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The Honorable Mayor Diane Howard/City Council <br />Page 3 <br />August 7, 2020 <br />concludes that the Project may be adopted under CEQA without any modifications to the 1548 <br />Maple Street EIR, a Supplemental EIR or further environmental review under CEQA. <br />Critically, however, the Addendum did not analyze the environmental impacts of relocating the <br />Maple Street Shelter to an existing, heavy industrial area. The Addendum says that this <br />relocation was "not included as part of the proposed project" because "the location of a <br />replacement facility has not yet been determined." Addendum at page 2-6. <br />That is not the appropriate standard under CEQA for the review of the environmental impacts <br />of a proposed project. An EIR must not limit its review to the impacts of project elements which <br />have been definitively "determined." Under CEQA, an EIR must include an analysis of the <br />environmental impacts of actions which are a "reasonably foreseeable consequence" of the <br />project. Laurel Heights Improv. v. Regents of Univ. of California, 47 Cal. 3d 376, 396 (Cal. <br />Supreme Court 1988). <br />Here, as part of the Project, the County would be given a nearly vacant site by the City that the <br />County says is the "best and only site" for relocating the Maple Street Shelter after looking "for <br />years" without success for another site. See City Staff Report at page 6. And, as noted above, <br />if the County does not relocate the shelter within two years, the County would be required to <br />pay the City two million dollars in liquidated damages. <br />Not only is it "reasonably foreseeable" that the County will move the Maple Street Shelter to <br />1402 Maple Street as part of the Project, it is a foregone conclusion. The environmental impacts <br />of this relocation, from the existing County property to a heavy industrial area, must therefore <br />be analyzed under CEQA. Neither the Addendum, nor the 1548 Maple Street EIR, nor any <br />other CEQA documentation provides this analysis for public review. <br />A Supplemental EIR, not an Addendum, is Required for the Project. <br />In fact, it appears that a Supplemental EIR, and not an Addendum is required in this instance <br />under CEQA. The City -owned property at 1402 Maple Street is designated Light Industrial <br />under the City's General Plan for "relatively low -intensity industrial uses" and GI (General <br />Industrial) under the City's Zoning Ordinance. General Plan at page BE -49. <br />Immediately adjacent to the site, to the southeast, land is designated under the General Plan as <br />Industrial — Port Related. Graniterock's Peninsula Concrete and Redwood City Building <br />Materials facility lies within this Industrial — Port Related General Plan category at 355 <br />Blomquist Street, immediately adjacent to the 1402 Maple Street property currently owned by <br />the City. <br />According to the General Plan: <br />The Industrial - Port Related category serves an important role: to protect and enhance <br />the valuable deep -water Port facilities in Redwood City. This designation provides for <br />heavy industrial activities requiring large properties and water access for materials <br />loading, storage, and processing, combined with convenient access for trucks, rail, and <br />port berthing facilities. Allowed uses include industrial operations involved in the <br />