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

Browse Search

Ms. Lindy Chan, Principal Planner City of Redwood City, Planning Services July 13, 2020 Page 15 (Pub. Res. Code § 21001(g); Cal. Code Regs., tit. 14, § § 15021(b), 15131(a) -(c), 15142 & 15382.) Phasing of development is also a crucial consideration in determining the extent of impact on schools. The timing of the development will determine when new students are expected to be generated, and therefore is an important consideration particularly when considering the cumulative impact of a project in conjunction with other approved or pending development. The District requests that the above categories of information be included so that the lead agency, District, and the public may adequately understand the direct and indirect impacts of the Project upon the District. (CEQA Guidelines § 15126.2(a) [requires consideration of indirect impacts] .) IV. The Draft EIR improperly streamlines environmental review of Parcel F. The proposed Project would involve the construction of 39 residential units on Parcel F, located at 1304 El Camino Real. As Parcel F is located in the City's downtown core, it falls within the land covered by the City's Downtown Precise Plan ("DTPP"). The City previously prepared and certified a Program EIR for the DTPP in 2010 and 2011, respectively (the "DTPP EIR"). The Draft EIR relies upon three EIR streamlining or tiering mechanisms in contending that the Draft EIR does not need to analyze the environmental impacts caused by development of the Project on Parcel F, including (1) the "Community Plan Exemption" contained in Public Resources Code section 21083.3 and CEQA Guidelines section 15183; (2) the `'Qualified Infill Exemption" under Public Resources Code section 21094.5 and CEQA Guidelines section 15183.3; and (3) the mechanism provided under CEQA Guidelines section 15168(c) for later activities contemplated by a Program EIR. (Draft EIR Appendix CNA, at 1-1 — 1-2.) The Draft EIR relies upon a "Consistency Analysis" contained in Appendix CNA, which purports to assess the proposed Project's consistency with the DTPP EIR through a "Checklist" contained in Chapter 3 of Appendix CNA. As explained in Appendix CNA, each of the above streamlining or tiering mechanisms applies only insofar as the proposed Project would not pose any new, project -specific significant impacts not previously analyzed by the City, and/or would not increase the severity of any impacts previously analyzed. (See, Appendix CNA at 1-1 — 1-2.) Under the Community Plan Exemption, Public Resources Code section 21083.3 and CEQA Guidelines section 15183 allow streamlined environmental review for projects that are "consistent with the development density established by existing zoning, community plan or general plan policies for which an EIR was certified... except as might be necessary to examine whether there are project -specific significant effects which are peculiar to the project or its site." (Emphasis added.) Similarly, under the Qualified Infill Exemption, the City notes in Appendix CNA that no additional environmental review would be required pursuant to the exemption "if the infill project would not cause any new specific effects or more significant effects." Finally, with regard to the third tiering mechanism, if the project will result in significant environmental impacts that were not examined in the program EIR, then the project proponent must prepare an EIR analyzing those impacts and