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 5 students, families, and staff related to the provision of school services. This short and conclusory analysis violates CEQA. With regard to a lead agency's determination that environmental impacts are insignificant (and can be scoped out of an EIR), the lead agency must include in either the Initial Study or the EIR the reasons that the applicable environmental effects were determined to be insignificant. (Pub. Res. Code § 21100(c); CEQA Guidelines § 15128.) An unsubstantiated conclusion that an impact is not significant, without supporting information or explanatory analysis, is insufficient; the reasoning supporting the determination of insignificance must be disclosed. (See, City of Maywood v. Los Angeles Unified Sch. Dist. (2012) 208 CA4th 362; 393; San Joaquin Raptor/Wildlife Rescue Ctr. V. County of Stanislaus (1994) 27 CA4th 713 [findings that project will not pose biological impacts to wetlands must be supported by facts and evidence showing that the lead agency investigated the presence and extent of wetlands on the property, which analysis must be disclosed to the public].) The Initial Study and Draft EIR fail to provide sufficient information needed to analyze all potential impacts of the Project under the stated Public Services threshold of significance. The Initial Study only purports to analyze whether the increase in students caused by the Project will result in a need for new school facilities. In doing so, the Initial Study relies solely upon the current enrollment capacity of Sequoia High School. This approach oversimplifies the myriad of ways in which large residential and commercial development projects, like the Project, can impact a school district's need for new or physically altered facilities in order to maintain performance objectives. The Initial Study and Draft EIR fail to analyze all potential impacts under this standard, including but not limited to: (1) whether the influx of students would require "physically altered" school facilities; (2) whether other impacts of the proposed Project, such as increased traffic, noise, or air pollutants in the neighborhood surrounding Sequoia High School, could impact the District's need for new or physically altered school facilities; and (3) whether other impacts of the proposed Project could otherwise interfere with the District's ability to accomplish its own performance objectives. The District anticipates that its ability to provide adequate service at Sequoia High School will be severely impacted by the Project. For this reason, the District requested that the Draft EIR identify, describe, and/or analyze the following: 1. Existing and future conditions within the District, on a school -by -school basis, including size, location and capacity of facilities. 2. Adequacy of both existing infrastructure serving schools and anticipated infrastructure needed to serve future schools. 3. District's past and present enrollment trends. 4. District's current uses of its facilities. 5. Projected teacher/staffing requirements based on anticipated population growth and existing State and District policies.