response to comment letter d2 anna-maria pardini

City of Petaluma December 2011

Deer Creek Village Project II. Response to Comments Final Environmental Impact Report Page II-201 SCH #2004092093

Response to Comment Letter D2 Anna-Maria Pardini

Response D2-1

The commenter expresses concern about the adverse traffic, energy consumption and traffic impacts associated with making trips outside of the City for building supplies. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

Response D2-2

The commenter states that the City is losing sales tax dollars to Rohnert Park and that while he prefers to shop locally it is not always possible due to store hours, forms of payments, pricing, and supplies. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

Response D2-3

The commenter states that more shopping choices in town would improve quality of life. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

Response D2-4

The commenter states that the City is losing sales tax dollars to internet retailers and that while he prefers to shop locally it is not always possible. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

From: Jensen, Deanna on behalf of CDD

Sent: Wednesday, March 09, 2011 2:49 PM

To: Bradley, Geoff; Hines, Heather

Subject: FW: Deer Creek Village DEIR

From: l.vicino [mailto:[email protected]]


To: CDD

Subject: Deer Creek Village DEIR

Honorable City Councilmembers:

I am writing to you to encourage the development of the Deer Creek

Village Project. We need such a development to bring revenue and jobs

into our community. The City Council, for some unknown reason, drags

their feet in bringing into our community new developments and more

revenue so that not only would it help with jobs in the City Hall but

jobs in the new developments.

So many of our citizens are losing jobs and along with that their homes.

Our country needs to bring jobs back to its citizens. With the jobs, it

will bring revenue to the City and to the State. It will also bring back

self-esteem back to many who have lost their jobs.

I am a senior citizen and I hope you hurry to put in these projects so

they will be beneficial to me, as the day will come when I can no longer

drive. Another reason to speed these developments up is that everybody

goes to Rohnert Park and Novato to spend their dollars, dollars that

Petaluma could be getting.

Please allow Deer Creek Village to get their development in SOON.

Louise Vicino

Petaluma homeowner

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Comment Letter D3

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Response to Comment Letter D3 Louise Vicino

Response D3-1

The commenter states that the City of Petaluma needs new jobs and revenue. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.




Subject: FW: deer creek lowes

From: [email protected] [mailto:[email protected]]


To: CDD

Subject: deer creek lowes

Yes...thank you

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Comment Letter D4

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Response to Comment Letter D4 Unnamed

Response D4-1

This comment expresses support for the proposed project. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.




Subject: FW: Deer Creek Village, DEIR

From: Jeanne McConnell [mailto:[email protected]]


To: CDD

Subject: Deer Creek Village, DEIR

Deer Creek Village is a premiere project that will create hundreds of new

jobs and generate much needed sales tax revenue for the city.

Please pass the project. Over 800 quality jobs. Will help generate sales

taxes for City services by encouraging consumers to shop locally.

Approximately $407,000 annually in new sales tax revenue for public

services such as police and fire protection, and road improvements. Funds

to help the City balance its budget deficit. Millions of dollars in

development fees for local neighborhood improvements

--

Jeanne McConnell

Phone 707-769-0953

Fax 707-769-8794

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Comment Letter D5

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Response to Comment Letter D5 Jeanne McConnell

Response D5-1

The commenter states that the proposed project would generate sales tax revenue and new jobs for the City of Petaluma. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.


Sent: Thursday, March 10, 2011 6:51 AM

To: Hines, Heather; Bradley, Geoff


From: [email protected] [mailto:[email protected]]


To: CDD


Dear Petaluma City Counsel,

I am a Petaluma resident in full favor of a Lowe's in our city. I spend

too much time and money out of town, giving the tax revenues and jobs to

others instead of to my local community. I have to travel through our

town in order to get to Lowe's in Cotati, creating more traffic and

pollution than if I could just drive a couple of streets over in order to

get to Lowe's Petaluma.

I encourage you to approve this measure quickly so we can all enjoy the

benefits.

Sincerely,

Charles Weaver

392 Sparrow Lane

Petaluma, CA 94954

707-658-1117

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Comment Letter D6

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Response to Comment Letter D6 Charles Weaver

Response D6-1

The commenter states that the proposed project would generate sales tax revenue and new jobs for the City of Petaluma. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

From: paul francis [[email protected]]

Sent: Monday, March 14, 2011 2:01 AM

To: Hines, Heather

Subject: Deer Creek DEIR missing link on City's website

Hi Heather,

Hope you are well.

I noticed that the "Appendix E Geotechnical" link of the Appendices

section of the Deer Creek DEIR, is not working on the city website. I'm

not sure if it is just a glitch on the city's end or if that section is

located in another place on the site.

Consequently, I request that the timeline for the public comment period

be extended to allow adequate time for the aforementioned report to be

accessed and reviewed.

Thank you.

Sincerely,

Paul Francis

Petaluma Neighborhood Association

www.petalumaneighborhoodassociation.org

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Comment Letter D7

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Response to Comment Letter D7 Paul Francis

Response D7-1

The commenter states that the Appendix E Geotechnical link of the DEIR Appendices was not available through the City’s website and requests that the timeline for the public comment period be extended to allow adequate time for review of the report. The commenter is correct that Appendix E of the DEIR was temporarily unavailable on the website at the initiation of the DEIR public review period. The City posts information and documents on its website as a convenience to reviewers and the public, but is not required to do so by CEQA. In addition to the DEIR being available on the City’s website as described, hard copies of the DEIR including Appendix E were available in full compliance with CEQA at the Petaluma Regional Library, Community Center, City Clerk, with copies available for purchase at the City’s cost of reproduction at the City Community Development Department. The City Council meeting on the DEIR was rescheduled to April 25, 2011 in response to concerns raised by the public regarding the proposed April 18, 2011 City Council meeting date. This rescheduled City Council meeting date resulted in the extension of the DEIR 45-day public review period by one week.


Sent: Monday, March 14, 2011 6:54 AM



-----Original Message-----

From: David and Janet Watts [mailto:[email protected]]

Sent: Saturday, March 12, 2011 10:14 AM

To: CDD


WE NEED THIS LOWE'S IN PETALUMA. LET'S GET MOVING ON GETTING NEW

BUSINESSES IN PETALUMA.

David and Janet Watts

1169 River Pine Circle

94954

(707) 775-4737

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Comment Letter D8

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Response to Comment Letter D8 David and Janet Watts

Response D8-1

The commenter expresses support for the proposed project. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.


Sent: Monday, March 14, 2011 2:45 PM


Subject: FW: Deer Creek Project

From: Edmund Molinari [mailto:[email protected]]

Sent: Monday, March 14, 2011 2:26 PM

To: CDD

Subject: Deer Creek Project

It's time for the City of Petaluma to move forward. Petaluma does not

have a lumber yard. The city loses a lot of sales tax when I and other

Petaluma citizens have to go to Cotati or Rohnert Park to purchase what

we need around the house. It's time for some of the council members stop

thinking about their personal agenda and start thinking about the needs

the Petaluma!!!!

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Comment Letter D9

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Response to Comment Letter D9 Edmund Molinari

Response D9-1

The commenter states that the proposed project would generate sales tax revenue for the City of Petaluma. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

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Comment Letter D10

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Response to Comment Letter D10 Janice Cader-Thompson

Response D10-1

The commenter requests that a different date for City Council meeting on DEIR instead of April 18, 2011 because some citizens can’t attend due to them observing the first day of Passover. In response to these concerns, the City Council meeting on the DEIR was rescheduled to April 25, 2011.

Response D10-2

The commenter states that the Park Place neighborhood has been notified that the DEIR is available for review and questions when the City would mail notices to the entire Park Place area. Notices regarding the availability of the DEIR were sent to the following: residents and business owners within a 1,000-foot radius of the project site, individuals who commented on the NOP, an interested parties list, the Argus Courier, the County Clerk, and the State Clearinghouse.

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Comment Letter D11

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Response to Comment Letter D11 Mary Glardon

Response D11-1

The commenter requests a different date for City Council meeting on DEIR instead of April 18, 2011 because some citizens can’t attend due to them observing the first day of Passover. Additionally the commenter requests an extension of the comment period because the DEIR includes too much information to review by the close of the comment period. The City Council meeting on the DEIR was rescheduled to April 25, 2011 in response to concerns raised by the public regarding the proposed April 18, 2011 City Council meeting date. This rescheduled City Council meeting date resulted in the extension of the DEIR 45-day public review period by one week.

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Comment Letter D12

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Response D12-1

The commenter states that the public had only one option in reviewing the DEIR for the Deer Creek Village project; by paying ninety dollars for a copy. The commenter adds that both the Petaluma Community Center and the Library public counters had two copies but only one was available at that time. The commenter questions how many copies were made available and how those copies were given away. The commenter requests that the 45 day review period for the DEIR be stopped until the city can make available copies of the DEIR for the public.

Copies of the DEIR were made available at the Petaluma Regional Library, Community Center, City Clerk, and for purchase at the City Community Development Department. In addition, the DEIR was made available on the City Community Development Department’s website at http://www.cityofpetaluma.net/cdd/deer-creek.html. While the cost of a copy of the DEIR is acknowledged, the City is not obliged to provide copies of the DEIR for free, and therefore the DEIR public review period was not put on hold as requested by the commenter. The City Council meeting on the DEIR was rescheduled to April 25, 2011 in response to concerns raised by the public regarding the proposed April 18, 2011 City Council meeting date. This rescheduled City Council meeting date resulted in the extension of the DEIR 45-day public review period by one week.

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Comment Letter D13

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Response to Comment Letter D13 David Keller

Response D13-1

The commenter requests a different date for City Council meeting on DEIR instead of April 18, 2011 because some citizens can’t attend due to them observing the first day of Passover. The City Council meeting on the DEIR was rescheduled to April 25, 2011 in response to concerns raised by the public regarding the proposed April 18, 2011 City Council meeting date.

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Comment Letter D14

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Response to Comment Letter D14 Louis Rose

Response D14-1

The commenter states that the proposed project would generate new jobs for the City of Petaluma. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

Hines, Heather

From:Sent:To:Subject:

Janice Cader-Thompson [[email protected]]Monday, March 21, 2011 12:46 PMHines; HeatherRE: 2011 DEIR Deer Creek Responses to the Planning Commission

Deer Creek Village ProjectDraft

Environmental Impact Report

Janice Cader-Thompson, RDHGerald A. Thompson732 Carlsbad CourtPetaluma, CA 94954

707 762-7279

City of PetalumaPlanning CommissionAttention: Heather Hines11 English StreetPetaluma, CA 94942

Re: 2011 Deer Creek Village Project DEIR CommentsPetaluma Planning Commission

Purpose of EIR

Page 1-1: To enable the City to consider the environmental consequences of approvingthe proposed project.

A Public Agency has an obligation to balance the projects significant impacts ontheenvironment with other conditions, including economic, social, technological, legaland other benefits.

Pg.1-2: CEQA requires findings regarding each significant in the EIRCEQA requires a good faith effort at full disclosure.

The draft EIR will focus on air quality, GHG emissions, transportation, trafficimpacts, and urban decay. (Fails to make good faith effort to disclose financialchallenges to achieving infrastructure that would meet challenges of mitigating impacts.)

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Pg.1-3: Case law'- lead agency is not obligated to undertake every suggestion giventhem, provided that the agency responds to significant environmental issues and makesa good faith effort at full disclosure.(Casino- reasonably foreseeable.) The DEIR does not calculate the Rohnert Park Casino.This Casino is reasonably foreseeable in the near future.

Comments are most helpful when they suggest additional specific alternatives ormitigation measures that would provide better ways to avoid or mitigate the significantenvironmental effects.

Executive Summary- Significant unavoidable impacts.Pg.11-12: The proposed project causes an increase in GHG emissions of 8,707 metrictons of co2 annually. (this exceeds BAAQMD thresholds by nearly 8 times)

In terms of assessing GHG emissions efficiency it exceeds BAAQMD threshold by 3times.

(Vote of Overriding Consideration is not adequate .... a program must be providedthat reduces this level to the greatest extent possible.) Perhaps, traffic signalizationprogram could be provided in immediate area plus other portions of the city to offsettraffic, with an ongoing A.D. Fee to support the ongoing costs of such a program.Perhaps a Green Roof on the main building whereby the Garden Center might berooftop. That would cut down the overall footprint of the project. (The currentmitigation calls for 20% energy reduction. This is inadequate ... legislation calls for80% of bUildings by 2015 to achieve 30% energy reduction efficiencies.}

Pg.11-15: Noise Impact Executive Summary Page.The land use across North McDowell is residential. Analysis is inadequate. This

neighborhood has an aging privacy fence- in a state of disrepair; it should be a soundwall. It is known that current noise will be-changed when 101 is widened; more carsand the road will be lifted changing the line of sound. It is referenced that the newstructures will lesson sound from freeway without acknowledging the changingconditions of Hwy. 101.

Pg.11-17: Recognizes Significant and Unavoidable impacts would result from trafficrelated noise and future railservice. (Rail service is beginning soon) While the GPadopted significant and unavoidable noise impacts in a statement of overridingconsideration, this project still has the responsibility to deal with this issue to thegreatest degree possible.

The project increases traffic on Hwy 101 to a degree of significance and exacerbatesa number of intersections in town that are already failing. The mitigations to noisereduction should include the installation of a sound wall on North McDowell to lessen thedegree of significant impact due to noise. Instead the EIR relies on a vote of OverRiding Considerations with no mitigations proposed. This is inadequate.

Pg.11-18: Traffic ImpactsEast Washington street North McDowell Impact traffic 3

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Corona Rd/ North McDowell Impact traffic 5ACorona Rd/ Petaluma Blvd North Impact traffic 5BEast Washington/ North McDowell Blvd Impact traffic 5D

Page 11-19Impact 6 Vehicle Queuing Impacts EastWashirigton at US 101 Southbound Rampswhere the storage capacity is exceeded with the addition of project created trips. East

.Washington/ North McDowellSouthbound Right Turn lane.

Impact traffic 7The proposal project is expected to increase the traffic volumes on steady freewaysegments expected to operate at levels Service F without the project by more then 10/0

(PG 11-20) of the segments theoretical capacity at Railroad Ave Pepper Rd to OldRedwood Highway and East Washington Street to Lakeville Highway (No casino)

Northwest US10l for Railroad Ave - Pepper Rd to Old Redwood Highway & EastWashington S to Lakeville Street segments would operate at LOSF. (No Casino)

Page 11-24Rainer Ave/ North McDowell Blvd

? Significant & unavoidable Impact.

Page 11-25Rainer Ave/ Project Access

? Significant & unavoidable

Page 11-25Corona Rd/ North McDowell

? Significant & unavoidable

Page 11-26East Washington/ North McDowell Southbound Queuing

? Significant & unavoidable (with queuing problems that would seem to makeemergency vehicle signs inadequate mitigation)

? Cumulative Freeway operation impacts significant and unavoidable.

(The cumulative effect of all these mitigation with the common denominator of NoFeasible Mitigations) measuresideiltified are inadequate. The consistent action taken is aPolitical Solution of a vote of overriding consideration.The Planning Commission and ultimately the City Council should be prOVided withpotential solutions. Perhaps the proposed mitigation fails to mitigate to a degree of lessthan significant but greater amounts of unacceptable levels of noise greenhouse gasemission and an inundation of traffic with NO attempt to offer proposals which to somedegree lessen the magnitude of the impacts is inadequate.

Page 111-5

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Residential Care Facility is identified as an allowable use. (This ties in with Option C theenvironmentally preferred alternative). Note: from property standpoint this use allowseconomic enjoyment and or benefit of property ownership.

Page 111-16Want to make sure the public recognizes that 5.44 acres set aside as Open Space is aland bank for the entire Rainier project including three protected mature oak trees.(Page 111-24) I suspect the oak trees will live a long and healthy life).

Pg. 111-28: Among the most important sustainable features of the project would be thePreservation and enhancement of the Deer Creek swale. The creek is proposed to berelocated? This is new to me? The creek was to have 50 feet on either side to protectthe creek and habitat it brings. That seems to be inconsistent with sustainability.) This isnew to me. Abigail Smith of the Bay Area Water Quality Control Board, enforcing waterquality was clear in letters to the city that the

Pg. 111-34: Project ObjectiveSatisfy the substantial demand for regional and neighborhood retail,office and dining

experiences. In the Petaluma trade area.(Studies would indicate over saturation of office space, some need of retail, some harmfrom retail cannibalization, no shortages of fitness centers. The opinion in the EIR is notfactual and inconclusive.

Pg.111-35: Discretionary ActionsPetaluma City Council should be added to the list of entities.

Pg.IV-A-1: The Significant Environmental Impacts that require votes of over ridingconsideration are: 1.) Air Quality, 2.) GHG Emissions, 3.) Cumulative, traffic noise,transportation, and traffic!!

The mitigations to lessen the impacts even if they are still at a level of significantneeds to be identified funded and implemented. This EIR is inadequate as it consistentlyinstead relies on Over Riding Considerations. The mitigations could include lessening

,the size of the project, garden roofs on major structures, sound walls for impactedneighborhoods, a fee and revenue stream to support city wide traffic coordinatingsignalization program to lessen GHG emissions, a tree plantingprogram along Hwy.101and elsewhere to improve air quality, and lessening the scope of the project, lessparking, and more open space; all of these mitigations could at least be a starting pointof lessening the significant and unavoidable impacts.

Pg. IV B-19: Collision AnalysisOld Redwood Hwy. 1.13 (State Avg. .43) Industrial Drive / Stony Point Road

Intersection.Professional Drive / North McDowel1.30Vs .14 State Avg.

East Washington/North McDowell Blvd. intersection collision rate 1.39 as to .43 stateavg.

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Theexisting plus pipeline does not assume the current coordinated signal system onNorth McDowell and East Washington is maintained in the future. Although these signalsystems have been coordinated in the past, present resources are not adequate tosupport thisfunction now or into the foreseeable future. (If signalization coordination isnot included because of financial reality, why is Rainier and Caulfield extensionsincluded? Aren't they equally challenged?

Pg. IV B-20: All of the study intersections are expected to continue operations at. .essentially the same levels of service as under existing conditions, with exceptions ofintersections along Corona. (This is false assurance. This statement assumes nodegradation of environment within the same service level category. But not all F's arethe same.

Pg. IV B-25: EXisting plus pipeline traffic volumes were derived form the final US101/Rainier Ave. Interchange TrafficOperations Report.

During P.M. Peak Traffic, 1610 standard trips generated thru this intersection.Analysis with 400,000 sq. ft. project and a 343,998 sq. ft. project adds 1330 more peaktrips thru this intersection. (Less of a project, Option C would mean fewer trips.)

Pg. IV B-26: The interchange project (Rainier) would be locally funded with developerfees, redevelopment funds, and assessments from proposed projects bordering theroadway improvement project. (DEIR is inadequate in financial feasibility of Rainier, andthe funding sources identified in the GP may not be feasible. It fails to address suchissues as state raid on redevelopment funds, the governors' effort to endredevelopment, declining real estate values affecting future bonding capacity. Evan ifRDA survives, as we know them, the long history of failed attempts to fund this projectis apparent. While the EIR recognizes a street signalization program is not financiallyviable, the DEIR fails to list the financial challenges of Rainier, in addition to the last CalTrans findings that the project was out of compliance with Cal Trans designstandardsand violates the primary purpose of 101 expansion; To Move Traffic.

Pg. IV B-27: Rainier Ave.jNorth McDowell unacceptable at LOS E

Pg. IV B-39: Under the Cumulative Scenario it is assumed that the Rainier Ave.extension will be an option for distribution of traffic. Yet there is no mention of GratonRancheria Casino, a reasonably foreseeable project that would impactthis same corridorof traffic. The resulting trip generation statistics for Hwy. 101 combined with theadditional inundation of local surface streets as 101 capacity is exceeded. This isinadequate.

Pg.IV B-47: East Wash.j North McDowell, existing condition LOS D, It will degrade toLOS E. Goes from 52.6 to 67.2 seconds delay at that one intersection. Add in trafficfrom the casino, our situation worsens.

LOS F intersections: Corona Road/ North McDowellCorona Road/ Petaluma Blvd. Nth.East Washington Str.j Nth McDowell

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101 Significant Impacts (significance is 10/0 additional traffic load in an alreadysignificantly impacted area.) Railroad Ave. - Pepper Road to Old Redwood Hwy., EastWashington to Lakeville Hwy.

Pg. IV B-62: The addition of project generated trips is not expected to cause areduction in travel speeds along this route sufficient to cause significant delays foremergency vehicles "lights" override traffics controls - sirens etc.

There is no analysis to substantiate this opinion. The opinion conflicts with many newsreports and statements from public safety through the years to say nothing of thepolitical propaganda regarding reasons for the need of the Rainier cross-town connector.The statement also fails to take into account Queuingissues on eh city streets andmitigations that call for expansion in with of queuing lanes and with an over flow of carsthe roadways become a parking lot at which point the siren etc. will effect responsetimes. If this is not so I would like the fire department to justify the many commentsthey have made in the pastabout the need to build Rainier crow-town connector to movethe traffic as a matter of life and death! The Hospital and Damon Doss the director of theHealth Care District have made similar statements in past. There is no accounting forthe significant occurrence of accidents at the Washington and McDowell intersectionwhich in the case of additional accidents would further degrade the mobil'ity at thiscrucial intersection even with sirens, light, etc.!

Page IV C-8 GHG Emissions

There is nothing in the terms of mitigations that adequately address even an attempt toapproach mitigations of this issue. It simply can't be enough to say VOTE OVER RIDINGCONSIDERATION. Under reduction of emissions for the future that is pushing off today'schallenge on to tomorrow when it will be more difficult with the added additional;cumulative impacts of excessive GHG Emission. These emission are just as or moresignificant that the emission from the Dutra Plant. The emissions from the Deer Creekproject are in the middle of our community with a prevailing south wind.

Mitigations that could be employed:? Could include but not limited to:? Less mass in the project7. Green Roofs, or garden or solar7 Platinum or Gold Leed Certified7 Street Signalization Coordinating Program7 No project until traffic mitigation are designed and funded and GHG Emissions

are reduced7

Page IV C-19Local CO Impacts

? Carbon monoxide emissions from traffic... Congested intersections with a largevolume of traffic have the greatest potential to cause high-localizedconcentrations of carbon monoxide. This project is next to a hospital and

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residential homes, community center, boys and girls club, neighborhoodschools, etc.

? This impact is considered less than significant because no one intersectionmeets the threshold but cumulatively all of theimpacted intersection and 101should be accounted for.

?Page IV C-25Table IV C-9

? This table shows the inadequacy of the proposed mitigations.? The threshold of significance for emissions Per Capita is 4.6. The unmitigated

Project Produces 13.5 and the mitigated Project Produces 13.0 (Almost 3 timesthe threshold of significance).

Mitigation AQ4 PFIV C-26? This is totally inadequate.

Page IV C-28Emissions

? 83% of emissions come from traffic. Measure AQA reduces project emissions by4%. (The Project is relying on Over Riding Considerations)

?Page V-ISignificant Unavoidable Conditions

? Air Quality GHG EmissionsNoise

? (a) Cumulative Traffic Noise Levels (a sound wall should be added to protectthose residence on North McDowell)

? Transportation and Traffic?

Urban Decay Analysis? City retail market has performed relatively well. The city leaks sales in apparel,

restaurants, service stations, bUilding materials and construction categories.?

Page V-4? Deer Creek 58.1 million net in new sales out of 94 million (The difference

represents 4% capture from existing Petaluma businesses.? Development of the proposed Deer Creek Village project,as well as other

proposed projects the City's pipeline including East Washington Place is likely tohave a significant impact on the existing retail space performance andpotentially create conditions that temporally (3-5 years) could be conductive tourban decay.

? New cumulative retail's capture of 12% of existing trade area retail sales in2015 would reduce by 9% by 2020 and 5.5% by 2025. (Note: In order for thisto be true growth rates must be achieved andwhat impacts of Internet SalesCapture is Projected What impact of mitigation of recession from events relatedto Oil in Libya, or Tsunami and Nuclear Events in Japan? (Petaluma is not anisland).

?

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Page V-5? Although Urban Decay Analysis states that temporary conditions conducive to

urban decay will likely result from the project due to the fact that anticipatedfigures exceed the general threshold of 10%/ the report also states that "urbandecay is by no mean guaranteed under this scenario."

? Begs the question: What mistakes could we make that would ensure urbandecay? What if Lowes were to become a Wal-Mart instead? This is a buildingand a land entitlement. Much of the square footage in the analysis isassigned to capture leakage. Substitute Wal-Mart for Lowes and much of thesquare footage then achieves cannibalization rather than leakage. I would haveto deduce that scenario would virtually guarantee achieving urban blight. Inother words with the project as proposed blight is likely but it is possible theidentical square footage with identical zoning are no way to prevent it'soccurrence could result in a Wal-Mart which would move us at least closer tothe guaranteed conditions of blight!

? The citizens have been promised a Target yet Regency does not have a signedcontract with Target, it tOO, could become aWal-Mart! This is a bUilding andland entitlement process only.

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? 407/000 net revenue in sales tax to the general fund.Most of that amount could be achieved with option C the environmentallysuperior alternative, depending on the tenant.

Page VI-4Alternative CResidential and commercial alternative.

?No alternative:

? There is "No Alternative" option: This is the logical direction until the questionsof Rainier interchange/crosstown connector is adequately addressed. Ifthepurpose of Rainier in the cities General Plan is to mitigate traffic with nointention of building the mitigation then the city council needs to make changesin transportation and land use in it's new General Plan. This sound like a legalissue going back to when Judge Sawyer favored the city in -----------------------

?Page VI-l0

? Alternative B? Reduced project alternative reduces potential traffic impacts by 25%. However,

cumulative traffic noise impacts the from both alternative B and the proposedproject would remain significant and unavoidable.

? Solution: No project? A sound wall for those homes backing McDowell needs to be incorporated with

the project due to unavoidable f)oise impact.

Transportation:

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? There is no analysis of Rushmore Ave is not calculated in the traffic There areNO crosswalks proposed from Rainier Ave to Maria Drive.

? Rainier has a curve in the road making it dangerous for crossing this 4-lanearterial.

? No mention of the Smart Train and Freight train. Past concerns for the need tobuild Rainier was to get across town to the hospital without being blocked by atrain. .

?Page VI-12

? Meets most of the projects goals?

Page VI-13Commercial and Residential Care Project Alternative

? Major Anchor tenant? Other retailor uses replaced with 50 bed residential care facility for elderly.? Why only elderly?? Located near proposed medical offices and Petaluma Valley Hospital.? However, impacts associated with operational greenhouse gas emissions would

remain significant and unavoidable for both Alternative c and the proposedproject.

?? More to come!

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Response D15-1

The commenter states that a Public Agency has an obligation to balance the project’s significant impacts on the environment with other conditions, including economic, social, technological, legal and other benefits. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

Response D15-2

The commenter paraphrases a portion of the last sentence of the second paragraph on page I-2 of the DEIR (Introduction) and cites a portion of the last sentence of the last paragraph on page I-2. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. The commenter states that the DEIR fails to make a good faith effort to disclose financial challenges to achieving infrastructure that would meet the challenges of mitigating impacts. Please refer to Topical Response 10, Traffic Mitigation Measures Considered but Rejected as Infeasible.

Response D15-3

The commenter paraphrases a portion of the second sentence of the second full paragraph on page I-3 of the DEIR (Introduction). The commenter states that the DEIR does not calculate the Rohnert Park Casino and that the casino is reasonably foreseeable. A thorough discussion of potential impacts of the Graton Rancheria Casino in Rohnert Park for CEQA purposes of cumulative development in Petaluma was contained in Master Response D for the General Plan FEIR. Volume 6A, Technical Appendix G-2, pages 39-42. That analysis is relied on for this second tier EIR. For ease of reference, Master Response D is set out below:

MASTER RESPONSE D: Casino Impacts

One casino project is proposed by the Federated Indians of Graton Rancheria (“Graton Rancheria”) in Rohnert Park, and a second has been mentioned in connection with a location south of Petaluma, approximately 27 acres south of the City limits off Highway 101 near Kastania Road. The City and Petaluma voters have made their opposition to casino development on the latter site by the Dry Creek Rancheria Band of Pomo Indians clear through the City Council’s placement on the ballot and voters’ overwhelming approval of a ballot measure in November, 2006, which authorized the City to take all possible actions to oppose that development. The Dry Creek Pomo project is determined to be too speculative to require inclusion in the cumulative impact analysis for the General Plan 2025 DEIR given the lack of



information presently available on use of the site and an opinion of the Associate Deputy Secretary of the Interior, by correspondence dated February 13, 2007, which states, in part:

“…Clearly, the Tribe did not exercise jurisdiction on the subject parcel in 1988, therefore it cannot be used for gaming purposes as a matter of law…. We anticipate changes to the rules that may result in fewer off-reservation properties being accepted into trust. In particular, we expect to consider a paradigm where the likelihood of accepting off-reservation land into trust decreases with the distance the subject parcel is from the Tribe’s established reservation or ancestral lands, and the majority of tribal members. Further, we plan to review our approach for soliciting and accommodating the view of elected officials (State, county, city, etc.) and community members in the local area as part of our IGRA Section 20 decisions. We also plan more detailed consideration of the broad implications associated with new gaming operations with established communities where gaming is not currently conducted. Finally, we expect continued Congressional efforts during the 110th Congress to restrict or terminate the options currently available under Section 20. Because the Department has not considered the relative merits of your Section 20 application yet, we cannot advise you further about its prospects for approval….”

The General Plan 2025 EIR is designed to evaluate the impacts of development in Petaluma over its 20 year time horizon within the City’s jurisdictional boundaries and cumulative effects of that development combined with certain extra-territorial projects. The General Plan EIR is not required to evaluate the direct impacts of possible projects outside of the City. Those impacts for a proposed Rohnert Park casino have been studied in a project-level draft environmental study under federal law, titled “Graton Rancheria Casino and Hotel Environmental Impact Statement,” published in March 2007 (“EIS”). The EIS is not yet final. It also must be recognized that the City has no control over approval of the Graton Rancheria project because the project is proposed by a sovereign tribe, which is not subject to local land use or zoning approvals or CEQA and because the project is outside the City’s boundaries. Therefore, the City cannot impose conditions or mitigation measures on the project.

As to the City’s General Plan, the physical impacts of a reasonably foreseeable extra-territorial project may be considered in the General Plan EIR to the extent they contribute to impacts from the General Plan itself on a cumulative basis. An EIR should not discuss impacts which do not result in part from the project evaluated in the EIR, i.e. Petaluma’s General Plan 2025. CEQA Guidelines, Section 15130(a)(1). The study of these cumulative impacts is required to be less detailed for a programmatic EIR like the General Plan EIR than it would be for a specific development project level EIR. See CEQA Guidelines Section 15152(b). Discussion of cumulative impacts need not be as extensive as that used for effects of the General Plan itself. CEQA Guidelines, Section 15130(b).



For purposes of the City’s General Plan 2025 cumulative impact analysis, a prior location considered for the Graton Rancheria project near the intersection of Lakeville Highway and State Highway 37 is not considered reasonably foreseeable. The impacts of using that site, including its impact on views and baylands restoration along the northern edge of San Pablo Bay led to widespread community, environmental and political opposition. The City believes that the Tribe’s donation in 2003 of the majority of its property at that site to the Sonoma County Land Trust and identification of sites in Rohnert Park acknowledge that evaluation.

The traffic impacts identified in the General Plan DEIR already include measurement of traffic from a prospective casino in Rohnert Park. The City of Petaluma provided land use information to Sonoma County for inclusion in the County’s traffic model that the County used to evaluate potential traffic impacts resulting from the Sonoma County General Plan 2020. The County study and traffic model included a Graton Rancheria casino project in Rohnert Park as one of the cumulative projects in its impact analysis for the County of Sonoma General Plan 2020 EIR. See Sonoma County General Plan 2020 (March 2006), page 6.0-4, available at http://www.sonoma-county.org/prmd/docs/eir/gp2020deir. The City’s General Plan “Future with Project” PM peak hour freeway volumes shown in the General Plan 2025 DEIR were pulled directly from the County model, which included casino trips on U.S. 101. The City’s DEIR at page 3.2-29 provides an explanation of the use of the County model. Regional casino-generated traffic through or to and from Petaluma, was assumed to use Highway 101. In this way, casino trips were included in analysis of cumulative traffic impacts resulting from the General Plan 2025. The City’s model run for the AM peak hour did not specifically include AM casino trips aside from general growth in trips to and from the north on Highway 101, but it is a fair assumption that the casino will not generate a large amount of AM peak hour traffic.

To the extent the City’s General Plan development contributes to regional traffic impacts, it has identified policies and programs to mitigate that impact by supporting the concept of identifying regional transportation needs and cooperative means to propose improvements, including imposition of fair share contributions to measures designed to alleviate regional traffic impacts.

The General Plan 2025 will update and revise Policy 5-P-12 as follows:

• Cooperate with local jurisdictions, County, State and Federal agencies toward identifying and implementing regional improvements to the network.

• Work with CalTrans and the Sonoma County Transportation Authority (SCTA) to achieve timely implementation of programmed freeway and interchange improvements.

• Designate SCTA as the agency with the overall responsibility for regional circulation and transit coordination between the City and County.

• Work with the County and SCTA to develop regional/subregional fees and/or allocate a fair share contribution to accommodate transportation demand created by new development.

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This is an adequate and appropriate means of mitigating regional cumulative impacts. CEQA Guidelines Section 15130(a)(3). Again, it must be recognized that the City’s responsibility is to evaluate impacts from its General Plan, not all impacts of the Graton Rancheria project, if and when those occur.

As to cumulative impacts on increased regional and local air pollution, the DEIR determined that the proposed General Plan’s compliance strategies would enable the City to adhere to the relevant air quality thresholds, resulting in a less-than-significant impact under CEQA. The Revised DEIR, Greenhouse Gas Emissions, concludes that the General Plan’s cumulative impact on greenhouse gas emissions and climate change is significant and unavoidable because of the unsettled status of regulatory thresholds; the difficulty of measuring the success of national, state and local reduction measures in the City of Petaluma; and the difficulty of measuring both the effect of City measures on the global climate and the effects of global climate change elsewhere on Petaluma. This cumulative analysis of greenhouse gas emissions within the General Plan study area and the conclusion of significant and unavoidable impact would not change with the addition of impacts from a casino project. Quantification of emissions from whatever casino project might be implemented, if any, is beyond the scope of the City’s General Plan EIR and not required. As noted above, the City has no power to impose greenhouse gas emissions mitigation, or any mitigation, on a future casino project.

The Graton Rancheria project is located approximately ten miles outside Petaluma’s boundaries. The City will not be providing water, wastewater, police or fire services to any prospective casino project and therefore no new cumulative impacts on such services require analysis in the DEIR.

Possible economic and social issues from casino impacts, including, as two commenters noted, an effect on Petaluma’s “identity and character;” citizens being drawn away from other recreation, music, parks and arts “as citizens are drawn to the illusive hope of instant wins at tribal casinos;” diversion of disposable income; school impacts based on assumptions that “imported workforce children” will be multi-lingual; possible increased demand for low-income housing, etc., are not required to be analyzed in the General Plan DEIR. For CEQA purposes, "Economic and social changes resulting from a project shall not be treated as significant effects on the environment." CEQA Guidelines Sections 15064(e) 15382, 15131; Public Resources Code Sections 21061.5, 21151(b). Here, the cited potential impacts are economic and social changes that do not arise from the General Plan, do not arise from or cause physical impacts in Petaluma, and which are speculative. Even if evidence of physical change had been provided, it would be at most an indirect physical change. CEQA Guidelines Sec. 15064(d)2). An indirect physical change may be considered only if it is reasonably likely to occur, and a change which is speculative or unlikely to occur is not reasonably foreseeable. CEQA Guidelines Sec. 15064(d)(3).

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Response D15-4

The commenter paraphrases a portion of the last paragraph on page I-4 of the DEIR (Introduction) as well as a portion of Impact AQ-4 as described in Table II-1 on page II-12 of the DEIR (Executive Summary). The commenter adds that a vote of overriding considerations is not adequate and states that a program must be provided that reduces this level to the greatest extent possible. The commenter provides suggestions to reduce GHG emissions. Please refer to Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures.

Response D15-5

The commenter states that the DEIR noise analysis is inadequate and that widening of Highway 101 will exacerbate noise impacts. Modifications to Highway 101 as part of the Marin-Sonoma Narrows project were analyzed as part of the environmental review of that project. These modifications included the necessary increase in the roadway’s profile and the additional traffic anticipated as a result of the widening project. Please refer to Topical Response 15, Noise Impacts and Mitigation Measures.

Response D15-6

The commenter expresses concern regarding project traffic noise and noise from future rail service. Please refer to Topical Response 15, Noise Impacts and Mitigation Measures.

Response D15-7

This comment cites the various traffic impacts identified in the DEIR and expresses concern that no feasible mitigation measures were identified for such traffic impacts as well as associated noise and greenhouse gas impacts. Please refer to Topical Response 15, Noise Impacts and Mitigation Measures, Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures, and Topical Response 10, Traffic Mitigation Measures Considered but Rejected as Infeasible.

Response D15-8

The commenter states that residential care facility, as described in Table III-1 on page III-5 (Project Description), is identified as an allowable use and adds that this allowed use ties in with Alternative C, the environmentally preferred alternative. The commenter is correct that Alternative C includes a residential care facility. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Please refer to Topical Response 10, Traffic Mitigation Measures Considered but Rejected as Infeasible and Topical Response 6, Alternatives to the Proposed Project, for more information.

Response D15-9

This comment requests that the public recognize that 5.44 acres set aside as open space is a land bank for the entire Rainier Avenue project. The comment is noted, and the DEIR states



that the 5.44 acres of open space is temporary, until and unless needed for Rainier Avenue construction.

Response D15-10

The commenter cites a portion of the first sentence of the last paragraph on page III-28 of the DEIR (Project Description) regarding the Deer Creek swale. The commenter questions if the swale is to be relocated and states that the swale was to have a 50-foot buffer. Deer Creek is not proposed to be relocated as part of the proposed project. Additionally, as stated in the second sentence of the same paragraph, the 50-foot buffer would be maintained. Please refer to Response to Comment C3-19 for additional preservation and management actions pertaining to the Deer Creek swale.

Response D15-11

The commenter cites the second bullet of the project objectives listed on page III-34 of the DEIR (Project Description). The commenter states that studies would indicate over saturation of office space, some need of retail, some harm from cannibalization, and no shortages of fitness centers. The commenter adds that the opinion in the EIR is not factual and inconclusive. The EPS Report (Appendix C to the DEIR) includes a qualitative discussion about vacancy. However, existing vacancy rates are not considered in the quantitative analysis because it evaluates the effect of the project relative to the existing “baseline” conditions. The significance criteria for urban decay impacts is described on pages 28 and 29 of the EPS Report. Lastly, the EPS Report assumes that the proposed project would initially be anchored by a home improvement store (e.g., Lowe’s). A different anchor tenant could have implications on the urban decay findings, as discussed under Comment D15-30. However, it is also important to note the urban decay analysis does not address the degree to which specific tenants will survive or be impacted by the proposed project. Rather, it focuses the project’s long-term effect on the health of the Trade Area retail sector in general. If the overall retail sector is strong, property owners will have an incentive to maintain their property in expectation that it can be leased to a new tenant within a reasonable time frame after it is vacated (e.g., if an existing tenant goes out of business). The EPS Report is based on current market trends and information that is readily available and can be identified with a reasonable degree of confidence.

Response D15-12

The commenter states that the list of agencies with jurisdiction over the proposed project under discretionary actions on page III-35 of the DEIR (Project Description) should include the Petaluma City Council. Certification of the FEIR is ultimately at the discretion of the Petaluma City Council. The Council’s discretion on the associated project, which consists solely of Site Plan and Architectural Review, would only be on an appeal of the Planning Commission’s decision. In response to this comment, the list of agencies with jurisdiction over the proposed project on page III-35 of the DEIR has been revised to read as follows:



This EIR serves as the environmental document for all discretionary actions associated with the development of the proposed project. This EIR is intended to cover all federal, state, regional, and/or local government discretionary approvals that may be required to develop the proposed project, whether or not they are explicitly listed below. The federal, state, regional and local agencies that may have jurisdiction over the proposed project may require, but are not necessarily limited to the following:

• City of Petaluma Planning Commission for Site Plan and Architectural Review

• Petaluma City Council

Response D15-13

The commenter lists environmental impacts that require a statement of overriding consideration and states that the mitigation measures to lessen significant environmental impacts should be included in the DEIR. Please refer to 15, Noise Impacts and Mitigation Measures), Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures, and Topical Response 10, Traffic Mitigation Measures Considered but Rejected as Infeasible.

Response D15-14

The commenter cites intersections with collision rates of more than twice the average rate, as described on page IV.B-19 of the DEIR. Please refer to Response to Comment C3-8 regarding the analysis of collisions.

Response D15-15

The commenter states that present resources at the City are not adequate to support a coordinated traffic signal system. The City currently maintains a traffic engineering staff consisting of a part-time traffic engineer, part-time traffic engineering technician and a full time traffic signal technician. One of the main duties of these positions is to ensure on-going operation and maintenance of the City’s traffic signal system, including signal timing modification and coordination of the entire system as deemed necessary.



Response D15-16

The commenter cites a portion of the first sentence of the second full paragraph on page IV.B-20 and states that this is a false assurance. In response, the degradation of intersection LOS to significant levels is identified in the City Roadway and Intersection Impact Criteria, page IV.B-34. With respect to the variation of average delay within a LOS grade, please refer to Table IV.B-1, on page IV.B-4 of the DEIR. At LOS F a traffic signal operates “with extreme congestion, with very high delays and long queues unacceptable to most drivers.”

Response D15-17

The commenter cites the first sentence of the first paragraph and paraphrases portions of the last paragraph on page IV.B-25 of the DEIR (Transportation and Traffic). The commenter states that Alternative C would mean fewer trips. Please refer to Topical Response 6, Alternatives to the Proposed Project.

Response D15-18

The commenter cites a portion of the second paragraph on page IV.B-26 and adds that the DEIR is inadequate in financial feasibility of the Rainier Avenue interchange. Please refer to Topical Response 7, Rainier Avenue Interchange/Cross-Town Connector and Other Roadway Improvements.

Response D15-19

This comment restates the findings on page IV.B-27 regarding the Rainier Avenue/North McDowell Boulevard level of service. This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.

Response D15-20

This comment recommends that the Graton Rancheria Casino be included in the DEIR cumulative traffic analysis. Please refer to Response to Comment D15-3.

Response D15-21

The commenter summarizes a portion of page IV.B-47 of the DEIR regarding project traffic impacts and suggests including the Graton Rancheria Casino as part of the impact analysis. Please refer to Response to Comment D15-3.

Response D15-22

The commenter summarizes a portion of page IV.B-62 of the DEIR regarding emergency access and response and states that there is no analysis to support the DEIR’s conclusion that



emergency access impacts would be less than significant. Please refer to Topical Response 11, Emergency Access Impacts.

Response D15-23

This comment states that the DEIR fails to provide adequate mitigation measures for GHG impacts and provides recommended measures to reduce the project’s GHG emissions. Please refer to Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures, and to Response to Comment C3-18.

Response D15-24

This comment appears to address concerns regarding carbon monoxide concentrations at sensitive receptors near the project. The DEIR analysis considered the impacts from all intersections affected by the proposed project and applied the appropriate screening analysis recommended in the BAAQMD CEQA Air Quality Guidelines. Additionally, see Response to Comment C3-11.

Response D15-25

This comment states that the DEIR fails to provide adequate mitigation measures for GHG impacts and expresses concern regarding the project’s GHG emissions. Please refer to Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures, and to Response to Comment C3-18.

Response D15-26

This comment states that the DEIR mitigation measures for GHG are inadequate. Please refer to Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures, and to Response to Comment C3-18.

Response D15-27

This comment states that 83% of the project’s GHG emissions are from traffic and that a mitigation measure only reduces these emissions by 4%. Please refer to Topical Response 13, Greenhouse Gas Impacts and Mitigation Measures.

Response D15-28

The commenter cites the first three bullet points on page V-1 and portions of the third and fourth paragraphs on page V-3 of the DEIR (General Impacts Category). This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters. Additionally, the commenter states that a sound wall should be added to protect



those residences on North McDowell Boulevard. Please refer to Topical Response 15, Noise Impacts and Mitigation Measures.

Response D15-29

This comment states that development of the proposed project, as well as other proposed projects in the City's pipeline including East Washington Place, is likely to have a significant impact on the existing retail space performance and potentially create conditions that temporally (3-5 years) could be conductive to urban decay. The EPS Report is based on current market trends and information that is readily available and can be identified with a reasonable degree of confidence. In reality, a variety of outcomes are possible and will likely be influenced by a range of events and activities that cannot be predicted or captured by this analysis.

Response D15-30

This comment questions what mistakes could we make that would ensure urban decay and what if the planned Lowe’s tenant were to become a Wal-Mart instead. The EPS Report (Appendix C to the DEIR) assumes that the proposed project would initially be anchored by a home improvement store. If a different type of tenant were to anchor the site, the EPS analysis would need to be modified to account for the potential for different economic impacts. The direction or scale of these impacts would depend on the size and market orientation of the actual tenant. The DEIR takes into account the project as proposed. Please refer to Topical Response 14, Urban Decay.

Response D15-31

This comment states that most of the $407,000 net revenue in sales tax could be achieved with option C, the environmentally superior alternative, depending on the tenant. The EPS Report does not address the economic implications of the “environmentally superior alternative.” The Report also does not address fiscal implications (revenues and expenditures generated by the project) with the exception of retail sales generated to the City’s General Fund. This comment expresses an opinion about the DEIR but does not state a specific concern or question regarding the sufficiency of the analysis or mitigation measures contained in the DEIR. The comment will be forwarded to the decision-making bodies as part of the FEIR for their consideration in reviewing the project.

Response D15-32

This comment refers to Alternative C on page VI-4 and states “residential and commercial alternative.” This comment does not address the adequacy of the DEIR nor does the comment raise a new environmental issue. Therefore, per Section 15204 of the CEQA Guidelines, no further response is required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters.



Response D15-33

The commenter presumably expresses support for a No Project Alternative and expresses an opinion regarding the Rainier Avenue Interchange/Cross-Town Connector’s inclusion in the General Plan. Although this comment is noted, modifications to General Plan policy are not part of the proposed project and criticisms of the General Plan do not constitute separate CEQA issues for this project.

Response D15-34

The commenter paraphrases a portion of the last full paragraph on page VI-11 of the DEIR (Alternatives). The commenter suggests that a solution to significant unavoidable impacts related to cumulative traffic noise would be “no project.” This comment is acknowledged and will be forwarded to the decision-making bodies as part of the FEIR for their consideration in reviewing the project. The commenter adds that a sound wall for those homes backing North McDowell Boulevard needs to be incorporated with the project due to unavoidable noise impacts. Please refer to Topical Response 15, Noise Impacts and Mitigation Measures.

Response D15-35

The commenter states that Rushmore Avenue is not analyzed as part of the DEIR. Please refer to Topical Response 9, Traffic Analysis of Additional Local Streets, for an explanation of why Rushmore Avenue was not included in the analysis. The commenter questions why the SMART Train and Freight Train Services are not included in the DEIR. The alignment of the Rainier Avenue Cross-Town Connector Project as currently being considered through the CEQA process would span above the railroad tracks and therefore train traffic (SMART or freight) would not interrupt cross-town traffic flow. The environmental impacts associated with the SMART Train and Freight Train Service are addressed in the individual EIRs prepared for those two separate projects. Additionally, the commenter states that the proposed project does not include a crosswalk from Rainier Avenue to Maria Drive and that Rainier Avenue has a curve in the road making it dangerous for crossing. These comments will be forwarded to the decision-making bodies as part of the FEIR for their consideration in reviewing the project.

Response D15-36

The commenter paraphrases a portion of the first sentence of the last paragraph on page VI-12 of the DEIR (Alternatives). The commenter states that Alternative B meets most of the project’s goals. This comment is acknowledged and will be forwarded to the decision-making bodies as part of the FEIR for their consideration in reviewing the project.

Response D15-37

The commenter paraphrases portions of the first, second, and fourth paragraph on page VI-13 of the DEIR (Alternatives) which pertain to Alternative C but does not address the adequacy of the DEIR. Therefore, per Section 15204 of the CEQA Guidelines, no further response is



required. Refer to Topical Response 2, Standards for Responses to Comments and Focus of Review of Commenters. The commenter also questions why only elderly care was considered for Alternative C. As described on page VI-5 of the DEIR, the 2025 General Plan land use designation for the project site is Mixed Use, which supports a variety of uses, including retail, specific types of residential, service commercial, and offices. Based on this zoning, the only types of residential uses permitted at the project site include residential care facilities and work/live residential uses. The City chose to include a residential care facilities component in Alternative C because it was considered more economically viable compared to work/live residential uses.

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