The URL can be used to link to this page

Home My WebLink AboutCD 1650 Los Gamos - Kaiser Permanente Office Building - Public comments Community Development Department MEMORANDUM Page 1 DATE: September 14, 2018 TO: Mayor Phillips and City Council Members FROM: Sean Kennings, Contract Planner SUBJECT: Addendum to City Council Staff Report for 9/17 hearing on Kaiser Permanente at 1650 Los Gamos Drive (Los Gamos Drive and Lucas Valley Road) APNs: 165-220-12, 165-220-13 This is an addendum to the Staff Report to the City Council for the Kaiser Permanente project at 1650 Los Gamos Dr, scheduled for review and action on Monday, September 17th. There were a few public comments made during the August 28, 2018 Planning Commission hearing regarding the proposed Project’s consistency with Greenhouse Gas Emissions and the California Senate Bill 32 (SB 32) enacted in January 2017, along with comments asserting that the EIR and the conditions of approval did not adequately assess the proposed Transportation Demand Management Plan (TDM) and the resulting mitigation measure MM TRAF-2. Staff was not able to include these in the main staff report, therefore is distributing this addendum. The following represents a summary of the comments, followed by staff response: 1. “City cannot rely on its General Plan and Climate Change Action Plan (“CCAP”) to support the EIR’s conclusion that the Project would have less than significant impacts with regard to climate change and GHG emissions, and that these documents were obsolete and reflective of 1990s thinking.” (Central to commenter’s claims is the assertion that the enactment of SB 32 on January 1, 2017 renders all previous programs to address climate change irrelevant.) Staff Response: The 2020 emissions reduction goal targeted by the CCAP (and, more specifically, the Appendix E to the CCAP, the “Greenhouse Gas Emissions Reduction Strategy”) is an official adopted policy of the City, reflects current state law, remains in effect, and has yet to be attained (2020 still being two years in the future), and therefore it is not “obsolete.” Since the CCAP and Greenhouse Gas Emissions Reduction Strategy meet the requirements of State CEQA Guidelines section 15183.5 for the streamlining of CEQA analysis of global climate change impacts and the Project is consistent with those documents, the EIR correctly concludes that the Project would have a less than significant impact. Notwithstanding, the continuing relevance of the 2020 emission reduction goal and thus the CCAP and Greenhouse Gas Emissions Reduction Strategy, the passage of Senate Bill 32 does not invalidate all climate change policymaking that came before it. Senate Bill 32 complements existing climate change requirements by introducing a 40% GHG emissions reduction goal for 2030. The point of SB 32 is to provide an interim emissions Community Development Department MEMORANDUM Page 2 reduction goal in order to assist in the attainment of the 2050 emission reduction goal previously adopted via AB 32 in 2006. It should be noted that the City’s CCAP acknowledges the 2050 goal and also, in its Greenhouse Gas Emissions Reduction Strategy, introduced planning of attainment of an interim 2035 goal, consistent with Executive Order No. B-30-15. Thus, the concept of further GHG emissions reduction being required beyond 2020 is explicitly part of the City’s CCAP. What SB 32 does provide is more information as to how the State is supposed to achieve the 2030 goal. More specifically, SB 32 required the California Air Resources Board (“CARB”) to prepare a new Scoping Plan that will provide the framework by which the necessary emission reductions are realized. The Scoping Plan was adopted by CARB on December 14, 2017 and is herein adopted by this reference. The Scoping Plan outlines that emissions reductions necessary to achieve the 2030 goal will occur through a variety of efforts, with which the Project is either consistent or which do not apply to the Project at all: Policy Primary Objective Highlights Project Consistency SB 350 Reduce GHG emissions in the electricity sector through the implementation of the 50 percent RPS, doubling of energy savings, and other actions as appropriate to achieve GHG emissions reductions planning targets in the Integrated Resource Plan (IRP) process. • Load-serving entities file plans to achieve GHG emissions reductions planning targets while ensuring reliability and meeting the State’s other policy goals cost-effectively. • 50 percent RPS. • Doubling of energy efficiency savings in natural gas and electricity end uses statewide. Consistent. While mainly targeted at utilities, the Project will be LEED certified and energy efficient. Low Carbon Fuel Standard Transition to cleaner/less polluting fuels that have a lower carbon footprint. • At least 18 percent reduction in carbon intensity, as included in the Mobile Source Strategy. Not applicable. City does not have control over fuel standards. Mobile Source Strategy (Cleaner Technology and Fuels [CTF] Scenario) Reduce GHGs and other pollutants from the transportation sector through transition to zero emission and low-emission vehicles, cleaner transit systems and reduction of vehicle miles traveled. • 1.5 million zero emission vehicles (ZEV), including plug-in hybrid electric, battery- electric, and hydrogen fuel cell vehicles by 2025 and 4.2 million ZEVs by 2030. • Continue ramp up of GHG stringency for all light-duty vehicles beyond 2025. • Reductions in GHGs from medium-duty and heavy-duty vehicles via the Phase 2 Medium and Heavy-Duty GHG Standards. • Innovative Clean Transit: Transition to a suite of innovative clean transit options. Assumed 20 percent of new urban buses Consistent. Project will feature VMT per employee that is 40% less than the average for the area. Also, the Project is located on an infill parcel in an urbanized, developed area. Community Development Department MEMORANDUM Page 3 purchased beginning in 2018 will be zero emission buses with the penetration of zero- emission technology ramped up to 100 percent of new bus sales in 2030. Also, new natural gas buses, starting in 2018, and diesel buses, starting in 2020, meet the optional heavy-duty low-NOX standard. • Last Mile Delivery: New regulation that would result in the use of low NOX or cleaner engines and the deployment of increasing numbers of zero-emission trucks primarily for class 3-7 last mile delivery trucks in California. This measure assumes ZEVs comprise 2.5 percent of new Class 3–7 truck sales in local fleets starting in 2020, increasing to 10 percent in 2025. • Reduction in vehicle miles traveled (VMT), to be achieved in part by continued implementation of SB 375 and regional Sustainable Community Strategies; forthcoming statewide implementation of SB 743; and potential additional VMT reduction strategies not specified in the Mobile Source Strategy, but included in the document “Potential VMT Reduction Strategies for Discussion” in Appendix C. SB 1383 Approve and Implement Short-Lived Climate Pollutant strategy to reduce highly potent GHGs • 40 percent reduction in methane and hydrofluorocarbon (HFC) emissions below 2013 levels by 2030. • 50 percent reduction in anthropogenic black carbon emissions below 2013 levels by 2030. Consistent. The Project will comply with any regulations concerning the disposal of organic waste and/or the disposal or handling of HFCs/refrigerants. California Sustainable Freight Action Plan Improve freight efficiency, transition to zero emission technologies, and increase competitiveness of California’s freight system. • Improve freight system efficiency by 25 percent by 2030. • Deploy over 100,000 freight vehicles and equipment capable of zero emission operation and maximize both zero and near- zero emission freight vehicles and equipment powered by renewable energy by 2030. Not applicable. The Project does not involve the freight transportation industry. Post-2020 Cap-and- Trade Program Reduce GHGs across largest GHG emissions sources Continue the existing Cap-and-Trade Program with declining caps to ensure the State’s 2030 target is achieved. Not applicable. The Project will not be subject to the Cap and Trade Program. Community Development Department MEMORANDUM Page 4 As shown above, this Project would not impede the achievement of SB 32’s goals. While the Scoping Plan makes clear that most of its programs concern industries or sectors unrelated to the Project, the Project’s efficiency in terms of being well-lower than regional VMT averages (see DEIR pp. 4.6-34 to 4.6-35) and the Project applicant’s proposal to make the Project energy-efficient demonstrates that it will aid, and not hinder, achievement of the State’s 2030 emission reductions goal. Thus, the Project is consistent with SB 32 and does not contradict the City’s findings of a less than significant climate change impact. 2. “The project description is ambiguous as to who the shuttles will serve. Please note the difference in the highlighted text on attached PDF pages 3 and 4 of the KP letter. This confusion is reflected in the EIR, as well as the staff report (PDF page 6). It’s clear the confusion started with your firm. We suggest you inform the City as to what KP's intentions actually are for the shuttles, so that the documents can be adjusted accordingly.” Staff Response: The shuttle is for employees. The Project Applicant’s Public Benefits Letter (dated July 25, 2018) and Page 27 of the August 28, 2018 Planning Commission Staff Report will be corrected (attachment 1). This clarification does not change the EIR’s analysis or conclusions, as the EIR correctly references shuttle service for employees. 3. “The Condition of Approval 107 is not a mitigation measure under CEQA, it is a condition of approval on the underlying land use approvals for the Project. What is relevant for the purposes of determining whether mitigation for environmental impacts has been prepared consistent with CEQA’s requirements is the mitigation measure proposed for adoption by the City for those purposes, specifically, Mitigation Measure TRAF-2 (“MM TRAF-2”).” Staff Response: Staff has revised the Conditions of Approval to correctly reproduce the entirety of MM TRAF-2 text, removed the “to the extent feasible” text, and moved the condition from Design Review Permit Condition #107 to be Use Permit Condition of Approval #10 in the Master Use Permits conditions. As this condition is a performance- based requirement, the condition has been correctly moved to the Use Permit section as this mitigation is an ongoing requirement of the use. Additional text has been included to highlight the annual survey submittal requirement of December 1st. An additional condition (#11) has been included to further require the entirety of the MMRP (and not just the mitigation included within) as an ongoing requirement, which includes the actions and monitoring of the mitigation measures. 4. “You should be aware of the fact that cities in Silicon Valley have been placing hard caps on daily vehicle trips for large employers, enforced by significant fines for overage. Such caps are obviously feasible, as they are currently in place in Community Development Department MEMORANDUM Page 5 other jurisdictions. Given that, an unenforceable condition of approval like this leaves the project legally vulnerable on grounds other than the flawed CEQA GHG findings I referenced in my testimony. We continue to believe that a 21st Century plan, based on reducing vehicle travel, would not only be feasible for KP, but also would cost less in the end. I’d be happy to discuss a TDM program with you that is designed to make a significant difference in vehicle travel. Stanford University continues to be an outstanding model of such programs.” Staff Response: As explained above, MM TRAF-2 as written, is an enforceable mitigation, consistent with CEQA requirements, and based on substantial evidence contained in the EIR and its technical appendices would reduce Impact TRAF-2 to a level of less than significant. Consequently, further or alternative mitigation is not required beyond the TDM program framework established by MM TRAF-2. Kaiser Permanente is required to submit an annual survey by December of each year that demonstrates that the Project will not result in a 0.01 increase in volume to capacity ratio as required by the EIR. If the survey and monitoring of the TDM program implementation reveals that the required performance standard is not being met, the City and project applicant will consider further TDM measures in order to correct the situation. 5. In a letter dated August 24, 2018, Caltrans responded to the Kaiser Permanente 1650 Los Gamos Drive FEIR with a comment that the operational analysis in the Fehr & Peers Final Traffic Impact Analysis (FTIA) of the mainline freeway counts was not acceptable. Caltrans requested reconciliation of the discrepancy in the FEIR and the FTIA. Response: Kaiser’s traffic consultant, Fehr & Peers, has responded to the Caltrans memo with revised background data and has provided a supplemental response in table form (attachment 2). This information will be forwarded to Caltrans for their ongoing review of the project as required for the permitting and construction of the off-site improvements. For additional information on the project, please contact Sean Kennings, the project planner, at Attachments: 1. Revised Public Benefits Letter from Kaiser Permanents 2. Table form response to 8/24/18 Caltrans Memo • • ~~,,~ KAISER PER M AN ENTE September 13, 2018 Jim Schutz, City Manager City of San Rafael 1400 Fifth Avenue, Room 203 San Rafael, CA 94901 RE : KAI SER PERMANENTE 1650 LOS GAMOS DRIVE MEDICAL OFFICE BUILDING PROJECT Dear Mr. Schutz, Thank yo u for your cons id eration of the Kaiser Permanente ("Ka iser") Los Gamos Drive Medical Office Bu ilding Proj ect ("the Project") located at 1650 Los Gamos Drive in Sa n Rafael. Kaiser proposes the add it ion of med ica l office as an allowable use in the Planned Development (PD) Zon ing District for an existing approximate ly 148,000 square foot office build ing and construction of a new three-leve l parki ng structu re on an existi ng surface parking lot located on the northwest portion of the 11.1-acre Project site immediately west of Los Gamos Drive . The Project also i ncludes Ka iser-implemented and f unded t raffic i mprovements at the Lucas Va\\ey Road and Los Gamos Drive i ntersect ion (identified in t h e Project's Draft Environmental Im pact Report ("DEIR") as "Alternative 4"). The Proj ect w ill allow Ka iser to suppleme n t and support existi ng Kaiser Permanente medical offices and support services in the North Bay region, incl uding o utJ:)atient services from the Ka iser Permane nte San Rafae l Medical Center ("Hosp ital"), into one conso lidated and convenient location that w i ll provide easy access from the freeway and proxim ity to p u blic transportation, offer convenient parking, and provide spaci o us medical offices that will better accommodate today's patient centered delivery of care . Completion of the Proj ect w ill allow for the moderni zation of Hospi tal clinical spaces over t i me as n eeded, ulti mately i njecting another $20- $50 million into the Hosp ital campus over t he next 5-10 years. Kaiser is comm itted to serving and i mprovi ng upon the community that it has called home for more than 60 years. In addi t ion to the opportunities referenced above, the Project w i ll provide the fo llowi ng community and econom ic benefit s to t he City of San Rafael and t he greater Marin community: A. Furtherance of City Goals and Po licies The Project will implement a nd is consist e nt w ith Cit'f goa ls, objectives, policies and programs for the Project Site described in the following City Gene ra l Plan Elements: Land Use, Neighborhood, Su stain ability, Circul ation, and Saf ety, as thorou ghly analyzed in the Project DEIR . The Pro j ect will also support San Rafae l's Obj ect ives and Design Gu idelines for t he North San Rafae l Commercial Center Neighborhood by p roposi ng a Project design that provides an entry and focal point off Los Gamos Drive, provides building and parking area setbacks improved with Land Use and Ent1tlemenh robust, drought-tolerant landscape, and screens mecha ni cal and other roof top equipment from view. Further, building i nteriors w ill be accented with art wor k c reated by local artists . B. Development of an Ex isting Infill Site The Project will facilitate the development of an infill site in an existing urbanized area in San Rafael and will re sult in regional environmental benefits because it will not require the extension of utilities or roads into undeveloped areas, is conve nient to ma j o r arteria ls, services and transit, including a SMART shuttle, a·nd will not directly or indirectly lead to the development of greenfield sites in the San Francisco Bay Area . C. Sign ificant Co mmunity Benefits and Traffi c/Infrastructure Investments The Project, as detailed in the DEIR's Applicant-Implemented Traffic Improvements Alternative 4 , results in economic and community benefits to the City by providing more efficient and improved intersection operations. As explained in the DEIR, Kaiser will voluntarily construct identified traffic and infrastructure improvements at Lo s Gamos Drive and Lucas Valley Road above and beyond what is required by the City's General Plan and the Project's identified fair- share contribution in order to improve intersectio n operations and reduce Project im pacts to less than significant. Intersection improvements include grading and restrip ing, traffic signal installation, new sidewa lks and curbs, pedestrian level lighting, and an extension of a Class II b i cycle lane. In addition, as an additional community benefit and voluntary Project contribution, Kaiser offers to fully fund these identified intersection improvements-at an approximate cost of $1,050,000-with no expectation of reimbursement by the City and County as in it ially contemplated i n the DEIR. This voluntarv contribution is in addition to $1,855,502 to be assessed by the City as a Proiect Development Impact Fee for Traffic Mitigation to be use d toward future citywid e circu lation and im provement projects identified i n the City's General Plan. D. Increased Economic Impacts to the City of San Rafael The Project will positively contribute to the City's local economy through new capital investment, as well as through retaining Kaiser's approximately 315 employees in the City and adding an additional 174 construction and trades jobs at peak construction. These employees are a primary source of potential business as a result of their patronizing r estaurants, shops and cafes. E. Enhanced Public Safety and Public Health Over the la st few years, Kaiser has contributed on average over $11 million to support charitable Community Benefit Resources that support the San Rafael Medical Center Service Area. The Project will continue that tradition of community service by improving public safety and public health by providing a major medical care facility to serve existing and future demand in the City and greater Marin region, which will in turn result in an increase in the quality and efficiency of rnedical care de livery to patients . The Project will supplemen t and support existing Kaiser medica l offices, hospitals, and other facilities i n t he r egion that are currently constrained in t h eir ability to enhance existi ng services or to renovate clinical areas. The Project w ill also provide integrated care options for local res idents at a conven iently located f aci lity with easy access to the freeway and proxim ity to pu blic transit options. As an additional Project ame nity,. and as pa rt of Kaise r's commitment t o a robust Transportation Dema nd Management plan intended to reduce midday and peak hour vehicle trips, the Project will include a small cafe serving hea lt hy meals and snacks, an d healthy cook ing demonstrations and nutrition t alks w ill be ava ilab le t o members, staff, and nonmembers. Cafe w i ll operate Monday-Saturday between the ho u rs of 8am and 6pm. I n a dditi on, as an a ncillary use to the Project 's proposed primary ca re m edical uses, Ka iser will relocat e and e xpand its Health Edu cation Cente r -a free and a va l uable resou rce for i ndividuals to access curr ent i nformation on hea lth and wellness and disease management and online tools to help manage health condit ions. Although Kaiser's Hea lth Education Cen t er has always been open to the pub lic, as part of the Project, it will now be centrally located w ith grea t er accessi bility to those who may be on ca m pus or prescri bed its use as medica l follow up (e.g., smoking cessat ion, etc.). The expa nd ed Hea lth Educat ion Ce nter will provide : • Hea lth Education professiona ls ava i la bl e to assist w ith onl i ne health information searches, Mond ay -Fr id ay, 9am-5pm; • Internet access to kp .org, M y Docto r Onli ne, the Kaiser Per m anente Cl inical Library, and other evidence-b ase d health-related sites; • Blood pressure se lf -ch eck equ ipment; • Body M ass Index sca le and body fat composit ion analyzer; • Health i nformation tip she ets (electronic and soft copy); and • Resting metabolic rate testi ng w ith we ight management ed ucatio n, ava i lable t o members and nonmembers for a no mi nal fee . The Health Education Ce n ter also offers classes to community members, including a no-cos t, six - week smoking cessation p r og ram and classes on crea t ing an Advance Hea lth Care Di rective . F. Implementation of Sust ainable Deve lopm ent Strateg ies The Proje ct will impleme nt a comprehensive environme ntal sustaina bility st rategy, including complying with Title 24 (California Energy Efficiency Standards) and se e king t o achieve a Ce rtified Leadership in Energy and Env ironmental Design (LEED) Gold certification or equivalent. In order to ach ieve a h igh level of sus t ai nab ili ty an d a LEED Go ld rating, Kaiser will also i mpleme nt many of its current green strategies, such as: • Solar panel distri b ution on the Project site is anticipated to provide m u ch of the electrical needs at t he b u ild ing and parking structure; • 39 Electric Vehicle chargi ng st ations will be installed at the Medica l Office Bu i ld ing (MOB) and parking struct ure, which exceeds t he current loca l requ irement and promotes Clean Veh icle use; • Shuttles t o transport employees from other loca l Ka iser facilities and the regional SMART rail service; • Standard-55 American Society of Heating, Refrigeration, and Air Cond it ion i ng Engineers (ASH RAE) compliance, a 20% better energy performance than standard ASH RAE; • Energy submetering for power, gas and water for optimal measurement and verification ability for post occupancy; • Direct Digital Control HVAC system for maximum energy savings; • High efficiency filtration for better indoor air quality; • 100% LED lighting systems w ith occupancy sensors throughout bu ilding; • High efficiency exterior that will reduce light pollution and save energy; • Ultra-low flow water fixtures, including toilets and sinks; • Photovoltaic thermal system that leverages the heat created in the photovoltaic system to heat the building water supply; • Recycled water for landscaping irrigation, toilets, cooling towers and closed loop hydronic system; • DIRTT Walls, an innovative, modular wall system that allows for future flexibility and reduction i n i nitial construction waste and duration; • Bike storage and racks for physicians, staff, and members; • On -site showers for staff and physicians; and, • Use of PVC-free materials, low or no volatile organ ic compound (VOC) free paints, CFC- free refrigerants, formalde hyd e-free casework, and use of recycled building materials. G. Greenhouse Gas Emiss ions Reduction and Congesti on Relief The Project incorporates a Transportation Demand Management (TDM) plan that will encourage alternate modes of transportation other than single-occupancy vehicles. The following TDM plan will be provided: • A TOM manager who is responsible for, but not limited to, developing and disseminating transportation information, aid ing em ployees in the se lection of transportation options, and communicating ava ila b le t ransi t alternatives; • An on-line transit informatio n center, as part of the internal website that provides information on the Kaiser Permanente TOM, t hat describes current public transit, vanpools, carpools and shuttle services serving the area; • A carpool and vanpool matching program; • Commuter subsidy for bicycle, transit or car/va npool use (current subsidy i s $60/month); • Pre-tax commuter spend i ng accounts; • Guaranteed Rid e Home program; and • Local Kaiser Shuttle to shu ttle employees to and from SMART Station and other Kaiser facilities in the City of San Rafael. The Project will also provide designated on-site bicycle parking, as well as dedicated parking fo r carpool/vanpools and electric charging stations for electric vehicles. Kaiser has already begun evaluating firms and services that may help implement its TDM efforts. In closing, Kaiser deeply values its 60-year relationship with the City. We believe the Project underscores Kaiser's long-term commitment to the community and supports the stability of Kaiser services for many years to come. As always, Kaiser is comm itted to being a good neighbor and strong community partner with the City and County, and appreciates the City's consideration of the proposed Project. Sincerely, Judy Coffe SVP / Area Manager Marin/ Sonoma Service Area Kaiser Foundation Health Plan, Inc. Cc: Paul Jensen, Community Development Director, City of San Rafael Raffi Boloyan, Planning Manager, City of San Rafael Patricia Kendall, Medical Group Administrator, Kaiser Permanente Jodie Clay, Team Manager, Kaiser Permanente Carol Harris, Community and Government Relations Manager, Kaiser Permanente Skyler Denniston, Sr. Land Use Manager, Kaiser Permanente Project:1650 Los Gamos (Kaiser)Commenter:CaltransVersion:Kaiser Permanente Medical Office Conversion - Final Environmental Impact Report (FEIR)Date:August 24, 2018IDComment TextAction Response1Mitigation Measure: We support the implementation of the "Applicant-Implemented Traffic Improvement Alternative" identified in the Draft Environmental Impact Report (DEIR) and FEIR. Comment noted. Comment noted. 2 Caltrans does not accept the use of analysis that is below 100 percent PeMS mainline counts. See response, no changes. The average percent observed of the aggregated data between September 2015 through November 2015 is 91-percent due to outliers, which were removed from the data set when used for the analysis. Each day was observed before being used in the analysis and typically reflects 100-percent observed or near 100-percent observed, during the peak hour. No new data will be collected or new analysis completed. The findings included in the FTIA remain. 3The Final Traffic Impact Analysis (FTIA) and Appendix F are inconsistent as they related to the identification of the Intersections 3 and 4; Intersection 3 is listed as southbound (SB) ramp intersection and Lucas Valley Road and Intersection 4 is listed as northbound (NB) ramp intersection at Smith Ranch Road.Comment noted, see Appendix F. The appendix was revised to denote the correct names. It should be noted that intersection 3 represents the southbound ramps and intersection 4 represents the northbound ramps, so while the intersection names may have switched, the intersection numbers were correct. Corrections were made on the following pages of Appendix F: 2, 55, 57. No changes were made to the conclusions. 4 The Cumulative No Project AM Peak count is inconsistent in the FTIA and Appendix F. See response, no changes. The Cumulative No Project and Cumulative Plus Project volumes illustrated in Figures 7-1 and 7-2, respectively, are consistent with the volumes used throughout the analysis. Note that Appendix F does not include volumes as it only reports queues. 5In addition, the NB off-ramp queues at Smith Ranch Road look as if the length is short and inconsistent with the description of the first paragraph of the FTIA on page 66. See response, no changes. The Cumulative No Interchange Improvement (without and with Project) show a northbound off-ramp that is approximately 1,500-feet and a right turn pocket that is approximately 320-feet, consistent with the length of the existing off-ramp. The addition of the Project results in queue spillback of the right turn pocket under the 95th-percentile and maximum queue. 6 Please reconcile this discrepancy in the FEIR and revised FTIA. Comment noted, see Appendix F. Appendix F was revised to denote the correct intersection names, intersection numbers were correct, and will be included in the FEIR. No other revisions were made. 7The project should be conditioned to contribute fair share traffic impact fees toward the improvements of storage capacity at the US 101 NB and SB off-ramps at the Smith Ranch Road and Lucas Valley Road intersections ramp terminals under post-project conditions as a condition of approval. Comment noted. Comment noted. 8Please submit a copy of the final staff report to Caltrans for our review. Comment noted.A copy of the final staff report will be submitted to Caltrans staff. Attachments(1) Appendix F - QueuesPage 1 of 1 From:Sean Kennings To:Brittany Bober; Raffi Boloyan Subject:Fwd: Kaiser Permanente Los Gamos Project Date:Friday, September 14, 2018 2:19:39 PM Attachments:ReponsetoFEIR_Final.pdf Kaiserneighborhoodpetition_v1.pdf Sean Kennings planning consultant LAK Associates, LLC ---------- Forwarded message --------- From: Michael Sharp Date: Fri, Sep 14, 2018 at 2:07 PM Subject: Kaiser Permanente Los Gamos Project To: Cc: Cecil Nielsen Dear Kate, CC: Sean Kinnings / Cecile Nielsen I will be unable to make the City Council Meeting on 9/17 as I am out of town. Therefore as one of the members of the community who has lead an effort to seek a common sense approach to the proposed 1650 Los Gamos project, I am asking you to seriously consider the alternatives that have been put forth at each of the public hearings that have been held to date and consider not certifying the final EIR. The members of the Mont Marin community who have spent a great deal of time and effort putting forward viable alternatives left the last planning commission meeting held on August 28th very upset after the planning commission failed consider any of the Mont Marin community comments and concerns. The lack of discussion on points raised by the community by the planning commission was shocking and disrespectful. It was clear that a decision had been made prior to the meeting and we hope the City Council members will display greater integrity at the meeting on 9/17. Given I respect your time and will not ask you go through the hours of testimony put forth to date I have summarized the key points the community members have made to date: 1) The neighboring community is not against Kaiser moving into 1650 Los Gamos, the community be against the building of an unnecessary 3-story parking structure when there are viable alternatives available. We believe through a well structure TDM program and utilizing the existing parking spaces more efficiently that Kaiser will be able to support all of their employees and members who make single use car trips. 2) We understand that the County of Marin would be willing to lease parking spaces to Kaiser on a short-term basis. If Kaiser is able to lease the parking spots in the short term it will give the City of San Rafael time to assess if the mandatory parking requirements currently in place are out of date given the progress being made in transportation. The Toyota / Uber and Volvo announcements this past week point to a future where people will not need to park cars in parking lots. I have provided many references below that undeniable point to changes that will be happening in the transportation field in the coming years. 3) At a time when climate change is accelerating we do not need the significant release of Green House Gases (GHG's) that would be pumped into the atmosphere during the construction of the parking garage that will be obsolete in 3 to 5 years. If the project is allowed to proceed without proper planning there will be a significant increase in GHG's related to increased congestion at the already saturated Lucas Valley / 101 on ramp. 4) The EIR only references old and out of date City of San Rafael Climate Action Plan standards and does not reference the more recent Senate Bill 32, that calls for a 40% reduction in GHG's by 2030. I'm sure Kaiser Permermante staff will employ the same tactics at the next meeting on 9/17 and will no doubt roll out the same union Reps and Doctors who are clearly financially motivated for the this project to proceed. As I will not be there to present and offer a rebuttal I hope that you as a member of the City Council see through the charade that that Kaiser and their friends will put forth. There are plenty of construction jobs in Marin and if the City gets it act together and comes up with a 21st Century plan to build affordable housing near transit hubs as well as increasing the mass transit options, there will be many more for years to come. Secondly Kaiser will no doubt parade a number of their pleading doctors. Kaiser is an expensive private member organization that charges high premiums for basic plans with high deductibles, these high deductible plans can leave families facing financial hardship when a family member requires urgent or emergency care. They are no saints maybe they should use some of the $1mm that they are planning to use for the junction and the several million they are spending on an unnecessary parking lot to lower members premiums. To provide you with further information I have listed below several references as well as the neighborhood petition asking for the project to be approved without the parking lot and the letter I sent to the planning commission ahead of the meeting on August 28th. References 1) https://www.bbc.com/news/business-45324753 The article states: “Many analysts think personal car ownership will drop dramatically when the self-driving, ride-sharing future is fully upon us - with major companies instead purchasing enormous fleets of vehicles. Toyota, then, may have just secured its biggest ever customer.” 2) https://www.denverpost.com/2016/10/15/denver-developers-future-parking-self- driving-cars/ "One University of Texas study, modeled on Austin, Texas, estimated the need for car parking would decrease by 90 percent if the entire city shifted to autonomous ride-sharing vehicles. " Other References: http://groovygreenliving.com/the-environmental-impact-of-parking-your-car/ https://phys.org/news/2010-12-free-nationwide-high-environmental.html https://journalistsresource.org/studies/environment/transportation/parking- environmental-impacts-development-policies-research-roundup https://www.theguardian.com/commentisfree/2018/mar/15/50-years-climate-change- denial https://www.citylab.com/transportation/2014/07/how-parking-spaces-are-eating-our- cities-alive/374413/ https://www.scientificamerican.com/article/reducing-parking-cut-auto-emission/ https://usa.streetsblog.org/2012/02/23/report-pollution-from-u-s-parking-spaces-costs- up-to-20-billion-per-year/ https://www.fastcompany.com/40434409/if-you-cant-ban-cars-downtown-just-take- away-the-parking-spaces http://climatechange.ca.gov/local.html Michael Sharp 15 Salvador Way San Rafael CA 94903 August 21st, 2018 Community Development Department Planning Division City of San Rafeal 1400 5th Avenue San Rafael CA 94901 Dear Members of the Planning Commission, I am writing in response to a postcard I received in the mail inviting me to comment on Project 1650 Los Gamos Drive Kaiser Medical Offices. I have read the final Environmental Impact and I have made both public and written comments on the Draft Environmental Impact report. I offer these comments: Senate Bill 32 (SB-‐32) is referenced in the Draft Environmental Impact report on page 4.4-‐11 and on page 4.4-‐15. However after reading and searching through the FEIR I do not see any reference to SB-‐32. It is my understanding and having consulted with an environmental lawyer who specializes in transportation litigation that failure to evaluate this project's consistency with SB-‐32 would render the FEIR inadequate. I would also like to note that the FEIR references both the San Rafael City 2020 General Plan and San Rafael’s Climate Change Action Plan (CCAP). Both these plans were written several years ago and the CCAP in currently under review and needs to be updated. The City is also in the process of gathering information for its 2040 plan now that the 2020 plan has run its course. Since these plans were written, a great deal of new data has been collected and analyzed on climate change together with the passage of SB-‐32 that calls for a more aggressive approach to tackling GHG emissions. The City of San Rafael’s Sustainability web page states “ Our Climate Change Action Plan is being updated. ” It is being updated because of the reason posted on the website on the same Sustainability webpage. “ The world’s atmosphere is warming faster than scientists anticipated. We can expect increasingly frequent and prolonged heat waves leading to drought, crop failure and wildfires.” This summer, The City of San Rafael has been severely impacted by the smoke from wildfires leading to a number of unseasonal spare the air days. In 2017, authorities had to close the schools because the air quality was unhealthy as a result of the wildfires. The impacts of climate change are here and without a comprehensive plan to reduce GHGs, it is going to get worse. I together with 50 of my nearby neighbors who signed a petition seeking a common sense approach to 1650 Los Gamos project, I believe the City of San Rafael Planning Commission can take a big step in fight against climate change by leading by example and requesting that Kaiser follow the latest climate change best practices with this project. If this project is allowed to continue unchecked the State of California’s mandate of a 40% GHG reduction by 2030 (SB-‐32) will be impeded by this project. This project INCREASES GHGs, instead of reducing them, by encouraging more vehicular travel, Kaiser is worsening existing conditions rather than improving them. The increase is going to come from both the increased number of vehicle trips to the facility as well as from an increase in congestion at the Lucas Valley and 101 off and on ramps. The FEIR states that “there may be a noticeable change in traffic patterns and vehicles in the circulation network as a result of the Project.” This statement is not specific but rather alluded to the fact that there will be a greater congestion and therefore an increase in GHG emissions. It is not only the people in our neighborhood who are aware of the drastic problem we are faced with and need to solve. The following issues were raised in an article is San Francisco Chronicle this summer published on July 16th 2018. The article stated: “Greenhouse Gas emissions (GHG’s) from the transportation keeps rising and since the transportation accounts for more GHG than any other sector, this must change if the state hopes to meet its future global warming goals.” “It takes about 18 months to prepare the data so the current GHG emissions figures are from 2016 but early fuels sales data for 2017 suggests there will be a further increase in GHG emissions from cars.” “The large emission reduction gains to date have come from the electricity sector. To meet the 2030 goal of 40% below the 1990 emission levels there needs to be a huge reduction in GHGs produced by cars and trucks. “ “Although we all hope that there will be an increase in the number of people driving electric vehicles, electric cars only account for 3 % of the new cars registered in the state last year. The majority of people are still buying gasoline fueled cars.” As noted above to meet the 2030 GHG emission target we need to reduce the number of vehicle miles travelled (VMT). If approved this project as outlined in the FEIR will increase the number of vehicle miles travelled, with a net increase of 437 car trips per day. Kaiser’s Transportation Demand Management (TDM) program was promoted as method to offset the increased vehicle trips, however the Kaiser TDM program is inadequate. For example, parking demand and trip generation appear to assume zero effectiveness of the TDM program. Kaiser can't claim to have a TDM program if even they don't believe it will affect anything. Second, the program isn't optimized. Note that there is no mention of Kaiser members in the shuttle program. Their shuttle system should definitely bring patients to the center from the train and from downtown, as a condition of approval. A similar project in Santa Rosa was challenged by TRANSDEF and the Sierra Club. They challenged the EIR for the Santa Rosa Sutter Hospital and they won because of the increase in GHGs as a result of the project and then reached a settlement: Sutter would give their employees free transit passes, and run a free shuttle to the train station. This is why we are calling on the City of San Rafael planning commission to address the concerns of the citizens of San Rafael and allow Kaiser to proceed with there plans under the following conditions. The proposed parking structure will not be constructed on the grounds that it will encourage more vehicle miles to be driven and more single occupancy vehicle trips to take place leading to an increase in GHGs at a time when the state is calling for a 40% reduction. As stated before, the parking concerns Kaiser and the City have are not a parking capacity issue but rather a parking management issue. There are enough parking spaces in a close proximity to the office building at 1650 Los Gamos to meet the current demand. I believe, in consultation with CEQA experts, that the following are feasible alternatives to building a parking lot to house 476 cars on an existing parking lot that already has space for 209. Are the significant amount of GHGs released during the construction really worth releasing to create an additional 267 spaces at this point in time. Rather than build the parking structure, Require Kaiser to restructure their current TDM program to include shuttle services from the local transit hubs and the neighboring communities. These shuttle services should be able to pick up employees and members. Shuttles should have the ability to carry bikes. Together with the neighboring businesses, the Sherriff Department and County offices come up with parking management system that fully utilizes all of the parking spaces on Los Gamos drive. Many of the spots in area are open most of the time. Successful solutions are known as Shared Parking/ Park Once is a strategy that seeks to shift parking demand into shared facilities rather than a proliferation of dedicated, accessory lots. This strategy can be accomplished by brokering shared-‐ parking agreements among private lot owners on Los Gamos who either experience offsetting times of peak demand or share customers who would walk between uses if allowed to leave their car in one place. Require Kaiser employees to pay for parking and offer Parking Cash-‐Out – An employer based strategy which allows the employer to charge employees for parking while giving employees a bonus or pay increase to offset the cost of parking. Employees may use this increase to pay for parking or may choose an alternative mode and “pocket” the difference. Require Kaiser members to pay for parking. The most effective parking strategies are cost-‐based or pricing measures that link parking rates more directly to demand or provide financial incentives and/or prime parking spaces to preferred markets such as carpools, vanpools and short term parkers. This reduces total parking demand, shifts travel to other modes, reduces vehicle miles traveled (VMT) and ensures a minimum number of parking spots are always available, avoiding the “circling” problem adding to congestion. If parking is free, convenient and abundant, there is little incentive to travel via any other mode. Parking is never free: it has a substantial cost and this cost is passed on to Kaiser members. Transparency allows commuters to make informed decision and balance the cost and benefits of alternative modes. A valet program could create more flexibility in the short term allowing for local transport networks to get up to speed. All of the items listed above would create sustainable alternatives to creating an additional 267 parking spaces. Lastly in terms of full disclosure I would propose that any member of the planning commission who could gain from the plan to build the parking lot to abstain from the vote. Just as we were asked to declare at the last meeting if we were Kaiser members, and I am happy to share that my family and I are all happy Kaiser members. Yours Sincerely Michael Sharp COMMON SENSE APPROACH FOR Ka iser Penna nente's 1650 Los Gamos Drive Med ical Office Building and Parking Structure we .we not ~bil'lst tkt K.Jis«'s plan to retont> l lw! bu,ld,n,a at t650Los G11mos D,i~, 1or medical offlct$, howevt-r we •re aiSl(inc vou to .support vour neighbors In r,e,qu~tlng th.it «•l~r ¥ltd the Citvof S.n fbiQtfwork with tM ,esidtlntiof SblvM!Ot w~. Slywtw Terr<lte. Con.c Mll\ld. Cone ~pistr.,no, etc., tocomt! up .;1h a parking ~lution th.at minin\uM t~ ,mp.act on thcl cn-.4ronmc:nt, mlnlmlu:-s the impact on tM tt')id,rntl ....tio's homH we doi.e to the proposed slt\Kh.tte ,1nd mlnlml:c-s the Impact on«>mmi.rtcn 'fttlo liW! in theneigtlborhood (Mont Manti, San Rllf.loel P;ut, Monttvldro, M.irlnwood and LUU:s V,1lley) we"'"~ «i.i\•1 dc>es no1 nee!d ,11 p1rking SU\l(h1re and/or could find• btuf't S<te lot thoc parting sm,Kturc th;11 would allow oSIPr a«eu in ik'ld 0111 of~ tM:ility. If t he J).l,l'k1n310t b PIil 00 the t'llst skft' of l,,0$ G11mos nPlrt to d 1t> Kllk#1 buildint, nwmt>tts ~00 stoff would havt easie, access to the! proposed medic~ !klilcl1ng and the mc-mbtrs e;ii:iting the f.adlitywould bot abte to P!'lter th@ 101 wittiovt tlSlt1g tf'l(l Los Gamos/1..UtJiS Vaillcy jl,MIIC1iot'I. ni. oxiUil'II p lan iS for 1he parline SU\IC1vre to be bv,lt into the hillside on the west side of Los Gamos. If J::<kSf't Is allow~ to build the p.ll'kil'II lot on t!\c west side of Los G11mos then there will bf a stgnlfkant Impact on: lNVIRONMfHT: adwrst ims,ac, Of\ e,cosy,ttm, emtnlons. c-t:c.. SAntY: inetffSf "'°"t , lnil,M'v, ~tc.. R($10[NTIA1. IMPACT'S: light pc:,lirtlon, Impai r \flcwl, lncre:,sc In partk\Ar matttr, ttc. TRAFRC: lncrc,a~ tHffiC, concestion, kllint, etc.. 1) The En'4iron!Mnt A, lht nu~r of l)llrlut'lg spa<~ 1eqvlrt'd $hotAd be looted at :.gain. There :ire SNt"ral paltjne lonwi dose ptOJtimity to the 1650 losG~ bu,ld•AJI lh;it .arcc:um:intlyundc,c trbllttd ;Kid wrth ~~ p11rtners.hiV-' and c:reiltiWwm to use ttwe s~ there ,hcMlfd be MOugl'I par\1ng ~s av.lilable to 1CtOmrnodilte the kais« WOftcrs ;ind membeo airs. The Lut thi"B the «iunty ne.ds 1111 this moment is• furtber inc:rt•Sf'"' MillM's !)et a,prt.i ~hide miles tr-'Vded (VMTs) wtien th.ere arc fc~ mltfE:.:,tions available wch as: 1) Atr.lng..-me-nts with .tdj:w:'A'nl ownors who l\ilve surplus p.i,rking. 2) Free shuttlts to ¥td from lo<-' t~,it hub$. 3) Flndi"4 additiOnillf Transpottadon de-niand m¥i~lf'mtnt (TDM) solutions. fo, IU!iset t:mplavtfl ,nd mtmbttS. 8) Thi$ proJKt wllhavc a s,gn!f!Qnt crwironml'fltill impact on the «osvstcm of 1hc :ttt:.1 whN"e the proposed muttl•slo,y parkinsk>t is pl;,nntd The structur@wil ,equ,re the remov;,I of ~rel mature trees. M~yof tht:$c trees ;ire AC$li"3 site, kx birds. C) This p,ro}e(t k In dlr«t oppoSitiOn to thot: WOft being done by M¥1n C,()unl'( SUPtfYISOt"s cffoirts to rf(lur.ft grH.ntwM.isc, t.lst'S (GHG's). This~ w,11 enc:our.ip more Qr use illt time ~nwe nc-td to rtduc:e the number ol trti>s l)C091t: are m~g In their cars.. KIiie Seal'$ w.as quoted In Sunday°$ Mllrin U <btf>d April 22nd 2018 s;aytnc the (IOunty nttds to eoo-. at low carbon fo«ns of tran-sport;,don. O~id Sdlonbrunn who i$ pte~lklnt of th!! Tr:in,p()f'Ultion SOlu'liOns defense fvndwas also quoted In the artldc In M.arln IJ on Aprll l200 S¥'\& "The County's blind spot i~ motor 11tholdts, C'YC' Mc:rc,ull'\£ aimovnts of drMng are r~ultlngln tnc)l'C GHG·s. • Buildii,a a l)llrkinc lot th.al d acu,m,nocJ/llte SU cars Is only t:Oi"i to make; the probkn'I worse. The car'bon emisSiOl'ls from the eon.nruaiOn ilklnc\loil £Miel'l,tC an lnae.tSt In GHG's. Mt to mention tM lncrc,s-c In traffic if the p,oj«:t moffl forward .lS K11!scr mcmbel$ '-''QUld bt enoot1raged to use tht1r personil C:¥$ 1;,thC'f th;in use ;,tternatM! transS)Ort,nJon. W<>ukl a, fleet of cltttric bus.tt not be, beuei use of tM money btfns put ,5ide by KAiis.tr to bu,ld a piirting lot? O) The followiing ;,re tht lmputs tM Oraift f,wi,onmenu,I lmc>K\ Report failed to identify, • 6ti"$ing ~e C¥S imo the ittai Is going to Jnoe~e &Htl !louse G.ast'S (GHG's) • The anc,c~ of mo,e than 3,700c.1r trips per d;ay will t(!jUlt in greeter f'lthaust emissions ~d as a result will increase the production of GHG's. The DIER in s«t_tl)l'l 4.4,6 '"Impact Gl-fG•l: The Project would nQI re-suit in, cumubtilldy COMidenbll' conttibu11on toa slgrwfit;ant cumulative ims,.Kt reliltNI to a,ttnhoo~• g11s ttnis.siOM. lteu th:tn Slanlfbnt)• • we ha~ c.ont.actcd California fn..tronmcntJl<Nflity Ac;t (C(QA) t'Xp(!rU who :iptt dl3t the ilKft~ in traffic.~ the rtmlMII of MatW'C ttee.s wm il'l(.tease tht aC'alinn o, "(..rttn House GM's,• The lncrc~c will come frotn mote freQ-ucnt trips to tlw? mt'dltal offQ and as a result of the idlot1g tlut will be gentfllted when drivers .ire waltlnt, 10 £Ct Into the ~rkingk>C as wdl :is drMnsaro,.md V.ltlou.s ttvcls of the JNrking )tructu,e tfit is deemed neces~ry1h,1t J1dd1tioMI patl:ini S9(1Cs t1re n~d ~ bdlcw: that by creating a stt00ure on the eilst ~kft of lm G:irnos will lead to ~ne, 1,.,mc flow and re-du« GHG', dluSCd by ldbng. 2 Re,sldentlal Impacts Al Ueht Pollution, lht OJff'Cnt plans ;,ppear to Show an lnac~c in the 3itl'IOI.Wl1 of ligtlts ~ed to ilh.iminatc fn thit .lrea If thl' J)fo;e<'t mOrt:S forward we ~lll fQr 1h1> d<ttiAn rc-.iicw board 10 et'l(0UlilfC Kaiser to US(' tcdlnolOgv th.tt minimllCS offsltc lmpKtsof JIRht pollution. we would IW>9() the p,otcct complif"i with ~!Mtt Sk'(" r«ommer.dadons al a minimum. 8) Und1Qping: The .,..-o,ea Wtll d»nse the -A@w that m.ll\yon ndth,boril'lg sttetts currcntlyen}ov. The hc,Q\jtj; lit the 109 of Satvadoir Way enjoy a lowly 'Mwof peel'\ treetops. Wdh the pl:ins to add SOiar pan&on the roof of thtl pl;mntd multi StOf'V p3fting wvcture to,;,cth« wfth ttie high he;cht or u,e plan~ parting lot, th;,t KaMI as a got>d faith measu,e wm c:omc up with:,, l11n~ mitig.tion pbn to ptot«t the nMur.t1I trff 'Mws wtcu«entlyenjoy, C) We would also 11kt to fully IJJ'lders~nd hO'N thl~ p,of«t c.o411d bcc:c:wnc>&cted without a ~ificent incre.•sc tn the ,mount of line parlicu~tc 11\;ltte-l being p;lSSfd ,nto tlWI ,tmcnpht'fe .,_d itnp;lCtif'l8 the h,c;itltl of the reildents In t!M.' ¥t.l. A) AnQthN' area ot a,t1cetn is the ctfme r:,,tcs a,ssociatcd with pa,rkingp,,.es. t"Ycn In rural ,reu, cuntnttv peoplt exe-1ds-t In this area :,,t all titncs of the day and use this ai t"'-'lr rootc 10 schools and wort. There Is a walk Ina p;1U1 th;n 1-akes pe,091e from our 1H.'i!Jlborh0od to thit YMCA gym, Of bus pad. When OOlkhng a large structl.W'e you si£11ifkan.1ty ,educe sight llr)CS ;,nd thu,. nwike it eaiSier for cttme to Iii~ pix.. evet'I it thl!, a,•a is next to the Sheriff offioo. (Crime in pad:int lots huo.Jttawf .parkingtod,1y.com,£atticledetaik..php ?id=US • 8) We would also a11:~ that tht' 11 would~ saN>r for if lht' itru«ure and 1»rk1t1g iS lin11ted to pawd ,lrt.s ncllt to the buadln,: !ts,clf ~ opPQSed to .a-on the street. Evwn if ., lght put in jbywalling t'tC. will oc:cur: • Brin«:ll'\C, mote urs Imo the ,lrta Is going to lncrt'ase tht' congestion at the -,lrHdy (O~)ttd wutl'lboood luc.u Vdeyon at1d off r.imps. The lnc;rc;is,c of more than l,700 r;ar t,ip) pc-r day whet, tht rnediC~offtCt ts folly operational h going to«C,llC un~fc silu.1tion$ fOf the m•nydlildrt'n wtio ridt' thot'ir bik~ ·""~to M,11., C,ttk Mlddlt $d,ool, M.J!Y SIIYclr,l, w~ ,l,Od Obdc School H,mo t,AMY 0f\hlll I '"" • SAN RAFAEL THE CITY WITH A MISSION DATE: September 17, 2018 TO: Mayor Phillips and City Council Members FROM: Raffi Boloyan, Planning Manager Sean Kennings, Contract Planner Community Development Department MEMORANDUM SUBJECT: Addendum to City Council Staff Report for 9/17 hearing on Kaiser Permanente at 1650 Los Gamos Drive (Los Gamos Drive and Lucas Valley Road) APNs: 165-220-12, 165-220-13 This is an addendum to the Staff Report to the City Council for the Kaiser Permanente project at 1650 Los Gamos Dr, scheduled for review and action on Monday, September 17th. Staff recommends three minor changes to the draft Resolutions, clarifying language with regards to Greenhouse Gas Emissions and S832. 1. Attachment 1 (Resolution for Certification of Final EIR) There are two minor corrections recently discovered in the Draft EIR that should be corrected. They are minor corrections and not substantive changes. Therefore, staff suggests the addition of a new recital, following "Now Therefore be it Resolved" that states the following: BE IT FURTHER RESOLVED, that the City Council certifies the final EIR with two minor clarifications to the Draft EIR text (both on page 4.4-10 of DEIR). These corrections/clarifications have no substantive impact, and correct the following information in the Greenhouse Gas Emission section: • 3rd bullet, 2nd sentence on page 4. 4-1 0 of Draft EIR. The numbers quoted are actually the "BAU + state reductions" scenario, and are not the City's emission reduction targets for 2020 and 2035. The emission reduction target for 2020 is 309, 603 MTCO2e, while San Rafael didn't actually adopt its own 2035 emission reduction goal. • 5th bullet on page 4. 4-10 of Draft EIR. First number should be 58,222, and the second number should be 88, 144. As per Table 5 of the GHG Emissions Reduction Strategy. 2. Attachment 2 (Resolution adopting CEQA Findings of Fact and Statement of Overriding Considerations and MMRP) Staff recommends that should the Council adopt Attachment 2, the Council include additional clarifying language to GHG Finding 4(a) on page 2-7 of Attachment 2, as illustrated by strikethru/under!ine below: Page 1 SAN RAFAEL THE CITY WITH A MISSION Community Development Department MEMORANDUM a. The Project's GHG Emissions Will Be Less Than Significant Facts in Support of Finding: As discussed on pages 4.4-12 to 4.4-13 of the DEIR and supported by evidence contained within the entirety of the record of proceedings, under CEQA, projects that are consistent with Climate Change Action Plan (CCAP) forecasts and implement applicable CCAP strategies are determined to result in less than significant GHG emissions. The Project is consistent with the City's General Plan 2020 and, therefore, would be consistent with the applicable CCAP measures if it meets the standards included in the Qualified GHG Emissions Reduction Strategy. As shown in Table 4.4-1 on page 4.4-13 of the DEIR, the Project is consistent with these standards. In addition. Senate Bill 32's 40% GHG emissions reduction goal for 2030 provides an interim emissions reduction goal in order to assist in the attainment of the 2050 emission reduction goal previously adopted by Assembly Bill 32 in 2006. The City's CCAP acknowledges the 2050 goal and also, in its Greenhouse Gas Emissions Reduction Strategy1 introduced planning of attainment of an interim 2035 goal. consistent with Executive Order No. B-30-15. Thus, the concept of further GHG emissions reduction being required beyond 2020 is explicitly part of the City's CCAP. Further, the Project's efficiency in terms of being well-lower than regional VMT averages (see DEIR pp_ 4.6-34 to 4.6-35) and Kaiser Permanente's stated commitment to make the Project energy efficient demonstrates that it will aid in the achievement of the State's 2030 emission reductions goal. aAG-aAs ~ result of the above, the Project's GHG emissions will be less than significant. 3. Attachment 5 (Resolution Conditionally Approving Design Review Permit} Additionally, Condition of Approval #108, is the applicant's fair-share contribution for the minor impact to Las Gallinas / Lucas Valley Road. The Planning Commission, in their review, concluded that the applicant's public benefit offer was adequate to off set this fair share contribution to the impact at Las Gallinas/Lucas Valley Rd, given that the intersection is outside the City's jurisdiction and there is no current identified improvement for this County intersection, and any modifications would require public outreach prior to design approval. Therefore the Commission's recommendation was the public benefit proposal addressed the fair share contribution at this intersection. However, the corresponding removal of the fair share requirement as condition of approval (#108 in Attachment 5) was not made in the Draft Resolution included in the staff report. Therefore, staff recommends that if the Council is to approve Attachment 5, removal of condition #108 be included in the motion. Page2