AIA Comments on County General Plan

AIA SCOPING COMMENTS FOR HOUSING ELEMENT EIR

By Email to “housing.element@dcd.cccounty.us”

Department of Conservation and Development

30 Muir Road

Martinez, CA 94553

Attn: Daniel Barrios

RE:  Scoping Comments for Housing Element EIR

Dear Mr. Barrios:

 The Alamo Improvement Association has received the Notice of Preparation for the subject EIR, including the proposed Housing Element Sites Inventory. The Housing Element will be an integral element of the impending new General Plan and will, by necessity contain goals, policies, actions, etc., that have not been described.  CEQA analysis of the Housing Element based upon the Sites Inventory separate from the whole General Plan makes it difficult for the public to determine where one CEQA project ends and the other begins in preparing scoping comments and, likely, comments to the Draft EIR.  A fuller description of the Housing Element “CEQA project” should be provided.  

Based upon the project information provided thus far, we offer the following comments pertinent to the preparation of this EIR:

Circulation:  Significant increases in housing and population densities not previously considered in the current General Plan will adversely impact current Levels of Service (LOS) at key intersections and thoroughfares. Current freeway rush hour bypass traffic will further impact ingress and egress from neighborhoods with access only to Danville Blvd. Signalization of uncontrolled intersections may be warranted as mitigation measures to control traffic flow and access. Large scale residential development along Danville Blvd may require public transit service increases and transportation management conditions on new developments. Mitigation measures such as TSM and impact fees should be considered

Emergency response and public safety:  High density residential development on Danville Blvd requires analysis of emergency response protocols and capabilities in the event of a failure of the high-pressure petroleum pipeline along the Iron Horse Trail, a major seismic event disabling the I-680 corridor, or a wildfire conflagration originating from Mount Diablo or Las Trampas wildlands. This is an environmental issue because it may require vegetation clearance of nearby wildlands, relocation of the pipeline and hardening or expansion of existing infrastructure. Fire stations may require modification

Dept. of Conservation & Development

Attn: Daniel Barrios

August 12, 2022 Page 2

and/or relocation as well as acquisition of additional equipment. Mitigation measures such as controlled burning, automatic pipeline shutoff valves, staged equipment and emergency response resources, and impact fees should be considered.

Water Supply and Sanitation:  Do EBMUD and CCCSD have planned capital improvement projects to increase service capacities to accommodate the growth implicated by the increased densities and population growth anticipated by the Housing Element. If not, the DEIR should evaluate the necessity for, cost of, and timing of such improvements necessary to service growth. Further, state law obligates the County to identify the sources of potable water to serve all new development.

Police and Fire Suppression:  Does the Sheriff or the San Ramon Fire Protection District have sufficient equipment and staff resources to serve the residents of Alamo should the number of dwelling units in Alamo increase by 359-484 (and over 3,000 as proposed in the draft General Plan Land use Map). What are the means of financing increases in capital facilities and uniformed staff. Will the existing residents be adversely impacted by a reduction in services. Mitigation in the form of taxes, assessments and impact fees should be evaluated.

Growth Inducing Impacts:  Projects shown in the Sites Inventory and the proposed General Plan Land Use Map, especially along Danville Blvd., will have growth inducing effects. As high-density developments are permitted on Danville Blvd, normal economic forces will induce other property owners to consolidate lots for development to maximize value and will seek General Plan amendments and rezoning. The historic pattern of urban development in California clearly demonstrates that introducing high value uses such as multi-story high density residential development creates an economic incentive for other similarly situated property owners to seek greater value for their property. As single-family homes are held for ultimate aggregation and development the quality and appearance of the neighborhood changes adversely. Properties become rentals, small home occupations flourish, landscaping is removed for off street parking and more incompatible uses are sought for approval like quick marts and restaurants. Mitigation measures such as design control, lot coverage limitations and a prohibition on non-residential uses should be considered.

Water Quality and Flood Control:  Increased urbanization will adversely impact surface waters, water habitat and water dependent species in local creeks such as Las Trampas Creek and San Ramon Creek. Flood control structures were sized based upon the urban development standards set in the prior General Plan and did not consider the increased urbanization anticipated by the Housing Element. What are the environmental impacts associated with increased channelization and impoundment weirs on local creeks. How are improvements to be funded.

Dept. of Conservation & Development

Attn: Daniel Barrios

August 12, 2022

Page 3

Air Quality:  The Housing Element DEIR should evaluate the increased emissions from mobile sources as well as particulates from construction activity. Many undeveloped properties were previously used for agriculture. Often these properties have the residues of toxic chemicals used in agriculture (e.g., Xavier Estates property in Alamo). Accordingly, the DEIR should examine the presence of contamination and the mitigation measures to remediate such properties.

Schools:  The addition of the units shown in the Sites Inventory, and in the General Plan, will have significant impacts on school enrollment. and the need for new facilities.  The DEIR should specify how these will be funded and by when they must be provided.

Mitigation Monitoring & Growth Management Program:  To assure that impacts are mitigated in a timely fashion and do not fall behind the pace of development, the EIR should include a Mitigation Monitoring & Growth Management Program that identifies sources of funding and establishes thresholds of development at which specified mitigations must have been accomplished to progress to further development.

 Thank you for the opportunity to offer CEQA scoping comments on the project as defined thus far.

Sincerely,

Roger Smith, 

President