Honorable Mayor and Members of the City Council through City Manager. Public Hearing to Receive Public Comment, Discuss the Draft Environmental

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1 Agenda Item # 5.A DATE: May 21, 2018 TO: FROM: SUBJECT: Honorable Mayor and Members of the City Council through City Manager Heather Hines, Planning Manageri Public Hearing to Receive Public Comment, Discuss the Draft Environmental Impact Report, and Take Possible Action to Direct Preparation of Final Environmental Impact Report for the Proposed Sid Commons Apartment Project, located at Northwest End of Graylawn Avenue. RECOMMENDATION It is recommended that the City Council receive public comment, provide comments on the adequacy of the Draft Environmental Impact Report ( DEIR) and, direct preparation of a Final Environmental Impact Report (FEIR). BACKGROUND The Sid Commons Apartment Project is a 278 -unit multi -family residential project on approximately 15 acres at the terminus of Graylawn Avenue, west of the existing Oak Creek Apartments. The project includes the following entitlements: A Planned Unit Development ( PUD) Amendment to remove current restrictions regarding use, oak tree retention, and access to the project site, as contained in the 1982 PUD approval for the Oak Creek Apartment project ( City of Petaluma Resolution No. 9628, December 1982), A Zoning Map Amendment to rezone APN from that PUD to R4 Residential 4) to enable development at densities up to 18 units per net developable acre consistent with the Medium Density Residential General Plan Land Use Designation), Subsequent Site Plan and Architectural Review for the development site, and Subsequent minor mapping ( lot line adjustment or tentative parcel map) reflecting the refined site plan. More background on the project and specific discussion about the CEQA process is provided in Attachment 1, Planning Commission Staff Report ( pages 1-2). On March 1, 2018, the City released a Draft Environmental Impact Report ( DEIR) for the Sid Commons Project. The DEIR was released for a 45 -day public review period, which ended on April 16, However, comments will be accepted up until the end of the City Council hearing on May 21, 2018.

2 On April 24, 2018, the Planning Commission held a public hearing to consider the DEIR and to receive public comments. The Planning Commission received oral comments from three speakers. The primary concern expressed was related to traffic impacts on Graylawn Avenue. In addition, the following concerns were expressed by one or more of the commenters: Ensure that the proposed EVA at Bernice Court include physical barriers to limit access to emergency vehicles only Potential impacts to Shasta Avenue residents if a rail crossing is pursued, and noting the difficulty of designing an at -grade crossing as the rail siding is currently 16 inches below the main line track Concern that the traffic count data for Graylawn Avenue as presented in the DEIR may be low, as more people are now living in many of the neighborhood residences because of the housing crunch (household size has increased) Clarification that traffic counts recently taken by the applicant team were not the basis of the DEIR, as due to the counts occurring during the recent spring break they may not reflect " normal" conditions Impacts associated with introducing impermeable surfaces onsite and diminishing the site' s ability to absorb water Importance of preserving pervious lands, wetlands, and riparian vegetation near the river Wildlife and habitat should be preserved Sediment in the river may be greater now than was anticipated in the flood modeling Flood events are changing and storms are becoming more extreme, therefore the DEIR may underestimate flooding impacts and lack information on the cumulative flooding effect Water quality should be better protected by strengthening best management practices and more stringent DEIR mitigation measures The proposed density is too high and the site is better suited to support fewer units A written petition was submitted to the Planning Commission at the hearing. The petition is signed by 40 neighbors on Graylawn Avenue, Bernice Court, Betty Court, and Jess Avenue. The majority note that they had reduced car trips during the period in which traffic counters had recently been observed ( March 2018), citing spring break. The petition expresses concern that the project would cause substantial significant negative impact to the neighborhood, principally from increased vehicle trips on Graylawn. Following discussion, the Planning Commissioners found that the DEIR adequately analyzed the environmental impacts of the proposed project. The Commission recommended that the Council find the DEIR adequate and direct preparation of the FEIR. Two specific clarifications that the Commission requested be addressed in the FEIR was a discussion regarding how current river N

3 conditions relate to the flooding model presented in the DEIR and clarification that flooding and sea level rise data used in the EIR is current. In addition, the Commission provided comments regarding specifics of the Project, including discussion of the following: The appropriateness and likelihood of an at -grade crossing over the railway through the proposed extension of Shasta was questioned Without the secondary access on Shasta, the Project density appears to be too much for Graylawn Concern related to flooding, given current siltation, changing storm events, and/ or sea level rise The project refinement prepared for SPAR review should be designed and oriented to its river setting and should respect the River Access and Enhancement Plan Desire that the proposed river path connect to the regional trail network Desire that the terrace should work around mature oaks to the maximum extent feasible Desire to. see onsite affordable housing included in the project Given issues with access, flooding, and river treatment, the appropriate density for the site appears to be more suitable in the range of units per acres Existing feel of Graylawn as a neighborhood street should be protected A majority of the Planning Commissioners stated a preference for a project that aligned closer with Alternative 4, precluded an at -grade crossing, and provided an appropriate buffer between new development and the riparian corridor. In addition to the three public comments received at the Planning Commission hearing, several written comments were received in response to the Notice of Availability published for the DEIR. The following provides a list of all agencies and individuals that submitted comment letters on the Sid Commons DEIR, each letter is also included at Attachment 2. From Brownsfield and Environmental Restoration Program, Department of Toxic Substance Control Date Received March 7, 2018 California Public Utilities Commission March 9, 2018 California Department of Transportation March 30, 2019 Sonoma Marin Area Rail Transit Aril 13, 2018 Reuben, Junius & Rose, LLP ( attorney representing the applicant) including: Exhibit A: from Trans edia Consulting Engineers April 16, 2018

4 Exhibit B: from Acclaim Companies ( applicant) Kallie Kull Aril 23, 2018 Tar n Obaid Aril 23, 2018 Donna Smith Aril 24, 2018 Petition Aril 24, 2018 On Apri124, 2018, the Planning Commission took action recommending that the City Council authorize preparation of a FEIR, and requested that the FEIR return to Planning Commission for consideration and a recommendation to City Council. DISCUSSION The purpose of the public hearing is to gather comments on the DEIR for the Sid Commons Project. After closing the public hearing and providing any Council comments on the DEIR, it is recommended that the City Council authorize staff to move forward with preparation of the FEIR. The purpose of the DEIR is to inform decision makers for the City of Petaluma, other responsible agencies, and the public of the potential environmental consequences of implementing the project, as proposed. Please refer to Attachment 1, the Planning Commission staff report, for additional information regarding the California Environmental Quality Act, and an Overview on the Sid Commons Apartments DEIR. When reviewing the DEIR, the City Council and members of the public should consider the following framework for providing comments: 1) Consider the adequacy of the DEIR in disclosing the potential impacts of the project and identifying mitigation measures; and 2) Identify any changes, clarifications, or additional information that should be incorporated in the Final EIR to better explain or disclose the potential environmental impacts. It is recommended that the City Council find that the DEIR adequately discloses potential impacts and identifies mitigation measures. The City Council should identify changes, clarifications, and additional information to be incorporated in the FEIR. Comments about the social and economic merits of the project that are not related to its potential environmental impacts and the DEIR should be reserved for a later time when the project' s requested entitlements are up for consideration. For the Sid Commons Apartments Project, it is anticipated that the requested entitlements, which include amendments to the Oak Creek Apartments Planned Unit Development ( PUD), and a zoning map amendment to change the PUD zoning on the northern portion of the site to R4 ( consistent with the existing zoning on the southern portion of the site and the General Plan land use designation), will be brought forward for consideration at the time the FEIR is being considered for certification. At the direction of City Council, staff will initiate preparation of a FEIR, which will incorporate necessary revisions and responses to environmental points raised during the public review period. At a future public hearing following completion of the FEIR, the City Council will M

5 consider certification of the FEIR following a meeting for consideration and recommendation by the Planning Commission. Certification of the EIR is required before action may be taken on the project' s requested entitlements. Response to each of the public comments received during circulation of the DEIR will be included in the FEIR. The Key Environmental Considerations presented in the Planning Commission Staff Report, see Attachment 1 ( pages 5-9), may be helpful to the Council' s consideration of the environmental analysis. The following additional discussion on Access is provided below in an effort to further describe considerations associated with the analysis of traffic volumes along Graylawn Avenue. Access This discussion builds off the access discussion at pages 5-7 of the Planning Commission Staff Report. The City' s Department of Public Works & Utilities, Street Design and Construction Standards & Specifications identify street standards for local residential streets including a traffic volume of less than 2, 000 average daily traffic (ADT) trips. To maintain Graylawn Avenue within the City' s ADT standard as a local residential street, minimize impacts to Graylawn area residents, and lessen neighborhood impacts relating to the proposed removal of the PUD access restriction from the northern 2/ 3rds of the Project site, all Alternatives set forth in the Sid Commons DEIR present a unit count that would not exceed the City' s Street Standard, including Alternative 4. Planning Commission heard from neighbors, both during public comment and in writing Attachment 2, pages 2-27 to 2-35), of the desire to maintain the existing residential character of the neighborhood and to minimize traffic impacts to Graylawn Avenue. Neighbors expressed concern about increasing the number of vehicles on Graylawn Avenue and how that increase would affect quality of life. Planning Commissioners reiterated concerns raised by the public regarding the ability of Graylawn to serve as the primary point of access for the full project as proposed ( 278 units). The applicant submitted a comment letter (Attachment 2) suggesting that the DEIR should utilize a lower trip generation rate and/or a trip reduction factor to modify the number of trips anticipated by the Project, such that additional units could be accommodated on- site without exceeding the City' s Street Standards. The transportation engineer hired by the applicant to review the DEIR ( Transpedia) suggested use of the Mid -Rise Apartments trip rate, which would reduce the anticipated daily trips by approximately 40%. At the Planning Commission hearing, the City' s DEIR traffic consultant clarified that the reduced trip generation rate advocated by Transpedia was not utilized in the DEIR because the project site is not in proximity to services and alternative transportation sufficient to justify a lower daily trip rate. The trip rate set forth in the DEIR is in accordance with the Institute of Transportation Engineers ( ITE) category for Apartments and is expected to be reflective of what would be generated by the proposed multi -family project given the site location. It should be noted that all traffic data collected for the DEIR was taken while schools were in session and weather was fair; no traffic count data was collected during spring break or holidays.

6 Neighbors providing public comment stated that they observed trip counting tubes during the recent spring break (March 2018). All of the traffic data in the DEIR predates this period. Based on input from the DEIR consultant and the City' s standards for conducting traffic impact analysis, the methodology used in the DEIR (application of the ITE Apartments land use category, etc.), appears to be the most appropriate given the site location. Council may wish to consider the appropriateness of the 2, 000 ADT capacity standard as set forth in the Street Design and Construction Standards & Specification in determining project alternatives and the appropriateness of the selected trip rate used in the DEIR. Please note, recent review of the trip generation equation that determines the number of apartment units possible within the City' s 2, 000 ADT residential street capacity standard revealed a rounding over simplification. With precise use of the applicable equation', 152 apartment units can be added without exceeding the City' s Standard; thus, Alternative 4 should be considered a 152 ( rather than a 149) unit project. The rounding error will be corrected in the Final EIR. FINANCIAL IMPACTS The processing of entitlements is subject to a cost recovery account with all staff time paid by the applicant. That cost recovery account currently maintains a positive balance. Additionally, the City has entered into a Professional Services Agreement with Lamphier- Gregory to prepare the EIR. All costs associated with preparation of the EIR are paid for by the applicant. ATTACHMENTS 1. Planning Commission Staff Report, April 24, Comment Letters Received to date, May 9, 2018 Items listed below are large in volume and are not attached to this report, but may be viewed in the City Clerk' s office. Sid Commons Apartment Draft Environmental Impact Report, prepared January 2018 Additionally, the Sid Commons DEIR and Appendix are posted to the City' s Major Development Project' s website at: cityofpetaluma. net/ cdd/ major- projects. html I The trip generation equation for the Apartment Land Use 220 category in the ITE' s Trip Generation 91h Edition is: of Trips = 6. 06( X) , where X is the # of dwelling units. Thus, x 152 units = ADT, which added to the existing 954 average daily trips on Graylawn is 1, 999 daily trips and below the City' s Standard. no

7 ATTACHMENT 1 DATE: April 24, 2018 AGENDA ITEM NO. 8. A TO: Planning Commission FROM: Tiffany Robbe, Senior Planner Olivia Ervin, Environmental Planner REVIEWED BY: Heather Hines, Planning Manager SUBJECT: Sid Commons Apartment Project Draft Environmental Impact Report Northwest end of Graylawn Avenue; Development at APNs and , and also involving APNs & 008, APN , and APN RECOMMENDATION It is recommended that the Planning Commission: Receive public comment on the Draft Environmental Provide comments on the Draft Environmental Impact Report ( DEIR); Impact Report; and Recommend by motion that the City Council authorize staff to move forward with preparation of a Final Environmental Impact Report ( FEIR). BACKGROUND In July of 2007, the City distributed a Notice of Preparation (" NOP") of an EIR for a 312 -unit version of the Sid Commons Apartment Project on acres, located at the northwestern terminus of Graylawn Avenue and west of the existing Oak Creek Apartments. Publication of the NOP initiated a 30 -day public review and comment period that began on July 11, 2007 and ended on August 9, The Notice of Preparation (NOP) advising that an EIR was to be prepared for the Sid Commons Apartment Project was sent to nearby neighbors and the State Clearinghouse for distribution to responsible and/ or trustee state agencies. A public scoping meeting for the EIR was held on July 25, 2007 to gather initial oral comments. Following preparation of the Initial Study in 2007, work on the Draft EIR commenced, but work was temporarily halted during periods when several large City-wide planning processes were underway. These processes included the preparation of the City of Petaluma General Plan 2025 completed in 2008) and preparation of the Rainier Cross Town Connector project and its associated Draft EIR ( released in July 2014), as well as on- going efforts regarding access constraints to the Project site from the proposed at -grade rail crossing of the SMART rail line ( via a proposed extension of Shasta Avenue), which would require approval by the California Public Utility Commission. Following the adoption of the General Plan 2025, the project was reduced to 278 units, the maximum number allowed within the Medium Density General Plan range of 8. 1 to 1-1

8 18. 0 units to the net acre. Additionally, the project was modified to implement General Plan Policy 8- P- 28, incorporating River terracing along the site' s Petaluma River frontage. The current project includes the following entitlement requests: A Planned Unit Development ( PUD) Amendment to remove the current restrictions regarding use, oak tree retention, and access to the project site, as contained in the 1982 PUD approval for the Oak Creek Apartment project ( City of Petaluma Resolution No. 9628, December 1982), A Zoning Map Amendment to rezone APN from that PUD to R4 ( Residential 4) to enable development at densities up to 18 units per net developable acre ( consistent with the Medium Density Residential General Plan Land Use Designation), Subsequent Site Plan and Architectural Review for the development site, and Subsequent minor mapping ( lot line adjustment or tentative parcel map) reflecting the refined site plan. On March 1, 2018, the City released a Draft Environmental Impact Report ( DEIR) for the Project. The DEIR was released for a 45 -day public review period, which will end on April 16, However, comments will be accepted up until the end of the City Council meeting which is tentatively scheduled for May 21St DISCUSSION The purpose of this staff report and the associated Planning Commission meeting is to facilitate comment on the DEIR for the Sid Commons Apartment Project. After providing an overview of the CEQA review process, this staff report provides a summary of the contents of the DEIR before concluding with a framework for providing comments on the DEIR, and a brief note on key DEIR topics. California Environmental Quality Act The purpose of this project -level EIR is to inform local decision makers, other responsible agencies, and the public of the potential environmental consequences of implementing the Sid Commons Apartment Project, as proposed. The EIR has been prepared in accordance with and in fulfillment of the California Environmental Quality Act ( CEQA) and Guidelines for the Implementation of CEQA ( State CEQA Guidelines). The City of Petaluma is the Lead Agency for the EIR. The Petaluma City Council has the principal responsibility for certifying the Final EIR for the project and approving the legislative entitlements requested for implementation of the project. As described in CEQA and the State CEQA Guidelines, public agencies are generally under a substantive obligation to avoid or substantially lessen significant environmental effects of a project where feasible. Consistent with that obligation, this DEIR identifies the following: 1) The potentially significant environmental effects of the proposed project, including cumulative effects resulting from the proposed project together with other past, present, and probable future projects; 1-2

9 ATTACHMENT 1 2) Mitigation measures that could substantially lessen or avoid any such significant environmental effects; 3) Any significant effects that cannot be mitigated to a less than significant level, and thus are unavoidable; and 4) Reasonable, potentially feasible alternatives to the proposed project that would meet most of the basic objectives of the proposed project while substantially lessening or avoiding at least one significant effect of the proposed project. Under CEQA, the Lead Agency's decision-making body (the City Council) is required to consider the information in the EIR, along with any other relevant information, in making its decisions on the proposed project. Pursuant to the City' s Environmental Review Guidelines, all projects requiring an EIR shall be referred to the City Council for certification and a final determination. The Planning Commission shall first consider the DEIR and any comments received and make a recommendation to the City Council on the adequacy of the DEIR. The Planning Commission may also request review of the FEIR prior to consideration by the City Council for certification. Although the EIR does not determine the ultimate decision that the City Council will make regarding implementation of the proposed project, CEQA requires the City Council to consider the information in the EIR and make findings regarding each significant effect identified in the EIR. If the City Council determines the EIR to be adequate, it will certify the FEIR as complying with CEQA requirements prior to taking action on the proposed project and requested entitlements. If the project is expected to have one or more significant environmental effects, and the City Council chooses to go on to approve the proposed project anyway, the City Council must make a statement of overriding considerations' explaining why the project' s economic, social, technological, legal, and other benefits outweigh its significant unavoidable environmental effects. Certain other public agencies, known as " responsible agencies," may be asked to issue approvals or permits required to implement the project. These responsible agencies may also use this EIR in their review and approval processes. Sid Commons Apartment Project DEIR Overview The DEIR is comprised of following sections: Chapter 1: ( Introduction) provides an introduction and overview describing the purpose of the Environmental Impact Report, the environmental review process, and the scope of topics addressed in the DEIR. Chapter 2: ( Executive Summary) presents a brief description of the proposed project, and summarizes environmental impacts anticipated with implementation of the proposed project. It provides a summary table that denotes potentially significant environmental impacts, describes identified mitigation measures, and indicates the resulting level of significance of each impact with mitigation. In addition, this section presents a brief description of alternatives to the 1-3

10 proposed project and identifies the environmentally superior alternative. Chapter 3: ( Project Description) describes the proposed project, including the requested approvals and entitlements and proposed land uses, as well as on and off-site project improvements such as access to serve the proposed development and riverside improvements, and states the project objectives. Chapters 4-17: ( Environmental Impact Analysis) describes the environmental and regulatory setting for the project by CEQA topic, provides an analysis of the project' s potentially significant environmental impacts; and identifies mitigation measures to avoid or reduce the magnitude of significant impacts. Chapter 18: ( Alternatives) summarizes alternatives to the proposed project and the comparative environmental consequences of each alternative. This section includes an analysis of the No Project Alternative, among others, as required by CEQA. Chapter 19: ( CEQA Conclusions) summarizes the significant and unavoidable impacts, identifies significant irreversible environmental changes, and provides an assessment of growth -inducing and cumulative impacts of the project. Chapter 20: ( References) provides a list of report preparers, technical consultants, and contributors, as well as citations for all resources and documents referenced. Appendices Includes those project specific primary sources referenced in the DEIR. As it provides a concise overview of the DEIR, the Executive Summary is included at Attachment A. Consideration of the Draft EIR When reviewing the DEIR, the Planning Commission and members of the public should consider the following framework for providing comments: 1) Consider the adequacy of the DEIR in disclosing the potential impacts of the project and identifying mitigation measures; and 2) Identify any changes, clarifications, or additional information that should be incorporated in the Final EIR to better explain or disclose the potential environmental impacts. It is recommended that the Planning Commission recommend (by motion) to the City Council that the DEIR adequately discloses potential impacts and identifies mitigation measures, and directs staff to move forward with preparation of the FEIR. The Planning Commission should also identify changes, clarifications, and additional information to be incorporated in the Final EIR. Comments about the overall merits of the project that are not related to its potential environmental impacts ( e. g., whether to amend the Petaluma Zoning Map and the Oak Creek Apartments PUD) should be reserved for a later public hearing when the project' s requested entitlements are agenized for consideration. This typically occurs at the same hearing at which the FEIR is considered for 1-4

11 ATTACHMENT 1 certification. Comments provided on the project' s merits will be documented but not responded to in the Final EIR, unless they are specifically related to a CEQA issue. The public review period for the DEIR ends on April 16, As part of the FEIR, the City will provide written responses to all comments on the DEIR received during the public review period. Comments may be submitted at any time prior to the end of the final City Council hearing on the DEIR ( date to be determined); although the City is not required to provide written responses to comments submitted after the close of the public review period, the City has traditionally accepted public comment for consideration on the FEIR through the end of the City Council hearing. Oral comments before the Planning Commission ( April 24, 2018) and City Council ( tentatively scheduled for May 21, 2018) on the DEIR will be considered during the FEIR' s preparation. At the direction of City Council, we will initiate preparation of a FEIR, which incorporates the necessary revisions and responses to environmental points raised during the public review period on the DEIR. The FEIR will be considered by the City Council for certification. If requested, the FEIR will come before the Planning Commission for review prior to consideration by the City Council for certification. Certification of the EIR is required before action may be taken on the project' s requested entitlements. However, the requested entitlements may be brought forward for consideration on the same date that Council considers certification on the EIR. Key Environmental Considerations The following provides focused discussion on the key issues discussed in the DEIR and likely to be of particular public interest. Access Dual access to the Project site is proposed via existing Graylawn Avenue and by the creation of an extension of Shasta Avenue from its current terminus on the west side of the SMART railroad tracks, at -grade over the tracks, and extending through to the Project site to Graylawn Avenue. An emergency vehicle access ( EVA) to the Project site is proposed at the existing approximately 32 - foot wide project frontage located at the end of Bernice Court. The California Public Utilities Commission ( CPUC) is responsible for rail safety and is the agency with authority to grant approval for an at -grade crossing of the Sonoma Marin Area Rail Transit SMART) owned tracks ( which are also used by the Northwestern Pacific Railroad for freight service). In their 2007 letter responding to the City' s Notice of Preparation ( NOP) for the Sid Commons EIR, CPUC staff clearly opposed any such proposed at -grade crossing. In recent communication, CPUC staff has maintained this position, citing their policy to oppose new at - grade crossings. This position is affirmed in the comment letter issued by the CPUC on the DEIR, see Attachment B. As the CPUC requires that the Proponent' s Environmental Assessment be submitted before the rail crossing request can be scheduled for a hearing, the applicant cannot receive a formal decision from the CPUC until the City acts on this EIR. In light of comments from the CPUC opposing an at -grade crossing of Shasta, and as four of the five Significant and Unavoidable Impacts identified by the DEIR relate to the at -grade crossing of Shasta ( Haz- 6, Noise -3, Transp- 7, and Transp- 9), each Alternative presented in the DEIR excludes 1-5

12 extension of Shasta Avenue onto the Project site, relying on primary access from Graylawn and secondary emergency vehicle access from an EVA at Bernice Court. Without a new source of primary site access via an at -grade connection to Shasta, Alternatives 3 and 4 would require an Amendment to the Oak Creek Apartment PUD1 to eliminate existing language stating that primary access to development upon the northern 2/ 3rds of the Project site APN- 009) must come from a new street ( rather than from Graylawn). Consistency with the City' s Department of Engineering, Street Design and Construction Standards & Specifications influenced all Alteratives set forth in the Sid Commons DEIR_ The City' s General Plan designates the two- lane Graylawn Avenue as a Residential Street. The Street Design and Construction Standards & Specifications identify street standards for local residential streets including a traffic volume capacity of not more than 2,000 average daily traffic (ADT) trips. As described in the Transportation/ Traffic Chapter of the DEIR, Fehr & Peers ( F& P) conducted a Roadway Capacity Analysis to assess the existing traffic volumes and remaining capacity, and to evaluate the project' s contribution to traffic volumes on Graylawn Avenue. F& P determined that the existing average daily traffic volume on Graylawn Avenue is 954 trips, leaving a design capacity of 1, 046 additional trips. Assuming all trips generated by the Sid Commons project as proposed (278 apartment units and 1, 808 daily vehicle trips) were added to Graylawn Avenue, the ADT would increase to 2, 762 vehicles. To maintain Graylawn Avenue within the City' s ADT standard as a local residential street, minimize impacts to Graylawn area residents, and lessen neighborhood impact relating to the proposed removal of the PUD access restriction from the norther 2/ 3rds of the Project site, all Alteratives set forth in the Sid Commons DEIR present a unit count that would not exceed the City' s Street Standard. The City' s Street Standards as defined by the General Plan Mobility Report are not identified as CEQA thresholds', but do provide a relative means of measuring the " livability" of local streets as related to increased traffic on Graylawn Avenue. Based upon analysis in the Traffic Chapter and supported by technical analysis, while residents living along Graylawn would notice a significant increase in daily vehicle traffic (nearly 3 times more daily trips with the 278 -unit Project than in the existing condition) and while residents living along Graylawn would experience more turning delay, and while these impacts are greater than the City Street Standard intends, adding all 1, 808 daily Project trips to Graylawn would not cause neighborhood intersections to decline to an unacceptable level of service triggering a CEQA impact ( see pages to 72). Thus, the decision- making bodies may consider a unit count that would generate trips in excess of the City' s ADT standard without triggering an environmental impact under CEQA. Should decision-making bodies wish to consider a unit count that would generate trips in excess of the City' s Street Standard ( more than 149 units), roadway livability and I The Oak Creek Apartment PUD was adopted in 1982 to enable development of the abutting 76 -unit Oak Creek Apartments and has been the zoning designation of the northern 2/ 3rds of the Project site since that time. 2 Under CEQA, traffic impacts are identified as significant if an intersection deteriorates fi om an acceptable level LOS D or better) without the project to an unacceptable level ( LOS E or D) with the addition of the Project. As page of the DEIR notes, the addition of all 1, 808 Project - generated daily vehicle trips to Graylawn would not cause such deterioration, for example the Graylawn and Payran intersection, currently at LOS B, would operate at LOS C if all Project -generated traffic were added at this intersection. 1-6

13 ATTACHMENT 1 traffic calming improvements could be required to minimize conflicts with exceedance of the 2, 000 vehicle trips per day design standards ( see page of the DEIR). Hydrology The Sid Commons project includes implementation of river terracing along the site' s frontage on the Petaluma River in accordance with General Plan Policy 8- P- 28 ( which calls for the construction of a flood terrace system to allow the River to accommodate a 100 -year storm event within a modified River channel, to the extent feasible given existing physical and natural constraints"). In accordance with General Plan Policy 8- P- 30, a project specific hydrology analysis and a river system wide hydrology analysis were preformed using the City' s Storm Water Management Model XP- SWMM). WEST Consultants examined the floodplain impact of the terracing component of the project, as well as cumulative effects of the various floodplain management scenarios. Generally, the XP- SWMM model indicates that at the Project site the reduction in water surface elevation for the terraced reaches averages feet for the 10 -year event and 0. 3 feet for the year event. The terraced grading plan for the Project would result in a net removal of approximately 21, 140 cubic yards of soil from the western river bank, as well as vegetation and woody debris, thereby expanding the channel capacity and lowering the base flood elevation. Although the Project' s proposed terraced grading reduces water surface elevations at and adjacent to the Project site, it does result in a negligible increase in peak flow and water surface elevations downstream, though not in a way that increases the current floodplain boundaries. The WEST modeling work found that the City' s floodplain management objectives are best realized through a combination of terracing along both sides of the River upstream of the weir, coupled with upstream stoimwater detention 3. Terracing generally results in localized reductions in water surface elevation and can slightly increase surface elevations downstream. Upstream detention without river terracing can lower water surface elevation, but the reduction is much less than can be achieved with detention and terracing. The river terrace for Sid Commons has been designed in close coordination with Planning and Public Works staff and was informed by biological constraints. WRA Environmental Consultants mapped the vegetation along the river terrace and provided recommendations to retain high priority native vegetation and resources including an existing riverside wetland. A preliminary Habitat Mitigation and Monitoring Plan was developed that specifies replanting and habitat restoration of the river terrace area and provides opportunities to accommodate wetland mitigation onsite. Conceptual Architecture and Site Plan 3 River terracing upstream of the weir and stormwater detention in the upstream reach are the two primary floodplain management policies directed by the General Plan ( 8- P- 28 and 8- P- 32). 1-7

14 The Project includes a conceptual site plan for the Project site that includes a 278 -unit apartment complex within multiple three- story structures, along with a community clubhouse and an outdoor swimming pool, located on the approximately acre net developable portion of the Project site ( Figure 3-7 of the DEIR). The Project also includes conceptual elevations at the 3 - story massing ( Figure 3-8 of the DEIR). These elevations are conceptual and are expected to be refined as part of the subsequent formal application for Site Plan and Architectural Review ( SPAR). Likewise, prior to SPAR review, the site plan is anticipated to be refined according to the parameters described by and mitigation measures outlined in the EIR, requirements of the R4 zoning district, and by any added Conditions of Approval. This EIR and the entitlements being requested at this time do not lock in a precise design, architecture, or even necessarily the specific number of units. Rather, the rezone specifies the density range and this EIR and other entitlements establish context within which the precise site plan must be accommodated. The DEIR presents mitigation measures to avoid, minimize, or offset environmental impact in order to provide accommodation of natural features on site such as trees, wetlands, and the river corridor and to provide adherence to setbacks from the railway, adjacent residential properties, and the Petaluma River. At the conclusion of these initial entitlement decisions, development parameters for the site ( such as site access, setbacks to resources, density range or maximum, etc.) will be established. The applicant will then refine the site plan and elevations, and submit design level detail through a SPAR application. Both the elevations and site plan will be subject to the subsequent Site Plan and Architectural Review process. Environmentally Superior Alternative The DEIR concludes that Alternative 3B ( 79 apartment units, with the river terrace and trail) is the environmentally superior alternative, having the least amount of new traffic and the least air quality emissions, and the smallest and most flexible development footprint thereby providing the greatest opportunity to reduce or avoid biological resource impacts of any development alternative. However, Alternative 3B is less successful at achieving many of the Project' s basic objectives such as providing new, relatively high-density residential development within the City' s Urban Growth Boundary and adding to the City stock of available multi -family housing. Additionally, it is not certain that the substantially reduced development potential of this Alternative could be financed considering the cost of the river terracing and river trail. Given the General Plan' s Medium Density Residential designation over the property, the abutting Oak Creek Apartment with a density of approximately 12 units to the net acre, and the current demand for housing, the decision makers may find Alternative 4 ( 149 apartment units with the river terrace and trail) to be the Preferred Alternative, as it comes closest to attaining many of the Project' s basic objectives while avoiding most ofthe Project' s significant and unavoidable impacts primarily by not including the Shasta Avenue at -grade crossing) as well as reducing the level of impacts under all environmental categories as compared to the Project ( primarily due to the reduced density).

15 ATTACHMENT 1 The DEIR' s consideration of the Proposed Project and the Alternatives provides the public and the decision -makers with the ability to consider a range of alternatives and to consider the residential density within the identified range that is most appropriate for the site. For example, should the City find a project exceeding the City' s 2, 000 average daily traffic trips standard appropriate, they could utilize the Enhanced Livability and Traffic Calming along Graylawn Avenue Mitigation option outlined on page and direct a hybrid between the Proposed Project and Alternative 4 one without an at -grade crossing of Shasta, with the river terracing and river trail, and with a unit count between that of Alternative 4 and the Proposed Project - that is between 149 and 278 units). PUBLIC NOTICE A Notice of Completion/ Availability ( NOC/ NOA) of the DEIR and Public Hearing was published in the Argus Courier on March 1, 2018, and mailed notices were sent to residents and property owners within 500 feet of the subject property, to interested parties who previously requested notification, and to all who commented on the Notice of Preparation. The NOC/ NOA was also filed with the State Clearinghouse and the Sonoma County Cleric. Copies of the DEIR have been made available at the Petaluma Library, the Community Center, City Hall, and digitally via the City' s website. Additionally, hard copies and CDs of the documents have been made available for purchase by the public at the Planning Division. Written comments that have been received to date on the DEIR accompany this staff report as Attachment B. ATTACHMENTS Attachment A: DEIR Executive Summary Attachment B: Public Comments on DEIR Received as of Publication of this Staff Report 1-9

16 ATTACHMENT 2 Public Comment Received Within DEIR 45-day Public Review Period From Date Received Brownfields and Environmental Restoration Program, March 7, 2018 Department of Toxic Substances Control California Public Utilities Commission (PUC) March 9, 2018 California Department of Transportation (Caltrans) March 30, 2018 Sonoma-Marin Area Rail Transit (SMART) April 13, 2018 Reuben, Junius & Rose, LLP (attorney representing the applicant) including: April 16, 2018 Exhibit A: from Transpedia Consulting Engineers Exhibit B: from Acclaim Companies (applicant) Public Comment Received Prior to Planning Commission (but after DEIR Public Review Period) From Date Received Kallie Kull, 36 Jess Avenue April 23, 2018 Taryn Obaid, 7 Graylawn Avenue April 23, 2018 Donna Smith, W. Payran and Graylawn April 24, 2018 Petition April 24, 2018 Public Comment Received Prior to City Council (but after DEIR Public Review Period) From Date Received Taryn Obaid, 7 Graylawn Avenue May 14,

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