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 17 V. The Draft EIR, Initial Study, and Consistency Analysis collectively result in an improper "piecemeal" review of the Project. CEQA forbids "piecemeal" review of the significant impacts of a project. (Aptos Council v. County of Santa Cruz (2017) 10 Cal.App.5th 266, 277-278.) "This standard is consistent with the principle that `environmental considerations do not become submerged by chopping a large project into many little ones—each with a minimal potential impact on the environment—which cumulatively may have disastrous consequences."' (Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Cal.3d 376, 396.) The Draft EIR defines the Project to include development on Parcels A -F. (See, Draft EIR at 2- 8.) However, the Draft EIR, in reliance on the Initial Study, primarily focuses on impacts to be caused by development of Parcels A-E. Meanwhile, the environmental analysis for development of the Project on Parcel F is mostly contained in the Consistency Analysis. By splitting up the Project into component pieces, the Draft EIR fails to demonstrate accurately the Project's anticipated impacts as a whole. For instance, while the Draft EIR states that the impact analysis "includes Parcel F in the assessment of VMT when determining the potential significance of project -related transportation effects," it is unclear whether the Draft EIR otherwise considers all potential traffic/transportation impacts of development on Parcel F. In analyzing whether the Project conflicts with any programs, plans, ordinances, or policies addressing the circulation system, and in assessing whether the Project would substantially increase hazards or result in inadequate emergency access, it does not appear that the Draft EIR considers the impacts of development on Parcel F throughout the analysis. (See, e.g., Draft EIR Figures 3.5-1C, 3.5-2, and 3.5-3, which do not specifically depict Parcel F.) It is likely that development on Parcel F, combined with development on Parcels A-E, would have more significant impacts on traffic/transportation than development on Parcels A-E, alone. By largely confining the analysis of Parcel F to the Consistency Analysis, the Draft EIR understates the Project's impacts on traffic/transportation, in violation of CEQA. It is also unclear whether the Draft EIR considers the Project as a whole in analyzing impacts to Public Services, including to the District. Development of new residential units on Parcels A-E may not individually have a significant impact on the District's need for new or physically altered school facilities in order for the District to maintain its performance objectives. However, adding a six -story residential complex that will be approximately 0.2 miles closer to the District's Sequoia High School on El Camino Real would likely amplify any impacts caused by a new mixed-use development on Parcels A-E. Accordingly, the impacts on public services caused by Parcels A -F must be considered together, rather than separately. VI. The proposed mitigation measures are inadequate to reduce the impacts related to schools to a less than significant level. Based on the deficiencies of the Draft EIR described above, it is District's position that the Draft EIR's conclusion that payment of school impact fees will mitigate school impacts to a less than