The URL can be used to link to this page

2013/11/12 City Council Resolution 2013-154RESOLUTION NO. 2013-154 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF ROHNERT PARK, CALIFORNIA ADOPTING THE MITIGATED NEGATIVE DECLARATION FOR THE REDWOOD EQUITIES GENERAL PLAN AMENDMENT, REZONING, AND STADIUM AREA MASTER PLAN FINAL DEVELOPMENT PLAN AMENDMENTS WHEREAS, the applicant, Redwood Equities Investments, LLC, proposes to amend the General Plan Diagram and Stadium Area Master Plan Final Development Plan (SAMP) (the "Project "); and WHEREAS, in addition to the Environmental Impact Report (EIR) certified for the SAMP (SCH # 2005042111), an Initial Study was prepared for the Project and on the basis of evidence in the whole record, there is no substantial evidence that the proposed project would have a significant effect on the environment with implementation of mitigation measures; therefore a Mitigated Negative Declaration was prepared. The Initial Study and Mitigated Negative Declaration are attached to this resolution as Exhibit l; and WHEREAS, pursuant to California State Law, the Mitigated Negative Declaration were circulated for a period of 20 days and a Notice of Intent was published in the Community Voice on October 4, 2013; and WHEREAS, pursuant to California State Law and the City of Rohnert Park Municipal Code (RPMC), a public hearing notice was published for a minimum of 10 days prior to the first public hearing in the Community Voice; and WHEREAS, on October 24, 2013, the Planning Commission held a public hearing at which time interested persons had an opportunity to testify regarding the Initial Study and Mitigated Negative Declaration; and WHEREAS, at the October 24, 2013 public hearing the Planning Commission of the City of Rohnert Park reviewed and considered the information contained in the Initial Study and Mitigated Negative Declaration for the proposal as well as information presented by staff and the public, and recommended its approval by the City Council; and WHEREAS, on November 12, 2013, the City Council of the City of Rohnert Park held a duly noticed public hearing at which time interested persons had an opportunity to testify either in support or opposition to the proposal; and WHEREAS, at the November 12, 2013 public hearing, the City Council reviewed and considered the information contained in the Initial Study and Mitigated Negative Declaration for the proposal as well as information presented by staff and the public; and WHEREAS, Section 21000, et. seq., of the Public Resources Code and Section 15000, et. seq., of Title 14 of the California Code of Regulations (the "CEQA Guidelines "), which Page 1 of 3 2013 -154 govern the preparation, content, and processing of Negative Declarations, have been fully implemented in the preparation of the Mitigated Negative Declaration. NOW, THEREFORE, BE IT RESOLVED that the City Council of the City of Rohnert Park makes the following findings, determinations and recommendations with respect to the Mitigated Negative Declaration for the proposed Project: 1. The above recitals are true and correct. 2. The City Council has independently reviewed, analyzed and considered the Initial Study and Mitigated Negative Declaration and all written documentation and public comments prior to making recommendations to the City Council on the proposed Project; and 3. An Initial Study was prepared for the project, and on the basis of substantial evidence in the whole record, there is no substantial evidence from which it can be fairly argued that the project will have a significant effect on the environment, provided that appropriate mitigation measure is incorporated into the project, therefore a Mitigated Negative Declaration has been prepared which reflects the lead agency's independent judgment and analysis. 4. The project would not result in an impact to endangered, threatened or rare species or their habitats, including but not limited to plants, fish, insects, animals and birds. There are no native species or plants, no unique, rare, threatened, or endangered species of plants, no sensitive native vegetation that will be affected by the Project. 5. The Mitigated Negative Declaration was prepared, publicized, circulated, and reviewed in compliance with the provisions of CEQA and the CEQA Guidelines; and 6. The Mitigated Negative Declaration constitutes an adequate, accurate, objective, and complete Mitigated Negative Declaration in compliance with all legal standards; and 7. The documents and other materials, including without limitation staff reports, memoranda, maps, letters and minutes of all relevant meetings, which constitute the administrative record of proceedings upon which the Council's Resolution is based are located at the City of Rohnert Park, City Clerk, 130 Avram Ave., Rohnert Park, CA 94928. The custodian of records is the City Clerk. BE IT FURTHER RESOLVED by the City Council of the City of Rohnert Park that approval of the Project would not result in any significant effects on the environment with implementation of mitigation measures identified in the Mitigated Negative Declaration and the City Council does hereby adopt the Mitigated Negative Declaration and Initial Study set forth in Exhibit I and direct the filing of a Notice of Determination with the County Clerk; and BE IT FURTHER RESOLVED by the City Council of the City of Rohnert Park that Exhibit 2 (CEQA Findings) and Exhibit 3 (Mitigation Monitoring and Reporting Program) of this Resolution provide findings required under Section 15091 of the CEQA Guidelines for significant effects of the Project; and Page 2 of 3 2013 -154 BE IT FURTHER RESOLVED by the City Council of the City of Rohnert Park that it does hereby adopt the CEQA Findings of Fact and mitigation measures (Mitigation Monitoring and Reporting Program) set forth in Exhibits 2 and 3; and DULY AND REGULARLY ADOPTED on this 12t1i day of November, 2013. CITY OF ROHNERT PARK Pam Stafford, Mayor ATTEST: J Am1e M. Buergler, City Clerk -k�� t Attached: Exhibits 1, 2, and 3 T,' .� ` .t AHANOTU: 1VLW. BELFORTE: i \`I( -: MACKENZIE: N6 CALLINAN: \jF`, STAFFORD: AYES: ( fi; ) NOES: (( ) ABSENT: ( ) ABSTAIN: ( r} ) Page 3 of 3 2013 -154 EXHIBIT I Proposed MITIGATED NEGATIVE DECLARATION In accordance with the California Environmental Quality Act, the City of Rohnert Park has prepared an Initial Study to determine whether the following project may have a significant adverse effect on the environment. On the basis of that study, the City of Rohnert Park finds that the proposed project will not have a significant adverse effect on the environment with implementation of mitigation measures. Thus, the City proposes to adopt this Mitigated Negative Declaration. PROTECT TITLE: Redwood Equities CPA /Rezone LEAD AGENCY: City of Rohnert Park 1.30 Avram Avenue Rohnert Park, CA 94928 -3126 CONTACT: Marilyn Ponton, Development Services Manager City of Rohnert Park, (707) 588 -2231 mponton0)rpc itv.orl, PROTECT LOCATION: The subject project site is comprised of 3.0 acres (APN: 143 -040 -127) in the northwest portion of the City. The site is located adjacent to the eastern border of the Stadium Area Master Plan (SAMP) area and bounded by the proposed Dowdell Avenue Extension (west); industrial/ business uses (north); the County Animal Shelter and City Wastewater Treatment Plant (east); and Costco (south). PROTECT DESCRIPTION: The project applicant, Redwood Equities Invostments, LLC, is Proposing to amend the boundaries of the Stadium Area Master Plata (SAMP) area to include, the vacant, 3.0 acre project site for future development of a portion of the high density residential housing units allocated in the SAMP. The SAMP, adopted by the City in February 2008, provides standards for development within the 29.8 acre SAMP area, which is located in the northwest corner of the City. The proposed project site is currently zoned "P -P` Public Institutional and the General Plan land use designation for the site is Public/ Institutional, The proposed project would amend the zoning designation of the site from P -1 to "PD" Planned Development and amend the General Plan land use designation from Public / Institutional to High Density Residential. The proposed project would also involve amendments to the text and figures included in the SAMP. INITIAL STUDY REDWOOD EQUITIES GPA / REZONE ig Q©IiISERT J�qp '%%.LA L I F 0 R 14 � 62 City of Rohnert Park PL2013 -041 OCTOBER 2013 REDWOOD EQUITIES GPA / REZONE INITIAL STUDY PROTECT TITLE: Redwood Equities GPA/Rezone LEAD AGENCY: City of Rohnert Park Development Services 130 Avram Avenue Rohnert Park, CA 94928-2486 CONTACT PERSON: Marilyn Ponton (707) 588-2231 PROJECT LOCATION: Labath Avenue Rohnert Park, CA APN: 143-040-127 PROJECT APPLICANT: Redwood Equities Investments, LLC 100 B Street, Suite 210 Santa Rosa, CA 95401 GENERAL PLAN: Existing: Public/Institutional Proposed: High Density Residential ZONING: Existing: Public Institutional (P-0 Proposed: Planned Development EXISTING LAND USE: Vacant land PROJEcTSUMMARY The project applicant, Redwood Equities Investments, LLC, is proposing to amend the boundaries of the City of Rohnert Park Stadium Area Master Plan ("SAMP") Planned Development ("PD") Zoning District to include the vacant, 3.0-acre project site. This would provide for future development of a portion of (lie high density residential housing units allocated in the SAMP. The SAMP Final Development Plan, adopted by the City of Rohnort, Park in February 2008, provides standards for development within the 29.8 acre SAMP area, which is located in the northwest corner of (lie City, The proposed project site is currently zoned "P-l" Public Institutional and the General Plan land use designation for the site is Public/Institutional. The proposed project would amend the zoning designation of the site from P-1 to "PD" Planned Development and amend the General Plan land use designation from Public / Institutional to High Density Residential. The proposed project would also involve amendments to the text and figures included in the SAMP Final Development Plan, PROJECT LOCATION The project site is to in the City of Rohnert Park, Sonoma County, California. The proposed project site is comprised of 3.0 acres (APN: 143-040-127) in the northwest area of the City, Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 1 PROJECT SITE CHARACTERISTICS The project site, located on Labath Avenue in the City of Rohnert Park, comprises approximately 3.0 acres of vacant land. The site previously supported a City wastewater treatment facility holding pond. The site is predominately flat and significantly disturbed. Onsite vegetation is sparse. SURROUNDING LAND USES AND SETTING The project site is located in the northwest portion of the City in an area predominately characterized by existing commercial and industrial/ business uses. The site is located adjacent to the eastern border of the SAMP area and bounded by the proposed Dowdell Avenue Extension (west); industrial /business uses (north); the City Animal Shelter and Wastewater Treatment Plant (east); and Costco (south). BACKGROUND DOCUMENTS AND PLANS SAMP Final Development Plan In accordance with the City of Rohnert Park Zoning Code 17.06. Article VII, the purpose of a "PD" Planned Development Zoning District is to set forth the standards for the development of a Final De =velopment Plan, The SAMP Final Development Plan (hereafter referred to as the SAMP) provides the specific development standards for the 29.8 acres within the SAMP area. Land uses within: the boundaries of the SAMP int Jude: High Density Residential (12 -24 units /acre), Commercial- Regional, and Parks/ Recreation. SAMP Environmental impact Report They SAMP Environmental Impact Report (EIR) (SCFI # 2W5042l l l) was certified by the City of Rohned Park City Council on in June 2008. The SAMP Final Development Plan and EIR are available for review upon request from the City of Rohnert Park Planning Department. Additional sources consulted in preparing the Initial Study are listed in the References section of this document. PROPOSED PROJECT CHARACTERISTICS As previously stated, the proposed project involves a General Plan Amendment, Zoning Amendment, and amendment to the SAMP. Each proposed project action is described below. General Plan Amendment The project proposes to amend the City of Rohnert Park General Plan Diagram (General Plan Figure 2.2 -1) to change the land use designation of the project site from Public / Institutional to High Density Residential. Figure 1 shows the proposed changes to the General Plan Diagram. Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 2 Zoning Amendment The project proposes to amend the boundaries of the SAMP Planned Development ( "PD ") Zoning District, which would require an amendment to the City of Rohnert Park Zoning; Map to change the zoning designation for the project site from "P -P" to "PD ". Figure 2 shows the proposed amendment to the Zoning Map. Stadium Area Master Plan (SAMP) Final Development Plan Amendment The project proposes to amend the boundaries of the SAMP PD Zoning; District to include the 3.0-acre project site. Expanding the SAMP boundaries to include the project site would increase the high density designated residential acreage from approximately 13.6 acres to 16.6 acres total and the total acreage within the SAMP would increase from 29.8 acres to 32.8 acres. The SAMP allows for development of a maximum of 338 housing; units within the designated high density residential areas. The project applicant is proposing to utilize the project site in combination with the 2 acre parcel adjacent to the southern boundary of the project site to develop 94 of the high density residential units allocated in the SAMP. The adjacent parcel is located within the SAMP boundaries. The project would also require minor amendments to the text and figures in the SAMP Final Development Plan to reflect the changes in acreage and boundary lint adjustments. ENTITLEMENTS AND REQUIRED APPROVALS The project would require the following, approvals from the City of R ohnert Park: • General Plan Amendment • Zoning Amendment • Amendment to Stadium: Area Master Plan Final Development Plan Redwood Equities GPA / Rezone October 2093 Administrative Draft Initial Study Page 3 f6mll Estate It "I dealisl I�ns 17ensut Ki�su4cnhal ,n_ -, �. M(extixmt 15ansitc ResuCr =[vial liia,h LMn.vy KesaienUal lud[t,utal Comwwrcml N C;omnt t wl R f innvee¢uf - R;' I1iVh 15envuy Rusidcnua) M.M.• *14(11 Mixed Use Otf ce PI iblw / 11wif ut wunl t ;"` Parda(Itcercanmt 01wa space Ir:ut•irounu•vfal Cona<<realion 0(.,11 Since Agw ollnnr and K""'mo. Nim;sgenteal r;anununv)' Separum •••••••• Sphere of Lvluonce ° �—�- °• 20 Ycar Urban Growth Eorsa&q City Lintits Existing• /Proposed • • • • Major Arterial (4 -6 lanes) . ••-•• -•• Minor Arterial (2 lanes) Major Collector (4 lanes) Minor Collector (2 lanes) Figure 2.2 -1 General Plan Diagram Adopted: 11/7/2000 Dlagrom Revlslons: nn/p 1/23/01 Row 2001.24 1124/01 R,w 2001 161 0/20/01 New 2001 -192 10112102 Rew 2002 -241 10/ 14107 Rems 2W3 236 ,nd 2WI.230 9/25/05 Res, 2005296 5/29/06 Rose 2006142 6119106 Rbs02006 -161 6/10/00 flew 2(w 81 8121110 Roso 2010 -102 12/7/10 Roso 2010.1 J3 Res, 20 10 195 ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED: The environmental factors checked below would be potentially affected by this project, involving at least one impact that is a "Potentially Significant Impact" as indicated by the checklist on the following pages. ❑ Aesthetics ❑ Agriculture and ❑ Air Quality Forestry Resources ❑ Biological Resources ❑ Cultural Resources ❑ Geology/ Soils ❑ Greenhouse Gas ❑ Hazards& Hazardous ❑ Hydrology/ Water Emissions Materials Quality ❑ Land Use/Planning ❑ Mineral Resources ❑ Noise ❑ Population / Housing ❑ Public Services ❑ Recreation ❑ Transportation/ Traffic ❑ Utilities / Service ❑ Mandatory Findings Systems of Significance ❑ None with Mitigation DETERMINATION: (To be completed by the Lead Agency) On the basis of this initial evaluation: ❑ I find that the proposed project COULD NOT have a significant effect on the environment, and a NEGATIVE DECLARATION will be prepared. [D I find that although the proposed project could have a significant effect on the environment, there will not be a significant effect in this case because revisions in the project have been made by or agreed to by the project proponent. A MITIGATED NEGATIVE DECLARATION will tx-- prepared. ❑ I find that the proposed project MAY have a significant effect (in the environment, and an ENVIRONMENTAL IMPACT' REPORT is required. F❑ I find that the proposed project MAY have it "potentially significant impact" or "potentially significant unless mitigated" impact on the environment, but at least one effect 1) has been adequately analyzed in an earlier document pursuant to applicable legal standards, and 2) has been addressed by mitigation measures based on the earlier analysis as described on attached shevK An ENVIRONMENTAL IMPACT REPORT is required, but it must analyze only the effects that remain to be addressed. ❑ I find that although the proposed project could have a significant effect on the environment, because all potentially significant effects (a) have been analyzed adequately in an earlier EIR or NEGATIVE DECLARATION pursuant to applicable standards, and (b) have been avoided or mitigated pursuant to that earlier EIR or NEGATIVE DECLARATION, including revisions or mitigation measures that are . posed upon the proposed project, nothing further is required. Signature: Date: 2--a J Printed Marilyn Pon'to'n AICP Development Services For: City of Rohnert Park Name: Manager Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 6 EVALUATION OF ENVIRONMENTAL IMPACTS: d) Create a new source of substantial light or glare ❑ ❑ ® ❑ which would adversely affect day or nighttime views in the area? a., b. The project area is not designated, or adjacent to, it scent' vista or a state scenic highway in the City of Rohnert Park General Plait (City of Rohnert Park, 200). There are no scenic resources or unique natural features at the site. The project site is graded and once supported a City wastewater holding pond. The project site is adjacent to the existing SAMP area: As noted in the SAMP EIR, the Sonoma County General Plan identifies U.S. 101 and Petaluma Hill Road as designated scenic corridors (Sonoma County, 21109), and the SAMP area is not visible from either of these corridors. The project would have no impacts to scenic vistas, nor would it result in damage to scenic resources. C. As stated above, the site is located in an urban area that contains a mixture of regional commercial, public/ institutional, and industrial park uses. The project site is vacant and once supported a wastewater treatment plant holding pond. The project proposes to amend the land use and zoning designation of the site from public /institutional to high density residential, and include the site within the SAMP area. The SAMP allows for the development of high density residential, commercial - regional, and park/ recreation land uses. The project, if approved, would add 3.0 acres of high density residential to the SAMP. However, the project applicant is not proposing to increase the number of high density residential units approved for development in the SAMP. The project site, in combination with the parcel located adjacent to the southern boundary of the project site, would be utilized for development of the remaining 94 high density residential units allocated in the SAMP. The project site is presently undeveloped with sparse vegetation. Surrounding parcels support industrial, commercial, and public facility land uses. By including the proposed project site in the SAMP, development of the project site and adjacent parcel would be required to implement Mitigation Measures AES-1 and AES-2 (included as Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 7 Less Than Significant Potentially With Less Than Significant Mitigation Significant No 1. AESTHETICS Impact Incorporated Impact Impact Would the project: a) Have a substantial adverse effect on a scenic vista? ❑ ❑ ❑ b) Substantially damage scenic resources, including, ❑ ❑ ❑ but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? c) Substantially degrade the existing visual character ❑ ® ❑ ❑ or quality of the site and its surroundings? d) Create a new source of substantial light or glare ❑ ❑ ® ❑ which would adversely affect day or nighttime views in the area? a., b. The project area is not designated, or adjacent to, it scent' vista or a state scenic highway in the City of Rohnert Park General Plait (City of Rohnert Park, 200). There are no scenic resources or unique natural features at the site. The project site is graded and once supported a City wastewater holding pond. The project site is adjacent to the existing SAMP area: As noted in the SAMP EIR, the Sonoma County General Plan identifies U.S. 101 and Petaluma Hill Road as designated scenic corridors (Sonoma County, 21109), and the SAMP area is not visible from either of these corridors. The project would have no impacts to scenic vistas, nor would it result in damage to scenic resources. C. As stated above, the site is located in an urban area that contains a mixture of regional commercial, public/ institutional, and industrial park uses. The project site is vacant and once supported a wastewater treatment plant holding pond. The project proposes to amend the land use and zoning designation of the site from public /institutional to high density residential, and include the site within the SAMP area. The SAMP allows for the development of high density residential, commercial - regional, and park/ recreation land uses. The project, if approved, would add 3.0 acres of high density residential to the SAMP. However, the project applicant is not proposing to increase the number of high density residential units approved for development in the SAMP. The project site, in combination with the parcel located adjacent to the southern boundary of the project site, would be utilized for development of the remaining 94 high density residential units allocated in the SAMP. The project site is presently undeveloped with sparse vegetation. Surrounding parcels support industrial, commercial, and public facility land uses. By including the proposed project site in the SAMP, development of the project site and adjacent parcel would be required to implement Mitigation Measures AES-1 and AES-2 (included as Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 7 Mitigation Measures 4 -1a and 4 -1b in the SAMP EIR). These measures would ensure that impacts to the visual character of the area remain less than significant by applying the City's design standards to future development projects. Development of the site with high density residential land uses would change the visual character of the site, but because the site does not provide substantial scenic value and the future development would be consistent with the urban nature of the project area, the project would have a less than significant effect on visual character in the project area. d. Future development at the project site would he required to comply with the City of Rohnert Park's lighting and glare standards (Municipal Code Section 17.12.050). Impacts would be less than significant. Mitigation Measures Mitigation Measure AES- 1(SAMP EIR Mitigation Measure 4-1a): The planning and design of projects constructed within the Stadium Area Master Plan shall conform to the Community Design Element of the Rohnert Park General Plan. Conformance review would occur prior to construction within the Project area utilizing the General Plan Urban Design Element, the Community Design Program, and the City's Subdivision Design Guidelines. Mitigation Measure AES -2 (SAMP EIR Mitigation Measure 4-1b): During the design review of proposed projects pursuant to Mitigation Me: ;asu.re A.E'S -1 (SAMP Mitigation Moasure 4- 1a), attention will he given to the interface between they industrial, institutional, commercial, and residential uses. The bui,tding and spaces shall be arranged to provide transition between uses that are complimentary to adjacent uses. The building materials, colors, linkage to sidewalks, parking placement, landscape design, and: plant materials will be selected to provide a transition between uses to compliment the new and existing uses. II. AGRICULTURE AND FOREST RESOURCES Would the project: Less Than Significant Potentially I With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact a) Convert Prime Farmland, Unique Farmland, or ❑ ❑ ❑ El Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non - agricultural use? b) Conflict with existing zoning for agricultural use, or a ❑ ❑ ❑ Williamson Act contract? c) Involve other changes in the existing environment ❑ ❑ ❑ 0 which, due to their location or nature, could result in conversion of Farmland, to non - agricultural use or conversion of forest land to non - forest use? Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 8 d. Result in the loss of forest land or conversion of ❑ ❑ ❑ forest land to non - forest use? e. Involve other changes in the existing environment ❑ ❑ ❑ which, due to their location or nature, could result in conversion of Farmland to non - agricultural use or conversion of forest land to non - forest use? a.- e. The proposed project site is located in an urban area, adjacent to existing commercial, business, public/ institutional, and industrial uses. The vacant project site is highly disturbed and once supported a wastewater treatment plant holding pond. The site is not identified as prime farmland, unique farmland or farmland of statewide importance; the project site is not under it Williamson Act contract; and the project site does not support any forestry resources. It is designated Public/ Institutional in they City's General Ulan and zonal Public /lnsstitutional (P -1). They site is not planned for or used for any agricultural or forestry purpose -s and the proposed project would not result in the conversion of any al,ricultural, or forest land, conflict with any agricultural use, or conflict with a Williamson Act contract. Mitigation Measures No mitigation measures are necessary. Less Than sofficant Potentially with Less Than SW--d Mitigation Significant No III. AIR QUALITY Impact Incorporated Impact Impact Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make the following determinations. Would the project= a) Conflict with or obstruct implementation of the ❑ ❑ ❑ applicable air quality plan? b) Violate any air quality standard or contribute ❑ ® ❑ ❑ substantially to an existing or projected air quality violation? c) Result in a cumulatively considerable net increase ❑ ❑ ® ❑ of any criteria pollutant for which the project region is non - attainment under an applicable federal or state ambient air quality standard (including releasing emissions which exceed quantitative thresholds for ozone precursors)? d) Expose sensitive receptors to substantial pollutant ❑ ❑ ® ❑ concentrations? e) Create objectionable odors affecting a substantial ❑ ❑ ® ❑ number of people? Redwood Equities GPA / Rezone October 2013 Page 9 Administrative Draft Initial Study a. The Project site is located within the San Francisco Bay Area Air Basin, which is designated non - attainment for the federal 8 -hour ozone standard. The area is in attainment or unclassified for all other federal standards. The area is designated non - attainment for state standards for 1 -hour and 8 -hour ozone, 24 -hour small particulate matter (PM10), annual PM10, and annual respirable particulate matter (PM2.5). To address the region's non - attainment status, the Bay Area Air Quality Management District (BAAQMD) adopted the Bay Area 2005 Ozone Strategy (BAAQMD, 2006) and the Bay Area 2010 Clean Air Plan (BAAQMD, 2010), which is an update to the 2005 Ozone Strategy and the prior Clean Air Plan (BAAQMD, 2000). The 2010 Clean Air Plan provides "an integrated, multi- pollutant strategy to improve air quality, protect public health, and protect the climate" This strategy includes a number of control measures to he adopted or implemented to reduce emissions of ozone, PM, air toxics, and greenhouse gases. The proposed project site, located adjacent to the current boundaries of the SAMP, would provide an additional location for.future development of the high density residential units allocated in the SAMP and assumed in the analysis in the SAMP EIR. In accordance with the conclusions in the SAMP h1R, the project would not be expected to conflict with the BAAQMUs attainment plan and would have no impact related to implementation of applicable air quality plans. b. - d. Future construction activities associated with development at the project sit(! would ge=nerates air pollutant emissions. The most substantial air pollutant would IX, dust, of which PM10 is as component. Wind erosion and disturbance to exposed areas would also be sources of dust emissions. The proposed project would change they General Plan and zoning designations for the site from Public Institutional to High Density Residential and PD; no specific construction is proposed at this time. In the future the project site would support development of a portion of the 94 remaining; High Density Residential units currently allocated to the SAMP area. The other portion of the 94 units would be built on the adjacent 2 -acre parcel to the south. While specific development plans for the project site are not known at this time, it is expected that the project site would support approximately 50 units (slightly more than half of the 94 units already allocated to the area). The Bay Area Air Quality Management District (BAAQMD) CEQA Guidelines (2010) include "screen ing criteria to provide lead agencies and project applicants with a conservative indication of whether the proposed project could result in potentially significant air quality impacts. If all of the screening criteria are met by a proposed project, then the lead agency or applicant would not need to perform a detailed air quality assessment of their project's air pollutant emissions." The future development that would be allowed by the proposed General Plan Amendment and Rezoning would consist of approximately 50 high density residences. This is less than the construction emissions screening size of 240 dwelling units and less than the operational emissions screening size of 451. units for the low rise apartments or general condo/ townhouse project types listed in the BAAQMD CF.QA Guidelines. The project size is the first of the screening criteria. Additional criteria are: Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 10 1. The following Basic Construction Emission Control Measures must be included in the project design and implemented during construction a. All active construction areas shall be watered at least two times per day. b. All exposed non -paved surfaces (e.g., parking areas, staging areas, soil piles, graded areas, and access roads) shall be watered at least three times per day and /or non -toxic soil stabilizers shall be applied to exposed non - paved surfaces. c. All haul trucks transporting soil, sand, or other loose material offsite shall be covered and /or shall maintain at least two feet of .freeboard. d. All visible mud or dirt track-out onto adjacent public roads shall be removed using wet power vacuum street sweepers at least once per day. The use of dry power sweeping is prohibited. e. All vehicle speeds on unpaved roads shall be limited to 15 miles per hour. f. All roadways, driveways, and sidewalks to be paved shall be completed: as soon as possible. Building pads shall be laid as soon as possible after grading unless seeding or soil hinders are used. g,. Idling; times shall he minimized either by shutting (Nuipment off when not in use or reducing the maximum idling time to, minutes (as required by the California airborne toxics control measure Title 13, Section 2485 of California Code of Regulations). Clear signage regarding; idling restrictions shall be provided for construction workers at all access points. h. All construction equipment shall be maintained and properly tuned in accordance with manufacturer's specifications. All equipment shall be checked by a certified mechanic and determined to be running in proper condition prior to operation. L The prime construction contractor shall post a publicly visible sign with the telephone number aatd person to contact at the City of Rohnert Park regarding dust complaints. Launchpad Development "Cwelve LLC and the construction contractor shall take corrective action within 48 hours. The Air District's phone number shall also be visible to ensure compliance with applicable regulations; 2. Construction - related activities would not include any of the following: a. Demolition; b. Simultaneous occurrence of more than two construction phases; c. Simultaneous construction of more than one land use type; d. Extensive site preparation; or e. Extensive material transport (greater than 1.0,000 cubic yards). By including the proposed project site in the SAMP, development of the project site and Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 11 adjacent parcel would be required to implement Mitigation Measure AIR -1 (SAMP EIR Mitigation Measure 5 -2a). This would ensure that future development allowed as a result of the proposed project would meet the criteria above requiring implementation of Basic. Construction Emission Control Measures. Further the project site is generally flat, supports sparse vegetation, and supports no existing structures. Based on the site characteristics, it is expected that the screening criteria related to construction- related activities would be met with future development of the project site. Therefore, with implementation of Mitigation Measure AIR -1, all of the BAAQMD screening criteria would he met and future development on the project site allowed by the proposed General Plan Amendment anti Rezone would have a less than significant impact related to criteria air pollutant emissions and exposure of sensitive receptors to substantial pollutant concentrations. Further, as described in Section 1.2 (A the BAAQMD 2010 CEQA Guidelines, Thresholds of Significance, "by its very nature, air pollution is largely ii cumulative impact. No single project is sufficient in size to, by itself, result in nonattainment of ambient air quality standards." Therefore, the thresholds of significance developed by the BAAQMD reflect the "emission levels for which a project's individual emissions would be cumulatively considerable." A projex -t with emissions that are below the thresholds of significance would not make a considerable contribution to any cumulative impacts. Because the future development allowed by the proposed project would remain: substantially below the screening criteria and therefore would have emissions that are substantially below the thresholds of significance, the project would" make a less thin significant contribution to cumulative air quality impacts. e. The City wastewater pump station is located on the parcel east of the project site. As discussed in the SAMP EIR, pump stations such as this one are not generally large sources of odors (City of Rohnert Park, 2007). Since preparation of the SAMP EIR, there has been no increase in odors, nor any anticipated increases, from current or future wastewater treatment or light industrial uses. Recent discussions with City pump station staff indicate that a slight odor can occasionally be detected, depending on wind conditions, within the pump station property and immediate vicinity, The staff also indicated that the odor can occasionally be detected outside the pump station fenced area and to the east, rarely to the west (City of Rohnert Park, 2013). In the event odor complaints are received by the BAAQMD from sources including the existing pump station or possible future permitted industrial usca, the agency will investigate and require odor abatement, if necessary under the provisions of BAAQMD Regulation 7, Odorus Substances. Mitigation Measures Mitigation Measure AIR -1 (SAMP EIR Mitigation Measure 5-2a): Each project sponsor is responsible for ensuring that the contractor reduces particulate, reactive organic gas (ROG), NOx, and carbon monoxide (CO) emissions by complying with the air pollution control strategies developed by the BAAQMD. Each project sponsor and contractor shall develop emission control strategies that implement the following control measures based on BAAQMD guidelines: Dust Control Measures: Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 12 For all construction sites: • Cover all trucks hauling construction and demolition debris from the site. • Water on a continuous as- needed basis all earth surfaces during clearing, grading, earthmoving, and other site preparation activities. • Use watering to control dust generation during demolition of structures or break -up of pavement. • Pave, apply water three times daily, or apply (non- toxic) soil stabilizers on all unpaved parking; areas and staging areas. • Sweep daily (with water sweepers) all paved areas and staging areas. • Provide daily clean -up of mud and dirt carried onto paved streets from the site. • Renovation, demolition activities, removal or disturbance of any materials that contain asbestos, lead paint or other hazardous pollutant s will be conducted in accordance with BAAQMD rules and regulations. • Properly maintain all construc lion equipment. For construction sites near sensitive receptors (or If residential development occurs prior to commencement of commercial development): • Install wheel washers for all existing trucks, or wash off the tires or tracks of trucks and equipment leaving the site. • Suspend dust - producing; activities during periods when instantaneous gusts exceed 25 mph when dust control me&Sulres are unable to avoid visible dust plumes. • Limit the area subject to excavation, grading; and other construction or demolition activity at any one time. For sites greater than four acres: • Apply soil stabilizers to previously graded portions of the site inactive for more than ten days or cover or seed these areas. • Water or cover stockpiles of debris, soil, sand, or other materials that can be blown by the wind. • Limit traffic speeds on unpaved roads to 15 mph. • Replant vegetation in disturbed areas as soon as possible. Construction Exhaust Mitigation Measures The potential air quality impacts from toxic air contaminant emissions from construction equipment and operations will be reduced with compliance with BAAQMD air pollution control strategies. Construction firms shall be required to post signs of Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 13 possible health risk during construction. The developer is responsible for compliance with the BAAQMD rule regarding cutback and emulsified asphalt paving materials. In addition, the construction contractors will implement a plan to use newer construction equipment, manufactured during or after 1996, that meets the NOx emissions standard of 6.9 grams per brake- horsepower hour for work constructed within 200 feet of residences. Potentially Significant IV. BIOLOGICAL RESOURCES Impact Would the project: a) Have a substantial adverse effect, either directly or Q through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or U.S. Fish and Wildlife Service? b) Have a substantial adverse effect on any riparian ❑ habitat or other sensitive natural community identified in local or regional plans, policies, Less Than regulations or by the California Department of Fish Significant and Wildlife or U.S_ Fish and Wildlife Service? Impact c) Have a substantial adverse effect on federally ❑ protected wetlands as defined by Section 404 of the Clean Water Act (including, but not limited to, marsh, vernal pool, coastal, etc.) through direct removal, filling, hydrological interruption, or other means? d) Interfere substantially with the movement of any ❑ native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors, or impede the use of native wildlife nursery sites? Less Than significant With Less Than Mitigation Significant Incorporated Impact ❑ e) Conflict with any local policies or ordinances ❑ ❑ ❑ protecting biological resources, such as a tree preservation policy or ordinance? f) Conflict with the provisions of an adopted Habitat ❑ ❑ ❑ Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan? a. As discussed in the SAM' EIR, biological studies completed in the project area did not locate special status plant species, but the area was classified as having suitable habitat for several special status animal species. The EIR determined that grasslands in the project vicinity are considered suitable as foraging habitat by birds, including special status species. The EIR concluded that development of the SA.MP area would result in No Impact 0 a i1 U Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 14 minimal loss of this foraging habitat and would not have a significant impact on habitat modification. The project area is also located within the potential range of the Sonoma County California tiger salamander (C71 S) and the northwestern pond turtle (City of Rohnert Park, 2007). According to the SAMP EIR, the northwestern pond turtle, a California species of special concern, would be unlikely to occur in the project area due to existing roadways ( including gutters and curbs) and surrounding development. The CTS is a federally endangered and California species of special concern. No CTS or special status plant species were found in any of the wetlands surveyed in 2001 -2002 and 2005. In addition, the U.S. Department Fish and Wildlife Service (USFWS) issued a letter, included as Appendix B to the SAMP EIR, determining that development in the SAMP area, including the project site, would be unlikely to affect CTS. The SAMP EIR further concluded that neither surveys nor mitigation would be required for the CTS in the SAMP area, including, the project site (City of Rohnert Park, 2007). Therefore, future development at the project site would be expected to have a less than significant impact on species identified as a candidate, sensitive, or special status species. b. There are no riparian areas located within the project site. Therefore, implementation of the project would involve no impacts to riparian habitat. C. The Wetland Delineation conducted by North Fork Associates for the SAMP area, including the proposed project site, found no occurrence of vernal pools or other natural wetlands (SAMP EIR). Low - quality, seasonal wetland areas (it) incur within the SAME' along the south anti east side of the former stadium. These wettand areas are not located on the project site. Further, those wetlands were not found to support any federally listed threatened or endangered, plants. In addition, the SAMP EIR also refers to the U.S. Army Corps of Engineers` confirmation that the wastewater treatment ponds, one of which was previously located on the proposed project site, are exempt from Section 404 permitting. The proposed project would, thus, have no impacts to wetlands. d. Although no special status species were observed to be nesting within the SAMP area, future development within the project site would be required to implement preconstruction Mitigation Measure BIO-1 (included in the SAMP EIR as Mitigation Measure 64a) to ensure potential impacts to nesting birds remain less than significant. e., f. The project site is vacant and highly disturbed. The site is not included in any local, regional, or state habitat conservation plan, and there are no protected trees (i.e., oaks and other native trees of significant size) located on the project site. No impacts to local policies, ordinances or plans would occur from implementation of the project. Mitigation Measures Mitigation Measure B10-1 (SAMP Mitigation Measure 64a): Pre - construction surveys will be conducted for nesting raptors and bat roosts within 500 feet of construction activities a minimum of 46 and 24 hours before project construction activities. Nest searches will be conducted in December/ January (if not earlier) before site construction begins and the vegetation within the construction area will be. removed and /or mowed between August 31 and February 1 to minimize the potential for birds to nest within the construction areas. If nests are found with no eggs or young, the nest will be moved by a qualified biologist. Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 15 If nesting birds with eggs or young are found during the surveys, one or more of the following measures may be implemented: • An exclusion zone will be established around nests with eggs or young; the need for and size of the exclusion zone is based on factors such as species sensitivity, topography, and proximity to roads and buildings. • Construction activities in the area will be postponed until young are fledged • The Biological Monitor will monitor the birds on the nest and stop construction if it appears that the birds will abandon the nest or young • In consultation with the California Department of Fish and Wildlife (CDFW), the nests could be relocated to a nearby area or to an approved wildlife rehabilitation center a. - d. A cultural resources survey for the SAMP area, including the project site, was conducted between October 2004 and February 2005 (City of Rohnert Park, 2007). No archeological materials were encountered as a result of the surface reconnaissance within the SAMP area. Buildings encountered during the survey consisted primarily of temporary structures associated with the stadium and had no architectural or historical significance. The survey indicated that prior disturbance in the project area has greatly altered the terrain, and any archeological resources Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 16 To minimize* the potential for birds to nest in the construction area, Wiest searches can beyconductett and tree removal and other vegetation removal can be done between October 1 and .February 1. This shall be noted! on improvement plans, grading plans and building plans. Less Than significant Potentially With Less Than Significant N ligation Significant NO V. CULTURAL RESOURCES Impact Incorporated impact Impact Would the project: a) Cause a substantial adverse change in the ❑ ® ❑ ❑ significance of a historical resource as defined in §15064.5? b) Cause a substantial adverse change in the ❑ ® ❑ ❑ significance of an archaeological resource pursuant to §15064.5? c) Directly or indirectly destroy a unique ❑ ® ❑ ❑ paleontological resource or site or unique geologic feature? d) Disturb any human remains, including those interred ❑ ® ❑ ❑ outside of formal cemeteries? a. - d. A cultural resources survey for the SAMP area, including the project site, was conducted between October 2004 and February 2005 (City of Rohnert Park, 2007). No archeological materials were encountered as a result of the surface reconnaissance within the SAMP area. Buildings encountered during the survey consisted primarily of temporary structures associated with the stadium and had no architectural or historical significance. The survey indicated that prior disturbance in the project area has greatly altered the terrain, and any archeological resources Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 16 that may have once existed in the area of the prior ac=tivities have most likely been destroyed (City of Rohnert Park, 2007). No further research was rec=ommended for buildings encountered during the survey. There are no known historic, archaeological, or paleontological resources or human remains onsitey. It is unlikely that previously unknown cultural resourc=es would be encountered during future site grading for construction of residential units. However, to ensure that impacts to cultural resources remain less than significant should any such resources be encountered during project grading and construction, Redwood Equities, LLC will implement Mitigation Measures CUL -1, CUL -2, and CUC 3. These mitigation measures were identified as SAMP EIR Mitigation Measures 7.1a, 7.1b, and 7.3a, and were also included in the City of Rohnert Park General Plan EIR. Mitigation Measures Mitigation Measure CUL -1: (SAMP EIR Mitigation Measure 7Aa) if at any time during, earth disturbing activities a concentration of artifacts or a cultural deposit is encountered, work shall cease in the immediate area and a qualified archeologist shall be contacted by the construction manager to evaluate the find and make further recommendations. Construction crews should be alert for cultu=ral resources which could consist of, but not lx? limited to, artifacts of stone, bone, wood, shell, or other materials; features, including hearths, structu=ral remains, or dumps, areas of discolored soil indicating the location of fire pits, post molds, or living; area surfaces. Mitigation Measure CUL -2: (SAMP EIR Mitigation Measure 7.1b) If human remairtsare encountered anywhere on the project site, all work shall stop in the immediate vicinity of they discovered remains. Both the County Coroner and a qualified archeologist shall be notified by the construction mana=ger immediately so that an evaluation can he performed. If the remains are deemed to be Native American and prehistoric, the Native American Heritage Commission shall be contacted by the Coroner so that it "Most Likely Descendant" can be designated and recommendatiolvs for treatment solicited pursuant to CEQA Section 15064.5(e). Mitigation Measure CUL -3: (SAMP EIR Mitigation Measure 7.3a) Per state law, in the event that paleontological resources or unique geologic features arc encountered during; construction, all earthwork within a 50 mater radius of the find will be stopped, the City of Rohnert Park notified, and a paleontologist retained to examine the find and make appropriate recommendations. Less Than Significant Potentially With Less Than Significant Mitigation Significant No VI. GEOLOGY AND SOILS Impact Incorporated Impact Impact Would the project: a) Expose people or structures to potential substantial adverse effects, including the risk of loss, injury, or death involving: Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 17 a. Surface Fault Rupture The closest known active fault traces are those of the Rodgers Creek fault, about 3 miles northeast of the SAMP area and the San Andreas Fault, about 15 miles southwest (City of Rohnert Park, 2007). As stated in the SAMP EIR, because the project area is about 3 miles from known trades of any potentially active fault and from known traces the nearest :coned active fault (the Rodgers Creek fault), fault -line surface rupture would not be a hazard within the project area. Impacts related to fault rupture potential would be less than significant. Groundshaking As discussed in the SAMP EIR, it is apparent that the City of Rohnert Park will he subjected to at least one major earthquake during the useful economic life of the Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 18 Less Than Significant Potentially With Less Than VI. GEOLOGY AND SOILS Significant Impact Mitigation Incorporated Significant Impact No Impact Would the project: i) Rupture of a known earthquake fault, as ❑ ❑ ® ❑ delineated on the most recent Alquist - Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Special Publication 42. ii) Strong seismic ground shaking? ❑ ® ❑ ❑ di) Seismic - related ground failure, including ❑ ❑ ® ❑ liquefaction? iv) Landslides? ❑ ❑ ® ❑ b) Result in substantial soil erosion or the loss of ❑ ❑ ® ❑ topsoil? c) Be located on a geologic unit or soil that is unstable, ❑ ❑ ® ❑ or that would become unstable as a result of the project, and potentially result in on- or off -site landslide, lateral spreading, subsidence, liquefaction or collapse? d) Be located on expansive sod, as defined in Table 18- ❑ ® ❑ ❑ 1 -B of the Uniform Building Code (1994), creating substantial risks to life or property? e) Have soils incapable of adequately supporting the ❑ ❑ ❑ use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater? a. Surface Fault Rupture The closest known active fault traces are those of the Rodgers Creek fault, about 3 miles northeast of the SAMP area and the San Andreas Fault, about 15 miles southwest (City of Rohnert Park, 2007). As stated in the SAMP EIR, because the project area is about 3 miles from known trades of any potentially active fault and from known traces the nearest :coned active fault (the Rodgers Creek fault), fault -line surface rupture would not be a hazard within the project area. Impacts related to fault rupture potential would be less than significant. Groundshaking As discussed in the SAMP EIR, it is apparent that the City of Rohnert Park will he subjected to at least one major earthquake during the useful economic life of the Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 18 structures located in the SAMP area. Resulting vibration from a 7.1 magnitude earthquake on the Rodgers fault, which is located approximately 3 miles from the project area, could cause damage to buildings, roads and infrastructure, and could cause ground failures such as liquefaction or settlement in alluvium and poorly compacted soils. This would be considered a significant impact. By including the proposed project site in the SAMP, development of the project site and adjacent parcel would be required to implement Mitigation Measure GEO-1 (SAMP EIR Mitigation Measure 8-2a), which requires compliance with state building code seismic requirements. This would ensure impacts related to groundshaking are less than significant. Liquefaction According to the SAMP EIR, liquefaction risk in the project area is considered to N, low (City of Rohnert Park, 2007). Landslides No landslide deposits have been mapped within the SAMP area or in the immediate vicinity. The California Geological Survey slope stability map of southern Sonoma County categorizes the project area as an area of the greatest relative stability because there are no slopes steeper than 1 percent. (City of Rohnert Park, 2007). b., c., d. As previously discussed, the project site once supported a wastewater treatment plant holding pond. Future construction activities at the project site would involve filling to bring the site up to grade for building foundations. As discussed in tfw SAMP EIR, the existence of expansive soils within the SAMP area makes it necessary to ensure the soils used for foundation support are sound. An acceptable degree of soil stability can be achieved by the required im- orporation of soil treatment programs (e.g- grouting, compaction, drainage control, time treatnivn't) in the excavation and construction plans to address site -srKx ific- suit conditions. The site - specific analysis is necessary for foundation support design in area- where unsuitable conditions are suspected. To ensure that the future development at the project site is not adversely affected by unstable soil conditions, t1w project would he required to implement Mitigation Measure GEO -2 (SAMP EIR Mitigation Measure 8- 3a:). Implementation of Mitigation Measure GEO -2 would ensure that impacts related to expansive soils would remain less than significant. V, No septic tanks or alternative wastewater disposal systems are proposed and the project would have no impact related to these types of wastewater disposal. Mitigation Measures Mitigation Measure GEO -1 (SAMP EIR Mitigation Measure 8 -2a): To reduce the primary and secondary risks associated with seismically induced groundshaking at the site, it is necessary to take the location and type of subsurface materials into consideration when designing foundations and structures in the Master Plan area. In the City of Rohnert Park, residential, commercial and institutional buildings, bridges, pedestrian overcrossings, and all associated infrastructure are required to reduce the exposure to potentially damaging seismic vibrations through seismic- resistent design, in conformance with Chapter 16, Redwood Equities GPA/ Rezone October 2013 Administrative Draft Initial Study Page 19 Structural Design Requirements, Division IV, Earthquake Design, of the California Building Code. Because the Master Plan area is in the "near- source" area (within 3.1 miles of a known active fault) of the Rodgers Creek fault, Section 1629, Criteria Selection, of the Building Code requires special seismic design factors to be applied to the project including: • The use of California Building Code Seismic Zone 4 Standards as the minimum seismic - resistant design for all proposed facilities; • Additional seismic- resistant earthwork and construction design criteria, based on future site- specific development projects; • Recommendations of a California Certified Engineering Geologist in cooperation with the project's California - registered geotechnical and structural engineers; • An engineering analysis thin demonstrates satisfactory performance of alluvium or fill where either forms part or all of the support, especially where the possible occurrence of liquefiable soils exist; and • An analysis of soil expansion potential and appropriate reme diation (compaction, removal /replacement, etc.) prior to using any expansive soils for foundation support. Mitigation Measure GEO -2 (SAMP E1R Mitigation Measure 8-3a): As part of the construction permitting pr(x -c-,s, the City requires completed reports of soil conditions at the specific construction sites to identify potentially unstable soil con iLions. The evaluation must be conducted by registered soil professionals-, and measure =s to eliminate inappropriate soils conditions, must be applied, depending on the soil conditions. The design of foundation support must conform to the analysis and implementation criteria described in the City's Building Code, Chapters 16,18, and A33. Adherence to the City's codes and policies ensures the maximum practicable protection available for users of buildings and infrastructure and their associated trenches, slopes, and foundations. Site - specific soil suitability analysis and stabilization procedures, and design criteria for foundations, as recommended by a California registered soil engineer during the design phase for each site where existence of unsuitable soil conditions is known or suspected, shall include, but not be limited to, the following specifications: a) During the design phase for each site where the existence of unsuitable soil conditions is known or suspected, the developer's registered soil engineering consultant shall provide documentation to the City that: Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 20 1. Site - specific soil suitability analyses has been conducted in the area of the proposed foundation to establish the design criteria for appropriate foundation type and support, and 2. The recommended criteria have been incorporated in the design of the foundation. b) During grading for the site, the registered soils professional shall be on the site: 1. To observe areas of potential soil unsuitability, 2. To supervise the implementation of soil remediation progran-ts, and `i. To verify final soil conditions prior to setting the foundations. c) The registered soils engineering consultant shall prepare an "as built" map, to be filed with the City, showing details of the site soils, the locution of foundations, sub - drains and c'y'an -outs, the results of suitability analyses and compaction tests. Less Than significant Potentially With Less Than Significant Mitigation Significant No VII. GREENHOUSE GAS EMISSIONS Impact Incorporated Impact impact Would the project: a) Generate greenhouse gas emissions, either directly ❑ ❑ ® ❑ or indirectly, that may have a significant impact on the environment? b) Conflict with any applicable plan, policy, or ❑ ❑ ® ❑ regulation adopted for the purpose of reducing the emissions of greenhouse gases? a. & b. Greenhouse gas emissions and climate change effects were not evaluated in the SAMP Ells. Climate change, which involves significant change -, in global climate patterns, has been associated with an increase in the average temperature of the atmosphere near the Earth's surface, or global warming. This warming has been attributed to an accumulation of greenhouse gases (GHGs) in the atmosphere, These GHGs trap heat in the atmosphere, which in turn heats the surface of the Earth. State and federal legislation has resulted in policies that define targets for reductions in GHG emissions. Climate change research and policy efforts are primarily concerned with GHG emissions related to human activity. In particular, California adopted the 2006 Global Warming Solutions Act (commonly referred to as AB 32), which established a statewide emission reduction target to ensure that GHG emissions in the year 2020 are equal to the statewide GHG emissions in 1990. The California Air Resources Board (ARB) 2008 Scoping Plan estimated that GHG emissions in the state would have to be reduced by approximately 29 percent from Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 21 business -as -usual (BAU) levels in order to meet the GHG emissions reduction requirement. Even before the passage of AB32, the City of Rohnert Park initiated actions to reduce GHG emissions and become more sustainable overall. These actions include: • Adoption of the California 2010 Building Code, referred to as CalGreen, which includes requirements for energy efficiency, water use efficiency, and other sustainability measures. • Energy Efficiency Ordinance 2007 -779. This ordinance also established Title 14- Sustainabilty, in the Municipal Code (March 2007) • City Council adopted resolution 2004 -111, which set a goal for GHG reductions of 20 percent by the year 20'10 for internal City operations (baseline year 2000) (May 2004) • City Council adopted resolution 2005-233, which sets a goal of green house gas reductions of 25 percent by the year 2015 for community -wide use, private and public (baseline year 1990) Quly 2005) 13AAQMD CEQA Guidelines (2010) screening criteria discussed in Section 11 Air Quality above include criteria for GHG emissions. Projects that meat all of the creening criteria can be determined to have a less than significant impact related to GHG emissions. The GHG screening criteria project size for high density residential development is 78 dwelling units (under either the low rise apartments or general condo /townhoust, development types), The future development on the project site that would be allowed under the proposed General Phan Amendment and Rezoning is assumed to consist of approximately 50 dwelling units. This future development project, would be smaller than the BAAQMID GHG emissions criteria. Therefore the future development that would be permitted under the proposed project would not be expected to generate GHG emissions that would result in a significant climate change impact. Mitigation Measures No mitigation measures are necessary. Less Than Significant Potentially with Less Than Significant Mitigation Significant No Vill. HAZARDS AND HAZARDOUS MATERIALS Impact Incorporated Impact Impact Would the project: a) Create a significant hazard to the public or the ❑ ® ❑ ❑ environment through the routine transport, use, or disposal of hazardous materials? b) Create a significant hazard to the public or the ❑ ® ❑ ❑ environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment? c) Emit hazardous emissions or handle hazardous or ❑ ❑ ❑ acutely hazardous materials, substances, or waste Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 22 d) Less Than Significant hazardous materials sites compiled pursuant to Potentially with Less Than Significant Mitigation Significant No VIII. HAZARDS AND HAZARDOUS MATERIALS Impact Incorporated Impact Impact Would the project: within one - quarter mile of an existing or proposed the environment? school? e) d) Be located on a site which is included on a list of ❑ ❑ ❑ hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? e) For a project located within an airport land use plan ❑ ❑ ❑ ❑ or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard for people residing or working in the project area? f) For a project within the vicinity of a private airstrip, ❑ ❑ ❑ would the project result in a safety hazard for people residing or working in the project area? g) Impair implementation of or physically interfere with ❑ ❑ ® ❑ an adopted emergency response plan or emergency evacuation plan? h) Expose people or structures to a significant risk of ❑ ® ❑ ❑ loss, injury, or death involving wildland fires, including where wildiands are adjacent to urbanized areas or where residences are intermixed with wildlands? a., b. The proposed project would allow for future development of residential units at the project site. Although the project site was once used for a wastewater treatment plan holding, pond, the Department of Toxic Substances Control, Human and Ecological Risk Division (HERD) issued a memorandum (in response to a letter issued by the California Regional Water Quality Control Board), dated July 2, 2009, that states, "The HERD concludes that the currently available data suggest that chemicals of potential concern are not present at levels that would be considered significant in a human health risk evaluaticm'(California Regional Water Quality Control Board, 2009). The project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials. Future construction of residential units at the proposed project site could expose construction workers, the public, or the environment to hazardous materials through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Small quantities of potentially toxic: substances (e.g., petroleum and other chemicals used to operate and maintain construction equipment) would be used at the project site and transported to and from the site during construction. Accidental releases of small quantities of these Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 23 substances could contaminate soils and degrade the quality of surface water and groundwater, resulting in a significant public safety hazard. By including the proposed project site in the SAMP, development of the project site and adjacent parcel would he required to implement Mitigation Measure HAZ-1 (SAMP EIR Mitigation Measures 9 -1a, 9 -1b, and 9 -1c). This would ensure that exposure to construction workers or the public to hazardous contaminants during construction would be reduced through standard control measures and preparation of the appropriate safety plans. Implementation and compliance with the City's plans, requirements, and. Mitigation Measure HAZ -1 would reduce any potential impacts to less than significant. C. The project would not create hazardous emissions or hazardous waste and would not handle hazardous materials or substances. There are no schools within 0.25 miles of the site_ The project would have no impact related to exposure of the project site to hazards and hazardous materials. d. A search of federal, state, and local databases regarding hazardous material releases and site cleanup lists was conducted for preparation of the SAMP EIR (City of Rohnert Park, 2007). The SAMP area was not identified in any of the records, is not ii -luded on the Department of Toxic Substance Control's site cleanup list, and is not expcx led to be affected by any offsite spill incidents. The project would have no impact related to the site being included on or affected by other sites that are included on a hazardous material release site. e_ - f. The project would have no impact related to airport safety. g. The project would not interfere with any adopted emergency or evacuation plans. Because the project site is located at the edge of current development, it would not hinder emergency services. The City is currently considering the development of a public safety facility within the SAMP, south of the project site. Construction of the public= safety facility would reduce response times to the site. Therefore, the projtx't would have a less than significant imprcc`t related to implementation of emergency plans. h. The City of Rohnert Park General Plan states that the potential for wildland fires varies within the City (City of Rohnert Park, 2000). The project site and surrounding area is developed with small areas of vacant land. The project site is surrounded by commercial and industrial development and future development of the site is not expected to expose workers or the public to wildland fire. By including the proposed project site in the SAMP, development of the project site and adjacent parcel would be required to implement Mitigation Measures HAZ -2a and HAZ -2b (SAMP EIR Mitigation Measure 9 -6a and 9 -6b) would ensure that risks associated with wildland fires remain less than significant). Mitigation Measures Mitigation Measure HAZ -1 (SAMP EIR Mitigation Measures 9 -1a through 9 -1c): a. The city shall require that contractors transport, store, and handle hazardous materials required for construction in a manner consistent with relevant regulations and Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 24 guidelines, including those recommended and enforced by the City of Rohnert Park Department of Public Safety (DPS). b. In the event of a spill of hazardous materials in an amount reportable to the DPS (as established by DPS guidelines), the contractor shall immediately control the source of the leak and contain the spill. If required by the DPS or other regulatory agencies, contaminated soils will be excavated and disposed of offsite at a facility approved to accept such soils. c. The City shall require development under the Master Plan to include plans to prevent the pollution of surface water and groundwater and to promote the health and safety of workers and other people in the project vicinity. These programs shall include an operations and maintenance plan, a site- specific safety plan, and a fire prevention plan, in addition to they Storm Water Pollution Prevention Plan (SWPPP) required to prevent impacts associate -1 with contaminated storm water. The programs are required by law and shall require approval by several responsible agencies. Required approvals are: the SWPPP shall be approved by they RWQCB; the site - specific safety plan and the operations and maintenance plan shall be approved by the Rohnert Park DPS. They City shall require the applicant to develop and implement a hazardous materials mainapement plan that addresses public health and !safety sues by providing, safety measures, int "luding ri:ylease prevention measures; employees trainin -T�, notification, and evacuation procedures; and adequate emergency response protocols and cleanup procedures. The City shalt, require project applicants and their designated contractors to comply with Cat -OSHA, as well as federat standards, for the storage and handling of fuels, flammable mite *riats, and common construction - related hazardous materials an¢1 for fire prevention. Mitigation Measure E AZ -2 (SAMP E1R Mitigation Measures 9-&t and 96-b): a. Prior to construction, if dry vegetation or other fire fuels exist on or near staging areas, or any other area on which equipment will be operated, contractors shall clear the immediate area of fire fuel. To maintain a firebreak and minimize the availability of fire fuels, the City shall require contractors to maintain areas subject to construction activities clear of combustibles natural materials to they extent feasible. To avoid conflicts with policies to preserve riparian habitat, areas to be cleared shall be identified with the assistance of a qualified biologist. b. The City shall require contractors to equip construction equipment that normally includes a spark arrester with an arrester in good working order. Less Than Significant Potentially with Less Than Significant Mitigation Significant No IX. HYDROLOGY AND WATER QUALITY Impact Incorporated Impact Impact Would the project: a) Violate any water quality standards or waste ❑ ❑ ® ❑ Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 25 d) Substantially alter the existing drainage pattern of ❑ ® ❑ ❑ the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off- site? e) Less Than ❑ Significant ❑ Potentially With Less Than Significant Mitigation Significant No IX. HYDROLOGY AND WATER QUALITY Impact Incorporated Impact Impact Would the project: discharge requirements? stormwater drainage systems or provide substantial b) Substantially deplete groundwater supplies or ❑ ❑ ® ❑ interfere substantially with groundwater recharge such that there would be a net deficit in aquifer additional sources of polluted runoff? volume or a lowering of the local groundwater table level (e.g., the production rate of pre- existing nearby wells would drop to a level which would not support Otherwise substantially degrade water quality? existing land uses or planned uses for which ❑ permits have been granted)? ❑ c) Substantially alter the existing drainage pattern of ❑ ❑ ❑ ❑ Hie site or area, including through the alteration of ❑ the course of a stream or river, in a manner which would result in substantial erosion or siltation on- or as mapped on a federal Flood Hazard Boundary or off -site? d) Substantially alter the existing drainage pattern of ❑ ® ❑ ❑ the site or area, including through the alteration of the course of a stream or river, or substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off- site? e) Create or contribute runoff water which would ❑ ❑ ❑ ❑ exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff? f) Otherwise substantially degrade water quality? ❑ ❑ ® ❑ g) Place housing within a 100 -year flood hazard area ❑ ❑ ❑ as mapped on a federal Flood Hazard Boundary or Flood Insurance Rate Map or other flood hazard delineation map? h) Place within a 100 -year flood hazard area structures ❑ ❑ ❑ which would impede or redirect flood flows? i) Expose people or structures to a significant risk of ❑ ❑ ❑ loss, injury or death involving flooding, including flooding as a result of the failure of a levee or dam? j) Inundation by seiche, tsunami, or mudflow? ❑ ❑ ❑ Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 26 The project site is located adjacent to the boundaries of the SAMP, an area of gently sloping plain (average gradient of about 1 percent). Elevations in this area range between 89 and 92 feet above mean sea level. The Largest concentration of impervious surface in the northwest area of Rohnert Park cx•curs in the existing commercial /industrial areas to the west, south, and cast of the SAMP. The northern portion of the SAMP area, including the project site, contains large areas of vacant or undeveloped land. As previously discussed, the project would allow for future development of high density residential units. The only expected discharge from the project site, once developed with residential uses, would he stormwater runoff generated by additional impervious surfaces. Effects of runoff are discussed below in subsection'c' and V. With the incorporation of stormwater detention features, stormwater runoff would not be expected to violate water quality standards. There are no waste discharge requirements established for the project site. Wastewater generated by they project site, once developed, would be treated by the Subregional System and the additional flows would not he expected to result in a violation of they system's waste discharge requirements. Because development at the project site would be required to comply with regional or lm-al regulations and policies prior to implementation, the effects on water quality would be less than significant. b. The future construction of impervious surfaces on the project site would reduce infiltration to the water bible. However, as discussed in they SAMP EIR, the project area is not considered a major or important recharge zone in the City (City of Rohnert Park, 2007). Most of the city's potable water supply welts draw from the intermediate aquifer, with a few drawing from the Deep and Lower aquifers. These aquifer-, receive almost no recharge from the Shallow aquifer in the SAMP area because they intervening clay and sandy clay deposits that underlay the SAMP area prevent substantial downward percolation. The delay of recharge to the Shallow aquifer in they SAMP area would have a less- than - significant effect on the amount of groundwater available to the City in the other aquifers throughout the groundwater basin. There would be a less than significant impact regarding groundwater supply or recharge. c., d. Future development at the project site would replace the existing pattern of drainage with landscaped areas and storm drains, but would not change the course of nearby off -site drainage ways. Development at the site could have adverse effects on downstream water quality through erosion, the transport of sediments and dissolved constituents entering the receiving waters, and increasing turbidity and contaminant load. Although the amount of surface alteration necessary to accommodate future development at the project site is not considered a significant change in itself, the alteration of topography to create building pads, parking lots, driveways, and utility corridors raises issues of erosion potential and downstream deposition of soil particles, even in the relatively flat alluvial plain. Even shallow cuts of less than a foot, or the process of placing fill for leveling or foundation support, have the Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 27 potential to create erodible surfaces and slopes if the cuts and fills are not specifically designed to protect their surfaces from wind and water. Erosion potential is low for almost all soils in the Rohnert Park area because of its flat terrain with a grade of less than 2 percent (City of Rohnert Park, 2000). The formation of embankments or uneven topography, the effects of machinery, and the removal of vegetation can increase erosion rates. Instances of erosion are likely during future development activities on the project site that would be allowed by the proposed General Plan Amendment and rezone. Water leaving the construction areas during the grading and construction period; could carry soil particles from the grading or construction sites, or could erode sail downgradient, if the flow were not controlled. In addition to the loss of material by erosion, the re- deposition of eroded material in water bodies in or adjacent to the project site could create turbidity (endangering aquatic life), reduce wildlife habitat, and reduce the wetter carrying capacity of streams and drainage ways, thereby potentially aggravating flood conditions. Erosive conditions created during the grading period can persist into the operations period. During the construction period, soils would be exposed to the erosive forces of wind and stormwater runoff. When de- vegetated and excavated, soils would he subject to gullying under the influence of moderate to heavy rains if required preventive action is not taken. Grading is expected to he minimal because of the low topographic relief across the project area. Most soils in the project have low erosion potential in their natural condition because they are a mixture of fine and coarse grain sizes. However, disrupted soils become more erosion -prone unless specific measures are taken to control erosion. As discussed in t1v SAMP EIR, the risk of construction impacts regarding, the potential to increase erosion of soil from the development of sites within the SAMP and subsequent deposition of particles in drainage ways, creeks, or wetlands would be reduced to within acceptable limits by requiring; an erosion and sediment transport control plan (City of Rohnert Park, 20W). By including the proposed project site in the SAMP, development of the project site and adjacent parcel would he required to implement Mitigation Measure HYDR04 (SAMP EIR Mitigation Measure 10 -1a), which requires compliance with state and local regulatory permit requirements regarding the non -point pollution source control of stormwater runoff through the application of Best Management Practices. This would ensure that sedimentation impacts are reduced to a less than significant level. e. The project site is vacant land that once supported a wastewater treatment plant holding pond. Future development of the site would involve covering the site with impervious surfaces such as driveways, parking lots, and buildings. The surfaces would be graded to direct drainage away from structures. The impervious surfaces would reduce surface water infiltration and increase the rate and volume of surface runoff leaving the site. Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 28 Site storm drainage patterns would be modified following development. Runoff from the project site would likely be diverted into new storm drains in the extension of Dowdell Avenue constructed by the developer of that portion of the SAMP. This would drain to Hinebaugh Creek. General Plan Policy HS -5 requires the SAMP to design and construct a storm drain system for the area that would conform to the SCWA Flood Control Design Criteria, and encourages the use of environmentally sensitive drainage improvements, including flow reduction and flood bypass systems, to ensure the protection of surface water quality and stream integrity. With the installation of landscaping buffers and detention facilities at the proposed neighborhood park (i.e., swales or similar designs), the SAMP would be able to detain the increased runoff to maintain the existing site runoff rate. Construction of new storm drain systems would be required to comply with the Stormwater Phase 11 regulations administered by the North Coast Regional Water Quality Control Board through permits to the city. With the stormwater detention measures (i.e_, landscaping buffers and facilities incorporated into the design of the neighborhood park) in place and operative there would be no increase in the runoff rate that leaves the site over the existing site level. The increased runoff volume would be able to be controlled tirroul;h evaporation and infiltration from the ern -site detention facilities. There would be a less than significant impact regarding surface runoff or flooding?; L Increased runoff from the construction of impermeable surfaces on the project site could lower the quality of stormwater runoff and infiltrating groundwater. The major contributor of contaminants to runoff and infiltrating, groundwater is the land: surface over which the water passes. 1,n developed area~, driveways, parking lots, sidewalks, streets and gutters are connected directly to storm drains that collect and guide stormwater runoff. Between . rainstorms, materials accumulate on these surfaces from debris dropped or scattered by individuals, street sweepings, debris and other particulate matter washed into roadways from adjacent areas, wastes and dirt from construction and renovation or demolition, fecal droppings from animals, remnants of household refuse dropped during collection or scattered by animals or wind, oil and various residues contributed by automobiles, and fallout of air -borne. particles. During rainfall, stormwater may take several paths when it reaches the ground surface. As water fills surface depressions, it seeps into the ground where the ground is permeable. Where the rate of rain roaching the ground exceeds the rate of infiltration, a film of water builds up on the ground surface. Once this film is of sufficient depth (about 0.1 inch), the water collecting on the ground surface begins to flow. The initial flow of each storm often contains the highest concentrations of pollutants, but this is not always the case because the phenomenon is dependent on the duration of the preceding dry weather period, rainfall patterns, rainfall intensity, the chemistry of individual pollutants, and other site - specific conditions. If uncontrolled, the accumulation of urban pollutants could have a detrimental cumulative effect because overland flow from paved surfaces and landscaped areas carries many of the above - listed contaminants, thereby contributing to the deterioration of the quality of stormwater runoff and infiltrating groundwater. The eventual result would be the deterioration of water quality in downstream receiving Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 29 waters. Reaches of drainage -ways downstream from the project site would carry stormwater runoff to Hinebaugh Creek and Laguna de Santa Rosa and, eventually, to the Russian River, which would be subject to water quality deterioration. The previous discussions of erosion and sedimentation control and storm- drainage system design provide documentation of the requirements to reduce turbidity and capacity effects. The City's General Plan Policy FIS -S encourages the use of environmentally sensitive drainage improvements to ensure the protection of surface water quality kind stream integrity. There would be no significant impact regarding pollution from surface water runoff. g. - j. Section 7.2, Drainage, Erosion, Stormwater, and Flooding of the city's General Plan anti Community Panel Number 060375 0868 B of FEMA's Flood Insurance Rata Maps for Sonoma County both place the SAMP and the project site outside the 500 -year zone and the 100 -year flood hazard area. There are no dams or levees in the vicinity of the project site. The project would not expose people or structures to significant loss related to flooding. The project site is physically removed from any large body of water and is not subject to inundation by seiche, tsunami, or mudflow. The projet -t would have no impact related to flooding or other water - related hazards. Mitigation Measures Mitigation Measure HYDRO -1: (SAMP EIR Mitigation Measure 141 -3a ) Because the SAMP Project would involve grading of an area that is greater than one acre, it would be subject to the conditions of the General Comtruction Activity NPDES permit from the Regional Water Quality Control Board. This permit requires the preparation of a Storm Water Pollution Prevention Plan (SWPPP). The SWPPP is required to identify the sources of sediment and other pollutants on site, and to ensure the reduction of sediment and other pollutants in stormwater discharged from the Site. A monitoring program is required to aid the implementation of, and assure compliance with, the SWPPP. The permit requirements of the RWQCB must be satisfied prior to project construction. As part of the SWPPP, an Erosion and Sedimentation Control Plan must be prepared for the Stadium Area Master Plan Site prior to grading. An erosion control professional, or landscape architect or civil engineer specializing in erosion control must design the Erosion and Sediment Transport Control Plan. The erosion and sediment transport control plan shalt be submitted, reviewed, implemented and inspected as part of the approval process for the grading plans for each Project. The Association of Bay Area Governments (ABAG) recommends the control plan be designed using concepts similar to those formulated by ABAG, as appropriate, based on the specific erosion and sediment transport control needs of each area in which grading, excavation, and construction is to occur. A few of the most critical techniques to be considered include, but are not limited to, the following types of erosion control methods: • Confine grading and activities related to grading (demolition, construction, preparation and use of equipment and material storage areas, staging areas, and preparation of Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 30 access roads) to the dry season, whenever possible. The dry season is generally deemed to be from April to September of each year. • If grading or activities related to grading need to be scheduled for the wet season, ensure that structural erosion and sediment transport control measures are ready for implementation prior to the onset of the first major storm of the season. • Locate staging areas outside major streams and drainage ways. • Keep the lengths and gradients of constructed slopes (cut or fill) as low as possible. • Discharge grading and construction runoff into small drainal;es at frequent intervals to avoid buildup of large potentially erosive flows. • Prevent runoff from flowing over unprotected slopes. • Keep disturbed areas (areas of grading and related activities) to the minimum necessary for demolition or construction. • Keep runoff away from disturbed areas during, grading and related activities. • Stabilize disturbed areas as quickly as possible, either by vegetative or mechanical methods. • Direct runoff over vegetated areas prior to discharge into public storm drainage systems, whenever possible. • Trap sediment before it leaves tl - -Site with techniques such as check darns, sediment ponds, or siltation fences. • Make the contractor resi-xrnsible for the removal and disposal in off-site retention ponds of all sedimentation that is generated by grading and related activities of the Project. • Use landscaping and grading methods that lower the potential for down - stream sedimentation. Modified drainage patterns, longer flow paths, encouraging infiltration Into the ground, and slower stormwater conveyance velocities are examples of effective methods. • Control landscaping activities carefully with regard to the application of fertilizers, herbicides, pesticides or other hazardous substances. • Provide proper instruction to all landscaping personnel on the construction team. During the installation of the erosion and sediment transport control structures, an erosion control professional shall be on the Site to supervise the implementation of the designs, and the maintenance of the facilities throughout the grading and construction period. The erosion control professional shall prepare an "as built" erosion and sediment control facility map, to be filed with the City, showing details of the structural elements of the plan and providing an operating and maintenance schedule throughout the operational period of the Project. These erosion and sediment transport control structures need to be in place prior to the onset of seasonal rains. If portions of these phases extend into the wet season, sediment can be prevented from leaving the construction sites through the use of silt fences, straw Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 31 bales, perimeter ditches, water bars, temporary culverts and swales, sediment traps, minimal grading concepts, and /or similar techniques appropriate for the Site. If grading or construction is to occur during the wet season, the Project will require an erosion and sediment transport control plan, designed by an erosion control professional, landscape architect, or civil engineer specializing in erosion control, that shalt meet the objectives for the grading and construction period of construction projects proposed for the Stadium Master Plan. A Best Management Practices (BMP) program, as required by the RWQCB, describes stormwater management practices (structural and operational measures) to control the quantity and duality of stormwater runoff, and aid in erosion control. Following construction, the permit requires the implementation of long -term measures to manage, runoff throughout the operational period of the Project. BMWs to prevent onsite or off - site erosion would be required in the stormwater management b) Conflict with any applicable land use plan, policy, or ❑ ❑ ® ❑ regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation ❑ ❑ ❑ EJ plan or natural community conservation plan? The project would not physically divide the existing community. The project would amend the City's General Plan from Public/ Institutional to High Density Residential and amend the Zoning Map to include the project site in the SAMP. The site previously supported a wastewater treatment plant holding pond and it is surrounded by business and commercial development and other vacant land. The adjacent parcel is within the SAMP and zoned for residential uses. The project would have no impact related to dividing existing neighborhoods. b. The project site General Plan Land Use Designation is Public/ Institutional. The project would amend the General Plan Land Use Designation to High Density Residential. The project site is zoned P -1 (Public/ Institutional District). The project would amend the zoning to P -D "Planned Development" and amend the boundaries of the SAMP to include the project site. With approval of the proposed amendments, the project would be consistent with the City's General Plan and Zoning Map, the SAMP, and other City plans and policies, and impacts would remain less than significant. Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 32 Less Than Significant Potentially With Less Than Significant Mitigation Significant No Impact Incorporated Impact Impact X. LAND USE AND PLANNING Would the project: a) Physically divide an established community? ❑ ❑ [❑ ED b) Conflict with any applicable land use plan, policy, or ❑ ❑ ® ❑ regulation of an agency with jurisdiction over the project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect? c) Conflict with any applicable habitat conservation ❑ ❑ ❑ EJ plan or natural community conservation plan? The project would not physically divide the existing community. The project would amend the City's General Plan from Public/ Institutional to High Density Residential and amend the Zoning Map to include the project site in the SAMP. The site previously supported a wastewater treatment plant holding pond and it is surrounded by business and commercial development and other vacant land. The adjacent parcel is within the SAMP and zoned for residential uses. The project would have no impact related to dividing existing neighborhoods. b. The project site General Plan Land Use Designation is Public/ Institutional. The project would amend the General Plan Land Use Designation to High Density Residential. The project site is zoned P -1 (Public/ Institutional District). The project would amend the zoning to P -D "Planned Development" and amend the boundaries of the SAMP to include the project site. With approval of the proposed amendments, the project would be consistent with the City's General Plan and Zoning Map, the SAMP, and other City plans and policies, and impacts would remain less than significant. Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 32 Planning principles encourage consideration of separating industrial and residential uses to reduce the potential for use conflicts from noise, odors, traffic, and visual character. As discussed in other section of this Initial Study, noise, air quality and traffic impacts are mitigated by existing goals, policies, regulation, and SAMP EIR mitigation measures, which would also be applicable to future development at the project site, as identified throughout this Initial Study. C. The project site is located within the area covered by the Santa Rosa Plain Conservation Strategy (USFWS, 2005). The purpose of the Conservation Strategy is to create a long- term conservation program to assist in the rec.ovety of CTS and four listed plant species. The project site is identified in the Conservation Strategy as "Area Within 1.3 Miles of Known CTS Breeding Area." As identified in the Conservation Strategy, impact to CTS is not likely on some lands within 1.3 miles from breeding sites that are surrounded by significant barriers or are otherwise unsuitable CTS habitat. As discussed above, in Section IV Biological Resources, no CTS have been identified on the project site and the USFWS has issued a letter to the project proponents stating; that development in the SAMP area, including the project site, would be unlikely to affect CTS (SAMP EIR). Therefore, future development at the proposed project site would not result in impacts to CTS nor result in conflicts with the Conservation Strategy. Mitigation Measures No mitigation measures are necessary. Less Than Significant Potentially With Less Than Significant Mitigation Significant XI. MINERAL RESOURCES Impact Incorporated impact No Impact Would the project: a) Result in the loss of availability of a known mineral ❑ ❑ ❑ resource that would be of value to the region and the residents of the state? b) Result in the loss of availability of a locally-important ❑ ❑ ❑ mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? a., b. There are no known mineral resources on the subject property and the site is not delineated on the General Plan as a mineral resource recovery site. Mitigation Measures No mitigation measures are necessary. Less Than Significant Potentially With Less Than Significant Mitigation Significant XII. NOISE Impact Incorporated Impact No Impact Would the project: a) Expose persons to or generate noise levels in ❑ ® ❑ ❑ excess of standards established in the local general plan or noise ordinance, or applicable standards of Redwood Equities GPA / Rezone October 2093 Administrative Draft Initial Study Page 33 Potential noise sources within the vicinity of areas designated residential uses in the SAMP and the project site include the Costco loading bays, the Animal Shelter Facility, and the City Wastewater Pump Station. The Costco loading bays face south and are separated from the future location for residential units within the SAMP, including the project site. The SAMP EIR concluded that noise from the loading bays could substantially exceed the City's Noise Ordinance limit at the boundary of the proposed residential development. The Animal Shelter is located adjacent to the eastern boundary of the project site. Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 34 Less Than Significant Potentially With Less Than XII. Significant Mitigation Significant NOISE Impact Incorporated Impact No Impact Would the project: other agencies? b) Expose persons to or generate excessive ❑ ❑ ® ❑ groundborne vibration or groundborne noise levels? c) Create a substantial permanent increase in ambient ❑ noise levels in the project vicinity above levels existing without the project? d) Create a substantial temporary or periodic increase ❑ ® ❑ ❑ in ambient noise levels in the project vicinity above levels existing without the project? e) For a project located within an airport land use plan ❑ ❑ ❑ ❑ or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels? f) For a project within the vicinity of a private airstrip, ❑ ❑ ❑ would the project expose people residing or working in the project area to excessive noise levels? a. The project site is located adjacent to the eastern border of the SAMP and bounded by the proposed Dowdell Avenue Extension (west); industrial /business uses (north); the Animal Shelter and City Wastewater Pump Station (east); and Costco (south). Existing, noise sources affecting the noise environment in the SAMP area include distant traffic from U.S. 1M and Redwood Drive, local traffic on l abath Avenue, other local streets serving existing development in the area, and noise generated by existing land uses in the area. A noise survey was conducted for the SAMP EIR to quantify existing ambient noise levels in the area. The noise monitoring survey hwused on the area designated for high - density residential, since residential land uses are considered to be noise - sensitive. The project site is located adjacent to and in the immediate area of the locations identified for residential uses in the SAMP EIR. Potential noise sources within the vicinity of areas designated residential uses in the SAMP and the project site include the Costco loading bays, the Animal Shelter Facility, and the City Wastewater Pump Station. The Costco loading bays face south and are separated from the future location for residential units within the SAMP, including the project site. The SAMP EIR concluded that noise from the loading bays could substantially exceed the City's Noise Ordinance limit at the boundary of the proposed residential development. The Animal Shelter is located adjacent to the eastern boundary of the project site. Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 34 Adjacent to the Animal Shelter, the potential issue regarding dog barking noise is the levels that occur during those brief periods when dogs are in the center's outdoor play area. The SAMP EIR concluded that the sound of the dogs barking; outdoors would be expected to be annoying at the closest residence,, generating nuisance complaints. Because the residential development would be multi- story, sound walls would not be an effective technique for reducing; noise from the Animal Shelter. Closed windows would result in meeting state and local standards for noise levels in residential arc -as. By including the proposed project site in the SAMP, development of the project site and adjacent parcel would he required to implement Mitigation Measure NOISE -1 (SAMP EIR Mitigation Measure 12 -1a) to reduce noise impacts on residential uses and ensures that this impact remains less than signific °ant. The City Wastewater Pump Station was not identified the SAMP EIR as a potential noise source in the project vicinity. Based on recent discussion with City staff, noises associated with pumps cycling on and off cannot be heard outside of the concrete block buildings at the facility (City of Rohnert Park, 2013). Impacts resulting from the exposure; of residence to noises from the Wastewater Dump Station would be less than significant. b. Limited g,roundborne vibration may occur during project construction; but would not occur during, project operation. Groundborn €y vibration during construction would not create= excessive disturbance to neighboring land uses and impacts from groundborne vibration would remain less than significant. C. The proposed project site is located in an area primarily developed with industrial, commercial, and institutional buildings. There are no existing, residential areas that would be directly affected by on -site noise or project - generated traffic. The potential for increases to vehicular traffic noise along, the street network were analyzed in the SAMP EIR by comparing existing noise levels to future noise levels on potentially most- affc _,cted street segments. The EIR concluded that traffic generated with buildout of the SAMP would not cause a substantial increase in noise (City of Rohnert Park, 2007). Because the project site is located adjacent to the SAMP boundaries and would be utilized to develop a portion of the residential units allocated in the SAMP, the future development at the project allowed by the proposed General Plan Amendment anti rezone would also not cause a substantial increase in traffic noise and therefore would result in a less than significant noise impact. d. As discussed in the SAMP EIR, future project construction activities within the SAMP would take place in phases and would include site grading, paving of roadways and parking areas, construction of buildings and common facilities. Construction within the SAMP would generate noise and would temporarily increase noise levels in the area. Noise impacts resulting from construction depend upon the noise generated by various pieces of construction equipment, timing, duration of each noise- generating activity, and the distance between construction noise sources and noise - sensitive receptors. The highest noise levels would be generated during grading and paving Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 35 activities, with lower noise levels occurring during building construction. The SAMP EIR concluded that noise levels produced by heavy equipment may interfere with normal residential activities at the new residences during busy construction periods. Noise generated by construction would create a temporary noise level increase, at these future noise sensitive receptors, but this would be considered a less than significant impact provided that the standard noise control measures included in Mitigation Measure NOISE -2 (SAMP EIR Mitigation Measure 12 -3a) are implemented. e., f. The prcajt,c-t site is not located within an airport land use plan or in the vicinity of a private airstrip. The project will have no impact related to airport or airstrip traffic and associated noise. Mitigation Measures Mitigation Measure NOISE -1 (SAMP EIR Mitigation Measure 124a): The following mitigation measures shall be implemented as part of the Project: Noise sensitive outdoor areas associated with the residential development, located within approximately 150 feet of Labath Avenue and with a direct line -of -sight to the roadway, or within 150 feet of the Animal Shelter, shall' be shielded utilizing solid noise barriers. Noise sensitive uses are defined to be private outdoor activity areas such as a rear yard or community space including the park or other noise sensitive outdoor areas. The noise barriers shall be 5- to f±- feet high, constructed of wood, concrete or masonry block, or concrete panels. To be effective, the barrier shall be constructed airtight over the surface and at the base and have a minimum surface weight of at least 3 tbs./ ft. Residences proposed within approximately 150 feet of Labath Avenue, or within "150 feet of the Animal Shelter, shall include forced air mechanical ventilation or air conditioning, satisfactory to the local building official, so that the occupants of the buildings may keep their windows closed at their discretion to control traffic noise intrusion. No other special building sound insulation treatments are necessary for residences proposed near Labath Avenue. Residential building facades located within approximately AV feet of the Costco loading bays, which also have a direct line -of sight to the loading bays, shall be designed to provide 30 dBA of noise reduction when going from outside to inside. Residential building facades within approximately 1,500 feet of the Costco loading bays, which also have direct line -of -sight shall be designed to provide approximately 25 dBA of exterior to interior noise reduction (Note: standard California construction, with the windows closed, normally provides 20 to 25 dBA of noise reduction). Noise control treatments necessary to achieve this may include such elements as sound rated windows and doors with sound transmission class ratings estimated to be STC 28 to 33. All buildings within 1,500 feet Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 36 of the Costco loading bays shall be provided with forced air mechanical ventilation or air conditioning as necessary to provide a habitable interior environment with the windows closed, satisfactory to the local building official. • Pursuant to the requirements of the State Building Code, a qualified acoustical consultant shall review the final design plans for the Project to confirm that they m4'essary noise control treatments have been included into the design to satisfy they 45 dB Ldn interior requirements set forth in the code. A report shalt be prepared and submitted along, with the plans at the time a building permit is requested. • Residential development shall be located no closer than 250 feet from the animal impoundme =nt center property line. Mitigation Measure NOISE -2 (SAMP E1R Mitigation Measure 12 -3a): Noise - generating activities at the construction site or in areas adjacent to the construction site associated with the Project in any way would be restricted to the hours of 8:00 a.m. to 6.00 p.m. (Ord. 152 § 3.1, 1971). • Use available noise suppression devices and properly maintain and muffle loud construction equipment. • Avoid the unnecessary idling, of equipment and stage construction equipment as far as reasonable from residences north of the site (preferably more than 200 feet from residences). • Notify adjacent uses of the construction schedule. • Designate a "noise disturbance coordinator" who would be responsible for responding to any local complaints about construction iu►ise. `lr i-te disturbance coordinator would determine the cause of the noise complaints (e.g., starting too early, bad muffler, etc.) and would require that reasonable measures warranted to correct the problem be implemented. Conspicuously post a telephone number for the disturbance coordinator at the construction site and include it in the notice sent to neighbors regarding the construction schedule. Less Than Significant Potentially With Less Than Significant Mitigation Significant XIII. POPULATION AND HOUSING impact Incorporated Impact No Impact Would the project: a) Induce substantial population growth in an area, ❑ ❑ ® ❑ either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)? Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 37 Less Than Significant Potentially With Less Than XIII. POPULATION AND HOUSING Significant tigation significant Impact Incorporated Impact Na Impact Would the project: b) Displace substantial numbers of existing housing, ❑ ❑ ❑ necessitating the construction of replacement housing elsewhere? c) Displace substantial numbers of people, ❑ ❑ ❑ ❑ necessitating the construction of replacement housing elsewhere? a. The project would involve a General Plan Amendment and Rezone to allow for future development of high density residential units its part of the SAMP. Impacks associated with huild.out of the SAMP were analyzed in they SAMP EIR, They SAMP EIR found that impacts related to population growth associated with huildout of they SAMP would be less than significant with implementation of applicable General Plan policies and Growth Management Program. b. - C. The site does not currently support any housing or residential use. No housing or residents would be displaced by the proposed project and the project would have no impact on housing or require construction of new housing. Mitigation Measures No mitigation measures are necessary. Less Than significant Potentially With Less Than Significant nt MiesipXIII. PUBLIC SERVICES Significant Incorporated Ima No Impact Would the project: a) Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the following public services: Fire protection? ❑ ❑ ❑ Police protection? ❑ ❑ ❑ ED Schools ❑ ® ❑ ❑ Parks ❑ ❑ ❑ Redwood Equities GPA I Rezone October 2013 Administrative Draft Initial Study Page 38 a. Fire and police protection: The City of Rohnert Park Department of Public Safety provides police and fire protection services within the City. The proposed project would allow for future development of a portion of the high density residential units allocated in the SAMP. According the SAMP EIR, buildout of the SAMP would result in the addition of approximately 1,W0 people. The increase in population resulting from development of the SAMP would: result in an increase in the demand for City fire and police protection services. As discussed in the SAMP EIR, the City's acceptable response time for emergency calls is four minutes (City of Rohnert Park, 2007). The SAMP EIR found that the response time to calls in the west side of U.S. 101 is often over four minutes and concluded that additional development associated with the SAMP would lac, expec'te'd to i c'rease the potential number of calls, and tlu refore >inc°realso response times. Mitigation included in the SAMP EIR (Mitigation Measure 14-1a) required construction of a new Department of Public Safety Station in the northwest area of they City. At tluw time the SAMP EIR was prepared, the City was considering locating they station on the project site. However, the City has recently identified an alternative sites, approximately 3.0 acres, located in the southwestern corner of the SAMP area, noting that the atteyrnative site would be better suited for the new Public: Safety Station because it provides greater accessibility and is more centrally located than the projml site. Construction of the station in the SAMP area would maintain a four - minute response time to all areas of they City and would comply with the SAMP EIR Mitigation Measure 14-1a. The SAMP EIR also found that the addition of one Public Safety officer would maintain the past operating average 1.4 Public. Safety officers to 1,000 residents. The combination of the construction of the station and addition of an officer would result in less than significant impacts on police and fire services (City of Rohnert Park, 2007). Schools: Future development of residences at the site will generate students that would attend area schools. The project site is located within the Cotati- Rohnert Park Unified School District (CRPUSD). Estimates included in the SAMP EIR indicate an average student yield of 0.4 elementary school students, 0.1 middle school students, and 0.2 high schoot students per household, including single and multiple family dwellings. The SAMP's proposed 3311 dwelling units, a portion of which would be developed at the project site, would be expected to result in 135 new elementary school students, 34 new middle school students, and 68 new high school students (City of Rohnert Park, 2007). Under current state legislation, the City cannot deny administrative or quasi- judicial approvals for a development based on the development's adverse impact on school Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 39 Less Than Significant Potentially With Less Than Significant Mitigation Significant XII1. PUBLIC SERVICES Impact In ated Impact No Impact Other public facilities? ❑ n a. Fire and police protection: The City of Rohnert Park Department of Public Safety provides police and fire protection services within the City. The proposed project would allow for future development of a portion of the high density residential units allocated in the SAMP. According the SAMP EIR, buildout of the SAMP would result in the addition of approximately 1,W0 people. The increase in population resulting from development of the SAMP would: result in an increase in the demand for City fire and police protection services. As discussed in the SAMP EIR, the City's acceptable response time for emergency calls is four minutes (City of Rohnert Park, 2007). The SAMP EIR found that the response time to calls in the west side of U.S. 101 is often over four minutes and concluded that additional development associated with the SAMP would lac, expec'te'd to i c'rease the potential number of calls, and tlu refore >inc°realso response times. Mitigation included in the SAMP EIR (Mitigation Measure 14-1a) required construction of a new Department of Public Safety Station in the northwest area of they City. At tluw time the SAMP EIR was prepared, the City was considering locating they station on the project site. However, the City has recently identified an alternative sites, approximately 3.0 acres, located in the southwestern corner of the SAMP area, noting that the atteyrnative site would be better suited for the new Public: Safety Station because it provides greater accessibility and is more centrally located than the projml site. Construction of the station in the SAMP area would maintain a four - minute response time to all areas of they City and would comply with the SAMP EIR Mitigation Measure 14-1a. The SAMP EIR also found that the addition of one Public Safety officer would maintain the past operating average 1.4 Public. Safety officers to 1,000 residents. The combination of the construction of the station and addition of an officer would result in less than significant impacts on police and fire services (City of Rohnert Park, 2007). Schools: Future development of residences at the site will generate students that would attend area schools. The project site is located within the Cotati- Rohnert Park Unified School District (CRPUSD). Estimates included in the SAMP EIR indicate an average student yield of 0.4 elementary school students, 0.1 middle school students, and 0.2 high schoot students per household, including single and multiple family dwellings. The SAMP's proposed 3311 dwelling units, a portion of which would be developed at the project site, would be expected to result in 135 new elementary school students, 34 new middle school students, and 68 new high school students (City of Rohnert Park, 2007). Under current state legislation, the City cannot deny administrative or quasi- judicial approvals for a development based on the development's adverse impact on school Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 39 facilities. Pursuant to this legislation, the sole mitigation for such impacts arising from administrative or quasi- judicial development approvals is fees imposed by the affected school district(s). Mitigation Measure PUB -1 (SAMP EIR Mitigation Measure 14 -2a), which requires school impact fees to be paid by developers consistent with fee sc:hedutes in place at the time development occurs. Fulfillment of the mitigation fee requirement is considered full mitigation and would ensure that impacts of student enrollments affecting schools would remain less than significant. Parks and other public facilities: Because the proposed project site would eventually be utilized to construct a portion of residential units allocated in. the SAMP, the project would result in no additional impacts to parrs and other public facilities, outside of those addressed in they SAMP EIR. The SAMP EIR found that development within the SAMP area would not result in a demand for parks and other public facilities to exceed the accepted service standards of the City. This impact is less than significant and no mitigation required. Mitigation Measures Mitigation Measure PUB-1 (SAMP EIR Mitigation Measure 14-2x, slightly modified): Prior to the issuance of building permits, the City shall require proof of payment of the statutory development fur• or the mitigation fee imposed by the school district that serves the SAMP area, at: authorized by state law (California Government Code; fr5995). In accordance with Section 65996 of the State Government Code, the proje d sponsor skull be required to pay the current school mitigation fees at the time that building permits are issued_ a. - b. The proposed project would change the General Plan and zoning designations for the site from Public Institutional to High Density Residential and PD; no specific construction is proposed at this time. In the future the project site would support development of a portion of the 94 remaining High Density Residential units currently allocated to the SAMP area. While specific development plans for the project site are not known. at this time, it is expected that the project site would support approximately 50 units (slightly more than half of the 94 units already Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 40 Less Than Significant Potentially With Less Than XV. RECREATION Significant Impact Mitigation Incorporated Significant Impact No Impact Would the project: a) Would the project increase the use of existing ❑ ❑ ® ❑ neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated? b) Does the project include recreational facilities or ❑ ❑ ® 0 require the construction or expansion of recreational facilities which might, have an adverse physical effect on the environment? a. - b. The proposed project would change the General Plan and zoning designations for the site from Public Institutional to High Density Residential and PD; no specific construction is proposed at this time. In the future the project site would support development of a portion of the 94 remaining High Density Residential units currently allocated to the SAMP area. While specific development plans for the project site are not known. at this time, it is expected that the project site would support approximately 50 units (slightly more than half of the 94 units already Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 40 allocated to the area). With an average rate of 2.59 persons per household in the City, the future construction of 50 units at this project site would support a population of approximately 130 people. This additional population would require approximately 0.65 acres of community and neighborhood parks, in accordance with the City's parkland standards. Further, this population increase is consistent with the projected population for the SAMP. The SAMP EIR concluded that buildout of the SAMP area would not cause the demand for parks and recreation facilities to exceed the accepted service standards of the City. The total SAMP project population would generate a need for 4.4 acres of park. To satisfy this, the SAMP area includes development of one half -acre park and the remaining 3.9 acres of park will be accommodated by dedication of parkland and /or fees contributed by new projects. The proposed project would not result in a significant increase in population; therefore, demand on existing, and planned recreational facilities would he less than significant. Mitigation Measures No mitigation measures are necessary. Potentially Significant XVI. TRANSPORTATIONrMAFFIC impact Would the project: a) Conflict with an applicable plan, ordinance or policy ❑ establishing measures of effectiveness for the performance of the circulation system, taking into account all modes of transportation including mass transit and non - motorized travel and relevant components of the circulation system, including but not limited to intersections, streets, highways and freeways, pedestrian and bicycle paths, and mass transit? b) Conflict with an applicable congestion management ❑ program, including, but not limited to level of service standards and travel demand measures, or other standards established by the county congestion management agency for designated roads or highways? Less Than Significant With Less Than Mitigation Significant Incor(p rated Impact ® ❑ No Impact 7I c) Result in a change in air traffic patterns, including [] ❑ either an increase in traffic levels or a change in location that results in substantial safety risks? d) Substantially increase hazards due to a design ❑ ❑ ❑ feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)? e) Result in inadequate emergency access? ❑ ❑ ® ❑ Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 41 a., b. The proposed project would change the General Plan and zoning designations for the site from Public Institutional to High Density Residential and PD; no specific construction is proposed at this time. In the future the project site would support development of a portion of the 94 remaining; High Density Residential units currently allocated to the SAMP area. While specific development plans for the project site are not known at this time, it is expected that the project site would support approximately 50 units (slightly more than half of the 94 units already allocated to the area). Based on Institute of Traffic Engineers (1717E) trip generation rates of 6.72 trips per dwelling unit for apartments (as evaluated in the SAMP EIR), this 50 residential units that could be constructed on the project site would generate 3,36 daily vehicle trips, with approximately 33 trips occurring in each peak hour (AM and PM peaks). The effect of these trips: was evaluated in the SAMP EIR as part of the. overall SAMP development and the proposed project would not increase traffic beyond the amount anticipated in the SAMP EIR. The SAMP EIR found that with implementation of mitigation measures requiring fixture development within the SAMP to contribute it fair share toward construction of necessary improvements, tmpads related to applicable transportation - related plans, policies or ordinances would be reduced to less than significant levels. By iiw[uding the prof- t,fsed project site in the SAMP, development of the project site and adjacent parcel would be required to implement Mitigation: Measure TRA -1 (which reflects Mitigation Measures 15 -la through 15-1e and 15 -2a through 15 -2c of the SAMP EIR), requiring; any applicant for future construction on the project site to contribute a fair share amount to the improvements identified in the SAMP EIR. C. The project would allow for future development of a portion of high density residential units allocated in the SAMP, in an area that is not within an airport land use plan. Due to the type of project it is, the project would not have the ability to change or affect air traffic patterns resulting in any potential safety risks. Therefore, there would be no impact on air traffic: patterns. d. The project does not include the development of any public roads nor does the project include any design features that could increase hazards. Future development at the project site would include internal driveways and parking lots that would be designed in compliance with the City's fire department standards as well as the City's traffic requirements. Therefore, the project does not Include any dangerous design features or incompatible uses that could result in hazardous conditions and there would be no impact. Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 42 Less Than Significant Potentially With Less Than Significant Mitigation Significant No XVI. TRANSPORTATIONITRAFFIC Impact Incorporated Impact Impact Would the project: f) Conflict with adopted policies, plans, or programs ❑ ❑ ® ❑ regarding public transit, bicycle, or pedestrian facilities, or otherwise decrease the performance or safety of such facilities? a., b. The proposed project would change the General Plan and zoning designations for the site from Public Institutional to High Density Residential and PD; no specific construction is proposed at this time. In the future the project site would support development of a portion of the 94 remaining; High Density Residential units currently allocated to the SAMP area. While specific development plans for the project site are not known at this time, it is expected that the project site would support approximately 50 units (slightly more than half of the 94 units already allocated to the area). Based on Institute of Traffic Engineers (1717E) trip generation rates of 6.72 trips per dwelling unit for apartments (as evaluated in the SAMP EIR), this 50 residential units that could be constructed on the project site would generate 3,36 daily vehicle trips, with approximately 33 trips occurring in each peak hour (AM and PM peaks). The effect of these trips: was evaluated in the SAMP EIR as part of the. overall SAMP development and the proposed project would not increase traffic beyond the amount anticipated in the SAMP EIR. The SAMP EIR found that with implementation of mitigation measures requiring fixture development within the SAMP to contribute it fair share toward construction of necessary improvements, tmpads related to applicable transportation - related plans, policies or ordinances would be reduced to less than significant levels. By iiw[uding the prof- t,fsed project site in the SAMP, development of the project site and adjacent parcel would be required to implement Mitigation: Measure TRA -1 (which reflects Mitigation Measures 15 -la through 15-1e and 15 -2a through 15 -2c of the SAMP EIR), requiring; any applicant for future construction on the project site to contribute a fair share amount to the improvements identified in the SAMP EIR. C. The project would allow for future development of a portion of high density residential units allocated in the SAMP, in an area that is not within an airport land use plan. Due to the type of project it is, the project would not have the ability to change or affect air traffic patterns resulting in any potential safety risks. Therefore, there would be no impact on air traffic: patterns. d. The project does not include the development of any public roads nor does the project include any design features that could increase hazards. Future development at the project site would include internal driveways and parking lots that would be designed in compliance with the City's fire department standards as well as the City's traffic requirements. Therefore, the project does not Include any dangerous design features or incompatible uses that could result in hazardous conditions and there would be no impact. Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 42 e. As discussed in the SAMP EIR, emergency access to the SAMP could take place via several interconnected routes including Business Park Drive, Martin Avenue, and Labath Avenue. All internal streets would be developed to the City's public street standards and would accommodate emergency vehicle circulation. The City has proposed constructing a Public Safety Station on a portion of the SAMP. As discussed above, in Section XIII Public Services, impacts resulting from response times to the project will be reduced to less than significant with construction and operation of this station. As discussed in the SAMP EIR, the SAMP is conceptual in nature and provides little information on what pedestrian and bicycle facilities would be included as part of any development. Formal development plans for the SAMP will he rewired by the City and must include adequate facilities for pedestrians and bicyclists, including sidewalk facilities that connect visitors, residents, and employees to nearby transit facilities. Additionally, due to the lack of public schools within a walkable distance from the SAMP area, children residing in the proposed residential component will need to be bussed. to aria schools. By including the proposed project site in the SAMP, development of the proi(x -t site and adjacent parcel would be r(M. uired to implement Mitigation Measure TRA -2 (included as Mitigation Measures 15 -5a and 15-5h in the SAMP EIR), which require construction of bicycle and pedestrian facilities and the provision of bussing for school -aged children within in the SAMP area. Implementation of these masures would ensure this impact is less than significant. Mitigation Measures Mitigation Measure TRA4: Prior to the issuance of building permits, the project shall be assessed impact fees or a proportional share contribution for the construction of they improvements identified in SAMP EIR Mitigation Measures 15 -1a through 154e and 15- 2a through 15 -2c: Mitigation Measure TRA -2 (SAMP EIR Mitigation Measures 5-5a and 5 -5b): All streets within the project site shall include sidewalks on both sides, all activity areas shall be connected by onsite sidewalks and /or paths; and the project applicant shall pay appropriate School District fees to offset costs associated with the establishment of bussing for school -aged residents of the project site through the City of Rohnert Park and the Cotati- Rohnert Park Unified School District. Redwood Equities GPA/ Rezone October 2093 Administrative Draft Initial Study Page 43 Less Than Significant Potentially With Less Than Significant Mitigation Significant XVII. UTILITIES AND SERVICE SYSTEMS Impact Incorporated Impact No Impact Would the project: a) Exceed wastewater treatment requirements of the ❑ ❑ ❑ applicable Regional Water Quality Control Board? b) Require or result in the construction of new water or ❑ ❑ ® ❑ wastewater treatment facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? Redwood Equities GPA/ Rezone October 2093 Administrative Draft Initial Study Page 43 a. As discussed in Section IX i lydrol€igy and Water Quality, wastewater yen €rated by the project site, once developed, would be treated by the Subregional System and the additional flows would not be expected to result in a violation of the system's waste discharge requirements. Therefore, the project would have no impact on complying with wastewater treatment requirements. b., d., Based on information contained in the SAMP EIR, the SAMP area could demand up to C. approximately 84,695 gallons of water per day or 94.87 acre -feet per year (AFY). As discussed in the SAMP EIR, the City has sufficient water supplies during a normal year, a single -dry year and multiple -dry years to accommodate anticipated development. Even if the recycled water storage facilities proposed in the Board of Public Utilities Interim Recycled Water Program are not built as planned, so that the supply of recycled water does not increase beyond that available currently, the water supplies would still be sufficient for the project and other planned growth (City of Rohnert Park, 2005). The City of Rohnert Park has sufficient water supply and water delivery infrastructure to serve the Project. By utilizing SCWA supply, recycled water supply and groundwater supply and by implementing water conservation measures consistent with the California Urban Water Council's Memorandum of Understanding,, the City has adequate supply to serve the Project. Accordingly, there would be no significant adverse environmental impact resulting from the project regarding the need for new or expanded entitlements or resources for Redwood Equities GPA /Rezone October 2013 Administrative Draft initial Study Page 44 Less Than Significant Potentially With Less Than XVII. UTILITIES AND SERVICE SYSTEMS Significant Impact Mitigation Incorporated Significant Impact No Impact Would the project: c) Require or result in the construction of new ❑ ❑ ® ❑ stormwater drainage facilities or expansion of existing facilities, the construction of which could cause significant environmental effects? d) Have sufficient water supplies available to serve the ❑ ❑ ® ❑ project from existing entitlements and resources, or are new or expanded entitlements needed? e) Result in a determination by the wastewater ❑ ❑ ® ❑ treatment provider which serves or may serve the project that it has adequate capacity to serve the project's projected demand in addition to the provider's existing commitments? f) Be served by a landfill with sufficient permitted ❑ ❑ ❑ capacity to accommodate the project's solid waste disposal needs? g) Comply with federal, state, and local statutes and ❑ ❑ ❑ regulations related to solid waste? a. As discussed in Section IX i lydrol€igy and Water Quality, wastewater yen €rated by the project site, once developed, would be treated by the Subregional System and the additional flows would not be expected to result in a violation of the system's waste discharge requirements. Therefore, the project would have no impact on complying with wastewater treatment requirements. b., d., Based on information contained in the SAMP EIR, the SAMP area could demand up to C. approximately 84,695 gallons of water per day or 94.87 acre -feet per year (AFY). As discussed in the SAMP EIR, the City has sufficient water supplies during a normal year, a single -dry year and multiple -dry years to accommodate anticipated development. Even if the recycled water storage facilities proposed in the Board of Public Utilities Interim Recycled Water Program are not built as planned, so that the supply of recycled water does not increase beyond that available currently, the water supplies would still be sufficient for the project and other planned growth (City of Rohnert Park, 2005). The City of Rohnert Park has sufficient water supply and water delivery infrastructure to serve the Project. By utilizing SCWA supply, recycled water supply and groundwater supply and by implementing water conservation measures consistent with the California Urban Water Council's Memorandum of Understanding,, the City has adequate supply to serve the Project. Accordingly, there would be no significant adverse environmental impact resulting from the project regarding the need for new or expanded entitlements or resources for Redwood Equities GPA /Rezone October 2013 Administrative Draft initial Study Page 44 water supplies. The SAMP EIR concluded that there would be no requirement for additional treatment facilities resulting from buildout of the SAMP, including the project site (City of Rohnert Park, 2007). The Subregional System, of which Rohnert Park is a member, operates wastewater treatment facilities which have a rated dry weather capacity of 21.4 million gallons per day. The City is allotted 3.43 million gallons per day of the total capacity (City of Rohnert Park, 2005). The SAMP EIR concluded that the resultant total wastewater generation associated with build -out of the SAMP would constitute about 2 percent of the total City of Rohnert Park allocation of average dry weather flow (City of Rohnert Park, 2007). in addition, the Rohnert Park General Plan indicates that the City will be expanding its sewer infrastructure (City of Rohnert Park, 2000). Any needed infrastructure improvements can be funded through a mix of capital improvement funds and developer fees. Based on the above information, they project would have a less than significant impact on the provision of wastewater treatment services and would not require additional treatment facilities. C. As dist°ussed in the SAMP EIR, runoff from the east side of the SAMP area, including they project site, would he diverted into new storm drains in the extension of Dowdell Avenue. This existing system in Laba.th Avenue was designed; with adequate capacity to convey storm drainage from the west half of the developed SAMP area to Hine >baugh Creek. As indicated in the SAMP EIR, the storm drain to serve the eastern half of the SAMP area would be constructed by the developer of that portion of the site and would drain to Hinebaugh Creak (City of Rohnert Park, AW). The City's General Plan Policy HS-5 requires project developers to design and construct storm drains that conform to the Sonoma County Water Agency Flood Control Design Criteria, and encourages the use of environmentally sensitive drainage improvements, including flow reduction and flood bypass systems, to ensure the protection of surface water quality and stream integrity. Construction of new storm drain systems would be required to comply with the Stormwater Phase 11 regulations administered by the North Coast Regional Water Quality Control Board through permits to the City. Therefore *, the project would have a less than significant impact related to construction of new stormwater drainage facilities. f. The project would generate solid waste; however, because the project would not result in an increase in the number of residential units assumed in the SAMP EIR analysis, it would not result in impacts outside of those analyzed in the SAMP EIR. The SAMP EIR concluded that the County of Sonoma would be capable of providing the solid waste disposal services necessary to serve the entire SAMP area, including during construction. In addition, the EIR indicates that the Central Disposal Site Landfill in Sonoma County, planned operate through the year 2050, has adequate capacity to accommodate the projecNs needs (City of Rohnert Park, 2007). In addition, the city must comply with Assembly Bill 939, passed in 1989, to reduce the volume of material sent to landfills by implementation of a recycling plan for both construction and operation phases of projects. Therefore, the project would result in no impact outside of those analyzed in SAMP EIR. Redwood Equities GPA / Rezone October 2093 Administrative Draft Initial Study Page 45 g. The project would comply with federal, state and local statutes and regulations related to solid waste and would have no impact related to solid waste regulations. Mitigation Measures No mitigation measures are necessary. Redwood Equities GPA J Rezone October 2013 Administrative Draft Initial Study Page 46 Less Than Significant Potentially With Less Than Significant Mitigation Significant XYIII. MANDATORY FINDINGS OF SIGNIFICANCE Impact Incorporated Impact No Impact a) Does the project have the potential to degrade the ❑ ❑ ❑ quality of the environment, substantially reduce the habitat of a fish or wildlife species, cause a fish or wildlife population to drop below self- sustaining levels, threaten to eliminate a plant or animal community, reduce the number or restrict the range of a rare or endangered plant or animal or eliminate important examples of the major periods of California history or prehistory? b) Does the project have impacts that are individually ❑ ❑ ❑ ❑ limited, but cumulatively considerable? ( "Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects)? c) Does the project have environmental effects which ❑ ® ❑ ❑ will cause substantial adverse effects on human beings, either directly or indirectly? a. The projet't site does not provide substantial habitat for wildlife, nesting birds, or fish, and does not support any sensitive natural vegetation communities. Future development at the project site would not reduce habitat for fish or wildlife species, threaten to elimu -kite a plant or animal community, adversely affect rare or endangered species, or eliminate important cultural resources. b. The analysis provided throughout this Initial Study demonstrates that the projects contribution to cumulative impacts would be .reduced to less than significant levels through mitigation. C. The analysis provided throughout this Initial Study identifies project impacts that may be potentially significant and identifies mitigation measures that would reduce each impact to a less than significant level. Redwood Equities GPA / Rezone October 2013 Administrative Draft Initial Study Page 47 REFERENCES Bay Area Air Quality Management District. 2000. Clean Air Plan. December 20. 2006. Bay Area 2005 Ozone Strategy. January 4. 2010. Bay Area 2010 Clean Air Plan. September 10. California Regional Water Quality Control Board, 2009. In the ,Matter of Water Quality Certification for Rohnert Park Startiunt Area Master Plant. August 6. City of Rohnert Park. 20011. General Plan (Fifth Edition). Adopted July 2000. . 2003. City of Rohnert Park Wastewater Polak 0ecomutissioning Report. December 5. 2005. City of Rohnert Park Final Water Supply Assessment. January. - - -. 2(X)7. Staditint Area Master Plan E1R. October. 2008. Stadium Area Muster Platt Final Development Platt. February. - - -. 2(71:1. Written communication from John McArthur, Community Services Director September 5. North Fork Associates. 2003. Wetlanel Delineation for t1w 32 -acre Stadium Area Master Plan. September. Sonoma County. 2008. Sonoma County General Plan. Adopted September 2.3. U.S. Fish and Wildlife Service, 2(X)5. Sutta Rosa Plain Conservation Strategy. December 1. Redwood Equities GPA /Rezone October 2013 Administrative Draft Initial Study Page 48 EXHIBIT 2 FINDINGS FOR THE REDWOOD EQUITIES GPA/REZONE PROJECT REQUIRED FINDINGS CEQA requires that, prior to approval of a project, the Lead Agency make specified findings related to each of the significant or potentially significant environmental effects considered in the Mitigated Negative Declaration/Initial Study (MND). The MND identified several significant or potentially significant effects on the environment. The City of Rohnert Park City Council's findings with respect to each of these significant or potentially significant environmental effects are presented below. It is anticipated that the City Council of the City of Rohnert Park will adopt the MND and Mitigation Monitoring and Reporting Program (MMRP) and approve the Project in conjunction with its adoption of this document. With these actions in place, all the Project environmental effects will be reduced to less than significant. The findings for the proposed Project are based upon substantial evidence, comprised primarily of the information, analysis and mitigation measures described in the MND and other information incorporated into these documents by reference. SECTION 1.0 FINDINGS OF THE LEAD AGENCY WITH REGARD TO THE SIGNIFICANT ENVIRONMENTAL EFFECTS OF THE PROJECT 1.1 ENVIRONMENTAL EFFECTS OF THE PROJECT THAT DO NOT REQUIRE FINDINGS Environmental effects that the MND found to be less than significant without mitigation do not require findings under CEQA. These effects include the following: Project Impacts on Agriculture and Forest Resources Project Impacts on Greenhouse Gas Emissions Project Impacts on Land Use and Planning Project Impacts of Mineral Resources Project Impacts on Population and Housing Project Impacts on Recreation Project Impacts on Utilities and Service Systems 1.2 ENVIRONMENTAL EFFECTS OF THE PROJECT THAT REQUIRE FINDINGS The environmental effects that were found by the Mitigated Negative Declaration/Initial Study (MND) to be significant and/or potentially significant prior to the application of mitigation measures include the effects listed below. As required by CEQA, the City of Rohnert Park City Council must make findings with respect to each of these significant effects. The City Council's findings, and the evidence in support of those findings, are detailed below The Project could substantially degrade the existing visual character or quality of the site and its surroundings. EFFECT: Development of the site with high density residential land uses would change the visual character of the site. MITIGATION: Mitigation Measure AES -I and AES -2 (SAMP EIR Mitigation Measures 4 -1a and 4-1b) identified in the MND require future development at the site to conform to the General Plan and apply the City's design standards. FINDING: Implementation of Mitigation Measure AES -1 and AES -2 identified in the MND would ensure impacts to the visual character of the area remain less than significant. Future development at the project site could violate air quality standards. EFFECT: Future construction activities associated with development at the project site would generate air pollutant emissions that could exceed the Bay Area Air Quality Management District ( BAAQMD) standards. MITIGATION: Mitigation Measure AIR -1 (SAMP EIR Mitigation Measure 5 -2a) identified in the MND would ensure that future development allowed as a result of the proposed project would meet the BAAQMD CEQA Guidelines by requiring implementation of Basic Construction Emission Control Measures. FINDING: Based on the site characteristics, it is expected that the screening criteria related to construction- related activities would be met with future development of the project site. Therefore, with implementation of Mitigation Measure AIR -1, all of the BAAQMD screening criteria would be met and future development on the project site allowed by the proposed General Plan Amendment and Rezone would have a less than significant impact related to criteria air pollutant emissions and exposure of sensitive receptors to substantial pollutant concentrations. The Project could have a substantial adverse effect on raptors, which are a special - status species. EFFECT: If raptors are actively nesting onsite, construction activities could disturb these birds. MITIGATION: Mitigation Measure BIO -1 (SAMP Mitigation Measure 6 -4a) identified in the MND will avoid impacts to nesting raptors by requiring a raptor nesting survey should construction activities begin during the nesting season. FINDING: Implementation of Mitigation Measure BIO -1 identified in the MND will reduce construction - related impacts to biological resources to a less than significant level. There is the potential that unknown cultural resources present at the project site could be adversely affected due to construction activities. EFFECT: While it is unlikely that previously unknown cultural resources would be encountered at the site, in the event that cultural resources are discovered during grading and excavation activities, this could result in damage to archaeological resources. MITIGATION: Mitigation Measures CUL -1, CUL -2, and CUL -3 (SAMP EIR Mitigation Measures 7.1 a, 7.1 b, and 7.3a) identified in the MND will ensure that unknown cultural resources discovered at the project site during grading and excavation activities will be protected.. FINDING: Implementation of Mitigation Measure CUL -1, CUL -2, and CUL-3 identified in the MND will reduce impacts to discovered cultural resources to a less than significant level. Strong ground shaking may be expected at the project site during the design lifetime of the proposed Project. EFFECT: The project site is located within the seismically active Bay Area and as such, future building at the project site may be exposed to a significant seismic event that could result in structural damage to residential structures. MITIGATION: Mitigation Measure GEO-1 (SAMP EIR Mitigation Measure 8 -2a) identified in the MND specifies Project compliance with state building code seismic requirements. Future buildings at the project site would be required to be designed to meet current code requirements to avoid substantial damage to buildings during a seismic event FINDING: Implementation of Mitigation Measure GEO -1 would reduce the potential for structural damage and would ensure impacts related to groundshaking are less than significant. There is the potential for the project site to be located on unstable soils. EFFECT: Future development at the project site could potentially be adversely affected by unstable soil conditions. MITIGATION: Mitigation Measure GEO -2 (SAMP EIR Mitigation Measure 8 -3a) identified in the MND would require preparation of a site- specific soil suitability analysis to be conducted by a registered soil professional to identify potentially unstable soil conditions. FINDING: Implementation of Mitigation Measure GEO -2 would ensure that impacts related to expansive soils would remain less than significant. Future construction of residential units at the proposed project site could expose construction workers, the public, or the environment to hazardous materials through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. EFFECT: Small quantities of potentially toxic substances (e.g., petroleum and other chemicals used to operate and maintain construction equipment) would be used at the project site and transported to and from the site during construction. Accidental releases of small quantities of these substances could contaminate soils and degrade the quality of surface water and groundwater, resulting in a significant public safety hazard. MITIGATION: Mitigation Measure HAZ -I (SAMP EIR Mitigation Measures 9 -la, 9 -lb, and 9 -1c) identified in the MND would require standard control measures for hazardous contaminants and preparation of the appropriate public safety plans. FINDING: Implementation of Mitigation Measure HAZ -1, in addition to compliance with the City's plans and requirements, would ensure that exposure to construction workers or the public to hazardous contaminants during construction would be reduced to less than significant. Future development at the project site could expose people or structures to a significant risk of loss, injury, or death involving wildland fires. EFFECT: The project site and surrounding area is developed with small areas of vacant land and future development of the site, while not expected to, could result in the exposure of workers or the public to wildland fire. MITIGATION: Mitigation Measures HAZ -2a and HAZ -2b (SAMP EIR Mitigation Measure 9- 6a and 9 -6b) identified in the MND specifies fire reduction requirements for contractors during construction of the site. FINDING: Implementation of Mitigation Measure HAZ -2a and HAZ -2b would ensure impacts associated with wildland fires remain less than significant. Future development at the project site could introduce pollutants and sediment into water runoff from the site and would increase the rate and/or volume of water runoff. EFFECT: Construction activities and operation of the project could introduce sediment and chemicals into runoff leaving the site. Development at the project site would increase impervious surfaces at the site, which would increase the rate and volume of water runoff from the site. MITIGATION: Mitigation Measures HYDRO -1 (SAMP EIR Mitigation Measure 10 -3a) identified in the MND would minimize water quality impacts on- and off -site by ensuring that appropriate Best Management Practices are implemented to protect water quality. FINDING: Implementation of Mitigation Measures HYDRO -1 would reduce potential water quality and drainage impacts to a less than significant level. The Project could result in exposure of residential uses to noise levels in excess of applicable standards. EFFECT: Future development of residential uses at the project site could result in exposing residences noise from adjacent land uses that would be likely to the City's applicable standards for noise. MITIGATION: Mitigation Measure NOISE -1 (SAMP EIR Mitigation Measure 12 -1a) identified in the MND would require the implementation of specific noise reduction measures to reduce noise impacts on residential uses. FINDING: Implementation of Mitigation Measure NOISE -1 would reduce noise impacts to future residential uses to less than significant levels. Future development at the project site could cause a substantial temporary increase in ambient noise levels in the project vicinity. EFFECT: Noise produced by heavy equipment during future construction at the project site could generate noise levels that may interfere with normal residential activities at the new residences during busy construction periods. MITIGATION: Mitigation Measure NOISE -2 (SAMP EIR Mitigation Measure 12 -3a) identified in the MND would require implementation of standard noise control measures for future construction at the project site. FINDING: Implementation of Mitigation Measure NOISE -2 would ensure construction - generated noise impacts associated with future development at the project site remain less than significant. Future development of residences at the project site would generate students that would attend area schools, potentially resulting in physical impacts associated with new or physically altered schools constructed to accommodate an increased student population. EFFECT: The proposed project would allow for future development of a portion of the high density residential units allocated in the SAMP. The development of residential units at the project site would be expected to generate students that would attend area schools. MITIGATION: Mitigation Measure PUB -I (SAMP EIR Mitigation Measure 14-2a, slightly modified) identified in the MND, which requires school impact fees to be paid by developers consistent with fee schedules in place at the time development occurs. FINDING: Fulfillment of the mitigation fee requirement of Mitigation Measure PUB -1 would be considered full mitigation and would ensure that impacts of student enrollments affecting schools would remain less than significant. Future development at the project site could result in, or contribute to, transportation- related impacts in conflict with applicable transportation- related plans, policies or ordinances. EFFECT: Although the Project proposed no specific construction at this time, the project site would eventually support development of a portion of the 94 remaining High Density Residential units currently allocated to the SAMP area. The effect of traffic trips associated with development of High Density Residential units was evaluated in the SAMP EIR. The SAMP EIR found that with implementation of mitigation measures requiring future development within the SAMP to contribute a fair share toward construction of necessary improvements, impacts related to applicable transportation- related plans, policies or ordinances would be reduced to less than significant levels MUIGATION: Mitigation Measure TRA -I (which reflects Mitigation Measures 15 -1a through 15- 1 e and 15 -2a through 15 -2c of the SAMP EIR) identified in the MND would require any applicant for future construction on the project site to contribute a fair share amount to the improvements identified in the SAMP EIR. FINDING: Implementation of Mitigation Measure TRA -1 would ensure that impacts related to applicable transportation - related plans, policies or ordinances would be reduced to less than significant levels. M h lrY� W co O O • 1 � / • 1 • • 1 • M ti C N O O � o O N o Z W N m z Z z ca E `—n c LoY E m E `�� ow E cc) — E- (_ c ca i .- L Q °� Q° . �- C cc -- ..- L Q0-00-0 OL L c C° m E i CL m w cc W ay a) _ (m a) 0) M C U N C C _ 0) 0 (0 C U C C M C a) .0 � m� E nQ � CL :3Ecn � w Ca �..L3Y a Ui O Q� O 0 U OL U Q Q c � O— m cn a� L co Y L Ei Y L EL M aa)i c ate) c c . °N c O € c p A 2 m Er O «- o 0 m m C3 CU f3 C13 a) L L cn .�. EL EL O E o it iii ° m CL o o Q L G L C3 C3 E3 0 _ is c a 0) ai c -0 -0 Ha)�cu�i a) " - m EC: E o a) °o ow ca 0 — T3Ll—a)c°3 eta`) acs �°, °�' c 0 a Qa o �a C U co U) 3 -a o - - �-0 c O Co C a) 0) L cn c '�' O a) a) .� C N a) C�> _. 3 Gl a) O C1 O a) Q - .- O E V Q L3 OL �= U) E .0 L. W C ° .� a) '� a) — t c "° w O a) 6" 6 Lim 6 O C a) cn .�.. C C E a) c a) W L —� �o L a) ° U c i �° cn O md0= N a a`�iW o� a a- Q�.c�3L Q Co a) c a) ° E 4ca� - °'u�m°� —� "— LLoa) 70 O c U a 3 L CO c o a) C .� O O E Q cu E a) U --o c a) N Z c0 w N a) m !3 Q Q C C a) a5 E a) a) E o L �[ O a) ° N as a�i c N O Q tq map 0 rnc�� 4 O '� "c °d �� a) �E v a) C6 7i �_ C V O U 'p (L6 3 O f�6 (cB CO �— N C= w a) /N� in . _� O N N Co 4 t L N U aa)) lo a) L '�. N C c a {.�. O Q a a) E m U c C7 W a)•- m-0 a)� a= a) ¢ C- a) a) �- N a) 3 cn �� L (� 0) CU @ = W �c c Eo �$(� a) c 02 m E wo ccY vs c `�� Q' �uj- -c ° v�i► -cU °� O a�� "gin C� o � E m �~ m vim) cu E ..... ...� YYQ ' =00 0 =00- �� ;a�N� O ul -0 `m o c)� c� =° Ncn nY E-a ai��to N Q e a) "° [1 U "N E.0 _ e Q� L C a) C a) C _ Q c O E O= E •N � L a) ,� mo o? .O to- u) O O C m o 3 U CL "' 5 c = a) a) := c N co a) y c E b a) N L a) U m Q co .0) a) N Q a) •'t-' -0 C m U) -° c �n in ' bj 41 z _ � ° °Er 3 m U)ZZ > Q� a).s.0 m ° cco 0 =gg � M ti C N O O � o O N o Z W MMM E cc 0 • • • (A 0 IM :t'- Co 0 0 0 Cc ca CL E (D cc !t- E CD 0 0 0 7E 0 0 im 7-0 lz C op 0 CL IA E ia 16 0. • >, CL a) > 0 a) 4) a (D I_- o E ca =3 CL m -a cu (D D- m m 0 E a) o 0 > C 5- Q -= 0 m ca C: t 0) 0 1-- a) ca -a� cu c O)o C- = M 0 ca :;= a) - > 0 LL z CL E t 0 �O :6 0-0 t5 vi 0- a) cn E 0 16 CU =3 cn a) C3 > N 0) >% C) - C: -0 C -0 0 m 0 -a -0 -0 a) a) 0) CL -0 (1) C 0 (D 01 cn cn (1) CU C>- U) CU a> a) M CU m 0 W 0 := A-- - = C 0 "0 - Z S =3 0 a) C 5, Co CL 0- m t::: 0 0 -C a) 4 a) J� " a) c cc E 0 > co 0) 0 E a) 0 0 r t r- a) IA d. E 0 a) Q 075 0 0)-o CD 0) CU N CA 75 -0 L) :3 0) CO P co c (n (D -0) M .03 - E cu - b 0-0 c: a) C, 0 0 E c - - 0 C z 5 > (n -.7.0 �o 0 E 0 :3 0).1-- S (D 0 C: — o I= U) 4- (D (D N a) r-_ m C"13 M cn 3: SL o o cu 0-0 m L) (D 0 m, E - c (D a) C: 0 "Fa - > 0 CL :3 0 (n U) co 0 -6 M :3 C: 0 C: :3 -0 0 0 0 C - M -0 a) - r_ 0) 0 C - c Co ) 75 .— 0 (D 'Fn (D Co - Co -5 C: -0 0 0 E ca 6 (D r- '4 0 0) 0 0 w 'F E n a) (D cn .0 0 (D 0 ca 0.0 — m 1- 0) - — 2 a) 0 (a -6 -0--a 0 co O (n 0 c'3 E tg o- =3 "0 0 C.) 0) CU C: 0)75 c E >1 (n CD CL o cc -0 (D ca -0 :3 (D cu a) 0 E -0 -0 0) (D U) 0 0 ca 2 o ca > 0 :3 0 a) 0 c C) -R Cc -0 C: M 0) ca > U) (n 0 m m m 0 c a) 0 m w mn 0) (D 0 > E cO E (D E c 4) 0 C) U) > 0 o c P-0 E o 0 0 �: 0 -2 a) 2 0 a) 00-0 m m '6 a) a) m co ••0 m Cc: C"u 3: T :D -0 a CL U) m 2,,5 a) j) U) 0- 0 0 "a = - 2 Q- 0 ix iE5 m o- § o- U- a) 0� o c X.2 a 0 = = 0 0 0 0 U= a) a) 0 c �2 > corn • co - 0 0 0 9 • m 0 a) 0 a) =3 a-) E amp 0) :3 0 0 U- CZ -CZ) O IN C14 bq Q �11 to O 0,0 z -El r7 O 4-0 E 0 a) m O 0 r. m a) Q C: c: 0 N (D 0 cl (D 0,6 c a) .O cr C: W 0 _0 5 0 c 0 0 4-0 Co (D .0 W7. o N ti O IN, "—I E 0 0 C 0 4) E 0 E 0 a) ca:) cc: a) 0 LO 0 M 0 -:s 0 a) E L) _0 cc 0) 0) C: q -0 > —0 -0 C: 0) (D cn .2 ca E a) -0 a) 0) a) 0 Co (D U) x 4) -0 a) ca :E- (0, '0 cc co a) Co cr M U) (D •0 —En -0 M 0.9 cu 0 2 cu Co 0 (D 75 0 (D -R C: CL 0 E (D 4 =3 .1) U) a) 0) > O E cn E a) a) -0 0 '0 Q) 0 =3 o o E u) cL a) (D a) U) = 0 a) 0 '5)— z a) 2 = o w 0 CU uj M w 0 0) X"a ca 5; 0) -0 w 0 0 0 > .0 ca w E 0 0 -2 a) 0 2 -o o o -a 0 M E 0 0 0 a) a) E E O 0 > (D co ;-- r- (D CL c M 0 L : -�; E 0 E 0 (D -Z3 co - CL o 110- 0 U — = c -0 =3 :0— c c oc = 0 0 0 0-0 cr c 0 M-on :p a) -5 (D 0 n C.) 0 0) 'E -0 ca 0 o (D :;= Ct, cn " a) 0 0 0 0 Co 0 E 0 Q —0 C =3 — a) 0) L) 0 -6 c: 0 0 -C ca a) 5 0. 0-0 CL u' -�Ci N .—� — (n a) 0 0 a) a) co E p (D a) >, a) cu —, j, a) :3:5 CU a) W a) 0) > CL z co cn := C E U) -�u a) E a) a) (D =) a) •0 '0 C -w > 0 0 E cu P- 0) > 0 m M= 0 0 0 E 0) . 0 (D > .0 -a .0 (D m cr CO U) 0 0) ca E ac o 0 E w a) 0 I cn x E a) E -- p 0 0) cu c E -C L co L q) -o 0�o - > o 0 0) 'a,tf 0 co 0 C� 0- CL w cL 0) (D c Cc 0.— C Co E cu :3 0 a- c u) c: c) cu =3 a) U) a E iF- m ca 5, m 0 CL 0 CU U- < a -o 0 a) E m 0 W-- > 05 0 L) a) .2 0 Q- 0 E a • • • • • • En CL m 0 :9 �9 cu c 0) Z co 9 A-- co > CL C 0 0 0 a) 0 0 m ca 0 CL-0 M m 0 o N ti O IN, "—I M E-+ W QD L- 0 0 r m_ a� a N O O � Q Q CD a �L O 0 C O -O 2 O C O O -0 Co LL 3 C �I 0 C C 0 CL 0) 1 �C Q d CL to N a) (6 CO L o �, LO � L a, a � 4_ L 0) N L (n `� rn to c p� (n (a c m 70 O N OL Co w - Q O V- Ql O L C _O 0.- -45 L (6 .c i a) O "a N O) - O� N ,� O n CZ T U co OL O 0 w c0 py'Q c co •a O LO c L N 0 O w O- O .Q n - _ O c N o to c 0)-O C C ..O N "6 'a m `•`_ 0 N O L O i L C 0 0 4 c to "�--� (p p L L, O E to N N L "O O to C 0) W c L' N C W� S� dam" Z L E 2 N 'D (D- O M O C N O U N d .-. (B C L (n N C4—.OW 7 V q) L Z- C4— (n � L Z N c O• (Q O co L (n � N .- E L ,. _ -z, (D y 3 L O O c-0 N N c N a _ C lB ca L O O7 O O- In L Q p a) E U(D C 3 ca "a cc �, O c C c C' o Q (o -r- U p L Q c E O� 0 (D E X pZ UJ pUj 0 c C N 0 O - p E N w N M m O O CL Z O p N N O E(D O (o U _ O yO C ( n c N U) O Q O 4N X o (n O) c6 = E � c U E L O N ° O O -p Z Q 0.0 v 0 "O a) N _ � 0 CU 3ai �' Co NLJ aU) a) � C0C: ai U0 6 ? C E L Q p OZ p U L Ca p M N 'p O O X p CO 0 ` 0-- U O3 �c c N O U U O Q_ CO: O U n p_ N O � L Q. O /m i cL c6 . O_ N- C - O O� � -C Q Q 0-0 (6 O" C " U 0 Q - -p N 7 c N " rn e co 0-- c m O� L O U .- U(6 (n c - _ O .c C c N m N O N- N O O c U .fl 3 .n 3 E E U T- E E M ti C N N O U 0 O ON N o O �i bq �7 O � �i M 4� E C-) cu 0— cy C: 0 N a) 0 cl a) a) 0 cr C W 0 -a 5 0 c 0 0 3: = -0 Cc (D .0 N O In Ll ON 4 O bq C, cc ca 0 Z 0 z ca a) of a) E E m a) a) -C a) E E Im C Ca 0 0 Oc CL C: Cc 0 , 5 0 -C CL -- E W 4) CC 0) 0 CL 76 a) -o a) 76 c C: E a) ca 'V 0 :3 -0 a- m 0 a) cL -0 a :3 a) 0 ca =w E 0 0 a) :3 a) 0 R :3 E 0 cu W W con D-Jo — CL 0, < -le IMF' m 0- cu S :3 a) 0 *0 c E 0 0 0 W 0 CL 0 0 0 0 C) 0 -1c cu CL o ca 0 A2 tf 0 a) ca a) co 0 c .L c E 0 00 EL U 0 0 w C) CL C: >1 ca >.m () a) a) c .0 0 -c a) M c a) c.) ca Ca :3 0 ca W E :5 z a) - 0 W a) LL o 7o E 0 -C :3 .0 > = — =3 -C 0 CU Ca .—'0 0 a) E En a) cu W 16 0 c- c C: 0 Z co) E > �j a) a) t = C W 0) C 0) 0 0 Z .45 0— c :3 E ca a- U) a) 0) W ca a) 0 0 0 > ca a) W Co ca -r- E Jc '-- — 0) -a a) -0 r - W co a) o a) a) cc 0 0) 0 a) 0 W W io W, 0) �a CD E w= a 0 m ca -r- :3 U, a) 0) W — 0 C;) V -r- cc C: � �c 0 a) r r- —0 o LLJ — m E — 2 m p �y -0 c E < a) 5 co - 0 U) 0 0) w a) 0 - 0 0-.Cr U)- m ca ca E a) -c m u io Z -Fu 3: 0) ca 0 2: c a) 4) 0) W c—: E E- a) 8) LL o n a) c D = !�-- E E 0 0 0 0 5 co -0 -C — 0 0 E c > a) 0 0 M Ca 0 cu c M 0 - 0 0 cL u > -0 cu 0 03 0 (0 a) m -,,e 0 C.) -0 0 0) � w 0 C: 0— E 0 -0 E a) a) Z'= 0 WU 0 N 0 c -.r- a) 0 0 3: -0 0) 0 --j C: 0 :3 m CL 0 - 0 M-0 m p c-6 E w ca a) -a m 0 < c 0) a) E 0 _j Z3 -- -0 tf -C &Z ca Z5 a) cu c :3 0-- cc W 0 0 C 70 > 0 C.0 C C 0 > 0 cu — 0 CL C.) IX (;D lc� 0 0-0 - 6 0 0 - r- cu a) CL 0 5 a) F2 - LO = E w 70 �= cu 0 cL > a) 0 te W" =0 wc :"3 E 0 z a) Z 0 ca) r p a) - C: - --,— -- 0) a) .0 C m 0 C: E W a) c E a) cc .j M a) a) Ca q 5 " — E —0 —ca 0 c cc >1 c Z �Q -0 0 a) W C 0— m -0 m c — .0 c: -2 6 - > — a) CU 0 ': O> -0 a) c: q N 0 0 0- 0 a) -0 cl C,3 z U) 0 0 0 0 (6 6 r� a) 2 Z, 0 (J) C: M 0 0 W 0 D w - M S -!ta—:=) cu 0 wo E U) 2 k- w -E a) -0 a) 6.9 in a) :2 U L 0 6 0 w :ER 0 w " -C . g 0 m 0 m ca 0 wo Ow .6 Z -r- 0— E < co 4) -c m 0 C) -a C: c — 0 c 0 w .2 a) 0 .z:, m E w t: =3 w E 0-() 0 w "0 E E — E w m 0 w ;Zs c E CU E n 0) U) 0 M'O -0 -0 M — 0— N O In Ll ON 4 O bq C, M H W N co CY �O O � fi C C N N O � Q 06 � Cl) AD .O c cr C O -02 O C O O 70 N I.D c G M O N rte., am O t0 z O o Q" v ao NO ral W rz z m (UO O O Z Z a) -C E E c L o a) E . E :.0 45 O >, IM i' L •✓ c)- 0 N O o C -C Q O O m m 7i 0) IS N wN m U 16 0) : Q a) Q E M N C ., i Q E C U a) Q_�Q :3 Co " o A E �w a) 0)=ci�Q ' 0 E t� o Q m Q ° ("Q Q U Q _ 0- cL N C C CL o 0 U C3 ,�. CL Lo Q m:3 : 'C U a) ca "C m w+ O.0U (A o o Ci � _T m _T U O � Y -o O a) ca t C a) m _ "� C - O m C T E _0 O .gym.. 0 m :z •"" (6 vm- Q_ C Cl N Y >' (a U m N S Q) > a) Co O (n a) C CO 0� 0 � a) Q �� 0 - U C cn L C 5 U Q Q O O E E Q) m Q N C U) 0 co m w- a�i U m C C7 a) m O 7 'Q "6 L w Cam(, C O _ ' W' m N O C (n .c i C -O U N C m C ` 3 a) M Y W aD N o C m 'omE W co 7(n 0 m c0 O Ln N � "0 � iQ� U ci N a) C LO �� 6 C' '�mmoma) 0p �3 "C 7 "O aicLEcU �mma��"' o- aEc � Q. T C a' C L Q' � Q A E g�C" C `rC-- a) c: O�a)iamo�mEom��C O 0 U m o U ICr U u)a) m m i m O C 4 = C m U (� N m a) --' -- a) O N C m C oo U N Q m-o 0 �_ O 0 "O m () G m U ° 0 W in u) aa)i W � >, -co c "- _ m 0) co O cn-p C - O m �MY� `-�., •� .- a) •MM3 ` m a) z a] O ..... C cN -0 Q � _= 0) a) C N O ,� cn o Q �' L N W 0 a) L y L O N C E C '\ m O J G in <.) Q e.. !A m Co 6 m Q C a) a) a) m U i a) . U a, - a) V C U a) o) �i 6i L O •✓ 0 u% � :i - C 0 d" m m m a) -C oM o a) o x ia0 C "C W m— .2- T Q) m m � C Y ao QE(n�c o -- a) � a) e 'U O m a O N <p U N 0 O O C O Co oLo O a)C'i ro' Coo m cLa �� v U) LLCO m o r n �F-N �Q coy El-) O °= c m Y N E cop "a O v 0 c) 5 u0) 5 v 0 v c U :2 p) O Q) C U C m2 � m o :.... 0) co 0) :3 - U C O o 3 Q W N 2 a) E • • ;.: m� m C 7 'C — w Q 0 m 'D � ,«L+ Q) E 7 Sc Q N Sc '2 OU u`Ji �' (06 aa)) � U U UO) o (n N M O N rte., am O t0 z O o Q" v ao NO ral W rz z M h W (D a r1 i a) a C C N O Od c C C � C -02 O C O C M ti CZ N N O Lo O ^' O O �i a0 � O N W "O O v T co N ° Z m a) a) C o U -C C O m m O Q U N Q� a) Q m cn° O Q co Q O '- Q Y CO 0 s IA 0 U Y o a :l3 a) c E o w , 5 . E O �... N U T O 'p c a- Q a) c 01 ,FT c "O C— c U) m O c OC N m 0 3 O U a) C ui c a) c O m a co •`'" C i C. C c �, ° is O C w � m c0 cA E .L L C- O m u2 a) •f U a) `° a N U c X = c ° m °� a) v () O ao �"u) � O p () N O O a Q° ° �, 0m o) cn •N m U a = c cn > N w `� O m CL O -0 O— ='5 N in 16 a) +` CL — O OU m N C a� ° -0� o O a Q O N c (� � N In L CL cc 0) co �� 0� c H— c U C C A N NQ�Qi� Y0- c N ai c��uiU)0C: °- m 02 `) -N'Fn —0 c N iq 'Fna cu a) ° m c c -q (X a�i°��c° ° 7 C C O m U (� C m C T° 0)� fU: g a) Co L E N U •C- O Co m C N c �+m p ¢ U Q� O a) Q 0.o C_ m a) c-0 E �w j O)O m U C v o Co ° 0) c O m O nQ )°c"O C a) a) "- - to - "X N � p C L3 U O c cn 'O a O c cn w •- "O m c `- '�- o ca °, N C O c c ° — a O m O G O O N .- N U O a) C- p �' ° Uj U U 4) m N O m O a) X. (n ._ U w O mU° ° �m ° N w- m �' W m'� ° >,� C ��m E ° c�i m �° m ��m� a).LU U >, 3: Om�� a) O TN co (6_ > n�n''U)aa)i0 -(D a)a)co -- °ac) �a a) -0.O cC��+ �.`-. ��mL N 6 Tc a) E a) rn O °- U a) N s) T c m c) c STUB y _ a) coo U O— N m 4) w a) Q U — -p � 0= j cn U�-° U c.0-- o C m�'r.mn =mn a C N m c N C H L ZE - a)m °c�E «- cchNO� U Co N N U�a6 Q) c c cn w W cs. m C m .c to Q• c Q a) X <C (n 3 a) — < CO 4) co �•. fn >, ° in cn ui O- M C U O m c ° m c c (D cn "-" a) C N a) =3 � cn O .0 a) O O v cn a cn m co N C E O .` c a) m Q E. cn a) • • • ami O O c O N U O. O O aD O> S g C. 0 C- E m 0 0 0-0 — C. m O (n Q 0- -O M ti CZ N N O Lo O ^' O O �i a0 � O N W "O O v M H W cu •—� CY Q �ffi W c C N q) O Q 06 cn •O C O O O 70 `V I ) L� to � c tr O O C N N E E'— u) c N N O c6 ..; �'a '0 _a) Oil) Q �Q c6 C Q O Y ca CL m r c0 a � 0 CL p C3 L L O cp C N O ca i C Q O CL C ca °Occ E� _� U U t1i O Q) M aL-. (D Q) ,� p _ �_ U) Q1 tq c6 cn O -p = ca co c N �. �. �� 30 emu,.. Q�ic� cca >�� vpi or�Q �;��_�cu Q° Z cn cn 'S p � i cQ I-- c6 M c6 N 'C = O (n �_ c m c c UI C (a U) c "�► to p u 3 O O ." T N N .L O Co c 0) N C N cn p V sT U c V Q 3 .- = w cD Q Q "c �_ N Q) E. O pi = — g U N o O U_ p (n O O 2, a,) to N Q. N m 'a 0 c Q O� 0 O Co Y co C .� m N> V O -p O 0 0-0 ., O O CL C3) O O O 0 O Q) -p p) N p N O N cu �C: (� O /yW U N — U O O 0 C r Q.N L O -0 O O fU C Y O�� .• Ln N (6 co .� Q) O� T cL p O N c6 O O co O N� 0) (U — (n >; 'C Q` i O E Q c C (Q y= U � C '� (n N 'O =i- U f0 ?i (� N c� U C U c "a 'C O p cL6 O O �p N O= p p N e-- �' 6 tT{ ],.c O to O _ O_ O U) c M N Q ca p) C N Q. .` 0)-o m cn 4— N O �( G[ C L O t p O N � U O N O O p O cB p u N a) O O a) C o N cu t- c p n -c _ 'p ) c0) U 3 O a) OO o E w O C O p)T Q) OQ O .Q 01'— c O Q-C p C a M O ym Co O a) N Q. F L w "p O O O a) O C C (D O c p) N c r- c6 p U j co ca CL O N a) can M C N N �C O u V blo Q O by O :z- (z W ,b0 c, en E-0 0-mo E co cr 0 r�Ii cy, 0 N O 0 a a) (D U C: (D — 0 0- W 0 705 0 c 0 0 3: �p -0 M (D O a O bq tII CU -0 �: o E N -o (D CU CO = a) CL co t: � 7a E 0 0 IM= .2 z 00 -W C E 0 0 tL 0 CL 2 > 0 C c C: S a) 0 W 0 (D ID— 0= CU UM) E Z6 CO a) 1� 3: 0 0 (D 0 > CD _0 C20 la-) m CO: >, D 75 E Q- :3 4) 70 >,.a) -0 co CL -.r- E— cL— — > 57 Z M 0 cn — = uj 0) 0 cf m a) - - W (D U) > —:3 02 — 0 0 0 0- c: m 0 - a) - 4) ca m `-mooin -c-�.,-- 6, 2 cl- Q- co — cc �c 0 n ca c 0 00-0 —(J) 0 — 2 . E o a) =7, Q- E E -0 — M 0 0 0,9 U) Cl — -0 "D 07 cu a) w , C cL m E > M b, cu > 0 >,mE c >,ca a) — 0 = 0 co a) A= E 22 a) Co Wr- — N .— — — �5, OZ C CU M U) L) — C a) 0 > —0 w b -0 Q- CL M M to — — o a) cc 0 z 0 C:s 0 U) > co 0 cc C: —0 0 CO -C a) C ca 0 CL 0 a) (D M -1 0 - 0) >, M -C 0 -0 -o wa — U) M >, CL > CL C (D -0 0 7F. 'a E c -o u) a- q ca 0 -2 0 .Oo a) .0 CL 0 0 0 m 0 1 r% a) a) (D — (U — — — m o — "0 0 3: :3 cu 0) a) C: (D 3: r a3 cu 4) -0 C, a) u) C_ E a) N 0 4) E cu a cL— m 0 0 L 0 m c > E� o M 0 W M m W -0 C M 0 (L E (n Q M 0 a) E (D O.C) lco E a) c: Q) a E — — — cr cu (a a) m 0 Cma = C)- C C: 0) :3 a) -0 � - 2 Q) 0 Q) -6 (D -0 >, 0 ca 0 0- u �o L) -0 r :3 in 0) >, Co C =3t 0 — a) IM cr,Fn a) -0 015 a) I-- CC=— en C a) C C: a) 0 m U) -o (D M —a) --- C L LL a), X cc >, = 0 U) E >, 0 0 = c � E , -c -.--a �o — ca wc - c U) a) E 0 co o 2 co - U) a- 0 " 0 0 (D 6, .0 --o cmn om 0 23 5i vi cn C *0 U) a) 0 >, a- - 72 �2 E E O-o o w— c cL w U, cr a -Fu a) 0 a) a) CL m Z6 -C: a) :3 Co cc a) > > i5 .2 > C o) a) ca a) -0 Q 0 o q-- -C c CL 2 -;- '5 cc Q- *Fn co 0 E a) 0 ca 'E " 6 " c Co 0 CL a) ca 5 0 0 w 0� M co c c a) M 0 0 0 -6 C: 0 CL CL 2 - a) 0) x C� m -r- 0) CL CL -a(L E 3: U) E -0 -C c E a) 0 U) " cc 0) ca CL Cu 3:3; o w w m 0 cu E m ca ca Z' O a O bq M H W cu CF N O O Cl C n� 06 V .O c O '"D2 O C O O M ti C N N O 4 C ^r by r O O to W '� o U) _T > m to z m m a) w u) (D p .- T c L w- OL Q ( O (a c � QENmvc) a) Q. M Q. N U 0 0 m m E m Q Q Q U Q Y m °- M 0 L Q 0 CL O _T U a. Y L d r- �! c N O L CL CL O E C �w c a) o m L N vN Q) 3 a) -0 c c o E w E T o = c m c o �07 ( ' Q c c m ° () Lc c - Y Co ar a N c o O- CU S 0) O c a.� — —O Q- Q O O OL n i Q> s Q c �� c a) > cu u m a =3 -0 � c E m 5 m -0 E2 E (M m a) 0 em C: -0 (n Q) o m E m m Z c6a) o o O m O L ) m aQQ O a Z O � L i > o c :E a) c m W �- 0 0 a) m a ` W M O a O a) O O 'a N 'Lm _ a) 0 - Q) m q 1 c -0 O m m m U a — o m LQ Co C c C4 O m O 7 :3 'a) n a Or L- O N M V c Q �o m O N (o�U) rl rn E(n C: . Q) 0 O o E w N U Z Q , >p O O O L O CL, nm aQc 0o3"a°m =3 L o c cc N :3 o c �c- m (D N o O mEmOaO °m >C7 - E c� m a) m u m c �m` in ) Y m u y �C: � Tc» mi c O a� m a) mE a) U) .2) Qi aX°O L u° �aQ o� UmEuini L N a o c N m m 0 m�0 m m m m m a� E O mL m �a) o"- T, E� ui �'> I c L c CL— cu L Q) c QE m o L ELEEa)a)n I— ,�U: -.EL m mo._, =� E m E UL 3t— m oID o) m m Q �g > M ti C N N O 4 C ^r by r O O to W '� o M E-0 O O 0 N (D ry CL C) cf) (D cr W -a 0 0 3: _0 (D w In Am 0 t:+ C: 0 0 cu 0-1 l4 v tII (%0 lz ca 4) w 6— : I ES 0- a) ca— a) a) ca ca 0L C.) .2 a ca 0) q .0 • a) -0 E- o -a E ca t: 0 a) -0 CL -a (D 0 0 0 CU m E 0) CL - CL CD < 0 W-4 ca IL V- 0 tr 0 0 0 >1 A a) 0 U) -0 a) -C 75 0) E 'a .2 ca cu c 15) 0 0 0 0 t a) E Z cu - c L COL W- COL E 0-0 N 0 E .- .- 4= -- --0 ca a) 0 c: a) 1 a) Liu - a) CL 0 - C13 0) m = (n -2 3: EL 00 --0.- :5- w ca a) -a U) o) = -� E < 0. a- m US (u C") a0.7 W. Z - 0 a) U 0 2 U) (D CO r >= ,. a) 0 - E E w 0 > 0 0 Q� :;-- 6 0 cc E .-Q U) 0- L) 0 0 cu :3 - o< >,ca- u) - - CU CU a) t-- .0 CL , - M-O 0 (D 0 c L) c: cc �6 U) cc lz ca , cn cc U) a) 4-: :C/3) -' � 0 a) 40T —C 2 ED CEO- IS) 0 N MM 0)-Q - - L c c a D-- 0 0 r: 0 0 0 _0 CO m :t-- Z 0 3: - E m -C 0() 0 0 -, o t 5; -Fa E a5 wON < E to 0)2 (D .2 a) > 0 a) a) 07 a) c E 9 w 0 W 0- CL :2 0 0(n E u) (D a- — 0 c > • 4 0 0 05 E -0 co U) a) -D > 0-0 � 0,0 WOMOWCOOM.0- in W p 0.<OMO-OCW .- (D - a) - M �5 0 _ro_ 0 w < c (D U) 3: *�, O.c --OocE -tm 6 E 0 CSI '55 C mL L a") c Y+ E . a 23 c (D cn �O *0 .0 - r- W M w U) w U) 1- -0 O 0 U) U) V 0)= a) M t a) 0 -0 a) --) F- c 0 U 0 cn a) 0) O CL C: U) E O c: 0 6) (D a) CL .0 C: - CL 0 2 E 0-0 -0 - — a") "D O W a) 0 0 c •` c 0 0 Q c 0 0 CL N Q Ca 0.,- a) a: 0 -e- .2 cn C-0 CL 0 a) -0 v) c, E a) 0 0 -T Co o cu 0 r- (0 CL 0 0 a) . E (n U) E F 0 ,r 0) m c 0 a) Mc - < - (D "0 (D .0 M U) C -- .2 a) to < c -C m 0 C (D < 0 -C 0 E 0)-b 5 - :3 cr —a 'D a) 0) -C a) 0 0 (D 0 o a) E > a) - 0 c m m - 0- c 0- 0 M 0- (D -5 C 0 = - 0- 2 - 0 C c m 0 =5 J_- 0 [p c 0 - 0 o 0 E m a) 0 0 (D a) 0 X 'a 0 CU CU 'n - .--a C: 0) 0 c 16 E I w c c 0 - - -0 0,0 0 0) cu -,5 cu a) E a) (D E E 8 2 ;6.2 0) c a 0 c -C a) 0 0- a) 0 0 - o w 0 0 o ti O IN O CL� to z bA 4- O �tz I E cc O 0 N CY, C c: 0 N O 0 a) CL 06 (D 0 cn 0 cr W 0 _0 5 0 c 0 0 -0 Co a) ti IN, bA E s3 -E 0 0 CL 0 c E o E 0 (D D & CD (D E E ao C: 1: co 0 E (D co 0) > 0 M c :3 U) 0 T (D -a) a) 0) CO C: Co 0 0 >, Cc a) cu I OM C: M > Co U) E 0), cc 0 CL 0 c C a) (D V) c :3 (D 0 o (D cn &_ 0 .0 0 a) --r- cu M w C� 0 - o 0) 6 0 c .0 ',5 4) 0 c M c E (n ca M Z c a) , w E 0 0 (a C= 0 0 M 0 CL 0 — W-0 o cu E U) cO co 0 (D > 0) E =3 a) :3 0 0 a) " CU 24.1 0) CU a) U) -0 0) (D 0 a) (D CL (D cn =3 _0 U) 0 E 07 0) r 0) co E 0 u) > . > E 0— -C o —0 'Fn =03 M M o a) 0 0 C: a) -- M — " E w 0 0 0 — M (D U) (h EL a) co 0) :�: C, 0 o 0 (D 0) -- a) 0) a) w U) (D G)W (D 0 0 Cn co 0) E 0 c 2 M > 0 -0 0) a) > 0 0 c 0 .— cu o E N — :p CL 0 0 cn 0_.,- 4) co cc u) 0 —0 0 0-0 >, a) -0 a) 0� 0)= 0 - a) 0 70 = = Co 4= cc a) 0 3�. > CL 0 IM 0) Z, 0) M 0 0 2 E w.c CU 0) -0 -C < " -0 M E a) 0 (D 0 a) (a r- pines 0 — c M N f6 0 =3 N a) O 0 —Cu 2 E a) cn o- E a) 2 0 M M —U) r- a) 2) cu '5 0 c -0 Gj US M C: co a) -0 01— C: 0) =3 21 N —2 E (n co U) U1 a) u' n Zn - a) u) cu E -0 ui ui > Q) E N 0 -C cu a _0 a) in o -0 C: a 0 cu c 0 0 0 E 0-0 0 C a) CL 0, a) 0 0 'Fn 0 0 Q) a) -0 (D U) M co CL 0 4— 0 E �e 0 V' E �e 0) U) C a O O ti IN, bA M F--4 W.-d -F� E C.) O a 0 r, � U. N (D 0 Q. (D U, C: 0 cr C W 0 70 5 0 c 0 0 -0 3., = CU (D ti O 110 O to iz, lz (z (� -Z E 0 0 o E o CL cn E co: -C 0 3: C: a 0) :e 'D C a) E 0 a) CID 2 �2 =3 >1 0 C) C Co C 42 0 0 r- (D -C = C: (D a) -C _0 — 0 Co -!= :�� 6 "2 co - o Cc: 02) GO) CL) 05 o a) CO 52 6) (D co 0 :E E p- ;i= q) M 4) C— CL �5 Na N CU c 0 ca ca 2 .� =— *Z6 � �5 U)'C (DO d :2 (6 fn E T — �z 0) a) ca a) .::� ca m 3r co 7 a) -Fa o o C: a) 2 0 0 E (D a) CU > -0 n:!-.c .R c Co > tt= cm C,E - - E x c CU 0)- 0) a) r- o.2 '� Q 0 co — E c m .0 co 14 w 0 CL 0 0 3: .2 w Co 0 W " Co .> - t 0 =3 - — C 0 mc 0 DL m U) 'n :5 4? C.) 0 c 0 c = m a) '— CU -0 C) " Ca LD 0 a) U) t 0 o U) =- -tz 0 cn 0 'F5 E a) a 0 0 C= 2 m 0 - a) 0 (1) 0) 0 o 0 q 3: a) 0 0,4-- .— . cu a) c .— :3 c 0 0 0 a) CD CC -- _0 — r- o E CL CD 0 � co a) m 0 —0 OCL.E Z CC U) .0 Co 0 - �S U) z 10 ,on 0) -0 — — -a -a.2 CL — C: 0 :E cu CC o — - CL 0- a) a) 0) 2. ig — = c M " .— a) -� cn C: c c a) c a) 0 rZ CL, m > M co 0 CC 0) w " = (D CU W c > r_ 0 2-0 0 a) .2 0 a) 0 := CL E 0) fn 0-0— m 0 c —ca 0) Co 0L - (D c) Q. 76 3: -0 L) E w CL c - cn D- o o " — C: Co - *0 0 c (D 0 Qw m c - g a) :3 0 > a) C _0 (n 0) C: �g c c :3 M c 4- (D m o 0) -6 '2 C: a) cu E N co.o-(6 0- -0 cu > 0) CU 0-0 - a) 0 cu 0 > 0 — E a) m > :� CU m m cn -0 E 0.2 Cc:y) :33 cQ 'Fn 0 (n a) m 0 0 CL E CD 0 0) c 0 c 0 0 c 0) " m 0 a) 0) r �6 a) .0 o :3 2 :t! w 0 ti O 110 O to iz, lz (z (� -Z E 0 m NV- V- (D 0 Q. (D CL oes (D U) C: cy 0 cr C W 0 _0 5 0 c 0 0 Co (D ti O o o C E C 0 0 o,. 0 C E o o E 1 0 75 -5 a) 0 1 Cc: a) a- 0 3: L o 0 - 4)� 0 C: V CO co 0 0- C: O 0 - 0 o'- 0- -0 w E—E 0 wD .0 -Z! a- U) 0 Co 0 0L 0- 3, 0 5 Z5 � 0 - , (D 0 CP 0 V tZ 0 - FL 002000 -Fuut-t c O)o 5; UOL - > -O)a)a) 0 1 E o -D �� C'C 0 C (a a.2 coo 0) 00 .0 -a) a 0 C) c: I C - . Co a - 0) 0- w a) 0 CL 0 E ca 0 a) 0 O C: CU I If 4) 0) O U) S a) 2 .— c L- 0 c: m C -a -D 0 C> M C: -r- w 5 C2. - > a) ca - 2 p p U) r- w w -2:� 1 0) E = C: - .0— a) co m 0 &3 E co u) a) O)o -c: M (D a) cu E CU 6 0 - L�- c: CO 0 E u) :3 -5- 0 o E C: a) (L 0 — 0 m cr 0 D m >, c - 0 -ia 2 L) .2 �5 a) E I � -0 a) -C > 2 cL a) E cc E c a 0) 0 L m E o 6) -C Co 'FA E c o) r a) 0- o o 0 c co .0 cu o uj M 0 a - u) 75 A: "a 0, 0 _0 (n -F,4 1 -0 U) --0 a) CU 0 E a) - - - a) 0 CU I a) CL� L) 0 O, 0) =3 -ffi —(D 0 E aw) >,-0 :S.9 C a) I CO 1 0 U) M ---a -a ca 0 a) "a -- - "a E'S 3: CL 0 r- 0 I E C -o CU -o 'M oT 0- C a) 0 c C;) a) C,_ o - W 0 > c T Co CL 0 CM - 04--0- o a D 0 cu 0) U) — M or Co C: '�6 c 0 0 a) N m 2 U) CL E cu U) 0 E .2 w 0 - 0 -F, (o co U) a) -0 0- 5 U) c C: - a) m 0) a) w 2,5 U) a) 1 0 0 a) a) 0) -0 w 0 E 2 0 2 E co -d 70 M a) 13- '0 1- a) Mcol- cn 0 0) -0 U; -0 F 0 C5 �w .-= U) CL 2 w m c -0 0 cu m 0 'M -2rm-.cm-co2 Mo C: D 0 0 c: c CC 2wrn 0 1 I - 0 E -0 M (n 0 CL 0 0 n, CIO -a m 0- a a) U) 0 0- 0� "a — 0 0 E a ti O o o M W C: c N O O Q elx a� CO •C �C: W0 O C O O -0 N LL5 6 M 0 N O Mm o o bq � O ti Q N W� :N T ill • j � w U a3 Z � m N :E a) ... E C L :f: O >, L C a) ._ w- V CL ) M �:Y (D = (D aS w O U C2 . m C.2 C�L-- 3 Q � a) U a, = Q-b Q U - Q ca CL a) d+�+ c L E © fr 0 CL "O DC >' U 0 �Q CL or E _o N _ O p >' O C p cu ZT >+ «L TON) — O Op Z E ,tea _ CS L CO 3 a) w 3 T a) O Cu t3 L C> L �_ f0 to L 3 'O -.0 Q) 'D = O �- s m C c) ccu to a)� v- � N 0> E E cn o i/1 i} �" E Q Q 41 E 0 -9 a) .� V 0 a) Ca O cc U) : a) (� CO 0 cn V .�.. O C2 O N to c - 00 LO a) 0) > C2 a) N O ,� ,4) � co ia) W O v) O N 'N a3 'O 30 a) -a� vi m L> a) O a) u) C a) ai L g,. cu n' ca " u 'L (6 = a) U a) tO a) O O O 0. N o-0 4 c m E� L E o� c a) N j� C— o o c E� �� <( o �a) 0j0 o O N a'Q °> �._ a)L `) L N O >� m o CO T-�cu-aa) `� "ccu3 (n %4oEc�uoao -com Q C cu 6- m 0) O C2 O a) In O, . co a) O E (n i O a) O � ,,,_ Q -C C> L � L - a-.. -0 a) a) 3 'F3 'cp Ri O C W -p — N O a) N O E 'p N 3 a) 0 0 m E 2 .-. C c J O O E a) O N a) — 0 N O C �_ N m N J to 6: O N cu a) O O 'o OU a) a) E i C '� ) C to - m4- C C O '= Z C 0 O a) E� cu� O ai LO w C a) O "F W 0 ui � a) a) N Q O C2 O a) cuE U)x >a) o L o N 'o `nEo a) N a) O m C a) a) '� T O C � N U 0 U 4? a) 6 cu Y N L_ v'- O" L O 0 N C2 N L p..0 L a) L C2 c6 i () C V` C `� O- C V U 0 O O CL e•- E O Q •"= t6 a) O ro- O 0 a) 3 3 0�� C o a) L O cn z .,C O '- Z a) >S >i Cn � L CL U Q N N �' .- O. O O E O O cu O Sa) M 0 N O Mm o o bq � O ti Q N W� :N M E cc a) I- .60 0 CL CL N a C: 0 O 0 a) CL 06 (9 a cn a) ip 0 cr C: W 0 _0 5 0 c 0 c CU a) A O ti a. O O O O 91 1 1 0 6 C E 7 0 E 0 a c 0 CL O (0, (j) -c E a) W>,76 , >, -§ , 2 0 0)10-- c m -0) oc T co -0 ai 0 := 1E D 2 o 0 c m C O -i5 a- V cu cw FD E 4) cn c —0 0) -xi CL Cn =3 E ol 75 C 0-0 0 46 o 0)_C (1) 0 -0 C: CO C 0) 0- S () 0 U) c 0= m 0) 0:5 0 0 c Tc U) g) L) E- CL Q Q) ca (j) (D c: (j) -t-- 0) 0 c: N a) 0) �o a) f o — E5 -6 to ca E ro- - M 0 C C 75 0 a) C 3: 0.- -5 �5:22 (D a) cO -r- E c ---a 0 US 0 o 0) c — -0 < E 0 co -!= 0 a) -0 a) N >' — — 0 co o m m -0 0 0 0 0 w 3: CO 0 a) — - -0 '0 -6 .0 0 a) "T -0 0 m > (D 3: X 0 0) a) c cu a) -0 a) E— ca cO (a C) 0 �c a) -a u) !z -0 C C) 3� -6 0 0 0 0 B c C%j -0 c (a -C I-- co o C: co (n CU a) (D COO CU�0.0 CDu) 0 .- — 0 (0 0 0 0) C 00 0 0 c,) 0 4-- — (D Co C,4 (D 'FD -j6 E a) E 42 4) 70 E a) C: U) (1) a) 6. r Co (1) a) I a)< a) C) C: (1) to C U) > a) >, c ca r- 0— -0 -- -Za (1) 4E (1) U, cc = .5; 0 E E cu o-(D cL 0 a)-O 0 0 o 0 c) C- (D z U) - - CO IE c E 0 0-0 cr 0 0— 0 - m 0 a) " C.-,) . m !E to —.r- a) (n (D (D a) CO 0 -0 5 u) - c,) a '§ .— -- 0 (D -0 -ia ca -- >1 0 o m 0 m E Ix a) co > ca m a) a) a) .— .0 X - (D — -- > > a) �c 0 0 c 0 Z 0 U) 0 C) o o >, _0 2 6 cu 0 0) 0 W-0-0 ca :3 CL —.0 c 0— 0).t-- C: (D 2 ca 0 0--ff. a) 0-- (U c: — C, � c -0 to CL C: 0 f E !E 0 CL -0 w E -0 '6 >, c :3 .2 10 �5 z m o)- 57< -0 U) C: 0 a) c 0 x 3� M < 0 ::� () E C: -0 a) CL W 0 CD 0) 0 0 -�5 a) r- M C 0 " U) -0 '0 '0 c c — c ig . 2 o cO 2 0) cu E 3: 0� . U) --o 0 a) (D a) r . 2 6 c=nl -� CL 0 (D O CL M :3 0� 0 0 0 a) (D CU .0 cn 0 0 Fo m c 0 C - r- -6 cn,§ -,- a) N (A > CL = M 0 m 0- 00 0 A O ti a. O O O O 91 1 1 0 6 en W ca v a. 0 v � c c N O O a� �co v O cr C W O -02 O C O O I.J.. .2 i� M ^v C N N O ^^O �V O O � O W "� o N 0 0 Z ca 4? L a) O a) ca a) C E L Q O a O • w W cQ Q) 0) a) ca co .2 0- e U- ` w ca C C E m cu U , = n Q :3 Ca 0 (n E Ui Q L 0) U '- Q Q Y Y :P4 �:.. co m IL ri D N °C a 0 CL 0 v C Y n o Y IL C G � w E Co U C _0 C p O M Z O O U ' E O O a a) L U U) a) N a) O N O U QI C Q C L� Q co C ai C a) a) O -O (7- O 2 O Q 2-0 to U (D a) O '� a) C L '.'.� U (n .L.� � N E a) C U 4' '� .o O �) O C N O C_ C Gt 7+ O O O O O i N O 2 O w_ W LL O U) C N O U L O L (n Q O _ U) 0) Q-us,� U �OUOQmcaE�� W N a E O �0- o n� C 0o o O o °� m Y= r Q E N E C 4 Q O N-0 C O 0 N N M �' w~ N C N O .D C 0 O� O. m Q E ca t3 s� Q � 0 N c a) (n W 0 O rn _V) Q U (D in co - U C Q on O O c6 C OL U s�sLO C) 0 �- a) �_ rT a) "- '7 O � U .r a) N ca a) a) >' u) Q a) L O�`�o�`� mcaa)) ccoo c `maoi°� o LLB Co — N ,��°� L m (n C z V M C Q 0 O a) ca E O 0 M z L u t? N Q ca U a) O (0 U1 0 O Q) p N Co (D U N O + a) Vi N '_ O C M U l a) p n O � p p O n a U U O O ) N u) co: C M O V r a) N = a) O O O -O N (UN n QUQ m az (n U) 2 _0 6:2 O U n L (m O oou 3 X ° Z6 M ^v C N N O ^^O �V O O � O W "� o 4-A E 0 cc (D L- .60 0 r l • • • • ti O O no �z Z 2T _a CO C3 ca 0 Z 0 z a) a) ti- 0 *(5 0 a) Q a) as -C z 2 t.-: z - -E C: (D 0 c Ca a) CL 3: a) c 0) E a) E a) CL CL 0 _r 0) p E c K =3 0 c 0 0 0 -0 z 2? = .0 CL =3 a U) 0 L .2 c C: 'a > ED m 0 ca 4) Cc .;,- E -0 M 0 :3 7a c m 0 0 (L 0 �O C13 C: > m 0- ca oo c 0 0 0 0 CL O 0 W C) 0 C ,44 E (U CL M ca (1) 03 Q a Q CL 0-- 0) c CL E ca 0- a) E ca C: m .:6 .9 ,,CSC .:3 c c =1 c 10-- m 0 r-L E Ix 0- U) U) 0 -02 c w -02 c ri) co 0 (U ca ca (a 0 Q) 0) (D 0 16 cL U) cu a) z_- c (D cu CO '0 -0 0 =3 a) E () ca 0 a) a) a) CD M 0 0) Ca wao -0 -0 0 :E-: 2 c �D �c a) 'r� C: 70 70 a CO =3 a- ca - I- -- 0 = E � V5 m a) Ca (n 0 LO a) a) W -C cn Z5 r- 0 0.0 C: E a (D U) Z 0 0) C CO 0 w CO U) cn C: 0 > r- 10 a) to > -- -C (D - a) :3 -o a 0 w T Lu T 0 c" to 0 (D a) ..0-0 U) N 0) 0 — (D - '0 z o 0-0-0-- - - - C: 0) 1- - 7= t-- — >, o o 0 C.) Q� *V5 0 -0 = 0 -le 0- — -0 (D >1 0 LO Q) Z5 -r- (b a) 0- cc z 0 "1 c: m -C: -C 0 a) < CU (D a) 0 I;Z 3: - cu a) E a- 0 Z.- tp- (D - ui b cu -0 a) :i-- C, 0 a) ]�- E a) U') ;4 0 L) - a) C a) a) -0 1) C-1 C CD '�5 —0 -0 ') E '(�, a) ca a) r_ > Ox-- 0 cn N LO r .— 0 1 0-- 1 0 "ZC LO CD cc 0 -0 a) U0, M- ICU- 0 �,'t cL,!:- cL 0) 4) - = in - 0 CL (D CL -Fu E a 6_ -- _ -0 M co co ca — :3 a) a) 0 4) - 0 5 cu E E 6) :zt 0.- C 0 "Z -E 0 IL CD X-- — 0 0) CD -- 75 -0 -- a) a) Ct3 a = 0 = -0 ca Ln — m -0 0 a) 0) a) C: a) =3 5; 0) c: 0 :5 �c L) 0 (6 CN 5 W M = I-- C I- U) CU CD � LO (0 0- (n E c: < 0 0-0 04 U) co 0 Z m .-- 0 � $ L 0 C LO 0 E p c M LO M 0 M (DV-- 0 0 0 m m 0 0 0 - -r- 0) CL.g = Q) (D 0 M- 'Z� 0 m 0- 0 0 o) ic 'E a) u) 03 := - 0)0 Q) W CO '- T W U) O�jp— " '-- 0) C 0. cn 0 0 c :t- 0)- :3 - 0 - 0 M,c — �g co -0 m Z3 t Z, I- U) 75 CL a) U) 0 (D ?. m a) -5 44)) 'a . a) Q) U C: a V) 0-- c 0 () . V) r 0 a CL — U) — :F; k 00 61 �� -a � C', - 0- m m m m U) 0 D ti O O no �z Z