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 7 increase the severity of any impacts previously analyzed. (See, Appendix CNA at 1-1 — 1-2.) Because the construction and operation of the proposed Project on Parcel F will pose new and/or more significant school and school -related impacts that were not analyzed in the DTPP, including impacts on the District's ability to provide its public service and transportation/traffic impacts related to schools and student safety (as discussed above and in the July 13 letter), the Draft and Final EIRs reliance upon the DTPP was legally improper. On these grounds, which have not been adequately addressed in the Final EIR, the District hereby maintains its objections to the streamlining mechanism relied upon in the Draft and Final EIRs. V. Improper "Piecemeal" Review of 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.) As noted in the July 13 letter, 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 attached as Appendix CNA to the Draft EIR. By splitting up the Project into component pieces, the Draft EIR fails to demonstrate accurately the Project's anticipated impacts as a whole. The Final EIR states that "[s]ite-specific Parcel F impacts with other proposed project development on Parcels A through E are analyzed in" the "air quality (construction emissions, health risks, and carbon monoxide hotspots); greenhouse gases and climate change; and transportation" sections of the Draft EIR. (Final EIR at 3-34.) The District did not dispute that some impacts of development on Parcel F were also included within the Draft EIR's analysis of the Project as a whole. However, it appears that Parcel F was excluded from several other portions of the Draft EIR, including portions of the traffic/transportation section. For instance, and as previously noted, 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 also remains unclear from the Final EIR 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 District reiterates its assertions that impacts on public services caused by Parcels A -F must be considered together, rather than separately.