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 16 corresponding mitigation measures. (CEQA Guidelines §§ 15162 and 15168(c)(1); Pub. Res. Code §§ 21100(a), 21151.) The Draft EIR's reliance upon each of the above streamlining mechanisms is misplaced, as the District anticipates that construction and operation of the proposed Project on Parcel F will pose new and/or more significant, Project -specific impacts on the environment that were not analyzed in the DTPP EIR. As discussed extensively above, the proposed Project Draft EIR fails to serve its purpose as an informational document, as it does not analyze numerous school and school - related impacts anticipated to be caused by the Project, including impacts on the District's ability to provide its public service, transportation and traffic impacts related to schools and student safety, air quality and noise impacts related to schools, and population and housing impacts related to school facilities. Each of the above deficiencies in the Draft EIR is also present in the Consistency Analysis and DTPP EIR. For instance, as explained above, the District anticipates that the proposed Project will pose significant impacts on student safety due to increased levels of traffic congestion on El Camino Real and its surrounding neighborhoods. In analyzing whether the proposed Project would "conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle and pedestrian facilities," the Consistency Analysis simply states that the proposed Project would comply with all requirements and promote all goals of the DTPP, and "no impacts beyond those identified in the DTPP Program EIR would result." (Appendix CNA at 3-69.) However, neither the Consistency Analysis nor the DTPP EIR analyze whether construction of the Project on Parcel F will pose impacts on student safety due to increased levels of traffic congestion. For this reason, the City's reliance upon the DTPP EIR in an effort to simplify analysis of the Project was improper. As another example, and again as noted above, the District anticipates that the proposed Project may impact the District's ability to provide its public service, as new students generated by the project combined with other impacts of the 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. The Consistency Analysis, as above, concludes that the impacts on schools would be less than significant, "and the project would not have any impacts above those analyzed in the DTPP Program EIR." (Appendix CNA at 3-64.) However, once again, neither the DTPP EIR nor the Consistency Analysis provide sufficient information needed by the public or the lead agency to meaningfully analyze the proposed Project's specific impacts on the District. Rather, the DTPP EIR appears to be based on the same misguided perception that SB 50 (including Gov. Code § 65996) and the payment of developer fees alleviates developers from analyzing and mitigating all possible school and school -related development impacts. The DTPP EIR and Consistency Analysis otherwise fail to analyze the 27 sub -categories of information noted by the District, above. Consideration of these categories is critical in order to understand whether the proposed Project, including development of Parcel F, could pose significant impacts on schools and the District. Because this information was missing from the DTPP EIR and the Consistency Analysis, streamlining environmental review for development of Parcel F was improper.