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

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Ms. Lindy Chan, Principal Planner City of Redwood City, Planning Services October 27, 2020 Page 3 affected populations (e.g., sensitive receptors), not because they work for a particular employer or have families whose students attend a particular school"].) Without consideration of these factors, it is impossible for the lead agency and public to assess the extent of any safety impacts posed by the Project on the District's students, families, and staff. Such an analysis of safety impacts is critical to the determination of whether the Project will impact the District's ability to provide public services and whether the Project will have traffic/transportation impacts (as discussed below). The Draft EIR, as modified by the Final EIR, likewise continues to fail appropriately to consider the District's needs at Sequoia High School beyond the issue of overcrowding, and the District's overall facilities capacity and needs (as opposed to just the District's capacity at Sequoia High School). By only addressing the District's current capacity at, and the Project's impacts on Sequoia High School in isolation, the Final EIR presents a misleading picture regarding the District's ability to provide adequate facilities needed to house additional enrollment. As explained in the July 13 letter, such a surface level description of school facilities is inconsistent with the requirements of CEQA. III. Analysis of Impacts Related to Schools A. Impacts on Schools The Draft EIR, as modified by the Final EIR, maintains an inadequate discussion of impacts on schools. The Initial Study, which is relied upon by the Draft EIR and the Final EIR, 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, Draft EIR, and now the Final EIR have all concluded that, because the District's Sequoia High School would have enrollment capacity to accommodate any students generated by the proposed Project at Sequoia High School, the Project would not result in a significant impact to schools. Further, the Final EIR again relies on SB 50 (Stats. 1998, Ch. 407) 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. (Final EIR at 3-5.) As explained in the District's July 13 letter and incorporated herein, this short and conclusory analysis is flawed. The Draft EIR, as modified by the Final EIR, fails to provide sufficient information needed to analyze all potential impacts of the Project under the stated Public Services threshold of significance, 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 in the neighborhood surrounding Sequoia High School, could impact the District's use or need for new or physically altered school facilities; and (3) whether other