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2014/09/11 Planning Commission Resolution (4)
PLANNING COMMISSION RESOLUTION NO. 2014-32 A RESOLUTION OF THE PLANNING COMMISSION OF THE CITY OF ROHNERT PARK, CALIFORNIA, RECOMMENDING CERTIFICATION OF THE FINAL ENVIRONMENTAL IMPACT REPORT, ADOPTING STATEMENT OF OVERRIDING CONSIDERATIONS, AND ADOPTING MITIGATION MONITORING AND REPORTING PROGRAM FOR THE NORTHWEST SPECIFIC PLAN, PREZONING, GENERAL PLAN AMENDMENTS, AND ANNEXATION FOR THE NORTHWEST SPECIFIC PLAN AREA LOCATED SOUTH OF MILLBRAE AVENUE, WEST OF DOWDELL AVENUE, NORTH OF BUSINESS PARK DRIVE, AND EAST OF LANGNER AVENUE IN SONOMA COUNTY, CA WHEREAS, the applicant, the City of Rohnert Park, filed Planning Application Nos. PLGP2014-0006, PLSP2014-0004, PLRZ2014-0003, PLAX2014-0001, and PLEN2014-0004, proposing approval of a Specific Plan ("Specific Plan"), Prezoning, General Plan Amendments, and Annexation for the Northwest Specific Plan Area ("Project"), as well as certification of an Environmental Impact Report ("EIR") for the Project, in accordance with the City of Rohnert Park Municipal Code ("RPMC"); and WHEREAS, the City retained P1aceWorks to prepare the EIR pursuant to the California Environmental Quality Act ("CEQA") for the proposed Project; and WHEREAS, the City of Rohnert Park, acting as the Lead Agency under CEQA, published a Notice of Preparation ("NOP") of a Draft EIR for the proposed Project on June 7, 2013. The NOP was distributed for a 30 -day comment period beginning on June 7, 2013. The City then initiated work on a Draft EIR for the project (Project); and WHEREAS, the City completed the Draft EIR on June 20, 2014 and circulated it to affected public agencies and interested members of the public for the required 45 -day public comment period, from June 20, 2014 to August 4, 2014; and WHEREAS, the Planning Commission of the City of Rohnert Park duly noticed and conducted a public hearing on July 14, 2014 in order to receive comments on the Draft EIR; and WHEREAS, on September 8, 2014, the City published the Final EIR for the Project, Exhibit A of this Resolution, which incorporates: 1) the Draft EIR; 2) comments received about the Draft EIR and responses to those comments; 3) changes, clarifications and corrections to the Draft EIR; and 4) appendices; 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 govern the preparation, content, and processing of environmental impact reports, have been fully implemented in the preparation of the EIR. WHEREAS, pursuant to California State Law and the RPMC, public hearing notices were mailed to all property owners within an area exceeding a three hundred foot radius of the Specific Plan area and a public hearing was published for a minimum of 10 days prior to the first public hearing in the Community Voice; and WHEREAS, on September 11, 2014, the Planning Commission held a public hearing at which time interested persons had an opportunity to testify either in support or opposition to the Final EIR; NOW, THEREFORE, BE IT RESOLVED that the Planning Commission of the City of Rohnert Park ("Commission") makes the following findings, determinations and recommendations with respect to the Final EIR for the proposed Project: Section 1. The above recitations are true and correct, and material to this Resolution. Section 2. The Commission has independently reviewed, analyzed and considered the Final EIR and all written documentation and public comments prior to making recommendations on the proposed Project; and Section 3. The Final EIR was prepared, publicized, circulated, and reviewed in compliance with the provisions of CEQA and the CEQA Guidelines; and Section 4. That the Final EIR constitutes an adequate, accurate, objective, and complete EIR in compliance with all legal standards; and Section 5. The information and analysis contained in the Final EIR reflects the City's independent judgment as to the environmental consequences of the proposed Project; and Section 6. 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 Commission'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. Section 7. The Final EIR identifies potentially significant effects on the environment that could result if the project were adopted without changes or alterations in the project and imposition of mitigation measures. Based thereon, the Commission further finds that: (a) Changes, alterations, and mitigation measures have been incorporated into, or imposed as conditions of approval on, the project. (b) These changes, alterations, and mitigation measures will avoid the significant environment effects identified in the Final EIR or lessen their impact below the threshold of significance. (c) These changes, alterations, and mitigation measures are fully enforceable because they have either resulted in an actual change to the project as proposed or they have been imposed as conditions of approval on the project. (d) The City has prepared a Mitigation Monitoring and Reporting Program to track compliance with these changes, alterations, and mitigation measures. BE IT FURTHER RESOLVED that on the basis of the evidence contained in the administrative record of the Final EIR, the Commission finds based on the information submitted following the conclusion of the public comment periods on the Draft EIR and following the consultant's responses thereto that the responses to comments provide clarification to the information contained in the Draft EIR and do not describe 1) a new substantial environmental impact resulting from the project or from new mitigation measures; 2) a substantial increase in an environmental impact; or 3) a feasible project alternative or mitigation measure that clearly would lessen the environmental impacts of the project that has not been adopted. The new information provided in the Final EIR does not constitute "significant new information" within the meaning of CEQA so as to require recirculation of the Final EIR. (CEQA Guidelines Section 15088.5) and such information does not change the analysis or determinations of significance of potential impacts. The responses to comments demonstrate the Draft EIR contains sufficient mitigation measures to minimize or reduce impacts to a less than significant level; and revised language provided in the responses to comments is intended to clarify the required action and intent of the measures to ensure compliance. BE IT FURTHER RESOLVED that the Planning Commission hereby recommends that the City Council of the City of Rohnert Park ("City Council") certify the Final EIR and direct the filing of a Notice of Determination with the County Clerk; and BE IT FURTHER RESOLVED that after considering the EIR and in conjunction with making these findings, the Planning Commission hereby finds that pursuant to Section 15092 of the CEQA Guidelines, approval of the Project will result in significant effects on the environment; however, the City eliminated or substantially lessened these significant effects where feasible, and has determined that the remaining significant effects are found to be unavoidable under Section 15091 and acceptable under Section 15093; and BE IT FURTHER RESOLVED that Exhibit A (CEQA Findings and Statement of Overriding Considerations) and Exhibit B (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 BE IT FURTHER RESOLVED that Exhibit A of this Resolution provides the findings required under Section 15093 of the CEQA Guidelines relating to accepting adverse impacts of the Project due to overriding considerations. The City has balanced the economic, legal, social, technological, and other benefits of the Project against the unavoidable environmental risks that may result, and finds that the specific economic, legal, social, technological, and other benefits outweigh the unavoidable adverse environmental effects. The Planning Commission hereby recommends that the City Council adopt CEQA Findings and the Statement of Overriding Considerations attached hereto as Exhibit A; and BE IT FURTHER RESOLVED that, pursuant to Public Resources Code Section 21081.6, the Planning Commission hereby recommends that the City Council approve the Mitigation Monitoring and Reporting Program attached as Exhibit B to this Resolution and require the Project to comply with the mitigation measures contained therein; and BE IT FURTHER RESOLVED that any interested person may appeal this Resolution of the Planning Commission to the City Council within 10 calendar days of its passage pursuant to RPMC Section 17.25.123. Any such appeal shall be in the form provided by RPMC Section 17.25.124 and with the payment of the fee established by the City. DULY AND REGULARLY ADOPTED on this 11th day of September, 2014 by the City of Rohnert Park Planning Commission by the following vote: AYES: � NOES: Z A38ENT: ABSTAIN: ADAMS I BLANQUIE N Attest: 0, (i-a� �--Yy Susanneve a Recording Secretary GIUDICE � HAYDON M City of Rohnert Park Planning Commission EXHIBIT A TO RESOLUTION NO. 2014-32 CEQA FINDINGS AND STATEMENT OF OVERRIDING CONSIDERATIONS RELATED TO THE CERTIFICATION OF THE NORTHWEST SPECIFIC PLAN EIR STATEMENT OF FINDINGS The findings and determinations contained herein are based on the competent and substantial evidence, both oral and written, contained in the entire record relating to the Project and the EIR. The findings and determinations constitute the independent findings and determinations by this City Council in all respects and are fully and completely supported by substantial evidence in the record as a whole. Although the findings below identify specific sections within the Draft and Final EIRs in support of various conclusions reached below, the City Council incorporates by reference and adopts as its own, the reasoning and analysis set forth in both the Draft and Final EIR and thus relies on that reasoning, even where not specifically mentioned or cited below, in reaching the conclusions set forth below, except where additional evidence is specifically mentioned. This is especially true with respect to the Council's approval of all mitigation measures recommended in the Final EIR, and the reasoning set forth in responses to comments in the Final EIR. The City Council further intends that if these findings fail to cross-reference or incorporate by reference any other part of these findings, any finding required or permitted to be made by this City Council with respect to any particular subject matter of the Project must be deemed made if it appears in any portion of these findings or findings elsewhere in the record. The Final EIR, comments and responses to comments and all appendices are hereby fully incorporated herein by this reference. I. INTRODUCTION These are the CEQA findings prepared by the City of Rohnert Park ("City") as lead agency for the Northwest Specific Plan project ("Project"). These findings pertain to the Project and the Environmental Impact Report prepared for that Project, designated as State Clearinghouse No. 2013062005. The Draft EIR, the Final EIR, and all the appendices comprise the "EIR" referenced in these findings. These CEQA findings are attached as Attachment A and are incorporated by reference into the resolution certifying the EIR. That resolution also incorporates an Attachment B, which contains the Mitigation Monitoring and Reporting Plan ("MMRP"), and which references the Project's impacts, mitigation measures, levels of significance before mitigation, and resulting levels of significance after mitigation. II. THE PROJECT The Northwest Specific Plan ("NWSP") proposes a mixed-use community on approximately 100 acres adjacent to the northwest City limits and within the City's Urban Growth Boundary. The NWSP area lies south of Millbrae Avenue, west of Dowdell Avenue, north of Business Park Drive, and east of Langner Avenue. Existing uses in the NWSP area include small-scale agricultural operations in the south district, single family and rural residential in both the north and south districts, and vacant and undeveloped land that have previously been used for agriculture. The proposed Project would provide for development of up to 398 residential units, 458,700 square feet of regional commercial uses, 218,200 square feet of industrial uses, 58,400 square feet of mixed-use, 100 hotel rooms, and parks and open space within the 100 -acre planning area. The Project proposes development standards and design guidelines to govern all development within the NWSP area. The Applicant is seeking approval of the NWSP, as well as General Plan amendments to reflect the NWSP. The Applicant has additionally submitted an application for Pre -Zoning and Annexation of the property to the City of Rohnert Park. The proposed NWSP and its accompanying documents are forwarded to Planning Commission for review and recommendation. The recommendations of the Planning Commission are forwarded to City Council for action. As noted above, the Project application includes a request for a General Plan amendment. The current land use designations on the Project site in the Rohnert Park General Plan are High Density Residential, Commercial, Office, Industrial, and Parks/Recreation. The project proposes to amend the configuration of the existing General Plan designations on the site and to add the Mixed -Use designation. If approved, this amendment would amend the Rohnert Park General Plan Land Use Map to accurately reflect the configuration of land uses included in the NWSP. The NWSP area is located outside of the existing City limit and is not currently included in the City of Rohnert Park Zoning Map. The entire NWSP is proposed to be zoned Specific Plan (SP). If zoned Specific Plan (SP), uses and development standards for the area would be determined by the proposed NWSP. Project Objectives Overall, Project objectives as stated by the project sponsor include the following, as provided in the EIR: • Define the vision for the future of the Northwest Specific Plan Area. • Establish a land use plan and policy framework that will guide future development of a mix of commercial, higher density residential, and light industrial uses within the NWSP area. • Implement development standards and design guidelines that reflect the surrounding context and community values, while promoting economically viable and vibrant development. • Provide a multi -modal circulation plan that supports buildout of the NWSP and ensures safe access for all users. • Provide a framework for development of a cohesive system of pedestrian/bicycle connections and trails linking activity nodes, retail, housing, parks, and open spaces together. • Design a preliminary drainage plan that includes Low Impact Development strategies to manage and treat stormwater runoff within the NWSP area. • Identify a framework for implementation and financing of the Specific Plan. III. ENVIRONMENTAL REVIEW OF THE PROJECT Pursuant to the California Environmental Quality Act, Public Resources Code Section 21000 et seq. ("CEQA") and the CEQA Guidelines, Code of California Regulations, Title XIV, Section 15000 et seq., the City determined that an Environmental Impact Report ("EIR") should be prepared to analyze the potential environmental effects of the Project. As required under CEQA, a Notice of Preparation ("NOP") describing the proposed project and issues to be addressed in the EIR was distributed to responsible agencies (to state agencies through the State Clearinghouse), and other interested parties for a 30 -day public review period beginning June 7, 2013. The City's Planning Department conducted an EIR public scoping meeting on June 20, 2013, to allow interested parties to provide comments on the project with regard to potential environmental issues that should be considered in the EIR. The Draft EIR was prepared and circulated for a 45 -day public review period beginning June 20, 2014, and ending August 4, 2014. A Public Comment Session was held on July 14, 2014, to allow interested individuals to present their comments on the Draft EIR in a public forum. In addition to the comments that were received at the July 14th meeting, the City also received comment letters on the Draft EIR from interested individuals, businesses and agencies. The City prepared responses to all comments received on the Draft EIR during the public review, which in some cases required revisions to the Draft EIR. The responses to comments, changes to the Draft EIR, and additional information have been incorporated into the Final EIR. CEQA Guidelines Section 15088.5 requires a lead agency to recirculate an EIR for further review and comment when significant new information is added to the EIR after public notice is given of the availability of the draft EIR but before certification. New information added to an EIR is not "significant" unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect that the project proponent declines to implement. The Guidelines provide examples of significant new information under this standard. Recirculation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR. Though changes have been made to the Draft EIR, the Final EIR does not contain significant new information as defined in the Guidelines and recirculation of the EIR is not required. IV. THE RECORD OF PROCEEDINGS The record upon which all findings and determinations related to the Project are based includes the following: a. The Draft EIR and Final EIR and all documents referenced in or relied upon by the Draft EIR and Final EIR. b. All information (including written evidence and testimony) provided by City staff to the Planning Commission and the City Council relating to the Draft EIR and Final EIR, the proposed approvals and entitlements, the Project or its alternatives. C. All information (including written evidence and testimony) presented to the Planning Commission and the City Council by the environmental consultant and subconsultants who prepared the Draft EIR and Final EIR, or incorporated into reports presented to the Commission and the Council. d. All information (including written evidence and testimony) presented to the City from other public agencies relating to the Project or the Draft EIR and Final EIR. e. All applications, letters, testimony and presentations presented by the Project Sponsor and its consultants to the City in connection with the Project. f. All information (including written evidence and testimony) presented at any public hearing or workshop related to the Project, the Draft EIR, and the Final EIR. g. For documentary and information purposes, all locally -adopted land use plans and ordinances, including, without limitation, general plans, specific plans and ordinances, together with environmental review documents, findings, mitigation monitoring and reporting programs and other documentation relevant to regulation and management of land use in the area. h. The MMRP for the Project. i. All other documents comprising the record pursuant to Public Resources Code Section 21167.6(e). The custodian of the documents and other materials that constitute the administrative record of proceedings upon which the Council's decision is based are located at the City of Rohnert Park, City Clerk, 130 Avram Avenue, Rohnert Park, CA 94928. The custodian of records is the City Clerk. The Planning Commission has relied on all of the documents listed above in reaching its decision on the Project, even if not every document was formally presented to the Commission or City staff as part of the City files generated in connection with the Project. Without exception, any documents set forth above not found in the Project files fall into one of two catego ries. Many of them reflect prior planning or legislative decisions with which the Planning Commission was aware in approving the Project. (See City of Santa Cruz v. Local Agency Formation Commission (1978) 76 Cal.App.3d 381, 391-392; Dominey v. Department of Personnel Administration (1988) 205 Cal.App.3d 729, 738, fn. 6.) Other documents influenced the expert advice provided to City staff or consultants, who then provided advice to the Planning Commission. For that reason, such documents form part of the underlying factual basis for the Commission 's decisions relating to the adoption of the Project. (See Pub. Resources Code, § 21167.6, subd. (e)(10); Browning-Ferris Industries v. Planning Commission of City of San Jose (1986) 181 Cal.App.3d 852, 866; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Cal.App.4th 144, 153, 155.) These findings are based upon substantial evidence in the entire record before the Council. The references to certain pages or sections of the EIR set forth in these findings are for ease of reference only and are not intended to provide an exhaustive list of the evidence relied upon for these findings. V. FINDINGS REQUIRED UNDER CEQA Public Resources Code section 21002 provides that "public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]" The same statute states that the procedures required by CEQA "are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects." Section 21002 goes on to state that "in the event [that] specific economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof." The mandate and principles announced in Public Resources Code section 21002 are implemented, in part, through the requirement that agencies must adopt findings before approving projects for which EIRs are required. (See Pub. Resources Code, § 21081, subd. (a); CEQA Guidelines, § 15091, subd. (a).) For each significant environmental effect identified in an EIR for a proposed project, the approving agency must issue a written finding reaching one or more of three permissible conclusions. The first such finding is that "[c]hanges or alterations have been required in, or incorporated into, the project which avoid or substantially lessen the significant environmental effect as identified in the final EIR." (CEQA Guidelines, § 15091, subd. (a)(1).) The second permissible finding is that "[s]uch changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been adopted by such other agency or can and should be adopted by such other agency." (CEQA Guidelines, § 15091, subd. (a)(2).) The third potential conclusion is that "[s]pecific economic, legal, social, technological, or other considerations, including provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or project alternatives identified in the final EIR." (CEQA Guidelines, § 15091, subd. (a)(3).) Public Resources Code section 21061.1 defines "feasible" to mean "capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social and technological factors." CEQA Guidelines section 15364 adds another factor: "legal" considerations. (See also Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 565 (Goleta II).) The concept of "feasibility" also encompasses the question of whether a particular alternative or mitigation measure promotes the underlying goals and objectives of a project. (City of Del Mar v. City of San Diego (1982) 133 Cal.App.3d 410, 417.) "`[F]easibility' under CEQA encompasses `desirability' to the extent that desirability is based on a reasonable balancing of the relevant economic, environmental, social, and technological factors." (Ibid.; see also Sequoyah Hills Homeowners Assn. v. City of Oakland (1993) 23 Cal.App.4th 704, 715.) The CEQA Guidelines do not define the difference between "avoiding" a significant environmental effect and merely "substantially lessening" such an effect. The City must therefore glean the meaning of these terms from the other contexts in which the terms are used. Public Resources Code section 21081, on which CEQA Guidelines section 15091 is based, uses the term "mitigate" rather than "substantially lessen." The CEQA Guidelines therefore equate "mitigating" with "substantially lessening." Such an understanding of the statutory term is consistent with the policies underlying CEQA, which include the policy that "public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such Projects." (Pub. Resources Code, § 21002.) For purposes of these findings, the term "avoid" refers to the effectiveness of one or more mitigation measures to reduce an otherwise significant effect to a less -than -significant level. In contrast, the term "substantially lessen" refers to the effectiveness of such measure or measures to substantially reduce the severity of a significant effect, but not to reduce that effect to a less - than -significant level. These interpretations appear to be mandated by the holding in Laurel Hills Homeowners Association v. Planning Commission (1978) 83 Cal.App.3d 515, 519-521, in which the Court of Appeal held that an agency had satisfied its obligation to substantially lessen or avoid significant effects by adopting numerous mitigation measures, not all of which rendered the significant impacts in question less than significant. Although CEQA Guidelines section 15091 requires only that approving agencies specify that a particular significant effect is "avoid[ed] or substantially lessen[ed]," these findings, for purposes of clarity, in each case will specify whether the effect in question has been reduced to a less -than -significant level, or has simply been substantially lessened but remains significant. Moreover, although section 15091, read literally, does not require findings to address environmental effects that an EIR identifies as merely "potentially significant," these findings will nevertheless fully account for all such effects identified in the Final EIR. CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to substantially lessen or avoid significant environmental impacts that would otherwise occur. Project modification or alternatives are not required, however, where such changes are infeasible or where the responsibility for modifying the Project lies with some other agency. (CEQA Guidelines, § 15091, subd. (a), (b).) With respect to a project for which significant impacts are not avoided or substantially lessened, a public agency, after adopting proper findings, may nevertheless approve the project if the agency first adopts a statement of overriding considerations setting forth the specific reasons why the agency found that the project's "benefits" rendered "acceptable" its "unavoidable adverse environmental effects." (CEQA Guidelines, §§ 15093, 15043, subd. (b); see also Pub. Resources Code, § 21081, subd. (b).) The California Supreme Court has stated, "[t]he wisdom of approving ... any development project, a delicate task which requires a balancing of interests, is necessarily left to the sound discretion of the local officials and their constituents who are responsible for such decisions. The law as we interpret and apply it simply requires that those decisions be informed, and therefore balanced." (Goleta II, supra, 52 Cal.3d at p. 576.) These findings constitute the City Council members' best efforts to set forth the evidentiary and policy bases for its decision to approve the Project in a manner consistent with the requirements of CEQA. To the extent that these findings conclude that various proposed mitigation measures outlined in the Final EIR are feasible and have not been modified, superseded or withdrawn, the City hereby binds itself to implement these measures. These findings, in other words, are not merely informational, but rather constitute a binding set of obligations that will come into effect when the Council adopts a resolution approving the Project. VI. CERTIFICATION OF THE EIR In accordance with CEQA, the CEQA Guidelines and the City Guidelines, the Council, as lead agency, certifies that the EIR has been completed in compliance with CEQA, the CEQA Guidelines and the City Guidelines. The Council further certifies that it has reviewed and considered the information in the EIR prior to approving any element of or entitlement for the Project. Similarly, the Council finds that it has reviewed the record and the EIR prior to approving any element of or entitlement for the Project. By making these findings, the Council confirms, ratifies and adopts the findings and conclusions of the EIR, as supplemented and modified by the findings contained herein. The EIR and these findings represent the independent judgment and analysis of the City and the Council. The Council certifies that the EIR is adequate to support the approval of the Project. The EIR is adequate for each entitlement or approval required for adoption of the NWSP and annexation of the NWSP area to the City of Rohnert Park. VII. MITIGATION MEASURES, CONDITIONS OF APPROVAL, AND MMRP Public Resources Code Section 21081.6 and CEQA Guidelines Section 15097 require the City to adopt a monitoring plan or reporting program with adoption of the EIR to ensure that the mitigation measures and revisions to the Project identified in the EIR are implemented. The Council finds that the MMRP included in Attachment B meets these requirements and hereby adopts the MMRP. The mitigation measures recommended by the EIR and incorporated into the Project are specific and enforceable. As appropriate, some mitigation measures define performance standards to ensure no significant environmental impacts occur. The MMRP adequately describes conditions, implementation, verification, a compliance schedule and reporting requirements to ensure the Project complies with the adopted mitigation measures. The MMRP ensures that the mitigation measures are in place, as appropriate, throughout the life of the Project. The mitigation measures described in Attachment B are incorporated into these findings as conditions of each of the approvals required for the Project. The mitigation measures set forth in Attachment B reflect the mitigation measures set forth in the EIR. The City may have modified the language of some of the mitigation measures and corresponding conditions for purposes of clarification and consistency, to enhance enforceability, to defer more to the expertise of other agencies with jurisdiction over the affected resources, to summarize or strengthen their provisions, and/or to make the mitigation measures more precise and effective, but has made no substantive changes to the mitigation measures. The City will use the MMRP to track compliance with Project mitigation measures. The MMRP will remain available for public review during the compliance period. VIII. FINDINGS REGARDING IMPACTS In accordance with Public Resources Code Section 21081 and CEQA Guidelines Sections 15091 and 15092, the Council adopts the findings and conclusions regarding impacts and mitigation measures that are set forth in the Draft EIR and Final EIR. These findings do not repeat the full discussions of environmental impacts contained in the Draft EIR and Final EIR. The Council ratifies, adopts and incorporates the analysis, explanation, findings, responses to comments and conclusions of the Draft EIR and Final EIR. The Council adopts the reasoning of the Draft EIR and Final EIR, of City staff reports, and of City staff and the presentations provided by the Project Sponsor. The Council has, by its review of the evidence and analysis presented in the Draft EIR and Final EIR and in the record, acquired an understanding of the full scope of the environmental issues presented by the Project. In turn, this understanding has enabled the Council to make fully informed, thoroughly considered decisions on these important issues. These findings are based on a full appraisal of the Draft EIR and Final EIR and the record, as well as other relevant information in the record of proceedings for the Project. Under Public Resources Code Section 21081(a)(2) and CEQA Guidelines Section 15091(a)(2) and 15092(b)(2)(A), the Council recognizes that some mitigation measures require action by, or cooperation from, other agencies. Similarly, mitigation measures requiring the Project Sponsor to contribute towards improvements planned by other agencies will require the relevant agencies to receive the funds and spend them appropriately. The Council also recognizes that some impacts can only be mitigated by actions taken by other agencies to build the relevant improvements, which will require action by these other agencies that are not enforceable by the City of Rohnert Park. For each mitigation measure that requires the cooperation or action of another agency, the Council finds that adoption and/or implementation of each of those mitigation measures is within the responsibility and jurisdiction of another public agency, and that the measures can and should be adopted and/or implemented by that other agency. The Council finds that, except as provided in Section XI below, following implementation of mitigation measures identified in the EIR and Attachment B, all of the Project impacts evaluated by the EIR will be less than significant as determined by the Draft EIR. IX. ENVIRONMENTAL EFFECTS NOT FOUND TO BE SIGNIFICANT AND NOT ADDRESSED IN DETAIL IN THE EIR During preparation of the EIR, the issue area of mineral resources was found not to result in significant impacts and therefore was not addressed in detail in the EIR. Pursuant to CEQA Guidelines section 15128, the reasons this issue was determined not to be significant are described below. Mineral Resources The California Department of Conservation, Geological Survey has classified lands within Sonoma County into Aggregate and Mineral Resource Zones (MRIs), which identify whether known or inferred significant mineral resources are present in areas. The Specific Plan Area is not within a Sonoma County Mineral Resource zone and is designated Rural Residential and Diverse Agricultural on the Sonoma County General Plan Land Use and Zoning Maps. Accordingly, the Specific Plan Area does not include any significant known or inferred mineral resources. Given this, implementation of the Specific Plan would not 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 or 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. X. IMPACTS EVALUATED IN THE EIR AND DETERMINED TO BE LESS THAN SIGNIFICANT WITH MITIGATION MEASURES The City Council agrees with the characterization in the Final EIR with respect to all Impacts initially identified as "significant" or "potentially significant" that would be less than significant with implementation of the mitigation measures identified in the Final EIR. In accordance with CEQA Guidelines §15091 (a), a specific finding is made for each impact and its associated mitigation measures in the discussions below. Impact Criteria, as included in the EIR, are included below to provide context for each Impact identified. The Council again ratifies, adopts and incorporates the full analysis, explanation, findings, responses to comments and conclusions of the EIR. Air Quality Impacts Impact AIR -4 The proposed Project could result in the placement of sensitive receptors proximate to major sources of air pollution or the siting of new sources of air pollution proximate to sensitive receptors in the City. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure AIR -4a requires applicants for future warehousing and other industrial land uses within the Specific Plan that: 1) have the potential to generate 100 or more diesel truck trips per day or have 40 or more trucks with operating diesel- powered transport refrigeration units ("TRUs"), and 2) are located within 1,000 feet of a sensitive land use (e.g., residential, schools, hospitals, nursing homes), to submit a health risk assessment ("HRA") to the City of Rohnert Park prior to future project approval. Mitigation Measure AIR -4b requires applicants for residential and other sensitive land use projects (e.g., hospitals, nursing homes, day care centers) within the Specific Plan within 1,000 feet of a major sources of Toxic Air Contaminants ("TACs") (e.g., warehouses, industrial, or roadways with traffic volumes over 10,000 vehicle per day), to submit an HRA to the City of Rohnert Park prior to future project approval. Finding: Implementation of Mitigation Measures AIR -4a and AIR -4b identified in the EIR and listed in the MMRP will ensure that Impact AIR -4 would be reduced to a less - than -significant level. Impact AIR -5 people. The Specific Plan would create objectionable odors affecting a substantial number of Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure AIR -5 requires applicants of future development projects under the Specific Plan that involve the uses listed below to prepare an Odor Management Plan and submit the plan prior to the City prior to project approval to ensure compliance with Bay Area Air Quality Management District Regulation 7, Odorous Substances. • Wastewater Pumping Facilities within 1 mile of sensitive land uses. • Transfer Station within 1 mile of sensitive land uses. • Composting Facility within 1 mile of sensitive land uses. • Asphalt Batch Plan within 2 miles of sensitive land uses. • Chemical Manufacturing within 2 miles of sensitive land uses. • Fiberglass Manufacturing within 1 mile of sensitive land uses. • Painting/Coating Operations within 1 mile of sensitive land uses. • Coffee Roaster within 1 mile of sensitive land uses. • Food Processing Facility within 1 mile of sensitive land uses. • Green Waste and Recycling Operations within 1 mile of sensitive land uses. • Metal Smelting Plans within 2 miles of sensitive land uses. Finding: Implementation of Mitigation Measure AIR -5 identified in the EIR and listed in the MMRP will ensure that Impact AIR -5 would be reduced to a less -than -significant level. Cultural Resources Impacts Impact CULT -1 The proposed Project would have the potential to cause a substantial adverse change in the significance of a historical resource as defined in Section 15064.5. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure CULT -1 requires future development projects permitted under the Specific Plan to include a project -specific review to determine their potential to affect archaeological deposits. If deemed necessary by this review, a pedestrian survey shall be conducted by a professional archaeologist. Finding: Implementation of Mitigation Measure CULT -1 identified in the EIR and listed in the MMRP will ensure that Impact CULT -1 would be reduced to a less -than - significant level. Impact CULT -2 The proposed Project would have the potential to cause substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure CULT -1 requires future development projects permitted under the Specific Plan to include a project -specific review to determine their potential to affect archaeological deposits. If deemed necessary by this review, a pedestrian survey shall be conducted by a professional archaeologist. Finding: Implementation of Mitigation Measure CULT -I identified in the EIR and listed in the MMRP will ensure that Impact CULT -2 would be reduced to a less -than - significant level. Impact CULT -3 The proposed Project would have the potential to directly or indirectly destroy a unique paleontological resource or site, or unique geologic feature. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure CULT -3 requires that in the event that fossils or fossil - bearing deposits are discovered during construction, excavations within 50 feet of the find be temporarily halted or diverted, and a qualified paleontologist must be notified to examine the discovery. Finding: Implementation of Mitigation Measure CULT -3 identified in the EIR and listed in the MMRP will ensure that Impact CULT -3 would be reduced to a less -than - significant level. Impact CULT -4 The proposed Project would have the potential to disturb human remains, including those interred outside of formal cemeteries. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure CULT -4 requires that if human skeletal remains are uncovered during construction, the contractor immediately halt work within 50 feet of the find, contact the Sonoma County coroner to evaluate the remains, and follow the procedures and protocols set forth in Section 15064.5(e)(1) of the CEQA Guidelines. Finding: Implementation of Mitigation Measure CULT -4 identified in the EIR and listed in the MMRP would ensure that Impact CULT -4 would be reduced to a less -than - significant level. Hazards and Hazardous Materials Impacts Impact HAZ-2 The Project would 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. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure HAZ-2 requires future project applicants to perform pesticide screening analyses of soil on properties within the Specific Plan Area currently or historically cultivated for agricultural purpose. If soils exceed pesticide levels established by the United States Environmental Protection Agency preliminary remediation goals for residential use, they will not be allowed to be reused on site. Mitigation Measure AIR -2a would require construction contractors to comply with BAAQMD Basic Control Measures for reducing fugitive dust emissions during construction. Finding: Implementation of Mitigation Measures HAZ-2 and AIR -2a identified in the EIR and listed in the MMRP will ensure that Impact HAZ-2 would be reduced to a less - than -significant level. Transportation and Traffic Impacts Impact TRANS -1B The proposed Project would contribute to unacceptable levels of service at the intersections of Golf Course Drive West/Redwood Drive and Golf Course Drive West/U.S. 101 South Ramps in the City of Rohnert Park under buildout conditions. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure TRANS -113.1 requires modification of the Golf Course Drive West/Redwood Drive intersection by restriping the eastbound lanes to create a left -turn lane, two through lanes, and a shared through/right-turn lane; reconfiguring the southbound approach to include dual left -turn lanes, a single through lane, and a right -turn lane; adding a right -turn pocket on the westbound approach; and adding a right turn overlap signal phase on the northbound approach. Mitigation Measure TRANS -113.2 requires modification of the Golf Course Drive West/U.S. 101 South Ramps intersection by restriping the lanes on the southbound approach to include a left-turn/through lane, through/right-turn lane, and right -tum lane, and making associated modifications to the signal equipment. Finding: Implementation of Mitigation Measures TRANS -113.1 and 113.2 identified in the EIR and listed in the MMRP will ensure that Impact TRANS -IB would be reduced to a less -than -significant level. Impact TRANS -11) The proposed Project would contribute to vehicle queues exceeding available storage on the U.S. 101 Northbound off -ramp at Commerce Boulevard under buildout conditions. Significance Before Mitigation: Significant Significance After Mitigation: Less than Significant Explanation: Mitigation Measure TRANS -11) requires implementation of Mitigation Measures TRANS -113.1 and 113.2 to reduce the potential impact to below a level of significance. Finding: Implementation of Mitigation Measures TRANS -113.1 and 113.2 identified in the EIR and listed in the MMRP will ensure that Impact TRANS -11) would be reduced to a less -than -significant level. XI. SIGNIFICANT AND UNAVOIDABLE IMPACTS Under Public Resources Code Section 21081(a)(3) and (b), and CEQA Guidelines Sections 15091(a)(3), 15092(b)(2)(B) and 15093, the Council determines that the remaining significant and unavoidable adverse effects on the environment identified by the EIR are acceptable due to the overriding considerations described in Section XIV below. The significant and unavoidable adverse impacts remaining after mitigation of the Project are as follows: Air Quality Impacts Impact AIR -1 The proposed Specific Plan would support the primary goals of the 2010 Bay Area Clean Air Plan, but buildout of the proposed Specific Plan would conflict with the requirements for community -wide vehicles miles traveled (VMT) increase in the Clean Air Plan. Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Policies and development standards in the Specific Plan would facilitate continued City participation and cooperation with the Bay Area Air Quality Management District (BAAQMD) and the Sonoma County Transportation Authority (SCTA) to achieve regional air quality improvement goals, promotion of energy conservation design and development techniques, encouragement of alternative transportation modes, and implementation of transportation demand management strategies. However, due to the programmatic nature of the Project, no additional mitigating policies or development standards are available, and project -level and cumulative impacts are considered significant and unavoidable. Impact AIR -2 The Specific Plan would violate an air quality standard or contribute substantially to an existing or projected air quality violation in Rohnert Park. Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Future construction under the Specific Plan would generate a substantial temporary increase in criteria air pollutants even with the implementation of Mitigation Measures AIR -2a and AIR -2b. Adherence to the BAAQMD Basic Control Measures for reducing construction emissions of PM10 and PM2.5 would ensure that ground - disturbing activities would not generate a significant amount of fugitive dust. Compliance with the policies and development standards included in the Specific Plan outlined in Chapter 4.2, Air Quality, of the Draft EIR would reduce construction exhaust emissions from development under the Specific Plan to the maximum extent practicable. Though future development under the Specific Plan would be subject to separate environmental review pursuant to the CEQA in order to identify and mitigate potential air quality impacts, cumulative impacts from development within the NWSP from construction would be substantial and therefore significant and unavoidable. In addition, compliance with the policies and development standards included in the NWSP and the Mitigation Measure GHG-la through GHG-le would reduce operational emissions from development under the Specific Plan to the maximum extent practicable. Mitigation Measure AIR -4a (for new sources of Toxic Air Contaminants [TACs]), would also reduce criteria air pollutants associated with light industrial land uses within the Specific Plan Area. Although future development under the Specific Plan would be subject to separate environmental review pursuant to CEQA in order to identify and mitigate potential air quality impacts, cumulative impacts from development within the Rohnert Park Specific Plan from operational emissions would be substantial and therefore significant and unavoidable. Impact AIR -3 Criteria air pollutants generated by land uses within the Specific Plan would cumulatively contribute to the nonattainment designations of the San Francisco Bay Area Air Basin (SFBAAB). Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Mitigation measures proposed to reduce Project -related emissions would reduce impacts to the extent feasible. Due to the programmatic nature of the proposed Project, no additional mitigating policies or development standards are available, and project -level and cumulative impacts are considered significant and unavoidable. Impact AIR -6 The Specific Plan, in combination with past, present, and reasonably foreseeable projects, would cumulatively contribute to air quality impacts in the San Francisco Bay Area Air Basin. Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Mitigation measures proposed to reduce Project -related emissions would reduce impacts to the extent feasible. Due to the programmatic nature of the proposed Project, no additional mitigating policies or development standards are available, and cumulative impacts are considered significant and unavoidable. Biological Resources Impacts Impact BI0-1 The Project would have a substantial adverse effect, either directly or through habitat modifications, on species identified as a candidate, sensitive or special status species in local or regional plans, policies, or regulations by the California Department of Fish and Wildlife (CDFW), or United States Fish and Wildlife Service (USFWS). Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: The NWSP area has potentially suitable habitat conditions for the 19 Special -Status Plant Species and 17 Special -Status Wildlife Species. Additionally, the entire Specific Plan Area is located within designated California tiger salamander ("CTS") Critical Habitat for the Sonoma District Population Segment. Implementation of Mitigation Measures BIO -la through BIO-lf, Impact 13I0-1 would reduce impacts to the extent feasible; however, due to the programmatic nature of the proposed Project, no additional mitigating policies or development standards are available, and impacts would remain significant and unavoidable. Impact BIO -2 The proposed Project would have a substantial adverse effect on riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Wildlife and Wildlife, or U.S. Fish and Wildlife Service. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: There are portions of the Specific Plan Area that were not available for assessing the potential for wetlands. However, it is estimated through visual observation and a review of aerial imagery that up to 10 acres of potentially jurisdictional habitat could be present on the parcels that were not included in the July 2013 survey. Therefore, this undocumented 10 -acre area could comprise Federally protected wetlands. Therefore, even with implementation of Mitigation Measures 13I0 -2a through 13I0 -2d, Impact 13I0- 2 would remain significant and unavoidable. Impact BIO -3 The proposed Project would 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. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: There are portions of the Specific Plan Area that were not available for assessing the potential for wetlands. However, it is estimated through visual observation and a review of aerial imagery that up to 10 acres of potentially jurisdictional habitat could be present on the parcels that were not included in the July 2013 survey. Therefore, this undocumented 10 -acre area could comprise Federally protected wetlands. Therefore, even with implementation of Mitigation Measures BIO -la through BIO -If and 13I0 -2a through BIO -2d, Impact 13I0-3 would remain significant and unavoidable. Impact BI0-4 The proposed Project would 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. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: As previously discussed the entire NWSP area is designated as Critical Habitat for the CTS and it should also be assumed that the CTS move across the NWSP area and development could result in a significant impact to this movement. Even with implementation of Mitigation Measures BIO -la through BIO-lf and 13I0 -2a through 13I0 -2d, Impact 13I0-4 would remain significant and unavoidable. Impact BI0-7 The proposed Project, in combination with past, present, and reasonably foreseeable projects, would result significant cumulative impacts with respect to biological resources. Significance Before Mitigation: Significant and Unavoidable Significant After Mitigation: Significant and Unavoidable Explanation: Future development in the NWSP area would contribute to the conversion of existing habitat to urban uses as is occurring in the surrounding area with implementation of other cumulative development considered as part of this cumulative impact analysis on biological resources. Accordingly, the Project's impacts in this regard would be cumulatively considerable. Even with implementation of mitigation measures, Impact BIO -7 would remain significant and unavoidable. Greenhouse Gas Emissions Impacts Impact GHG-1 The Specific Plan would generate greenhouse gas (GHG) emissions that would either directly or indirectly have a significant impact on the environment. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: Despite compliance with existing federal, State, and local regulations that serve to reduce GHG emissions to the maximum extent practicable and the implementation of the Mitigation Measures GHG-la through GHG-le, GHG emissions would continue to exceed the exceed BAAQMD's efficiency criteria. Consequently, GHG impacts are considered significant and unavoidable. Impact GHG-2 The Specific Plan would potentially conflict with an applicable plan, policy, or regulation for the purpose of reducing the emissions of GHGs. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: Policies and development standards in the NWSP would facilitate continued City participation and cooperation with BAAQMD and SCTA to achieve regional air quality improvement goals, promotion of energy conservation design and development techniques, encouragement of alternative transportation modes, and implementation of transportation demand management strategies. However, due to the programmatic nature of the Project, no additional mitigating policies or development standards are available, and project -level and cumulative impacts are therefore considered significant and unavoidable. Impact GHG-3 The Specific Plan, in combination with past, present, and reasonably foreseeable projects, would result in significant cumulative impacts with respect to GHG emissions. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: Implementation of Mitigation Measures GHG-la through GHG-le and compliance with existing federal, State, and local regulations would reduce GHG emissions to the maximum extent practicable. However, no single project is large enough to result in a measurable increase in global concentrations of GHG emissions, and therefore GHG emissions impacts identified in Impact GHG-1 and GHG-2 are the proposed Project's cumulative contribution to cumulative impacts. Therefore, cumulative GHG emissions impacts of the proposed Project are significant and unavoidable. Noise Impacts Impact NOISE -3 Under the existing with project scenario, a significant impact would occur due to a substantial increase in ambient noise levels that could affect properties outside the Specific Plan Area. Significance Before Mitigation: Significant Significant After Mitigation: Significant and Unavoidable Explanation: The significant impacts would affect properties outside the NWSP area; therefore, the only way to mitigate such impacts would be to build sound walls or other noise barriers on these properties to reduce traffic noise from adjacent roadways. Implementation of such mitigation cannot be guaranteed since it would require the cooperation of private property owners outside the NWSP area. As a result, the existing plus project impacts to ambient noise levels would be significant and unavoidable. Transportation and Traffic Impacts Impact TRANS -IA Future development under the Specific Plan would contribute to unacceptable Level of Service (LOS) F operation at Stony Point Road/Millbra Avenue and Stony Point Road/Golf Course Drive West in the County of Sonoma. Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Mitigation Measure TRANS -IA states that Stony Point Road shall be widened to two through lanes in each direction, consistent with Figure CT -Ig of the Sonoma County 2020 General Plan. While widening of Stony Point Road to two lanes in each direction is included in the Sonoma County 2020 General Plan and would improve operation at both intersections to acceptable levels, this is currently an unfunded project. Because neither the City nor County currently have resources to develop and implement a regional impact fee program, there is currently no means of collecting funds for this County improvement. As a result, the impact is considered significant and unavoidable. Impact TRANS -1C, Future development under the Specific Plan would contribute to unacceptable LOS F operation on mainline U.S. 101 to the north of Golf Course Drive in both the northbound and southbound directions under buildout conditions, increasing the freeway segments' volume - to -capacity ratio by greater than 0.01. Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Mitigation Measure TRANS -1C identifies that widening U.S. 101 to include additional through lanes in each direction would reduce the impact; however, widening the freeway is considered infeasible, as it would require major reconstruction of multiple freeway structures, right-of-way acquisition including many homes and businesses, potential relocation of city streets paralleling the freeway corridor (including Redwood Boulevard and Commerce Avenue), and would be likely to create additional secondary environmental impacts. The Metropolitan Transportation Commission ("MTC"), County of Sonoma, City of Rohnert Park, and SCTA recognize that U.S. 101 will experience congestion into the foreseeable future, and concur that long-range regional solutions focusing on transit -supportive land use planning, alternative transportation modes, stronger jobs -housing balances, and increased support of transportation demand measures are the key components needed to address regional mobility. While the NWSP emphasizes each of these goals, the residual impacts to U.S. 101 are considered to be significant and unavoidable Impact TRANS -7 Implementation of the proposed Project, in combination with past, present, and reasonably foreseeable projects, would result in additional cumulatively considerable impacts. Significance Before Mitigation: Significant Significance After Mitigation: Significant and Unavoidable Explanation: Cumulative traffic impacts are the same as the project -specific impacts, since the future traffic model relies on cumulative traffic data. Therefore, the proposed project's cumulative impacts to traffic would be significant and unavoidable since feasible mitigation is not available for Impacts TRANS-lA and 1C. XII. FINDINGS REGARDING ALTERNATIVES Reasonable Range of Project Alternatives CEQA Guidelines §15126(a) require that an EIR describe a reasonable range of alternatives that would obtain most of the basic project objectives but would avoid or substantially lessen any of the significant environmental affects of the project and that the EIR evaluate the comparative merits of the alternatives. Case law indicates that the lead agency has the discretion to determine how many alternatives constitute a reasonable range (Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 566); and that an EIR need not present alternatives that are incompatible with fundamental project objectives (Save San Francisco Bay Association vs. San Francisco Bay Conservation & Development Commission (1992) 10 Cal.AppAth 908). CEQA Guidelines §I5126.6(f) states that the range of alternatives required in an EIR is governed by a "rule of reason" that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice. Feasibility of Project Alternatives Additionally, CEQA Guidelines §15126.6(a) provide that an EIR need not consider alternatives that are infeasible. CEQA Guidelines §15126.6(f)(1) provides that among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries, and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site. Alternatives Evaluated Based upon guidance contained in the CEQA Guidelines, the Draft EIR considered three alternatives to the proposed project: No Project — 2020 General Plan Alternative, Mixed -Use Only Alternative, and Reduced Density Alternative. No Project Alternative The No Project — 2020 General Plan Alternative assumes that growth would occur as allowed under the City's existing 2020 General Plan and Zoning. No land use changes associated with the proposed NWSP would move forward. Instead, future development in the NWSP area would be subject to existing policies, regulations, and land use designations as per the existing 2020 General Plan. Because the area the General Plan designated for the Northwest Specific Plan was reduced with implementation of the Graton Rancheria Resort and Casino, the land use program in the proposed NWSP was revised and recalculated to eliminate the portion that is now under the jurisdiction of the Federated Indians of Graton Rancheria Tribe. The No Project — 2020 General Plan Alternative would allow for the development of more high-density housing (450 units compared to 398 units), more office (260,000 square feet compared to 58,400 square feet), and hotel space (100 rooms compared to none). However, this alternative would allow for slightly less commercial and office/light industrial uses. Finding: The City Council finds that this alternative is infeasible in that it would not meet the project sponsor's objectives, would provide no significant advantage from an environmental standpoint over the proposed project, and would not implement the General Plan policies, which call for development of a specific plan for the Northwest area. Explanation: While the existing General Plan identifies the land uses and provides guiding policies for development in the NWSP area, it does not define the vision for the NWSP area and establish specific goals and policies, land uses and development standards that are intended to fulfill that vision at the same level as the proposed NWSP. Furthermore, under this alternative, there are no recommendations for circulation and other physical infrastructure improvements to support buildout of the NWSP area, nor is there an implementation strategy and conceptual financing plan for achieving the goals in the NWSP. Mixed -Use Only Alternative Under the Mixed -Use Only Alternative, the NWSP area would be the same size as the proposed Project and would be comprised of mixed-use land use and open space designations. The Mixed -Use Alternative would not include any Office/Light Industrial land uses and the overall non-residential land use designations would be reduced. This alternative would accommodate the up to 600 high-density dwelling units and 200,000 square feet of commercial land use. Approximately 40 acres of the NWSP area would be designated as Open Space for Environmental Conservation and would not be developed. Finding: Though the EIR identified the Mixed -Use Only Alternative as the Environmentally Superior Alternative to the proposed project, the City Council finds that this alternative would not meet the project objectives. Explanation: As outlined in the City's 2000 General Plan, the vision for the Northwest Specific Plan included high density residential, commercial, office and parks land uses. Those land uses are specified in the project objectives described in the EIR. The Mixed - Use Only Alternative does not meet the project objectives because it does not provide the range of land uses identified in the objectives and the General Plan. Additionally, the Mixed -Use Only Alternative would not provide the Project benefits to the same degree as the Project given its smaller size. (See Section XIV. below for a discussion of Project benefits.) Under this alternative, the City would not receive as much of the substantial tax revenue as from the Project and the public improvements associated with the Project would not be constructed to the same degree because of a loss of some development impact fees needed to fund traffic improvements. Reduced Density Alternative The Reduced Density Alternative, would include the same proposed land use designations as the proposed Project, but the amount of land designated for development would be reduced by 50%, with the exception of residential, which would remain at 398 multi -family housing units. Approximately 50 acres would be designated as Open Space for Environmental Conservation and would not be developed. Finding: Though the EIR identified the Reduced Density Alternative as having slightly reduced impacts when compared to the proposed project, the City Council finds that this alternative would not avoid the Significant and Unavoidable impacts of the proposed project to air quality, biological resources, greenhouse gas emissions, noise, and transportation and traffic and is not consistent with the densities outlined in the General Plan policy for development within the plan area. Explanation: The General Plan vision for the Northwest Specific Plan included growth of the area consistent with adjacent plans, provision of residential units and with more intense development than provided in the Reduced Density Alternative. This development is shown in Table 6.1 of the Draft EIR. The Reduced Density Alternative describes substantially less commercial, industrial and office use than provided in the City's General Plan. Additionally, the Reduced Density Alternative would not provide the Project benefits to the same degree as the Project given its smaller size. (See Section XIV. below for a discussion of Project benefits.) Under this alternative, the City would not receive as much of the substantial tax revenue as from the Project and the public improvements associated with the Project would not be constructed to the same degree because of a loss of some development impact fees needed to fund traffic improvements. Environmentally Superior Alternative Sections 21002 and 21081 of CEQA require lead agencies to adopt feasible mitigation measures or a feasible environmentally superior alternative in order to substantially lessen or avoid otherwise significant adverse environmental effects, unless specific social or other conditions make such mitigation measures or alternatives infeasible. CEQA regulations prevent consideration of the "no project" alternative as the environmentally superior alternative. The EIR determined that the Mixed -Use Only Alternative would be the Environmentally Superior Alternative. The Mixed -Use Only Alternative would not eliminate unavoidable significant adverse air quality, biological resources, GHG emissions, noise, and traffic impacts identified for the project, under approved and cumulative development scenarios, and mitigation would still be required for construction air quality, biological resources, cultural resources, hazards and hazardous materials, noise, and traffic and circulation. However, the EIR determined that the Mixed -Use Only Alternative could provide specified benefits in that it would generate fewer trips and associated traffic, air quality, GHG emissions, and noise impacts would be reduced as a result (although these would remain significant). XIII. FINDINGS REGARDING GROWTH INDUCEMENT Section 7.3 of the EIR provides an analysis of growth inducement effects of the proposed Project, as required by CEQA Guidelines §15126.2(d). In summary, CEQA requires a discussion of how a project could increase population, employment, or housing growth in surrounding areas and consideration of the impacts resulting from this growth. CEQA Guidelines indicate that a project would normally have a significant effect on the environment if it would induce substantial growth or concentration of population. Section 7.3 of the EIR discusses the manner in which the Project could contribute to or encourage such growth. Growth can be induced in a number of ways, such as through the elimination of obstacles to growth, through the stimulation of economic activity within the region, or through the establishment of policies or other precedents that directly or indirectly encourage additional growth. Induced growth would be considered a significant impact if it can be demonstrated that the potential growth would directly or indirectly have a significant effect on the environment. Finding: The Project would directly generate population growth by providing housing for approximately 956 people and commercial and industrial development that could generate approximately 1,200 jobs. Project construction would generate jobs in the construction, materials fabrication and supply industries up until the time of construction completion. The provision of construction jobs would create an indirect demand for local goods and services. Construction of the project is not expected to generate substantial population growth or new economic activity in the region because project construction would be expected to employ construction workers already living and working in the Bay Area. Construction of the project would include provision of new infrastructure for the Project and its development components. This new infrastructure would lessen potential obstacles to growth, but is considered growth accommodating and not directly growth inducing. The project would be consistent with the City of Rohnert Park General Plan and would comply with the City's Growth Management Program, which ensures that the rate of population growth will not exceed the average annual growth rates established in the General Plan. The Project would not construct infrastructure beyond that needed to serve the Project area and would develop at a pace that would ensure that public services would not be inhibited or overtaxed. The Project would be consistent with City and County General Plan policies regarding growth within the urban growth boundary and would not be expected to induce substantial growth outside this boundary. Explanation: The NWSP would offer primary employment jobs as well as a range of temporary construction jobs. Overall, opportunities for population growth and employment provided by the NWSP would be consistent with the General Plan Land Use and Growth Management Element goals and policies. The rate of job growth would be generally proportional to the rate of project development anticipated under the City's Growth Management Program. Infrastructure would be constructed and sized to accommodate the proposed development and would therefore not be expected to induce substantial growth beyond that proposed by the Project. The pace of growth associated with the Project would align with the ability of utility and public service providers to adequately serve the project. XIV. STATEMENT OF OVERRIDING CONSIDERATIONS Pursuant to Public Resources Code Section 21081 and CEQA Guidelines Section 15093, the City Council has balanced the economic, legal, social, technological, and other benefits of the proposed Project against the significant and unavoidable impacts associated with the proposed Project, and has adopted all feasible mitigation measures that would avoid or substantially lessen a significant impact. The City Council has also examined potentially feasible alternatives to the Project, and determined that none are feasible. The City Council hereby adopts and makes the following Statement of Overriding Considerations regarding the significant and unavoidable impacts of the Project and the anticipated economic, legal, social, technological, and other benefits of the Project. A. Significant and Unavoidable Impacts Based on information contained in the record and in the EIR, the City Council has determined that the Project would result in the following significant and unavoidable impacts as identified by the EIR: Impact Impact Description Number AIR -1 The proposed Project would support the primary goals of the 2010 Bay Area Clean Air Plan, but buildout of the proposed Project would conflict with the requirements for community -wide vehicle miles travelled (VMT) increase in the Clean Air Plan. AIR -2 The proposed Project would violate any air quality standard or contribute substantially to an existing or projected air quality violation in Rohnert Park. AIR -3 Criteria air pollutant emissions associated with buildout of the Specific Plan would cumulatively contribute to air quality impacts in the San Francisco Bay Area Air Basin. AIR -6 The Specific Plan, in combination with past, present, and reasonably foreseeable projects, would cumulatively contribute to air quality impacts in the San Francisco Bay Area Air Basin. BIO -1 The Project would have a substantial adverse effect, either directly or through habitat modifications, on species identified as candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the California Department of Fish and Wildlife or United States Fish and Wildlife Service. BIO -2 The proposed Project would have a substantial adverse effect on riparian habitat or other sensitive natural community identified in local or regional plans, policies, and regulations or by the California Department of Wildlife and Game, or U.S. Fish and Wildlife Service. BIO -3 The proposed Project would 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. BIO -4 The proposed Project would interfere substantially with the movement of a 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. BIO -7 The proposed Project, in combination with past, present, and reasonably foreseeable projects, would result in significant cumulative impacts with respect to biological resources. GHG-1 The proposed Project would generate GHG emissions that would either directly or indirectly have a significant impact on the environment. GHG-2 The Specific Plan would potentially conflict with an applicable plan, policy, or regulation for the purpose of reducing the emissions of GHGs. GHG-3 The proposed Project, in combination with past, present, and reasonably foreseeable projects, would result in a significant cumulative impact with respect to GHG emissions. NOISE- The proposed Project would cause a substantial permanent increase in 3 ambient noise levels in the Project vicinity above levels existing without the Project under the existing with project scenario. TRANS- The proposed Project would contribute to unacceptable operation (LOS IA F) at Stony Point Road/Millbrae Avenue and Stony Point Road/Wilfred Avenue in the County of Sonoma under buildout conditions. TRANS- The proposed Project would contribute to unacceptable LOS F operation 1C on the northbound U.S. 101 weaving segment between Golf Course Drive an Santa Rosa Avenue buildout conditions, increasing the freeway segment's volume -to -capacity ratio by 0.01. TRANS- Implementation of the proposed Project, in combination with past, 7 present, and reasonably foreseeable projects, would result in additional cumulatively considerable impacts. B. Finding The City Council has considered all potentially feasible mitigation measures to substantially lessen or avoid the Project's significant and unavoidable impacts. Where feasible, such mitigation measures have been adopted as part of the Project. The imposition of these measures will reduce the identified impacts, but not to a less -than -significant level. The Council finds that it is not feasible to fully mitigate these Project impacts. The City Council has also considered all potentially feasible alternatives to the Project. The City Council finds that there are no feasible alternatives that would reduce the above significant and unavoidable impacts to a less -than -significant level. The Project's impacts identified and discussed above therefore remain significant and unavoidable. C. Overriding Considerations After review of the entire administrative record, including, but not limited to, the Final EIR, the staff report, applicant submittals, and the oral and written testimony and evidence presented at public hearings, the City Council finds that specific economic, legal, social, technological and other anticipated benefits of the Project outweigh the significant and unavoidable impacts, and therefore justify the approval of the Project notwithstanding the identified significant and unavoidable impacts (Pub. Resources Code, § 21081; CEQA Guidelines, § 15093.). The benefits are addressed in detail in Section XIV.D below. The City Council specifically adopts and makes this Statement of Overriding Considerations acknowledging that this Project has eliminated or substantially lessened all significant effects on the environment where feasible (including the incorporation of feasible mitigation measures), and finds that the remaining significant and unavoidable impacts of the Project, which are identified above in Section XIV.A and described in Section XI, are acceptable because the benefits of the Project set forth below in Section XIV.D outweigh the significant and unavoidable impacts identified. The City Council finds that each of the overriding considerations expressed as benefits and set forth below in Section XIV.D constitutes a separate and independent ground for such a finding. Any one of the reasons for approval cited below is sufficient to justify approval of the Project. Thus, even if a court were to conclude that not every reason is supported by substantial evidence, the City Council will stand by its determination that each individual reason is sufficient by itself. The substantial evidence supporting the various benefits can be found in the preceding findings and in the documents found in the Record of Proceedings, as defined in Section IV. D. Benefits of the Project The City Council has considered the EIR, the public record of proceedings on the proposed Project and other written materials presented to and prepared by the City, as well as oral and written testimony received, and does hereby determine that implementation of the Project as specifically provided in the Project documents would result in the following substantial public benefits: 1. The Project Would Generate Sales and Property Tax Revenues For The City. The sales generated by commercial components of the Project will generate increased sales tax and property tax revenues for the City. These revenues would go to the City's General Fund, which is the primary funding source for the construction, operation and maintenance of a number of essential City services, programs and facilities including fire and police services, recreation programs, transit operations, library services, public infrastructure such as water and sanitary sewer service, and administrative functions, among other things. 2. The Project Would Contribute To Continued Economic Development, Construction of Roadway Improvement, and Maintenance of City Services and Facilities. The Project will mitigate impacts to the intersections of Golf Course Drive West/Redwood Drive and Golf Course Drive West/U.S. South Ramps through road improvements or payment of fees. Additionally, applicants for future projects within the NWSP will pay applicable traffic impact fees for their share of regional transportation improvements. These applicant shall pay impacts to local roadway systems as expected by construction vehicles and the increase in population generated by the Project. These applicants shall be responsible by the payment of fees to offset the cost of increased services and maintenance generated by the Project. Future projects within the NWSP area will also be subject to the payment of fees to provide for and maintain public infrastructure such as Public Facilities Financing Plan fees to help fund off-site improvements, City-wide and Regional Traffic fees, Pavement Maintenance fees, Public Services Impact fees, and Maintenance of On -Site Infrastructure fees. The public improvements will be funded and maintained through a Funding Mechanism such as a community facilities district. These fees and funding mechanisms would be described in future Development Agreement. 3. The Project Would Enhance Opportunities For Housing In The City. The Project would allow for the development of up to approximately 400 dwelling units within the areas designated Mixed -Use. These units would assist the City in meeting its affordable housing requirement by providing affordable units (including low and very low income units) according to the City's inclusionary housing ordinance. 4. The Project Would Contribute To A Functional And Attractive Environment. The Project includes development standards and design guidelines that will guide future development to enhance the overall aesthetic quality of the area and to blend with the existing development in the surrounding area. 5. The Project Would Provide Quality Goods And Services Desired By City Residents. The Project will facilitate the development of regional commercial and local retail uses that will provide quality goods and services to the Project area and surrounding neighborhoods. Determination and Adoption of Statement of Overriding Considerations The City Council has weighed the economic, legal, social, technological, and other benefits of the proposed Project, as set forth above in Section XIV.D, against the significant unavoidable impacts of the Project identified in the EIR (and identified above in Section XIV.A). The City Council hereby determines that those benefits outweigh the risks and adverse environmental impacts of the Project, and further determines that the Project's significant unavoidable impacts are acceptable. Accordingly, the City Council adopts the Statement of Overriding Considerations, recognizing that significant unavoidable impacts will result from implementation of the Project. Having (i) adopted all feasible mitigation measures, as discussed in the EIR; (ii) rejected alternatives to the Project, as discussed in the EIR; and (iii) recognized the significant unavoidable impacts of the Project, the City Council hereby finds that each of the separate benefits of the proposed Project, as stated herein, is determined to be unto itself an overriding consideration, independent of other benefits, that warrants approval of the Project and outweighs and overrides its significant unavoidable impacts, and thereby justifies the approval of the Project. EXHIBIT B MITIGATION MONITORING AND REPORTING PROGRAM Mitigation Monitoring and Reporting Program This Mitigation Monitoring and Reporting Program (MMRP) for the proposed Northwest Specific Plan (proposed Project) is intended to ensure the implementation of mitigation measures identified as part of the environmental review for the proposed Project. The M1IRP includes the following information: ' A list of mitigation measures; * The party responsible for implementing the mitigation measures; The timing for implementation of the mitigation measure; * The agency responsible for monitoring the implementation; and ' The monitoring action and frequency. The City of Rohnert Park must adopt this M1l1RP, or an equally effective program, if it approves the proposed Project with the mitigation measures that were adopted or made conditions of project approval. 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