LSA ASSOCIATES, INC.

2215 FIFTH STREET BERKELEY, CALIFORNIA 94710

510.540.7331 TEL 510.540.7344 FAX

CARLSBAD FORT COLLINS FRESNO

IRVINE PALM SPRINGS PT. RICHMOND

RIVERSIDE ROCKLIN SAN LUIS OBISPO

MEMORANDUM

DATE:

July 12, 2013 Emery Unified School Board of Trustees Judith Malamut and Amy Paulsen, LSA Response to Comment Letter Submitted by the Community Commenters on Emeryville Center of Community Life Draft Initial Study Mitigated Negative Declaration

TO:

FROM:

SUBJECT:

Attached please find responses to CEQA-related comments provided in the Community Commenters letter dated July 11, 2013, on the Draft Initial Study/Mitigated Negative Declaration (IS/MND) on the Emeryville Center of Community Life project . The following provides a response to the comments received. These responses are provided at a level of detail commensurate with that of the comments. These responses are in no way meant to limit the District's ability to reference any other portions of the draft Mitigated Negative Declaration in greater detail in the future for any reason. Upon review and consideration of each comment, LSA finds that no new or more severe significant impacts have been identified than those already identified and mitigated in the IS/MND, and that no new mitigation measures or alternatives that would further substantially reduce impacts have been identified or proposed beyond those already proposed in the IS/MND and incorporated into the project. Based on this analysis, LSA confirms that the mitigation measures necessary to avoid or reduce project-related impacts to a less-than-significant level are identified and incorporated and made a part of this Mitigated Negative Declaration. These mitigation measures have been agreed to by the District, and therefore, the project would not result in significant environmental impacts, and an MND is the appropriate CEQA document to be adopted. The responses in this memorandum are keyed to the comments numbered within the comment letter. If text changes to the IS/MND Document or Mitigation Measures are proposed, they are shown within this memorandum with new text shown in underline and deleted text shown in strikeout. The following introductory comments are made to provide general clarification: 1. Should the School Board of Trustees adopt the Emeryville Center of Community Life (ECCL) IS/MND, the Board will also adopt a Mitigation Monitoring and Reporting Program (MMRP). As noted in Section 15097 of the CEQA Guidelines:
In order to ensure that the mitigation measures and project revisions identified in the EIR or negative declaration are implemented, the public agency shall adopt a program for monitoring or reporting on the revisions which it has required in the project and the measures it has imposed to mitigate or avoid significant environmental effects. A public agency may delegate reporting or monitoring responsibilities to another public agency or to a private entity which accepts the delegation; however, until mitigation measures have been completed the lead agency remains responsible for ensuring that implementation of the mitigation measures occurs in accordance with the program.

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2. It should be noted that CEQA does not require mitigation measures to be prepared unless s a significant environmental impact has been identified. 3. CEQA requires the evaluation of physical environmental impacts associated with a proposed project. As set forth by CEQA Guidelines, inconsistencies between the project and applicable General Plan and other policies do not constitute impacts in and of themselves. A policy inconsistency is considered to be a significant adverse environmental impact only when it is related to a policy adopted for the purpose of avoiding or mitigating an environmental effect, and it is anticipated that the inconsistency would result in a significant adverse physical impact based on an established significance criterion. 4. While it has been the Districts intent to comply with City regulations to the maximum extent feasible, it should be noted that the District is a State institution, and therefore exempt from local land use regulations when land use development is used to further its educational mission. 5. Evaluation of project alternatives are not required as part of a Mitigated Negative Declaration. Responses to Comments Comment #1. The following text changes are proposed to the IS/MND to provide further clarification that the Musco back visors will be installed on field lights as part of the project. The following text revisions are made to page 45 of the IS/MND: Musco back visors can will be installed on field lights to further reduce off-site light trespass where specific neighboring site conditions warrant.

The following text revisions are made to page 56 of the IS/MND: Mitigation Measures AES-1: The District shall implement the following measures: The District will identify three distinct lighting scenarios Scenario A: Competitive Athletic Use (six poles in use); Scenario B: Recreation and Community Use (four poles in use); and Scenario C: Clean-up Use (minimal lights on) to allow for field light levels at the lowest acceptable setting for safety depending on the type of field use. This includes flexibility of light level settings for practices where the full competitive safety light levels may not be needed. The light poles will have an additional 1/3 power reduction switch to further adjust and reduce lighting to provide the lowest safe lighting levels needed for any event. UnlessIf a District game or City-sponsored event is occurring, all lighted use of the field shall conclude at 8:30 p.m., with lighting turned off at 9:00 10:00 p.m. This 9:00 p.m. ending time coincides with the required time for end use of the PA system. For all other events, use of the field shall conclude at 8:30 p.m., with lighting turned off at 9:00 p.m. Except for District games, no lighting of the field will occur on Saturdays and Sundays exceeding the Scenario B lighting scheme.

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Musco back visors will be installed on field lights as part of the project.

Comment #2. All of the Musco fixtures that are proposed have external visors installed that shield the light coming out of the front of the fixture. The use of back visors to reduce the amount of light behind the pole has been, and will be, applied on a light fixture by fixture basis in the proposed lighting plan and during installation to help meet the need for basic safety on the field and to screen spill light. Using back visors can degrade the performance on the field, so where these visors need to be used to reduce light spill has been, and will continue to be, closely evaluated when the lights are installed and are adjusted. The proposed lighting design balances the off-site spill and glare while meeting IES light level and safe-play uniformity standards on the fields as well as being IDA (Dark Skies) compliant. The District will adjust and install back visors where necessary to meet the light levels identified and evaluated in the IS/MND such that spill light would be under the maximum 2.0 footcandle threshold on adjacent properties and safe play can take place on the fields. Therefore no additional impacts associated with light and glare will occur as part of the project that would not be mitigated by Mitigation Measure AES-1. The appropriate application of the fixture visors, as well as, back visors will allow for controlled spill and glare while meeting safe and playable lighting standards on the fields. Comment #3. As stated in response to Comment #2, the proposed lighting design and adjustments during installation will balance the off-site spill and glare while meeting IES light level and safe-play uniformity standards on the fields. The District will adjust and install back visors where necessary to meet the light levels identified and evaluated in the IS/MND such that spill light would be under the maximum 2.0 footcandle threshold on adjacent properties and safe play can take place on the fields. Comment #4. The section that the commenter is referring to is titled Localized CO Impacts. The Bay Area Air Quality Management District (BAAQMD) has established a screening methodology that provides a conservative indication of whether the implementation of a proposed project would result in significant CO emissions. According to the BAAQMD CEQA Air Quality Guidelines, the proposed project results in less-than-significant impacts to localized CO concentrations because the following screening criteria were met:

The project is consistent with an applicable congestion management program established by the county congestion management agency for designated roads or highways, regional transportation plan, and local congestion management agency plans; The project would not increase traffic volumes at affected intersections to more than 44,000 vehicles per hour; and The project would not increase traffic volumes at affected intersections to more than 24,000 vehicles per hour where vertical and/or horizontal mixing is substantially limited (e.g., tunnel, parking garage, bridge underpass, natural or urban street canyon, below-grade roadway).

The proposed project would not conflict with an applicable congestion management program for designated roads or highways, the regional transportation plan or other agency plans. Additionally, traffic volumes on roadways in the project vicinity are less than 5,000 vehicles per hour (significantly less than the 44,000 vehicle per hour threshold). While the commenter is correct in noting that the incorrect peak hour trips are indicated in the text (the correct peak hour trips would be 686 AM peak hour trips), this is still significantly below the 30,000+ peak hour trips that the project would need to

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generate to result in a localized CO impact. It should be noted that all air quality modeling assumed a 686 AM peak hour rate and accounted for all net new regional trips associated with the project. The following text revisions are made to page 60 of the IS/MND: The proposed project would not conflict with an applicable congestion management program for designated roads or highways, the regional transportation plan or other agency plans. Additionally, traffic volumes on roadways in the project vicinity are less than 5,000 vehicles per hour, and the project is expected to generate a maximum of 450 686 AM peak hour trips. Emissions associated with the project are shown in Table 11. As noted in the IS/MND, the California Emissions Estimator Model (CalEEMod) v.1.1 was used to generate the projected operational emissions. Use of this air quality model is recommended by the BAAQMD, which is the agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as for monitoring ambient pollutant concentrations. Additionally, the significance thresholds identified by the BAAQMD are also listed in the table, as well as the statement identifying that the project would not exceed any of the BAAQMD thresholds. Project assumptions used in the model are described in the Project Description of the IS/MND (pages 5 to 32) as well as the modeling outputs from the traffic analysis (pages 118 to 159 and Appendix E). Additional details on the specific calculations methods of analysis incorporated into CalEEMod can be found in Appendix A of the CalEEMod Users Guide found at www.caleemod.com. As noted in the IS/MND, there would be no significant operational air quality impacts associated with the project so an operational air quality mitigation measure would not be warranted. Comment #5. The IS/MND agree that migratory birds are protected under the Migratory Bird Treaty Act and CITES, and it is unlawful to pursue, hunt, take, capture or kill; attempt to take, capture or kill; and possess them. The District has not in the past, and will not in the future undertake these unlawful activities. However, The existing athletic fields are not considered critical habitat for the Canada geese or hunting grounds for raptors such as Coopers Hawk, and construction of the project and improvements such as turf fields will not cause a significant impact on Canada geese and raptors in Emeryville. Comment #6. Chemical compounds in artificial turf are regulated and are not be expected to affect surface water quality. For the type of turf chosen, the District is required to provide proof of ISO 9001, ISO 14001 and OHSAS 18001 certifications. A study by the New York State Department of Environmental Conservation did not identify significant chemical leaching from crumb-rubber infilled synthetic turf fields.1 Laboratory testing of stormwater runoff from a synthetic turf field performed in that study did not identify volatile organic compounds or semi-volatile organic compounds above laboratory detection limits. Metals detected in the runoff were below established surface water quality standards. Although leaching of certain compounds from artificial turf was noted in one type of laboratory tests, the study concluded that under real world conditions no adverse effects to aquatic life would result from use of this type of synthetic turf fields. The attached figure showing the Stormwater Management Plan shows additional information regarding drainage on the project site.
New York State Department of Environmental Conservation, 2009, An Assessment of Chemical Leaching, Releases to Air and Temperature at Crumb-Rubber Infilled Synthetic Turf Fields, May.
1

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Comment #7. As described in the response to Comment #5, the existing sports fields are not critical habitat for the Canada geese and other native and migratory birds that may occasionally use or rest on the site. Replacement of the grass with turf would not interfere with the movement or migratory patterns of native or migratory wildlife, and no significant impact would occur. Comment #8. To provide further clarification that the District will perform all identified mitigation measures, the following text revisions are made to pages 75-76 of the IS/MND: Mitigation Measures CULT-1: Archaeological monitoring should shall be conducted for construction-related ground disturbance below soil that is demonstrated to be fill in the project site. The monitoring should shall be done in accordance with, and as guided by, an Archaeological Monitoring and Evaluation Plan (AMEP) prepared and implemented for the project. The purpose of the AMEP is to ensure that significant archaeological deposits discovered during construction are identified, evaluated, and appropriately treated through the use of a pre-established research design and field evaluation strategy, consistent with the requirements of CEQA Guidelines 15126.4 (b)(3)(C). The AMEP should shall be approved by the District well in advance of construction, and its implementation should shall be made a condition of the issuance of a grading or building permit for the project. The AMEP should shall be prepared by professionals who meet the Secretary of the Interiors Professional Qualifications Standards in historical archaeology and prehistoric archaeology. The AMEP should shall include a construction monitoring component and an evaluation component. The monitoring component of the AMEP should shall refine the archaeological sensitivity of the project site to: (1) identify areas that will be subject to monitoring; (2) define the frequency of monitoring; and (3) identify those areas with little to no possibility of containing intact deposits. This assessment should shall focus on the project sites land use history based on historical maps and photographs, past site improvement/utilities construction plans, historical documents, and soils/geotechnical information. The possibility for encountering human remains during construction should shall also be addressed by consultation with the appropriate descendant groups. The evaluation component of the AMEP would guide fieldwork if archaeological resources or human remains are identified during monitoring. The purpose of this component is to establish an evaluation process to shorten the time necessary to respond to and evaluate the significance of discoveries made during archaeological monitoring. The evaluation component should shall contain a field study and technical analysis work plan to guide the methods and procedures to be used during the significance evaluation. The treatment of human remains during the evaluation process should shall be addressed, and procedures for the respectful treatment of such remains should shall be developed through consultation with descendant communities prior to the final draft of the AMEP. Comment #9. To provide further clarification that the District will perform all identified mitigation measures, the following text revisions are made to page 76 of the IS/MND: Mitigation Measure CULT-2: Should paleontological resources be encountered during project subsurface construction activities, all ground-disturbing activities within 25 feet should shall be redirected and a qualified paleontologist contacted to assess the situation, consult with agencies

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as appropriate, and make recommendations for the treatment of the discovery. If found to be significant, and project activities cannot avoid the paleontological resources, adverse effects to paleontological resources should shall be mitigated. Mitigation may include monitoring, recording the fossil locality, data recovery and analysis, a final report, and accessioning the fossil material and technical report to a paleontological repository. Public educational outreach may also be appropriate. Upon completion of the assessment, a report documenting methods, findings, and recommendations should shall be prepared and submitted to the District for review, and (if paleontological materials are recovered) a paleontological repository, such as the University of California Museum of Paleontology. Comment #10. Please see Response to Comment #8. Comment #11. No active or potentially active faults are known to be present in Emeryville. The Guidelines for Evaluating Seismic Hazards in California cited in Mitigation Measure GEO-1a requires the evaluation of risks from all known active and historic seismic source zones taking into account all available historical seismicity data, including available paleoseismic data, the geologic risk rate of regional active faults, and site-specific response characteristics. These guidelines address all reasonably foreseeable seismic effects at the project site. Comment #12. The following text revisions are made to page 80 of the IS/MND: Therefore, the liquefaction hazard is potentially significant unless mitigation is incorporated. Implementation of Mitigation Measures GEO-1a and GEO-1c would reduce the liquefaction hazard impact to a less-than-significant level. Comment #13. To provide further clarification that the District will perform all identified mitigation measures, the following text revisions are made to page 81 of the IS/MND: Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the project applicant to include analysis of the potential for unstable soils impacts as part of the designlevel geotechnical investigation to be prepared for the proposed project, would will reduce the potential impacts related to unstable soils impacts to a less-than-significant level. Comment #14. To provide further clarification that the District will perform all identified mitigation measures, the following text revision is made to page 81 of the IS/MND: Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the project applicant to include analysis of the potential for unstable soils impacts as part of the designlevel geotechnical investigation to be prepared for the proposed project, would will reduce the potential impacts related to unstable soils impacts to a less-than-significant level. Comment #15. As noted in the IS/MND, the California Emissions Estimator Model (CalEEMod) v.2011.1.1 was used to estimate the greenhouse gas emissions associated with the project. Use of this model is recommended by the BAAQMD, which is the agency primarily responsible for regulating air pollution emissions from stationary sources (e.g., factories) and indirect sources (e.g., traffic associated with new development), as well as for monitoring ambient pollutant concentrations. Project assumptions used in the model are described in the Project Description of the IS/MND (pages

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5 to 32) as well as the modeling outputs from the traffic analysis (pages 118 to 159 and Appendix E). Additional information about CalEEMod can be found at www.caleemod.com. Comment #16. CEQA requires the evaluation of physical environmental impacts associated with a proposed project. As set forth by CEQA Guidelines, inconsistencies between the project and applicable General Plan and other policies do not constitute impacts in and of themselves. A policy inconsistency is considered to be a significant adverse environmental impact only when it is related to a policy adopted for the purpose of avoiding or mitigating an environmental effect, and it is anticipated that the inconsistency would result in a significant adverse physical impact based on an established significance criterion. The commenters letter does not provide specific examples of how an inconsistency results in a specific significant adverse physical impact based on the checklist criteria. Additionally, it should be noted that whether or not the District has met the policies and goals of the Emeryville General Plan or other plans is a subjective assessment. The District created a site plan with pedestrian and bicycle amenities, encourages various forms of modes of transportation, and does not preclude any improvements noted by the comment letter at some point in the future. It should also be noted that the comment letter provided by the City of Emeryville did not raise any concerns about the project not being consistent with the Emeryville General Plan. Comment #17. To provide further clarification that the District will perform all identified mitigation measures, the following text revision is made to page 81 of the IS/MND: Implementation of the following mitigation measures would will reduce potentially significant impacts associated with potential hazardous materials in soil, soil vapor, groundwater, and building materials at the project site to a less-than-significant level: Comment #18. The school classrooms, services and facilities developed under the project are subject to a number of State requirements for emergency safety and evacuation plans which, have, and would protect future students and workers from an accident at or near the school. School Districts have a legal responsibility to be prepared to meet emergencies (California Government Code Section 3100). A comprehensive Safe School Plan is required under Education Code Section 35294.2. A civil defense and disaster preparedness plan must be prepared and tested at least twice a year (Education Code 33031). Therefore, the Safe School Plan anticipates emergency situations, such as the previous hydrogen gas tank accident at the AC Transit bus yard, and has in place safety and evacuation plans to which the District will continue to adhere. Comment #19. Any improvements to the gym would not change the use of the site as a potential evacuation site. The construction period associated with improvements would be limited in duration, and would not result in a significant impact related to implementation of or physical interference with an adopted emergency response plan or emergency evacuation plan. As part of the update to the Citys safety plan, the City and District will work together to identify a secondary location during construction and improvement of the gym. Comment #20. The artificial turf would be considered an impervious surface under stormwater regulations and the project is required to comply with the Water Boards Municipal Regional Permit (MRP), cited in Mitigation Measure HYD-2. Stormwater runoff from the field will be captured and treated in accordance with Provision C.3 of the MRP. No flooding impacts would result.

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Comment #21. The text of the IS/MND reads Implementation of a required SWPPP indicating that the District will implement the identified mitigation measures. Additionally, as noted previously, the District will implement all mitigation measures within the IS/MND. Please see Response to Comment #6 for a discussion of artificial turf. Comment #22. Please see Response to Comment #16. Comment #23. The City of Emeryville General Plan Policy T-P-3 states "A Quality of Service standard that seeks to optimize travel by all transportation modes shall be developed and used to measure transportation performance. The City does not recognize Level of Service (LOS) as a valid measure of overall transportation operations, and sets no maximum or minimum acceptable LOS levels, with the exception of streets that are part of the regional Congestion Management Agency network. (These streets may change, but as of 2008 included San Pablo Avenue, Frontage Road, and Powell and Adeline streets). LOS shall not be used to measure transportation performance in environmental review documents or for any other purpose unless it is mandated by another agency over which the City has no jurisdiction (such as Caltrans, Berkeley, Oakland, and the Congestion Management Agency), and then it shall only be used for the purposes mandated by that agency." The City is currently in the process of developing transportation impact study guidelines that will specify the required analysis necessary to further the City's General Plan Goals. As guidelines have not yet been established and adopted, the scope of work for the evaluation of the potential impacts of the ECCL was reviewed by City staff and is similar to other recent analyses prepared for land use developments within the City. Levels of service were calculated for vehicles, as well as transit, bicycle and pedestrians. Additionally, as the Project would increase traffic along San Pablo Avenue, which is part of the Congestion Management Agency network, as well as a State Route, guidelines from both Caltrans and Alameda County Transportation Commission were considered in the assessment. Changes to the evaluation criteria or analysis methods would not likely result in the disclosure of impacts previously unidentified. Comment #24. The City of Emeryville Pedestrian and Bicycle Plan indicates that traffic volumes can be higher than the threshold for small segments provided additional treatments are provided, which includes the turn-about proposed as part of the project that would also serve as a traffic calming device. The bulk of additional traffic from the project along the segment of 53rd Street between Boyer Avenue and San Pablo Avenue would occur during a 30 minute period in the morning and a 30 minute period in the afternoon on school days, approximately 180 days of the year. On weekends and non-school days, traffic volumes would be similar to current conditions as access to the community center would primarily be provided from 47th Street. Please see Response to Comment #16 for a discussion regarding policy consistency and physical environmental impacts. Comment #25. The proposed addition of a new outfall into the on-site culvert would be within the project site. The inflow (onto the site) and outflow (away from the site) locations would not change

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from the existing conditions, and the addition of a new outfall into the culvert would not significantly change existing conditions. Mitigation Measure HYD-1 and HYD-2 would mitigate stormwater pollutants generated by the project during construction and operation, respectively. Comment #26. To provide further clarification that the District will perform all identified mitigation measures, the following text revision is made to page 81 of the IS/MND: Implementation of the proposed project could degrade the quality of the environment; however, implementation of Mitigation Measures BIO-1, BIO-2, BIO-3, CULT-1, and CULT-2 would will ensure that potential impacts related to biological and cultural resources would be reduced to less-than-significant levels. With mitigation, the proposed project would not: 1) substantially degrade the quality of the environment; 2) substantially reduce the habitat of a fish or wildlife species; 3) cause a fish or wildlife species population to drop below self-sustaining levels; 4) threaten to eliminate a plant or animal community; 5) reduce the number or restrict the range of a rare or endangered plant or animal; or 6) eliminate important examples of the major period of California history. Comment #27. The comment letter does not identify any information or cite specific cumulative impacts that were not evaluated in the IS/MND. No further response can be provided. Comment #29. The comment letter does not identify any information or cite specific environmental effects that were not evaluated in the IS/MND. No further response can be provided.

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LSA ASSOCIATES, INC. 2215 FIFTH STREET BERKELEY, CALIFORNIA 94710

510.540.7331 TEL 510.540.7344 FAX

CARLSBAD FORT COLLINS FRESNO

IRVINE PALM SPRINGS PT. RICHMOND

RIVERSIDE ROCKLIN SAN LUIS OBISPO

MEMORANDUM

DATE:

July 12, 2013 Emery Unified School Board of Trustees Judith Malamut and Amy Paulsen, LSA Recommended Text Changes tp the Emeryville Center of Community Life Initial Study Mitigated Negative Declaration

TO:

FROM:

SUBJECT:

Following are recommended text changes to the Draft Initial Study/Mitigated Negative Declaration (IS/MND) on the Emeryville Center of Community Life (ECCL) project, response to comments made on the IS/MND, for consideration by the District Board prior to adoption. The text changes to the IS/MND Document are identified with new text shown in underline and deleted text shown in strikeout. The following text revisions are made to page 45 of the IS/MND: Musco back visors can will be installed on field lights to further reduce off-site light trespass where specific neighboring site conditions warrant.

The following text revisions are made to page 56 of the IS/MND: Mitigation Measures AES-1: The District shall implement the following measures: The District will identify three distinct lighting scenarios Scenario A: Competitive Athletic Use (six poles in use); Scenario B: Recreation and Community Use (four poles in use); and Scenario C: Clean-up Use (minimal lights on) to allow for field light levels at the lowest acceptable setting for safety depending on the type of field use. This includes flexibility of light level settings for practices where the full competitive safety light levels may not be needed. The light poles will have an additional 1/3 power reduction switch to further adjust and reduce lighting to provide the lowest safe lighting levels needed for any event. UnlessIf a District game or City-sponsored event is occurring, all lighted use of the field shall conclude at 8:30 p.m., with lighting turned off at 9:00 10:00 p.m. This 9:00 p.m. ending time coincides with the required time for end use of the PA system. For all other events, use of the field shall conclude at 8:30 p.m., with lighting turned off at 9:00 p.m. Except for District games, no lighting of the field will occur on Saturdays and Sundays exceeding the Scenario B lighting scheme. Musco back visors will be installed on field lights as part of the project. The following text revisions are made to page 60 of the IS/MND:

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The proposed project would not conflict with an applicable congestion management program for designated roads or highways, the regional transportation plan or other agency plans. Additionally, traffic volumes on roadways in the project vicinity are less than 5,000 vehicles per hour, and the project is expected to generate a maximum of 450 686 AM peak hour trips. The following text revisions are made to pages 75-76 of the IS/MND: Mitigation Measures CULT-1: Archaeological monitoring should shall be conducted for construction-related ground disturbance below soil that is demonstrated to be fill in the project site. The monitoring should shall be done in accordance with, and as guided by, an Archaeological Monitoring and Evaluation Plan (AMEP) prepared and implemented for the project. The purpose of the AMEP is to ensure that significant archaeological deposits discovered during construction are identified, evaluated, and appropriately treated through the use of a pre-established research design and field evaluation strategy, consistent with the requirements of CEQA Guidelines 15126.4 (b)(3)(C). The AMEP should shall be approved by the District well in advance of construction, and its implementation should shall be made a condition of the issuance of a grading or building permit for the project. The AMEP should shall be prepared by professionals who meet the Secretary of the Interiors Professional Qualifications Standards in historical archaeology and prehistoric archaeology. The AMEP should shall include a construction monitoring component and an evaluation component. The monitoring component of the AMEP should shall refine the archaeological sensitivity of the project site to: (1) identify areas that will be subject to monitoring; (2) define the frequency of monitoring; and (3) identify those areas with little to no possibility of containing intact deposits. This assessment should shall focus on the project sites land use history based on historical maps and photographs, past site improvement/utilities construction plans, historical documents, and soils/geotechnical information. The possibility for encountering human remains during construction should shall also be addressed by consultation with the appropriate descendant groups. The evaluation component of the AMEP would guide fieldwork if archaeological resources or human remains are identified during monitoring. The purpose of this component is to establish an evaluation process to shorten the time necessary to respond to and evaluate the significance of discoveries made during archaeological monitoring. The evaluation component should shall contain a field study and technical analysis work plan to guide the methods and procedures to be used during the significance evaluation. The treatment of human remains during the evaluation process should shall be addressed, and procedures for the respectful treatment of such remains should shall be developed through consultation with descendant communities prior to the final draft of the AMEP. The following text revisions are made to page 76 of the IS/MND: Mitigation Measure CULT-2: Should paleontological resources be encountered during project subsurface construction activities, all ground-disturbing activities within 25 feet should shall be redirected and a qualified paleontologist contacted to assess the situation, consult with agencies as appropriate, and make recommendations for the treatment of the discovery. If found to be significant, and project activities cannot avoid the paleontological resources, adverse effects to paleontological resources should shall be mitigated. Mitigation may include monitoring,

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recording the fossil locality, data recovery and analysis, a final report, and accessioning the fossil material and technical report to a paleontological repository. Public educational outreach may also be appropriate. Upon completion of the assessment, a report documenting methods, findings, and recommendations should shall be prepared and submitted to the District for review, and (if paleontological materials are recovered) a paleontological repository, such as the University of California Museum of Paleontology. The following text revisions are made to page 80 of the IS/MND: Therefore, the liquefaction hazard is potentially significant unless mitigation is incorporated. Implementation of Mitigation Measures GEO-1a and GEO-1c would reduce the liquefaction hazard impact to a less-than-significant level. The following text revisions are made to page 81 of the IS/MND: Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the project applicant to include analysis of the potential for unstable soils impacts as part of the designlevel geotechnical investigation to be prepared for the proposed project, would will reduce the potential impacts related to unstable soils impacts to a less-than-significant level. The following text revision is made to page 81 of the IS/MND: Implementation of Mitigation Measures GEO-1a and GEO-1c, which requires the project applicant to include analysis of the potential for unstable soils impacts as part of the designlevel geotechnical investigation to be prepared for the proposed project, would will reduce the potential impacts related to unstable soils impacts to a less-than-significant level. The following text revision is made to page 81 of the IS/MND: Implementation of the following mitigation measures would will reduce potentially significant impacts associated with potential hazardous materials in soil, soil vapor, groundwater, and building materials at the project site to a less-than-significant level: The following text revision is made to page 81 of the IS/MND: Implementation of the proposed project could degrade the quality of the environment; however, implementation of Mitigation Measures BIO-1, BIO-2, BIO-3, CULT-1, and CULT-2 would will ensure that potential impacts related to biological and cultural resources would be reduced to less-than-significant levels. With mitigation, the proposed project would not: 1) substantially degrade the quality of the environment; 2) substantially reduce the habitat of a fish or wildlife species; 3) cause a fish or wildlife species population to drop below self-sustaining levels; 4) threaten to eliminate a plant or animal community; 5) reduce the number or restrict the range of a rare or endangered plant or animal; or 6) eliminate important examples of the major period of California history.

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