AgdaPkt 2020-11-09 Joint SA PFA - Laserfiche WebLink

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Ms. Lindy Chan, Principal Planner City of Redwood City, Planning Services July 13, 2020 Page 4 Study" prepared for the District by Jack Schreder & Associates in March 2018 ("SFJS"). By only addressing the District's current capacity at Sequoia High School in isolation, the Initial Study presents a misleading picture regarding the District's ability to provide adequate facilities needed to house additional enrollment. As explained below, such a surface level description of school facilities is inconsistent with the requirements of CEQA. II. The Draft EIR does not meet its purposes as an informational document because it fails to provide an adequate analysis of environmental impacts related to schools. A. The Draft EIR contains an inadequate discussion of impacts on schools. The Draft EIR improperly "scopes out" numerous environmental impact categories, including those related to Public Services. As noted by the Draft EIR: California Environmental Quality Act (CEQA) Guidelines Section 15128, Effects Not Found to be Significant, allows environmental issues for which there is no likelihood of significant impact to be `scoped out,' and not analyzed further in the environmental impact report (EIR). The project Initial Study provided in Appendix IS analyzed the environmental impacts of the proposed development on Parcels A through E. All topics in the CEQA Environmental Checklist (Appendix G of the CEQA Guidelines) were evaluated. As detailed in the Initial Study, all impacts were found to be less than significant or less than significant with mitigation, with a few exceptions. (Draft EIR at 6-1.) However, the Initial Study does not contain an adequate discussion of school related impacts, and so cannot be relied upon as grounds to scope out probable impacts on schools. The Initial Study states that the proposed Project would have a significant impact on schools if it would: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, or the need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times, or other performance objectives [for the provision of school services]. The Initial Study and Draft EIR conclude that, because the District's Sequoia High School would have enrollment capacity to accommodate any students generated by the proposed Project, the Project would not result in a significant impact to schools. (Initial Study at 4.15-6.) The City then relies on SB 50 (Stats. 1998, Ch. 407), and specifically Government Code section 65996, for the conclusion that "payment of the applicable school impact fee is deemed to be full and complete mitigation under CEQA for impacts on school facilities." (Initial Study at 4.15-5-6; Draft EIR at 6-8.) In other words, the DEIR concludes that because the District has capacity to accommodate the 100+ students to be generated by the Project, it will not require new facilities. Accordingly, and because the Developer would be subject to school impact fees (also referred to as "developer fees"), the DEIR concludes that there can be no other impacts on the District, its