Safeway IS comment 7-3-07
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July 3, 2007 Mr. Michael Ferry City of Santa Cruz Planning and Community Development Department 809 Center Street, Room 206, City Hall Annex Santa Cruz, California 95060 Re: Safeway-Almar Expansion Initial Study Dear Mr. Ferry: The University of California Santa Cruz offers the following comments on the Draft Initial Study prepared by the City of Santa Cruz for the proposed Safeway-Almar Expansion Project. 1. Scope and description of the project: The project description is inadequate in scope and detail. In fact, in violation of CEQA's requirements, the Initial Study includes neither a location map nor a site map, and lacks adequate information on site layout, location of proposed driveways, and phasing of demolition and construction. Further, the Initial Study presents conflicting data regarding the scope of the proposed project. For example, the project site is described on pages 1 and 3 as 6.4 acres, and on page 17, in the discussion of air quality impacts from grading, as 4.62 acres. This discrepancy suggests that air quality impacts from grading may be understated in the Initial Study. Further, it also calls into question the analysis of increased stormwater runoff, since it is unclear whether the entire increase in impervious surface area is addressed. In addition, the project description indicates that the project would include 407 parking spaces (IS, p 2), while the traffic analysis indicates that there would be either (p ...
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July 3, 2007 Mr. Michael Ferry City of Santa Cruz Planning and Community Development Department 809 Center Street, Room 206, City Hall Annex Santa Cruz, California 95060 Re: Safeway-Almar Expansion Initial Study Dear Mr. Ferry: The University of California Santa Cruz offers the following comments on the Draft Initial Study prepared by the City of Santa Cruz for the proposed Safeway-Almar Expansion Project. 1.Scope and description of the project:The project description is inadequate in scope and detail. In fact, in violation of CEQA's requirements, the Initial Study includes neither a location map nor a site map, and lacks adequate information on site layout, location of proposed driveways, and phasing of demolition and construction. Further, the Initial Study presents conflicting data regarding the scope of the proposed project.For example, the project site is described on pages 1 and 3 as 6.4 acres, and on page 17, in the discussion of air quality impacts from grading, as 4.62 acres.This discrepancy suggests that air quality impacts from grading may be understated in the Initial Study. Further, it also calls into question the analysis of increased stormwater runoff, since it is unclear whether the entire increase in impervious surface area is addressed.In addition, the project description indicates that the project would include 407 parking spaces (IS, p 2), while the traffic analysis indicates that there would be either (p 26) 374 or 375 (arithmetical error) parking spaces.These errors again suggest that the projects impacts on stormwater runoff and parking capacity may not be accurately characterized. In addition, the Initial Study improperly piecemeals the project by omitting a portion of it from the environmental analysis.Both the Geology and Soils and Hazards sections of the document indicate that excavation and offhaul of soils will be needed prior to construction, to clean up hazardous waste on the expanded parcel, and to remove “questionable” fill. Since this work must be carried out to accommodate the project and as part of project design, the environmental impacts of this site preparation work should be assessed in the environmental document. The Initial Study does not appear to have considered any of the impacts of the necessary site preparation and hazardous materials cleanup work with regard to construction traffic, air quality, human health risk, noise, or water quality. 2.General Plan 1990-for the CitysTiering: This Initial Study claims to be tiered from the EIR 2005, because, “The project site was considered as part of the citywide development and buildout in the General Plan EIR” (IS p 2). According to the Initial Studys reference section, the
Safeway-Almar IS Comment, July 3, 2007
General Plan EIR was prepared in 1992. Conditions have changed substantially in the City of Santa Cruz since that time. Reliance on a 15-year-old EIR for tiering purposes without extensive documentation of changes in conditions suggests that the analysis presented may not accurately address existing conditions. The Initial Study needs to assess whether the public services, recreational facilities, housing, traffic infrastructure and utilities considered in the General Plan EIR in 1992 have, indeed been developed in a way that will be adequate to serve the increased development area and density proposed for this site and to provide necessary services for the increased employee and indirect population.For example, were all of the mitigation measures committed to in the EIR prepared for the General Plan actually implemented?If not, how have conditions changed?Are the traffic, air quality and water supply baselines accurate according to current data?These types of issues must be resolved to ensure that the assumptions underlying the Initial Study are appropriate. 3.Appropriate level of environmental analysis: Under Utilities, the Initial Study states, “Project water use should be quantified and project and cumulative water impacts further analyzed in the EIR.” (IS, p 27).The University agrees on both counts.First, CEQA does not permit the deferral of analysis.The City must quantify the Project's impacts on water supply and cannot adopt any environmental document until this has been done.Second, the City admits an EIR is required to evaluate the Project's direct and cumulative impacts on the City's water supply. However, the Determination (p. 13) indicates that the City proposes to issue a Mitigated Negative Declaration.Given the City's admission that an EIR should be prepared to analyze the Project's water supply impacts, the City's proposed adoption of a Negative Declaration is improper. The EIR must also analyze the Project's potential for resulting in exposure of people to hazardous materials.Under Mandatory Findings of Significance, the Initial Study analysis indicates, “No environmental impacts have been identified which would have direct substantial adverse effects on human beings except for potential exposure to hazardous materials, which will be further reviewed in the EIR.”Again, these statements indicate that the Project may result in significant impacts and that an EIR should be prepared.Given the Projects potentially significant impacts associated with water demand and hazardous materials (as recognized in the Initial Study) and with traffic, the preparation of an EIR clearly is needed. 4.Air Quality: The dust control measures included in the project are inadequate to ensure that dust is not entrained off site, particularly given that site preparation (including hazardous materials cleanup) apparently will include substantial off haul of excavated materials, some of which is contaminated. Ata minimum, the mitigation measure should include stringent protections to ensure that soil from excavated areas is not carried into the commercial parking area, wheel washing at the site exit, and a requirement that loaded offhaul trucks be covered, These measures are needed both to minimize PM10emissions, and to minimize health risk, as noted below.In addition, if substantial off haul is required, the air quality analysis should assess the potential for diesel emissions concentrations in the vicinity of sensitive receptors (such as Bayview Elementary School at Bay and Mission). 5.Geology and Soils: As noted above, the analysis indicates that “questionable fill” will need to be removed from the site.Mitigation Measure 2, which requires that the Project be designed to comply with recommendations of the geotechnical engineering report, notes that “the exact location of the reservoir, and unengineered fill” will need to be determined upon demolition of Page2
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the existing structure.This statement raises a number of questions about the site. Is there a buried, filled reservoir on the site?If so, is this a historic feature?Was there a watercourse across the site? Is the fill underlying the building contaminated?Although it may not be possible to obtain detailed information about this underlying “questionable fill” prior to development, if there is reason to think there is a former reservoir on the site, the history of the site should be described in the Initial Study as a basis for understanding whether the project poses potential impacts with respect to cultural resources, geotechnical issues, water resources, and uncharacterized hazardous materials. In addition, the potential hazards, air quality, traffic and noise impacts of excavating and off-hauling “questionable fill” must be assessed. 6.Hazards: TheInitial Study reports that a health risk assessment of the site indicated a potential risk associated with petroleum hydrocarbons, copper and lead.While the Initial Study proposes, as mitigation, that a completion of site cleanup and remediation measures as required in a previously-prepared “Remedial Action Plan,” and proof of regulatory compliance, be required as a condition of Project approval, the Initial Study does not disclose whether the stipulated remedial action plan addresses only the clean-up of the vacant lot, or the Project as proposed. Further, the Initial Study indicates that this cleanup was to take place in 2004, and it apparently has not been completed as of 2007.In these circumstances, it is not certain that the Project will not have any significant hazards impacts and, thus, the City's proposed Negative Declaration cannot be sustained.In addition, as noted above, the Project description does not include a description of the required cleanup activity, and the analysis of the environmental effects of the Project does not address potential impacts of the cleanup. For example, what are the potential traffic impacts of truck trips to offhaul contaminated soils?What are the air quality and human health risks associated with potential spills or releases during the clean up process?Further, Mitigation Measure 1 (in the air quality section of the initial study) does not include measures to prevent offsite entrainment of contaminated soil, such as wheel washing, covering off offhaul trucks. The information provided in the Initial Study is insufficient to determine whether the remediation program was designed to protect construction workers and subsequent users of a grocery store and café on the site.Additional information about and analysis of this issue are needed. 7.Hydrology and Water Quality: As noted above, the discrepancies in the Project description regarding the size of the Project site and the number of parking spaces calls into question the accuracy of the analysis of the increase in stormwater runoff associated with the proposed Project. Further, the fact that the Project will more than double the existing number of parking spaces and includes paving and development of a vacant lot that presently is unpaved suggests that the Project should include facilities to capture and clean stormwater runoff, which have not been included in the Project description or the analysis. The Initial Study should describe the types of facilities that will be included in the Project to ensure that there are no prohibited discharges and ensure compliance with construction and new commercial activity Best Management Practices as required by the Citys Stormwater and Urban Runoff Pollution Control ordinance. Theenvironmental impacts associated with these facilities must also be analyzed as part of the proposed Project.Further, the Project should include facilities to facilitate infiltration, use grey water for irrigation to reduce demands on the City's water system, and other “environmentally friendly” practices. In what ways is the proposed project “environmentally friendly” (IS, p. 2)?
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Safeway-Almar IS Comment, July 3, 2007
8.noted above, the project description does not provide adequate information about theNoise: As impacts of construction.Substantial amounts of noise would be anticipated in connection with excavations, demolition, off hauling, and then construction, and this will be taking place while the shopping center is in use.While the shopping center is not a noise-sensitive use, there are residences along Younglove, Rankin and Miramar, within close proximity to the Project.These residences can be expected to experience not only construction noise (of unspecified duration), but also substantially increased operational trafficwith the project generating almost 1,900 new trips per day.It appears no noise study has been performed, and there is not sufficient data included in the Initial Study to conclude that the Project will not cause a substantial permanent or temporary increase in ambient noise levels in the Project vicinity.This analysis cannot be deferred; the City must conduct itbeforeit adopts the CEQA document for the Project. 9.Traffic:Construction traffic.The Initial Study includes no description of the volume of anticipated construction traffic, the duration of construction, or how construction traffic will be accommodated while the commercial use of the site continues.Given that site preparation (including hazardous waste remediation) will require off haul that could be substantial (no data are provided in the Initial Study); that the Project site is located on a congested main thoroughfare; and that pedestrian and automobile traffic will continue to enter and exit the site throughout construction, the effects of truck traffic on and off site should be quantified and assessed. Construction traffic could result in pedestrian safety, air quality and noise impacts, as well as traffic congestion and traffic hazards.These impacts must be assessed in the CEQA document for the Project; CEQA does not permit the City to summarily dismiss them without either data or analysis.Further, depending on the route taken by off-haul trucks, and the volume of off-haul and duration of construction, construction traffic could result traffic-related noise and air quality impacts at sensitive receptors along the off-haul route, such as Bayview Elementary School, which is located at Mission and Bay. Trip generation.The analysis of operational traffic discounts peak hour trips is based on shuttle usage, but the referenced shuttle ceased operation in March 2005 due to inadequate ridership. The peak hour trips generated by the Project therefore have been incorrectly calculated.The figures must be increased by 12 trips7% more peak hour trips than analyzed. Intersections assessed.The operational traffic analysis assesses only 7 intersections, most in the immediate vicinity of the Project.Since the Project adjacent to Mission Street with its many congested intersections would add almost 2,000 operational trips, this traffic could affect far more than just those studied in the Initial Study.Traffic studies and modeling should be conducted to determine whether the Project will have effects on Miramar/Mission or the heavily congested MissionStreet/Bay Street intersection.The Project includes a new light at the Miramar/Mission Street intersection and “assumed that the [new] intersection would be interconnected to and coordinated with the Mission Street/Almar Avenue/Younglove Avenue intersection” (p 23).What is the basis for this assumption?It appears to rely on coordination on signal timing with Caltrans (since Mission Street is a state highway), and also on funding of the cost of coordination.Will the Project mitigation include the coordination of signal timing as needed? Thereis no mitigation measure committing to this.Would signal timing extend to the Bay/Mission Street intersection if necessary? Impacts on neighborhood streets.The Initial Study maintains that there will be “modestly increased traffic levels on residential streets surrounding the project” (p 25).This would seem to Page4
Safeway-Almar IS Comment, July 3, 2007
be contradicting the traffic modeling, which predicted an increase on Miramar sufficient enough to warrant the inclusion of a new stoplight in the proposed project. However, the Initial Study goes on to say that increased traffic may be noticeable as a “quality of life” issue for some residents. TheInitial Study does not consider the quality of life impacts of increased traffic to be significant (p 25), but indicates that the City will consider a traffic-calming plan to reduce speed on affected streets.However, the Initial Study makes no commitment to carry out this plan. This analysis appears to be equivocal as to whether an impact would occur, and whether mitigation is needed, and does not provide any mechanism or commitment to implement the measures that would reduce the impact. Cumulative impact. The Initial Study identified a cumulative impact at Bay Street/Mission Street to which the proposed Project would contribute, but maintains that the Projects contribution to this impact would be mitigated to a less-than-significant level by its contribution to the Citys Traffic Impact Fee program. Reliance on this is highly questionable, as the City's TIF ordinance specifically states that it does not constitute mitigation under CEQA.The UCSC 2005 LRDP also identifies a cumulative impact at Mission/Almar/Younglove, an intersection immediately adjacent to the proposed Project, to which the Project inevitably will contribute substantial traffic. The 2005 LRDP EIR indicates that this intersection would deteriorate to LOS E in the PM peak hour under cumulative conditions. This intersection is listed on the Citys 2007 TIF spreadsheet, but no improvement is identified or cost assigned.Even if the Project paid TIF fees and these fees were assumed to satisfy the Project's obligation to mitigate its traffic impacts as required by CEQA, these fees cannot be considered to mitigate the impact that is likely to occur at this intersection because it is not included in the City's TIF program of improvements. 10.Water demand: The Initial Study estimates that the proposed project would result in an increased demand of 0.7 mgy of water and that this demand would be within the remaining capacity in average years.However, the Citys own analysis (IWP EIR 2006) states that cumulative water demand will exceed supply sometime before 2015.The Initial Study says that the Project would be required to implement conservation measures in drought years.However, since the vast majority of water use in this commercial facility would presumably be for routine interior operations, the Project's ability to reduce its water demand in drought years would likely be minimal. Asnoted above, the University agrees that the “Project water use should be quantified and project and cumulative water impacts further analyzed in the EIR” (p 27). The Initial Study indicates that the proposed Project would contribute to a cumulative impact on water supply, but that the contribution, because it would be small, is not cumulatively considerable. CEQAdoes not permit such a conclusion.Rather, the City must determine whether the Project's incremental impact on water supply is cumulatively considerable. The Initial Study goes on to say that the Project would pay a system development fee toward the cost of development of a new water supply.The Initial Study paints an optimistic picture regarding the development of a desalination plant to provide a new water supply. However, in its comments to the University on the LRDP EIR, the City maintained that it was premature and therefore inappropriate to rely on the desalination plant as a source of future water supply.If the City's position is accepted, the City cannot rely on the desalination plant to conclude that the water supply impacts of the proposed Project are not cumulatively considerable.
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Safeway-Almar IS Comment, July 3, 2007
We also note that the Initial Study misstates UCSC growth in water demand under the 2005 LRDP as 180 MGY.In fact, the UCSC 2005 LRDP EIR projects the maximum UCSC growth in water demand under full build-out of the LRDP as 162 MGY by 2020.No UCSC projection indicates an increase in demand of 180 MGY, and this figure is not supported by any projection that can be made based on the actual UCSC water use data as measured by the City's meters. CONCLUSION The Safeway-Almar Center Expansion Initial Study is seriously deficient for all the reasons identified above.Moreover, the City has acknowledged in the text of the document itself that an EIR should be prepared for this Project.Accordingly, the University urges the City to strengthen the Initial Studys analysis of potentially significant environmental impacts before determining whether its obligations under CEQA are appropriately satisfied by a Mitigated Negative Declaration, or whether preparing an EIR is necessary. Thank you for the opportunity to comment on this Initial Study. Sincerely,
Frank Zwart, AIA Campus Architect Associate Vice Chancellor, Physical Planning and Construction
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