information is added to the table as shown below.



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Table 3.1-2 Proposed Project Consistency with City of Burlingame Plans and Policies


General Plan Community Development Goal II: To maintain and enhance the identity of the City and encourage a maximum sense of identification by residents with the City. c. Establish a pattern of dominance and subordination in important visual features; create harmony with diversity.

Potentially Inconsistent. The height and bulk of the structure as proposed dominate the site, and adds one multistory, dominant type of structure on the street and removes two subordinate, two-story single-family structures. The project, consisting of a four-story façade with a stepped back fifth story, contributes a dominant structure and removes two subordinate structures but still allows the street to retain the diverse pattern as there are two-, three-, and four-story structures on the street.

d. Create distinctive visual qualities - a Burlingame image (analyze existing visual qualities and build on the best of these).

Partially Inconsistent. While the structure has distinctive visual qualities such as horizontal wood siding on the ground floor and some architectural fenestration, individual floor patterns are repeated above the second story.

f. Use trees of appropriate size and character as a design framework to enhance a sense of identity.

Consistent. Street trees will conform to City specifications.

Downtown Specific Plan Goal S-1: Improve the streetscape, particularly at the pedestrian scale.

Inconsistent. Consistent. Ground level treatment with consisting of a wide entrance walks, benches, and water features would add diversity to existing street experience and improves the streetscape at the pedestrian scale. Height of building would dominates a sense of pedestrian scale, but it is set back 18 to 31 feet from the front property line.

Policy S-1.3: Streetscapes should reflect Burlingame's designation as a “tree city.” Trees should be planted throughout the downtown as an integral part of the streetscape, and mature street trees should be preserved whenever possible.

Consistent. The existing trees will be protected and new trees will be planted.



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Goal D-1: Protect and preserve historic character. Policy D-1.1: Ensure that new construction fits into the context and scale of the existing downtown.

Consistent. Height and bulk of building are similar to other existing multifamily structures on the street and the Downtown Specific Plan anticipates similar heights, up to a maximum of 75 feet. Along the front façade, the top floor is set back 10 feet from the rest of the building, providing a sense of a four-story building when viewed from nearby locations.

Goal D-3: Preserve and enhance small-town scale with walkable, pedestrian-scaled, landscaped streets.

Consistent. Height of building may dominate a sense of pedestrian scale but will maintain the walkable, landscaped street.

Policy D-3.2: Evaluate development in the Downtown Area that is proposed to be taller than surrounding structures (i.e., over 40 feet) for potential to create new shadows or shade on public and/or quasi-public open spaces and major pedestrian routes.

Consistent. Shadow study provided in Appendix B.

5.3.1. Architectural Diversity Design buildings to maintain general compatibility with the neighborhood.

Consistent. The existing neighborhood is generally composed of two- to four-story structures below 50 feet in height, but is generally compatible with the surrounding structures in mass and articulation. Along the front façade, the top floor is set back 10 feet from the rest of the building, providing a sense of a four-story building when viewed from nearby locations.

Respect the mass and fine scale of adjacent buildings even when using differing architectural styles.

Partially Inconsistent. The Although the existing building is approximately 20-25 feet taller than any other building in the block, the proposed project is consistent with the adjacent modern style building and with other existing buildings on the block characterized by simple massing, flat walls and repetitive fenestration. Along the front façade, the top floor is set back 10 feet from the rest of the building, providing a sense of a four-story building when viewed from nearby locations.



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Plans and Policies Consistency Maintain the tradition of architectural diversity, but with human scale regardless of the architectural style used.

Partially Inconsistent. At a height of 57 feet, plus rooftop appurtenances and with repetitive design elements, the building exceeds a human scale as seen from the immediate neighborhood. However, human-scale elements, such as a front entry element, a pedestrian walk, water feature and benches are provided at street level, and individual balconies are provided on the upper floors.

5.3.2.1 Entrances: Primary pedestrian access to all ground-level uses should be from the sidewalk along the public street. Entrances should be clearly defined features of front facades.

Consistent. The primary pedestrian access to the proposed building is from a pedestrian walkway that connects to the Douglas Avenue sidewalk. The entryway is clearly defined by the pedestrian walkway to the front door.

5.3.2.1 Architectural Compatibility Massing and street facades shall be designed to create a residential scale.

Partially Inconsistent. Continuous repetition of elements on the upper stories is not consistent with enhancing visual interest and creating a sense of human scale, however this design element exists on multifamily residential buildings on this block. The proposed project provides human-scale elements at the street level, such as a front entry element, a pedestrian walk, water feature, and benches, and on the upper levels individual balconies provide residential scale and character.

Articulation, setbacks, and materials should minimize massing, break down the scale of buildings, and provide visual interest.

Partially Inconsistent. The Although the design of the upper stories is repetitive of the lower levels and on a single plane, with no variation in setbacks. the building is viewed as a single large mass, articulation is provided by way of using a different material on the ground level (horizontal wood siding), incorporating balconies throughout the building, horizontal sun shades above windows, projecting eaves, setting back the front right corner of the building, and articulating the walls along the front and left sides of the building.



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Plans and Policies Consistency 5.3.2.1 Architectural Design Consistency: Facades should include projecting eaves and overhangs, porches, and other architectural elements that provide human scale and help break up building mass. All exposed sides of a building should be designed with the same level of care and integrity. Facades should have a variation of both positive space (massing) and negative space (plazas, inset doorways, and windows).

Consistent. A front entry element, a pedestrian walk, water feature and benches are provided at street level, and individual balconies are provided on the upper floors to provide human scale and to provide a variation of both positive and negative space.

5.3.2.2 Ground Level Treatment: Residential development may have a finished floor elevation up to 5 feet above sidewalk level to provide more interior privacy for residents. Entry porches or stoops along the street are encouraged to bridge this change in elevation and connect these units to the sidewalk to minimize any physical separation from the street level. The street-level frontage should be visually interesting with frequent unit entrances and clear orientation to the street.

Consistent. The entrance to the proposed building is off-set from the street by the pedestrian walkway, which provides privacy for residents. Landscape features and hardscape features, including a concrete wall and wooden planter/fence also provide privacy to residents. The proposed building is connected to the sidewalk by the pedestrian walkway, which provides clear orientation to the street. The street-level frontage is made visually interesting by the pedestrian walkway, water feature, and benches.

5.3.4.2 Windows Building walls should be accented by well-proportioned openings that provide relief, detail and variation on the facade.

Partially Inconsistent. Although Wwindow patterns are not varied within facades, the project does provide varied window sizes and grid patterns that provide relief to building walls.

Windows should be inset generously from the building wall to create shade and shadow detail.

Inc Consistent. Aluminum window systems flush with are inset approximately four inches from the building walls.

Reflective glass is undesirable because of its tendency to create uncomfortable glare conditions and a visual barrier.

Consistent. The proposed building does not include reflective glass.

Where residential uses are adjacent to each other, windows should be placed with regard to any open spaces or windows on neighboring buildings so as to protect the privacy of residents

Consistent. The building would be separated from the neighboring residences by driveways, walkways, and landscaping.

5.3.4.3 Materials: Building materials should be richly detailed to provide visual interest. The use of materials that are reflected in the historic architecture present is encouraged. Metal siding and large expanses of stucco or wood siding are also to be avoided. Roofing materials and accenting features such as canopies, cornices, tile accents, etc. should also offer color variation. Residential building materials should be made of quality details such as wrought iron, wood framed windows, wood brackets and tile roofs.

Inconsistent. Large expanses of stucco and wood siding proposed. No wood framed windows. Flat roof. No roof The roof is flat roof and lacks accenting features such as canopies, cornices, or tile accents. However, stucco and wood siding, flat roofs and metal/aluminum windows, are present on existing multifamily residential buildings on this block.



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Plans and Policies Consistency 5.4.1.1 Massing and Scale Transitions: Transitions of development intensity from higher density development building types to lower can be done through different building sizes or massing treatments that are compatible with the lower intensity surrounding uses. Massing and orientation of new buildings should respect the massing of neighboring structures by varying the massing within a project, stepping back upper stories, reducing mass by composition of solids and voids, and varying sizes of elements to transition to smaller scale buildings.

Partially Inconsistent. Massing does not step back upper stories has only moderate composition of solids and voids and does not vary sizes of upper floor elements to transition to smaller scale buildings. Stepping back the upper floors varies the massing and helps to transition to smaller scale buildings.

5.4.1.1 Privacy: Privacy of neighboring structures should be maintained with windows and upper floor balconies positioned so they minimize views into neighboring properties, minimizing sight lines into and from neighboring properties, and limiting sun and shade impacts on abutting properties.

Inconsistent. Windows and upper floor balconies not reflective of minimizing sight lines into surrounding neighboring properties. The proposed 5-story building would shade an approximately 80 percent greater area than existing structures on the properties. Stepping back floors would reduce views to neighboring properties and reduce shading.

Burlingame Urban Forest Master Plan Sycamore theme tree. Consistent. No sycamore trees would

be removed from the Douglas Avenue project site.

Burlingame Zoning Regulations: Chapter 25.29 R-4 Residential District No building or structure shall be constructed in an R-4 district which exceeds six (6) stories or seventy-five (75) feet in height

Consistent. The proposed building is 5 stories and 60 feet in height and thus does not exceed the height limits of 6 stories and 75 feet.

The maximum lot coverage for all buildings and structures, including balconies, stairs, roof overhangs exceeding twenty-four (24) inches, trellises and improvements which exceed thirty (30) inches in height, shall be fifty (50) percent for interior lots and sixty (60) percent for corner lots.

Consistent. The proposed project lot is an interior lot and has a lot coverage of 49.40 percent (see page A 1.0 of the proposed project site plan). The proposed project does not exceed the maximum lot coverage of 50 percent.

2.2.6.3 Response PM-6.3 See Master Response 3 for an in‐depth discussion about the potential inconsistencies with City of Burlingame policies, goals, and objectives from the height of the proposed project.

2.2.6.4 Response PM-6.4 The proposed project is consistent with the intent of the Downtown Specific Plan because the proposed project would be consistent with the goals and policies established in the Downtown Specific Plan. The pertinent parking policies for the proposed project and the rationale for the project’s consistency with those goals and policies are described in Table 2.2‐1.



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Table 2.2-1 Proposed Project’s Consistency with Downtown Specific Plan Parking Goals and Policies

Goals and Policies Consistency Goal P-1: Explore creative parking solutions. Policy P-1.1: Encourage the use of “alternative” vehicle types with ample bicycle parking and free parking for electric cars.

The proposed project is considered transit oriented development because it is near a Caltrain station. The proposed project’s proximity to the Caltrain station encourages the use of public transportation.

Policy P-1.2: Devote less land for parking Downtown while accommodating increased demand by using the land more efficiently with decked or underground parking.

The proposed project design includes a below-ground parking structure.

Policy P-1.3: Conceal parking areas through the use of attractively designed above- or below-ground parking structures. Goal P-4: Re-examine Downtown parking requirements Policy P-4.1: Downtown parking requirements should promote more efficient use of land. For example, consider shared parking, proximity to transit, and walking distance.

The downtown area is walkable from the proposed project.



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2.2.6.5 Response PM-6.5 The parking requirements in the Downtown Specific Plan can be revisited but the proposed project is subject to the current policies in the Downtown Specific Plan.

2.2.6.6 Response PM-6.6 The information in Table 3.13‐1 identifies the assumptions that were made to calculate the numbers in Table 3.13‐2. Table 3.13‐1 identifies the typical trip rates (trips per dwelling unit) that are used to calculate the number of trips that would be generated for apartments and single‐family homes. Table 3.13‐2 identifies the trips that are estimated for the existing 4‐unit apartment and 2‐unit single‐family home at 1128‐1132 Douglas Avenue. It is necessary that Tables 3.13‐1 and 3.13‐2 use different metrics (rate of trips and total trips) because they show two different pieces of information.

2.2.6.7 Response PM-6.7 See Master Response 1 and 2 regarding impacts to traffic and parking from deliveries or guest parking, including the consideration of a turnaround design. The project includes one space dedicated for deliveries or guest parking due to the reduction in the number of residential units.

2.2.6.8 Response PM-6.8 As described in Response PM‐6.1, the permissible construction hours have been changed by Ordinance No. 1930 (Ordinance of the City of Burlingame Amending Section 18.07.110 of the Burlingame Municipal Code to Restrict Construction Hours). The Draft EIR limited the construction hours through MM Noise‐4. The noise limits in MM Noise‐4 are consistent with Ordinance No. 1930, except for the construction start time on weekdays; MM Noise‐4 is amended to match the noise ordinance start time of 8 a.m. on weekdays and 9 a.m. on Saturdays. The 1 hour later start would still allow for 8‐hour construction days; therefore, the newly adopted construction hours will not impact the duration of the proposed project construction. The applicant has indicated that the revised hours would not change the construction duration.

2.2.6.9 Response PM-6.9 A person traveling in a vehicle at approximately 25 miles per hour (mph) would see the proposed project for approximately 30 seconds. An average bicyclist travels at approximately 10 mph; therefore, a bicyclist on Bellevue Avenue would be exposed to the proposed project for approximately 1 minute and 15 seconds. An average pedestrian walks at approximately 3 miles per hour; therefore, a pedestrian walking on Bellevue Avenue would be exposed to the proposed project for approximately 4 minutes and 10 seconds.

2.2.6.10 Response PM-6.10 The analysis of the cumulative aesthetic impacts on pages 3.1‐19 and 3.1‐20 identifies the assumptions made in determining that the cumulative aesthetic impact is less than significant. The cumulative aesthetic impact is considered less than significant because all new development projects are required to be consistent with the guidelines adopted in the Downtown Specific Plan.



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2.2.6.11 Response PM-6.11 Yes, the Tree Study was peer reviewed by the City Arborist. Appendix D of the Draft EIR provides the City Arborist’s comments on the Tree Study.

2.2.6.12 Response PM-6.12 The proposed project will plant trees in the ground, rather than in planters.

2.2.6.13 Response PM-6.13 See Response PM‐6.14, PM‐6.15, PM‐6.18, PM‐6.19, and PM‐6.27 regarding the data that was used in the Draft EIR.

2.2.6.14 Response PM-6.14 Page 3.11‐5 also includes the reference for the 5.1% vacancy rate. The 5.1 percent vacancy rate data was obtained from the California Department of Finance report E‐5 Population and Housing Estimates for Cities, Counties, and the State for the years of 2011 to 2015 (California Department of Finance 2015). The 5.1 percent vacancy rate was calculated by finding the percentage of housing units that were vacant. The Report identified a total of 13,077 housing units, of which 12,409 were occupied and 668 were vacant in 2015 (668/13,077). The vacancy rate accounts for all housing units and therefore all rents.

Data for 2016 was made available by the Department of Finance after the analysis for Population and Housing was calculated and was thus not included in the Draft EIR. The 2016 data shows that the City of Burlingame has a vacancy rate of 7.6 percent, with 13,114 total housing units, 12,115 of which are occupied and 999 were vacant (California Department of Finance 2016).

The vacancy rate for 2016 is greater than the 2015 vacancy rate. This change would not change the analysis discussed in the Draft EIR. The larger vacancy rate shows that the City of Burlingame has sufficient housing to accommodate the 22 persons displaced by the proposed project.

The vacancy rate was updated in the EIR to reflect the most recent data. Table 3.11‐2 on page 3.11‐2 of the Draft EIR has been changed as follows:

Table 3.11-2 Housing Estimates and Projections

City or County

2010 Housing

Housing Projections1 Growth Percentage

Vacancy2 Rate 2020 2025 2030 2035 2040

San Mateo County

257,8371 277,200 286,790 296,280 305,390 315,100 0.01% 4.9%

City of Burlingame

13,0273 13,620 14,230 14,890 15,520 16,170 0.05% – 0.8%

7.6% 5.1%

Source: 1ABAG 2009, 2California Department of Finance 2016 2015, and 3U.S. Census Bureau 2015



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Page 3.11‐5 of the EIR is changed as follows:

The demolition activities and the movement of the historical home would result in the displacement of the current occupants, which are estimated to be 22 people (19 on Douglas Avenue and 3 on Oak Grove Avenue). There is existing housing in the City that could accommodate this small number of displaced persons. The City has a vacancy rate of 7.6 5.1 percent, which is sufficient to accommodate persons displaced by the proposed project (California Department of Finance 2016 2015). The proposed project would ultimately create more housing through the construction of 27 apartments that could house up to 62 people. The proposed project would add 27 units in the City and would help the City fulfill its housing needs obligation of 863 units for the 2015 to 2023 planning period. The proposed project would not displace substantial numbers of existing housing units or people and would not necessitate the construction of replacement housing. The impact would be less than significant.

Page 3.11‐5 of the EIR is changed as follows:

Housing development projects in the City are in varying stages, and new housing is constructed as some older units are demolished. In the Downtown Specific Plan area, multi‐family housing units are replacing single‐family houses and thereby providing more housing units to meet the City’s projected housing needs. The City currently has an overall vacancy rate of 7.6 5.1 percent which is adequate to accommodate displaced residents from the proposed project and other projects that may displace residents at the same time.

Section 3.11.7 References on page 3.11‐6 of the EIR is changed as follows:

California Department of Finance. 2016. ʺE‐5 Population and Housing Estimates for Cities, Counties, and the State, 2011‐2016 with 2010 Census Benchmark.ʺ

California Department of Finance. 2015. Report E‐5 Population and housing Estimates for Cities, Counties, and the State, January 1, 2011‐2015, with 2010 Benchmark.

2.2.6.15 Response PM-6.15 The information in Table 3.12‐1 was the most recent data available at the time the Draft EIR was prepared. The information presented in Table 3.12‐1 was obtained by reviewing the information available from the California Department of Education and the California Department of General Services and by contacting by telephone staff at the City of Burlingame Planning Division, the Burlingame School District, and the San Mateo Union High School District.

Additional enrollment data has been made available for 2015‐2016 since the publication of the Draft EIR. Table 3.12‐1 has been updated with the new enrollment data, as shown below.



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Table 3.12-1 Enrollment Rates and Capacities for Schools Serving the Proposed Project

School Capacity

Student Enrollment During the School Year1 2010-2011

2011-2012

2012-2013

2013-2014

2014-2015

2015-2016 5

McKinley Elementary School 583

2 342 384 386 482 522 519

Burlingame Intermediate School 1,176³ 837 889 922 953 1,004 1,018

Burlingame High School 1,3504 1,360 1,314 1,352 1,306 1,316 1,339

Source: 1California Department of Education 2015, 2G. Hellier, personal communication, Planning Division, personal communication, 4P. Chavez, personal communication 5 California Department of Education 2016a

2.2.6.16 Response PM-6.16 The Downtown Specific Plan does not identify any service ratio goals for schools or parks. The City of Burlingame General Plan does identify goals for schools and parks; however, the policies do not establish a numerical goal. The following goal and implementing objective are a part of the City of Burlingame General Plan.

Community Development Goal 1: Assure that Burlingame will continue to be a ʺwell‐roundedʺ City with residences, schools, business, industry, and space and facilities for social, recreational, and cultural activities.

Implementing Objective (g) of Goal 1: Provide a wide range of public facilities and services (parks, cultural facilities, utilities, schools, etc.) to serve residents and business enterprises.

The Trust for Public Land produces an annual report that provides an almanac of the parks and recreation systems of the 100 most populous cities (The Trust for Public Land 2015). The report includes a wealth of park data including parkland as a percentage of adjusted city area and parkland per 1,000 residents (The Trust for Public Land 2015).

2.2.6.17 Response PM-6.17 The next closest high schools for the proposed project and for the cumulative projects are San Mateo High School, Mills High School, and Aragon High School, which are located approximately 1.4, 3.1, and 3.3 miles respectively from Burlingame High School, respectively. Some high school students that would live in the cumulative housing projects may have to attend San Mateo High School, Mills High School, or Aragon High School if Burlingame High cannot accommodate those students. Some portion of high school students may also attend private high schools such as Mercy, Nueva, and several schools in San Francisco.

Table 2.2‐2 summarizes the capacities and historical enrollment rates at Burlingame, San Mateo, Mills, and Aragon high schools. Burlingame High has not exceeded its capacity, San Mateo High has exceeded its capacity since 2012, and Aragon High has exceeded its capacity since 2015. The cumulative impact analysis for high schools identifies that the cumulative projects would add approximately 84 high school‐age students to the population (page 3.12‐8 of the



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Draft EIR). Because San Mateo and Aragon are already exceeding their capacity and because Burlingame High School does not have enough capacity to accommodate an additional 84 students, the addition of students from cumulative projects would contribute to local high schools exceeding their capacities. The California Government Code Section 65995 addresses the potential impacts to high schools from development projects. As explained in the cumulative impact analysis for high schools, the cumulative development projects would be required to compensate San Mateo Union High School District for impacts associated with additional students using the high schools, per California Government Code Section 65995. This compensation would ensure that impacts to Burlingame High School, San Mateo High School, and Aragon High School would be less than significant.

Table 2.2-2 Enrollment Rate and Capacities at Burlingame High School, San Mateo High School, and Aragon High School

School Capacity

Student Enrollment During the School Year c

2011 - 2012 2012 - 2013 2013 - 2014 2014 - 2015 2015 - 2016

Burlingame High School 1,350 a 1,314 1,352 1,306 1,316 1,339

Mills High School 1,454 b 1,325 1,284 1,232 1,214 1,198

San Mateo High School 1,445 b 1,373 1,489 1,469 1,555 1,615

Aragon High School 1,465 b 1,499 1,441 1,441 1,423 1,473

Source: a Chavez 2015 b Chew 2016 c California Department of Education 2016b

Some students that may have to attend

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