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Ms. Lindy Chan, Principal Planner <br />City of Redwood City, Planning Services <br />July 13, 2020 <br />Page 3 <br />Guidelines § 15002(a)(1) and (a)(4).) In line with this goal, the preparer of an EIR must make a <br />genuine effort to obtain and disseminate information necessary to the understanding of impacts of <br />project implementation. (See, CEQA Guidelines § 15151; Sierra Club v. State Board of Forestry <br />(1994) 7 CalAth 1215, 1236.) <br />An EIR must describe existing environmental conditions in the vicinity of the proposed project <br />from both a local and regional perspective, which is referred to as the "environmental setting." <br />(CEQA Guidelines § 15125.) This description of existing environmental conditions serves as the <br />"baseline" for measuring the qualitative and quantitative changes to the environment that will <br />result from the project and for determining whether those environmental effects are significant. <br />(Id.; see also, CEQA Guidelines § 15126.2(a); Neighbors for SmartRail v. Exposition Metro Line <br />Constr. Auth. (2013) 57 C4th 439, 447.) <br />District facilities are a critical part of the Project location's environment, and should be considered <br />throughout the Draft EIR impact categories. As noted, the Project's Parcels A-E and Parcel F are <br />located a mere few blocks southeast of the District's Sequoia High School and Administrative <br />Offices, along El Camino Real. The Project is proposed within the District's Sequoia High School <br />Attendance Boundary, which includes several neighborhoods northeast and southwest of the <br />Project. The proposed Project will be located in between Sequoia High School and the area in <br />which a substantial portion of the District's staff and students that attend Sequoia High School <br />reside, along the main road used by those staff members, students and their families to travel to and <br />from school and the District Office. The Project is located on a road and in a neighborhood that <br />has been heavily impacted by traffic, traffic exhaust, and fumes due to increased development.' <br />The Draft EIR purports to describe the Project's environmental setting in each of the five <br />environmental impact categories that are analyzed in the Draft EIR. (Draft EIR at ES -3.) <br />However, none of the five impact categories include any reference to the District, Sequoia High <br />School, or the District Office. The Draft EIR does not discuss the location of Sequoia High School <br />or its close proximity to the proposed Project. The Draft EIR likewise fails to describe or address <br />the current vehicular and pedestrian paths of travel used by District staff, students and their <br />families to get to and from school or the District Office, in the context of a neighborhood that has <br />already been severely impacted by traffic. Without consideration of these factors, it is impossible <br />for the lead agency and public to assess whether there are any impacts posed by the Project on the <br />District's students, families, and staff, and whether those impacts are significant. As discussed <br />below, the District anticipates that the Project will pose significant impacts in these areas. <br />This omission follows on the Initial Study prepared in July 2019. The Initial Study's description of <br />the environmental setting as it pertains to the District was inadequate in that it assumed that the <br />District's Sequoia High School is located 1.5 miles northwest of the Project site. Thus, the Initial <br />Study misstates the distance between the proposed Project and the District's Sequoia High School <br />by over 100%, underestimating any potential environmental impacts to the District caused by the <br />Project. The Initial Study also violates CEQA Guidelines section 15125 in that it failed to <br />appropriately consider the District's overall facilities capacity. The District's overall enrollment <br />currently exceeds the District's overall facilities capacity, as noted in the "School Fee Justification <br />2 Redwood City General Plan (October 11, 2010) at Figure BE -14; pp. BE -106 and BE -131. <br />